LAC-IEE-17-28

ENVIRONMENTAL THRESHOLD DECISION

Activity Title: Haiti Water, Sanitation and Hygiene Project Activity Number: TBD Life-of-Activity Funding: $44,400,000 Life-of-Activity: Aug 2017 – February 2022 IEE prepared by: Elizabeth Jordan Reference ETDs: LAC-IEE-16-43 Recommended Threshold Decision: Categorical Exclusion

Negative Determination with Conditions Positive Determination

Bureau Threshold Decision: Concur

Comments: None

SUMMARY OF FINDINGS

1.1 Purpose and ScopeThe purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the activities under the USAID/Haiti Water, Sanitation and Hygiene Project and on this basis, to recommend determinations and, as appropriate, attendant conditions, for these activities. Upon final approval of this IEE, these recommended determinations are affirmed as 22 CFR 216 Threshold Decisions and conditions become mandatory elements of project/program implementation.

This IEE also documents the results of the Mission’s Climate Risk Management process (Annex 2).

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1.2 Program DescriptionThe objective of the Haiti WASH Project (“the Project”) is increasing sustainable access to water and sanitation services in Haiti. Specifically, the Project will focus on increasing access to safe water and sanitation services in government of Haiti (GOH) identified priority cholera “hotspot” communes and in communes recovering from cyclical disasters such as Hurricane Matthew. The Project uses an integrated program approach that serves to create an enabling environment for sustainable improvements in WASH in Haiti by investing in the development of appropriate water and sanitation infrastructure with the corresponding strengthening of the technical and fiduciary capacity of actors to sustainably operate and maintain water and sanitation infrastructure and deliver quality services.

Through these activities, the Project stands to support USAID’s global Water and Development Strategy 2013-2018 (The Water Strategy) Strategic Objective 1 (SO1) “Improve health outcomes through the provision of sustainable safe water, sanitation, and hygiene” and the Senator Paul Simon Water for the World Act (2014) which makes access to safe water and sanitation a specific policy objective of U.S. foreign assistance. The Project also contributes to the “Post-Earthquake USG Haiti Strategy – Toward Renewal and Economic Opportunity,” under Pillar A: Infrastructure and Energy, Pillar C: Health and Other Basic Services, and Pillar D: Governance and Rule of Law.

1.3 Issued DecisionsThe following table contains the threshold determinations for each activity covered under this IEE. Descriptions of each activity, analysis of potential environmental impacts, and activity-by-activity determinations, as well as mitigation measures and any conditions are described in more detail in Sections 3 and 4 of the attached IEE. Upon approval of this IEE, these recommendations become affirmed Categorical Exclusions and Threshold Decisions, and implementation of recommended conditions becomes mandatory.

Intervention Category Determinations IR 1: Increase Access to Sustainable Water ServicesIR 1.1: Water Infrastructure Engineering Services

Positive determination, with potential change following Scoping Statement

IR 1.2: Water Infrastructure Construction Positive determination, with potential change following Scoping Statement

IR 1.3: Technical Assistance for Water Service Providers

Negative determination with conditions for activities related to supply chain strengthening for water treatment products

Categorical Exclusion for all other activitiesIR 2: Increase Access to Sustainable Sanitation ServicesIR 2.1 Support to sanitation enterprises Negative determination with conditionsIR 2.2 Waste Treatment & Fecal Sludge Management Engineering Services

Positive Determination

IR 2.3 Wastewater Treatment & Fecal Sludge Management Construction

Positive Determination

IR 3: Improve the Enabling Environment for Sustainable Implementation, Operation, and

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Maintenance of Water and Sanitation ServicesIR 3.1 Provision of technical assistance to national and sub-national governments

Categorical Exclusion

IR 3.2 Dissemination of project knowledge and learning

Categorical Exclusion

1.4 Implementation RequirementsThe attached IEE includes conditions and requirements that must be fully implemented. Activities issued a Positive Determination will require a Scoping Statement and an Environmental Assessment as required by Agency regulation and policy.

1. All proposed activities with the determination of Categorical Exclusion fall within a category of activities that has been pre-determined to not have an impact on the environment. For such activities, no additional environmental analysis will be required prior to the award.

2. Implementation of activities receiving a recommendation of Negative Determination or Negative Determination with Conditions, are not likely to have a significant impact on the environment if the specified mitigation actions are taken and actively monitored. Thus implementation of the activities for which negative determinations are recommended are contingent on full implementation of a set of general monitoring and implementation requirements, specified in Sections 3 and 4 of the IEE. These require: (a) Implementing Partner (IP) briefings on their environmental compliance responsibilities; (b) Development and approval of Environmental Mitigation and Monitoring Plan (EMMP), and Water Quality Assurance Plans (WQAPs), where applicable; (c) Development and approval of additional environmental screenings once specific sites are under investigation for the construction of small-scale infrastructure; (d) Integration of EMMPs and WQAPs in work/implementation plans and budgets; (e) Integration of compliance responsibilities in prime and sub-contracts and sub-grant agreements; (f) Assurance of sub-grantee and sub-contractor capacity and compliance.

3. The finding of Positive Determination means that significant environmental impacts are possible, and a more in-depth scoping and/or an environmental assessment will be required to further investigate impacts and mitigating factors. No activities for which a Positive Determination has been recommended may start until an environmental scoping and assessment, undertaken by individuals qualified to evaluate sanitation and drinking water systems, is completed, and appropriate clearance is provided by the Bureau Environmental Officer (BEO).

4. Any additional funding action and/or change in geographic or project scope will require additional analyses to provide the basis for a threshold determination, and/or to ensure they are consistent with the findings of this document. If new activities are not included as part of the analysis documented in this report, or if they have the potential for negative direct, indirect or cumulative environmental impacts, the Contract Officer’s Representative (COR) will perform additional analyses consistent with 22 CFR 216, resulting in appropriate documentation signed by the Bureau Environmental Officer (BEO).

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5. The COR will provide copies of the annual report of the activity to the MEO/BEO which provides the necessary details to ensure continued compliance with the conditions of this IEE.

6. This report does not include analysis of any activities that involve the use or procurement of pesticides, or any activities listed in 22 CFR 216.2(d) or 22 CFR 216.5, or any activity listed in the Foreign Assistance Act, Sections 117, 118, and 119. A Mission-wide Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) will include such analysis.

7. Implementation will in all cases adhere to applicable host country environmental laws and policies.

8. It is the responsibility of the COR to ensure that the program activities are consistent with this analysis. Unforeseen adverse impacts should be immediately reported to the Contracting Representative.

Attachments: Initial Environmental Examination

BEO Concurrence:

___________________________________ ____________Diana Shannon Date:Bureau Environmental OfficerBureau for Latin America & the Caribbean

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CLEARANCE PAGE

___________________________________ ____________Veena Reddy Date:Acting Mission Director USAID/Haiti

Cleared by:

AAbellard/AMEO: Date:

RDonohoe/OIEE: Date:

RClausen/REA: Date:

JGraetz/PCPS: Date:

CRyder/RLO: Date:

CBarratt/DMD: Date:

Drafted by: Elizabeth Jordan, USAID/W E3/WO, ejordan@usaid.gov

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/tt/file_convert/5c9307ae09d3f206488be1a7/document.doc

Initial Environmental Examination (IEE)

Activity Location: Haiti

Activity Title: Haiti Water, Sanitation and Hygiene (WASH) Project

Activity Number: TBD

Life-of-Activity Funding: $44,400,000

Life-of-Activity: Aug 2017 – February 2022

Reference Threshold Decision: None

IEE Prepared by: Elizabeth Jordan

Date Prepared: March 21, 2017

Recommended Threshold Decision: Categorical Exclusion: X Negative Determination: Positive Determination: X Negative Determination with Conditions: X

1 BACKGROUND AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of IEEThe purpose of this IEE is to provide the first environmental review and associated threshold environmental determinations for Haiti WASH project activities. In accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), and ADS 204, this IEE provides a first review of the reasonably foreseeable effects of the Haiti WASH project on the environment. The IEE provides the information and analysis sufficient to reach one of four threshold decisions regarding the overall environmental effects of the project. For each activity addressed by the IEE, threshold decisions are recommended. Further, the IEE recommends determinations and, as appropriate, the associated mitigation conditions for project activities. Once the IEE is approved, the recommended determinations are affirmed as 22 CFR 16 Threshold Decisions and/or Categorical Exclusions, and mitigation conditions become essential elements of implementing the Haiti WASH project. The IEE is part of a mandatory environmental review and compliance process meant to achieve environmentally sound development activity design and implementation.

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1.2 Program Background (Context and Justification)Access to potable water and sanitation in Haiti remains the lowest in the Western Hemisphere. Only 58 percent of the population has access to improved water sources, and only 28 percent has access to improved sanitation. Safe collection, transport, and treatment of fecal waste are practically non-existent throughout Haiti. The GOH has focused on awareness and promotion campaigns to encourage households to build their own latrines and on addressing the need for sanitation facilities in public schools, health institutions, and other public spaces. As a result, open defecation rates have dropped from almost 50 percent in 1990 to about 20 percent in 2015. Surveys, however, indicate that the use of improved sanitation facilities has only increased from 18 percent to 28 percent, signifying that much of the population still relies on shared or unimproved facilities. Water -- and especially sanitation infrastructure -- often lags behind housing, albeit informal and ad hoc. In informal or unplanned settlements, where the poorest and most vulnerable urban populations generally live, rampant urban population growth and high population density may be accompanied by an increased risk of person-to-person (and person-environment-person) transmission of infectious diseases.

Due to this lack of access to water and sanitation services, diarrheal disease is a leading cause of mortality in children under age five in Haiti and is responsible for 12 percent of all child deaths. Poor WASH is also a key factor in malnutrition, as repeated bouts of diarrhea, parasitic infections, and environmental enteropathy all lead to the inability to absorb and utilize nutrients. Moreover, the lack of clean water and sanitation services contributed substantially to the severity and rapid spread of the cholera epidemic that began in Haiti in October 2010. Notwithstanding the recent spikes in 2015 and 2016, primarily in a dozen identified “hot spots”, the average number of cholera cases has shown a decrease since 2010.

The GOH enacted a new water law in 2009, which created national and regional entities to develop and regulate the sector and control its actors. This law established the National Water and Sanitation Directorate (Direction Nationale de l’Eau et de l’Assainissement - DINEPA). DINEPA is responsible for: (i) the preparation of the sector strategy and policy in coordination with the relevant Ministries and institutions; (ii) the establishment of water tariffs; (iii) the establishment of water quality standards for water supply and sanitation; (iv) approval of water services contracts; and (v) the preparation and monitoring of key performance indicators in the sector. Unfortunately, and as a result of the 2010 earthquake and subsequent cholera outbreak, DINEPA has had to take on the role of an executing agency of investment projects financed in majority by international donors to respond to these emergencies. The majority of the WASH sector investment has been driven by donor funding, with only one percent of the total funding for the sector between 2006 and 2015 contributed by the Haitian government. The 2009 Water Law also called for the decentralization of WASH services to the regional (Offices Reginaux de l’Eau Potable et de l’Assainissement - OREPA) level. The Rural Department Units (URDs) are the decentralized structures of OREPAs for rural areas, with responsibility for ensuring compliance with the quality of water and sanitation services in rural areas on behalf of the OREPAs. Currently, however, although the OREPAs and URDs have a robust mandate, they have limited authority, funding, management capacity, and human resources to effectively operate. This leads to weak operations and maintenance and a lack of sustainability. Municipalities, slated to assume operations in the future, also have limited ability to control fee-based services, especially where the law prohibits municipalities from collecting taxes directly.

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1.3 Description of ActivitiesThe primary goal of the Haiti WASH Project is to reduce the prevalence of cholera and other waterborne diseases to improve the health and prosperity of the Haitian People. The Project will lay the foundation for a long-term, sustained effort to increase access to safe water and sanitation in Haiti, where many communities suffer from high incidences of cholera and diarrheal disease. This will be achieved through increasing and sustaining access to WASH services, and increasing the practice of proven behaviors that promote better hygiene. The project utilizes a multi-pronged approach, including improving access to water and sanitation infrastructure, behavior change and strengthening the enabling environment for sustainable WASH improvements. Activities associated with each of this project’s Intermediate Results (IRs) are described in more detail below.

IR 1: Increase Access to Sustainable Water ServicesThe adequate supply of water is a huge need in Haiti, and the long-term functionality of water systems is a pervasive challenge. Additionally, many water systems lack the necessary water treatment to ensure safe drinking water. The main categories of activities under this IR are:

Water Infrastructure Engineering and Construction: The project will expand access to safe water by working with DINEPA and local authorities in targeted municipalities to develop plans or incorporate existing plans and strategies for water system extensions, water safety plans, and other mechanisms for ensuring safe water delivery. This will include assessments of the existing water systems’ capacity and needs, development of engineering designs, and ultimately construction of planned water infrastructure. This infrastructure may include extensions of piping networks, expanded pumping infrastructure to increase system capacity, master meters, public water points, or other infrastructure. Detailed plans for these construction activities will be determined after award on the basis of assessments completed by the Contractor.

Technical Assistance for Water Service Providers: The project will also build the capacity of the targeted water utility/service, including training and support to develop standard operating procedures, developing business plans to finance infrastructure, maintenance, and operations, analyzing and restructuring tariffs for water services, improving tariff collection, planning for capital improvements, providing improved customer services and/or developing water safety plans. In addition, the contractor will work to strengthen the domestic supply chain to facilitate the provision (procurement and/or production) of long term stocks of chlorine and spare parts (pipe, fittings, etc.) for the water service providers.

IR 2: Increase Access to Sustainable Sanitation ServicesDespite gains in reducing open defecation, access to improved sanitation remains low in Haiti. The GOH mandates a no-subsidy approach for sanitation, yet there are limited low-cost, high quality products available in the local market, prohibiting low-income households from accessing improved sanitation facilities. In addition, there are limited fecal sludge management services in Haiti, and no fully functioning wastewater treatment facilities outside of Port-au-Prince. The main categories of activities under this IR are:

Support to Sanitation Enterprises: This project will work to expand on the involvement of the private sector in sanitation service delivery and strengthen the efficiency, effectiveness and commercial orientation in the sector overall. The project will work with entrepreneurs and small enterprises to facilitate the development of viable market-based business models for household

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latrines and fecal sludge management, increase demand for sanitation, and build the capacity of these private actors, through technical assistance in areas such as business plan development, sanitation tariffs (for servicing), billing systems, and/or capital improvements planning.

Waste Treatment & Fecal Sludge Management Engineering and Construction: To address the lack of waste treatment services in Haiti, the project will also support the design and construction of select wastewater treatment infrastructure, including the completion of the waste treatment plant in Cap Haïtien and the development of other small-scale decentralized treatment systems, utilizing low-cost options as appropriate. In each target area, the Contractor will perform a thorough assessment of the existing wastewater systems, identify key infrastructural needs, perform appropriate pre-design analyses, and develop a list of potential construction projects to be completed. Detailed plans for these construction activities will be determined after award on the basis of assessments completed by the Contractor.

IR 3: Improve the Enabling Environment for Sustainable Implementation, Operation, and Maintenance of Water and Sanitation Services

To support DINEPA’s transition from an implementation (utility) role to its mandated role of regulator, as well as the transition of the sector toward the decentralized structure called for in the 2009 water sector reforms, the project will provide technical assistance across multiple tiers of government. This will include targeted capacity development to national, sub-national, as well as private, and civil society stakeholders through mentoring, training, vocational trade development, twinning, and/or direct support in areas such as development of national plans and strategies for expansion, monitoring and maintenance of water systems, and the establishment of new sanitation administration units at the regional level.

1.4 Geographies TargetedAccess to improved water services and sanitation facilities are low throughout Haiti; however, USAID will not be able to address this challenge nationwide. Therefore, priority areas were selected on the basis of need and opportunity for sustained impact through coordination with other donors and USAID-funded programs. The types of communes to be targeted fall into two categories: (1) priority cholera hotspots and (2) Hurricane Matthew affected areas. Consistent with the GOH Cholera Elimination Plan, the Haiti WASH Project intends to begin in each targeted commune with interventions in the urban and peri-urban areas, to reach the objective of ensuring access to safe water and sanitation on a reliable and sustainable basis. As needed and as financially and technically feasible, project activities will be extended to nearby rural areas.

To address the persistent cholera challenge, the USAID Haiti WASH Project will direct up to 75 percent of project resources on a priority basis in key cholera “hot spot” communes, identified in the GOH National Cholera Elimination Plan (2016-2018), beginning in Cap Haïtien and Mirebalais, and moving into other priority cholera communes as feasible. The remaining project resources will be directed to addressing the needs of the Hurricane Matthew affected communes in Haiti’s south, including Les Cayes and Jeremie, where the incidence of diarrheal disease related to unsafe water has dramatically increased, the cholera risk is elevated, and the GOH and donor investments require WASH support.

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2 BASELINE INFORMATION AND APPLICABLE HOST COUNTRY REQUIREMENTS

2.1 Geography The Republic of Haiti shares with the Dominican Republic (DR) the second largest island of the Caribbean called Hispaniola. Haiti occupies one third (27,750 km2) of the territory on the western side of the island. It is surrounded by the Atlantic Ocean to the North, the Caribbean Sea to the West and South and by the DR to the East. The Haitian coastline covers 1535 km. Haiti also includes five satellite islands: La Gonave (670 km2), La Tortue (180 km2), Ile-à-vache (52km2), Cayémites (45km2) and La Navase (Navassa island: 7 km2). Haiti’s population is estimated to be 8 million with a 2.08% annual growth rate (IHSI, 2000). Haiti is one of the most densely populated countries in the Caribbean, with a current population density of 286 inhabitants per km2. This rapidly growing population is increasingly concentrated in urban areas, primarily in increasingly dense informal settlements in untenable areas such as steep hillsides, ravines and floodplains rendering inhabitants vulnerable to inundation and landslides.

Haiti is an Amerindian word that means Mountainous land. Mountains occupy 75 percent of the country and their orientation greatly influences local rainfall and insolation regimes. The climate of the plains and lower montane regions is primarily tropical monsoonal, while that of the montane area is sub-tropical. The dominant winds are from the northeast and the northerly directions. As a result, the moist ecosystems generally occur on the windward mountain slopes and the sub-humid ecosystems occur in the rain shadow of the leeward exposure. Most precipitation is brought by the North East Trade Winds and to a lesser extent by winds from the east. In general, precipitation increases and evapotranspiration decreases as a function of elevation in Haiti. The major portion of the rainfall that occurs on the island is orographic, or the result of warm moist air rising rapidly as a result of the mountainous topography. The humid and wet montane systems are the source of major rivers and streams in the country, as well as the aquifers of the highly porous limestone substratum. Dissected by numerous mountain ridges and flowing across two relatively narrow peninsulas, Haiti’s rivers (more than 158) are mostly short and swift flowing. The exception is the Artibonite River which originates along the border with the Dominican Republic and flows for approximately 290 km. Along this river is found the country’s major hydroelectric power generating facility (Le Barrage hydro-électrique de Peligre). In Haiti, exposed rock formations are igneous, metamorphic and sedimentary origin. The latter formations are the most abundant (80 percent) and are represented by limestone deposits from the middle and upper Eocene era. Accordingly, the parent material of soils in Haiti is primarily limestone. Pockets of basalt soils (mostly igneous rock) are found throughout the country, giving rise to soils that are less fertile and more highly eroded. More highly weathered oxisoils and beauxitic soils (sols ferralitiques et sols ferrugineux) are a feature of several montane areas of the country.

2.2 Climate and Natural ResourcesHaiti experiences tropical humid conditions year-round with a long wet season, predominantly in the northern and southern regions of the island. Between March and November, Haiti experiences two periods of peak rainfall. Haiti has an average annual rainfall of 1460 mm (approximately 58 inches), and a high per capita potential renewable freshwater resources, it is among the poorest countries in terms of

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access to water supply. The quality and availability of hydrologic data is low, which constrains the ability to effectively plan and manage Haiti’s water resources.

Haiti has 11 main drainage basins fed by a variety of interweaving rivers and streams carrying fresh water down from the mountains. The intermittent streams of these systems, particularly on the windward mountain slopes, are vulnerable to rainfall-induced flash floods during the rainy season. The Artibonite River is Haiti’s largest waterway, running 280 km through a 9,500 km2 watershed. It originates in the eastern end of the island and spans the Artibonite and Centre departments. Other large streams include Les Trois Rivières, Rivière Grand’Anse, and Rivière du Massacre (or Rio Dajabon), and Rivière Pédernales. The Trois Rivières is the second longest river and discharges into the Atlantic at Port-de-Paix. The Rivière Grand’Anse has the second highest discharge and reaches the coast near Jérémie on the southern peninsula. The Rivière du Massacre and the Rivière Pédernales begin in the Dominican Republic and form parts of Haiti’s border with the Dominican Republic before flowing into the Atlantic Ocean and Caribbean Sea, respectively.

The natural and physical environment is largely degraded throughout Haiti’s varied landscape of coastlines, mountains, and plateaus. Water quality is similarly in decline, particularly with regard to surface waters in urban areas. Furthermore, information on aquifers is scant, and pollution of these water resources is potentially a significant problem. Agricultural and industrial activities and untreated sewage have contaminated both surface and groundwater resources in many areas. Additionally, watersheds have been destabilized by rampant deforestation, which has accelerated soil erosion causing siltation of water systems and reservoirs, decreased agricultural production, reduced groundwater recharges, and increased runoff, damaging mangroves and barrier reefs. Similarly, the lack of waste management systems causes contamination of water supplies and creates many challenges to public health.

Climate change poses new threats to Haiti as rainfall patterns change and droughts become more common. Haiti is located in the middle of a hurricane belt, with the most severe storms routinely occurring from June to October, which typically cause widespread flooding and deadly landslides. The most significant climate-related hazards in Haiti include flooding, drought, intense rainfall, landslides, severe soil erosion, saltwater intrusion, and hurricanes. Additionally, the supply and quality of water resources may be threatened by reductions in precipitation, inadequate water-related infrastructure, and saltwater intrusion. Semi-arid areas are most affected by droughts, and may become more drought-prone as the climate warms. The areas most exposed to annual droughts include:

western part of Département Nord-Ouest lower part of Département Nord-Est northern part of Département Artibonite, from Gonaïves to Anse-Rouge east of Département Sud-Est, from Bainet to Cotes de Fer high area between the Département Sud and Département Nippes, between Aquin and Azile area of Jérémie in Grande-Anse area stretching from Arcahaie to Cul-de-Sac Plain

2.3 Haitian Environmental Law and PolicyIn addition to complying with the terms of 22 CFR 216, USAID’s Environmental Procedure, project activities must also adhere to relevant GOH environmental laws and regulations. GOH requirements

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regarding water resources use and management (both drinking water and water for irrigation), and environmental impact assessment are of particular priority.

The GOH enacted a new water law in 2009, which created national and regional entities to develop and regulate the sector and control its actors. This law established the National Water and Sanitation Directorate (Direction Nationale de l’Eau et de l’Assainissement - DINEPA). DINEPA is responsible for: (i) the preparation of the sector strategy and policy in coordination with the relevant Ministries and institutions;(ii) the establishment of water tariffs; (iii) the establishment of water quality standards for water supply and sanitation; (iv) approval of water services contracts; and (v) the preparation and monitoring of key performance indicators in the sector. However, the advent of the 2010 earthquake and subsequent cholera outbreak relegated DINEPA to the role of executing investment projects financed primarily by international donors in order to respond to these emergencies. The majority of the WASH sector investments have been driven by donor funding with only one percent of the total funding for the sector between 2006 and 2015 contributed by the GOH. The 2009 Water Law also called for the decentralization of WASH services to the regional (Offices Reginaux de l’Eau Potable et de l’Assainissement - OREPA) level. The Rural Department Units (URDs) are the decentralized structures of OREPAs for rural areas, with responsibility for ensuring compliance with the quality of water and sanitation services in rural areas on behalf of the OREPAs. Currently, the OREPAs and URDs have mandates without the necessary authority, funding, management capacity, or human resources, leading to weak operating systems and a lack of sustainability.

The Framework Decree on Environment, “Décret Cadre sur l’Environnement” was promulgated on January 26, 2006.  It represents a major step in terms of prospects to resolve jurisdictional conflicts in environmental management, and provides a legal foundation for a national policy on the environment and for environmental management in Haiti.  Article 56, Chapter IV of the decree states that “Policies, plans, programs, projects or activities likely to have impact on the environment must be subjected to an environmental assessment….”  Implementation of the decree, however, poses major challenges, and to date no regulations for environmental impact assessment have been put forward.   

There are many other Haitian laws that deal with the environment.  Some of the relevant laws include: The Haitian Constitution (Chapter II, Title IX); Ministerial decree of July 10, 2013 prohibiting the exploitation of mangroves; The Watershed Management Policy of 1999 from the Ministry of Agriculture, Natural

resources and Rural development. Decree of October 8, 1992, which proclaims public utility 15 water points; Decree of March 3, 1981 creating framework law governing waste management and

elimination; Decree of October 27, 1978 on fishing; water pollution, natural resource conservation,

protected areas, and species protection; Haitian Rural Code of 1962; Law of September 19, 1958 protecting soil erosion determining area extent and regulating

forest management; Decree of March 17, 1950 proclaiming public utility big irrigation, drainage and land

improvement works.

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In 2015, the GOH launched the Bureau National d’Evaluation Environnementale (BNEE). The BNEE is a technically devolved body under the Ministry of Environment, and whose mission it is to promote and implement the Haitian National Environmental Assessment System, to ensure that all plans, programs, projects and activities are implemented under clear environmental compliance with rules and regulation. 1This environmental assessment system will include Environmental Impact Assessments (EIA) that will analyze, upstream, the potential environmental consequences of the various GOH programs, plans and public policies, in order to prioritize those for which negative impacts on the natural environment and ecosystems are lower. Environmental and Strategic Assessments, another element of the system, are to improve planning by analyzing programs, plans and policies in light of sustainable development priorities.

3 ENVIROMENTAL EVALUATION AND THRESHOLD RECOMMENDATIONS FOR PROJECT ACTIVITIES

As described in Section 2, this project aims to create substantial improvements in Haiti’s WASH sector, decrease dependence on unsafe water supply sources, and improve sanitation. To do this, the project will invest in appropriate infrastructure improvements, technical assistance, behavior change programs, and in improving the enabling environment for a more financially and technically capable WASH sector. The initial focus will be on three target areas considered cholera hot spots. This section describes the likely environmental impacts of different activities, provides a recommended threshold determination for each activity or type of activity, and outlines recommended mitigation measures.

3.1 Increasing Access to Sustainable Water Services (IR 1)Activities under the umbrella of (IR 1), Increasing Access to Sustainable Water Services, vary in terms of their potential for direct, indirect, or cumulative effects on the environment.

IR 1.1 and IR 1.2: Water Infrastructure Engineering & ConstructionThe detailed engineering and construction activities under IR 1.1 and IR 1.2 are yet to be determined, however, the potential activities planned do not qualify for a categorical exclusion. The pre-development site work, including drilling test bore holes, site preparation and the construction of water infrastructure, and other small-scale structures; the maintenance and rehabilitation of existing water supply infrastructure, including small-scale construction, and maintenance; and the construction and operation of new water systems, which may include drinking water treatment systems, filtration and disinfection systems, ground level and/or elevated water storage tanks; piped water distribution systems; public tap stands/kiosks; yard taps; direct piped connections to homes, businesses, and institutions; development of groundwater resources through rehabilitation of existing boreholes or drilling of new boreholes for municipal/community use.

Activities under IR 1.1 and IR 1.2 have the potential to directly or indirectly impact the environment in the following ways:

1 Accessed on 4/11/2017 at http://www.haitilibre.com/article-15435-haiti-environnement-lancement-du-bureau-national-d-evaluation-environnementale.html13

Runoff, dust and noise from small-scale construction associated with drilling bore holes, building pipelines, and cleaning and minor rehabilitation of existing, dysfunctional infrastructure for inspection and testing, etc.

Contamination of ground and surface water through diesel/oil spills associated with construction equipment.

Contamination of the environment and risks to worker safety because of improper handling of reagents and other chemicals used in water quality testing and at water treatment plants.

Depletion of groundwater or surface water when abstraction for new piped water system exceeds replenishment of groundwater/surface water resources, including cumulative impacts from this project and other projects

Creation of human health risks from provision of biologically or chemically contaminated water. Even if water is not contaminated initially, it can become so through leaks and corrosions in pipes or in poor management of water treatment facilities.

Environmental impacts from the design, construction and operation of small-scale water systems are generally considered to be minimal, per 22 CFR 216.3 (a) (2) (iii) - small scale construction of water piping extensions, drilling of new boreholes – and can usually be controlled below the level of significance by appropriate siting, design, construction, maintenance, facilities operation and water quality monitoring. With respect to the last few mitigating factors on the list above, capacity building in equipment/system operation and maintenance is an essential corollary to construction/installation of small-scale water systems and facilities, and will be an integral part of the activities associated with IRs 1.1 and 1.2. However, it is possible that some larger scale construction activities, such as the development of new water sources for municipal systems or large extensions to piped water networks will be identified as a result of the Contractor’s assessments.

In accordance with 22 CFR 216.3 (a) (2) (iii), it is recommended that activities under IR1.1 and IR 1.2 receive a Positive Determination. Once the final list of construction activities has been developed, a Scoping Statement will be developed, per 22 CFR 216.3(4).

As a result of this Scoping Statement, the determination may be changed to a Negative Determination with Conditions for any activities determined to fall under the definition of small scale. If activities retain a Positive Determination, a detailed Environmental Assessment must be undertaken in accordance with procedures outlined under 22 CFR 216.3 (a) (4) and 22 CFR 216.6. Such additional environmental review, and any associated mitigation measures, must be completed before any activity under IR 1.1 or IR 1.2 is initiated. If the determination is altered to a Negative Determination with Conditions as a result of the Scoping Statement, the following conditions must be met before the activities listed above can commence:

Infrastructure plans must reflect environmentally sound design consideration, and adequate procedures and supervision must be in place to ensure compliance with requirements and implementation of best practices in construction and at construction sites. Related best practices and recommended environmental mitigation measures can be found in the USAID Sector Environmental Guidelines for Water Supply and Sanitation (http://www.usaidgems.org/Documents/SectorGuidelines/Wat%20San%20Guideline%20Final_w_GCC_Addition__May11.pdf). Pursuant to ADS 201, a climate risk screening is also required as a part of the design process in order to reduce the risks of climate variability and change on infrastructure investments.

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An Environmental Mitigation and Monitoring Plan (EMMP – Annex 1) must be developed and implemented, and it must include specific description of all monitoring and mitigation actions. The EMMP must be submitted to and approved by the COR and MEO/BEO prior to commencement of infrastructure maintenance and/or design efforts.

A Water Quality Assurance Plan (WQAP) must also be developed and implemented to help ensure the delivery of safe and reliable water.

IR 1.3 Technical Assistance for Water Service ProvidersNearly all of the activities described in this sub-IR fall under the class of activities not normally considered to have foreseeable environmental impacts, per 22 CFR 216.2(c)(1)(i). Because such activities have no or limited scope of physical interventions and no direct effects on the environment, 22 CFR 216.2(c) (2) recommends a Categorical Exclusion for: (i) education and training; (iii) workshops and meetings; (v) document and information transfers; (vi) contributions to national organizations; (xiv) programs to develop capacity of host country stakeholders to engage in development planning; and (xv) activities that involve the application of design criteria. For IR 1.3, such activities include but are not limited to:

Meeting and working with municipalities and other local stakeholders to assess the existing water system;

Training to improve drinking water disinfection and other treatment; Desk-top studies and assessment of sources for any water system expansion; Developing water safety plans and other water quality monitoring programs; Training and capacity building to improve maintenance and operation of the water supply system; Assistance to water service providers to develop business and financing plans; Assistance or research to support changes in tariffs or tariff collection for water services; Preparing environmental plans or assessments.

Additional activities under IR 1.3 that may have environmental effects and do not qualify for a categorical exclusion are those related to strengthening supply chains for provision of spare parts and/or water treatment supplies. Although no actual physical construction will be funded or implemented under IR 1.3, strengthening the supply chain for water treatment supplies could have environmental impacts depending on the type and source of such supplies. Thus these activities are recommended for a Negative Determination with Conditions.

Pursuant to that determination, the following conditions must be met before the activities receiving a Negative Determination with Conditions can commence:

An Environmental Mitigation and Monitoring Plan (EMMP – Annex 1) must be developed and implemented, and it must include specific description of all monitoring and mitigation actions. This document shall be submitted to, and approved by the COR and MEO/BEO prior to commencement of infrastructure maintenance and/or design efforts.

3.2 Increase Access to Sustainable Sanitation Services (IR 2)Similar to IR 1, there are three sets of activities that fall under IR2. These activities differ in terms of their potential to have direct, indirect, or cumulative effects on the environment.

IR 2.1: Support to Sanitation Enterprises

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IR 2.1 includes activities to support sanitation enterprises to increase the demand for household sanitation services, including support to local entrepreneurs and utilities to meet the increased demand for construction, services, and maintenance of improved sanitation, and potential support to operators of public latrine blocks. Under this IR, the project will build demand for sanitation through market-based approaches, facilitate the development of viable market-based business models, build the capacity of private actors, and expand access to promising, low-cost, high quality sanitation products. The project will also work in partnership with local private service providers to strengthen and professionalize the operations of fecal sludge management services, through support for business plan development, sanitation tariffs (for servicing), billing systems, and/or capital improvements planning. While there will be no direct design or construction of sanitation systems under this sub-IR, indirectly, such activities will lead to the construction and operation of small-scale sanitation systems, including latrines. Foreseeable environmental impacts of such systems include:

Construction of small-scale sanitation infrastructure may also lead to contamination and/or degradation of water sources. Sanitation projects may contaminate or degrade the quality of surface water, ground water, soil, and food, which may be caused by improper siting of sanitation facilities, improper disposal of excreta or wastewater, improper operation of sanitation facilities, among other causes. This contamination can degrade the water quality of streams, lakes, estuaries and land habitats, leading to nutrient contamination, alteration of ecosystem structure and function, and loss of biodiversity.

Improper handling and disposal of sewage and fecal sludge from households can contaminate surface water, groundwater, soil and food. In turn, this contamination can lead to disease transmission (and resulting malnutrition), higher infant mortality, reduced economic productivity, and increased cost of downstream water treatment for domestic and industrial uses.

Impacts to worker and community health through contact with fecal waste that is improperly disposed of. Some of the risks of the FSM process can include health hazards to desludging operators, leaking of sludge from trucks, dumping of untreated sludge, and use of untreated new sludge as fertilizer.

Despite the potential for impacts listed above, the interventions envisioned as part of IR 2.1 are considered small-scale, with no direct implementation of infrastructure under the project. The impacts described above can be controlled below the level of significance by appropriate siting, maintenance, and technical assistance and capacity-building of small-scale sanitation service providers and users. With respect to the last, capacity-building in equipment/system maintenance is an essential component of the work under this sub-IR. Thus in accordance with 22 CFR 216.3 (a) (2) (iii), it is recommended that activities under IR 2.1 (as described above) receive a Negative Determination with Conditions.

Pursuant that determination, the following conditions must be met in before the activities listed above can commence:

An Environmental Mitigation and Monitoring Plan (EMMP – Annex 1) must be developed and implemented to ensure that impacts described above are eliminated or mitigated, and it must include specific descriptions of all monitoring and mitigation actions. This document shall be submitted to and approved by the COR and MEO and REA prior to commencement of infrastructure design and construction efforts. The EMMP should include plans to implement sanitary surveys as described in USAID’s Water Strategy Sanitation Implementation Brief.

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IR 2.2 and 2.3: Waste Treatment & Fecal Sludge Management Engineering and ConstructionActivities under IR 2.2 and IR 2.3 are focused on addressing the lack of fecal sludge management and waste treatment services in Haiti. In densely populated urban and peri-urban areas, the Haiti WASH project will support the design and construction of select wastewater treatment infrastructure, including the completion of the waste treatment plant in Cap Haïtien and the development of other small-scale decentralized treatment systems, utilizing low-cost options as appropriate. Pursuant 22 CFR 216.2 (d)(1), wastewater treatment facilities qualify for a Positive Determination, pursuant to 22 CFR 216.3 (a)(2)(iii), and require a Scoping Statement and a detailed Environmental Assessment, to be prepared in accordance with procedures outlined under 22 CFR 216.3 (a) (4) and 22 CFR 216.6. Such additional environmental review, and any associated mitigation measures, must be completed before any activity under IR 2.2 or IR 2.3 is initiated.

3.3 Improve the Enabling Environment for Sustainable Implementation, Operation, and Maintenance of Water and Sanitation Services (IR 3)

Pursuant to 22 CFR 216.2(c)(1)(i), because such activities have no or limited scope of physical interventions and no direct effects on the environment, 22 CFR 216.2(c) (2) recommends a categorical exclusion for: (i) education and training; (iii) workshops and meetings; (v) document and information transfers; (vi) contributions to national organizations; (xiv) programs to develop capacity of country to engage in development planning; and (xv) activities that involve the application of design criteria. All activities under IR3 are geared towards providing technical assistance to national and regional governments, and disseminating project learning, activities that fall within the class of actions listed in 22 CFR 216.2(c) (2). Thus a Categorical Exclusion is recommended for all activities under IR3. Such activities may proceed without any additional review or conditions.

4 SUMMARY OF RECOMMENDED DETERMINATIONS AND INCLUDING CONDITIONS

Per the above analysis, the following determinations are recommended for activities in the USAID/Haiti WASH activities covered under this IEE.

Intervention Category Recommended Determinations IR 1: Increase Access to Sustainable Water ServicesIR 1.1: Water Infrastructure Engineering Services

Positive determination, with potential change following Scoping Statement

IR 1.2: Water Infrastructure Construction Positive determination, with potential change following Scoping Statement

IR 1.3: Technical Assistance for Water Service Providers

Negative determination with conditions for activities related to supply chain strengthening for water treatment products

Categorical Exclusion for all other activitiesIR 2: Increase Access to Sustainable Sanitation ServicesIR 2.1 Support to sanitation enterprises Negative determination with conditions

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IR 2.2 Waste Treatment & Fecal Sludge Management Engineering Services

Positive Determination

IR 2.3 Wastewater Treatment & Fecal Sludge Management Construction

Positive Determination

IR 3: Improve the Enabling Environment for Sustainable Implementation, Operation, and Maintenance of Water and Sanitation ServicesIR 3.1 Provision of technical assistance to national and sub-national governments

Categorical Exclusion

IR 3.2 Dissemination of project knowledge and learning

Categorical Exclusion

4.1 Requirements for Environmental Review and Capacity Building ProceduresRolling identification of specific project activities will require additional assessment of the potential for environmental impact of activities as they become more fully developed and specific sites are identified for interventions. This modus operand provides an excellent opportunity to promote environmental review among the project’s partners, subcontractors and grantees, to build their environmental management capacity, and Haitian environmental management capacity overall. The project team should provide training to subcontractors and grantees to bring their environmental management capacity to a level sufficient for them to take responsibility for preparing required environmental review documentation. Requirements for subcontractors and grantees to prepare necessary environmental review documentation shall be written into subcontracts and grant agreements.

4.2 Environmental Responsibilities & Conditions As required by ADS 204.3.4, the Task Order COR (TOCOR) is responsible for ensuring that

appropriate environmental guidelines are followed, mitigation measures in the IEE are funded and implemented, and that adequate monitoring and evaluation protocols are in place to ensure implementation of mitigation measures.

The TOCOR and MEO will conduct spot checks to ensure that conditions in the IEE are met. These evaluations will review whether guidelines are properly used to implement in an environmentally sound and sustainable manner according to USAID and applicable U.S. Government policies and regulations.

If any new activities are planned outside the scope of this approved Regulation 216 environmental documentation, USAID shall prepare an amendment to the documentation for BEO approval. No such new activities shall be undertaken prior to receiving written approval of such amendments.

Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental documentation shall be halted until an amendment to the documentation is submitted and written approval is received from the BEO.

Contractors will be required to ensure that activities of funded sub-contractors will result in no adverse environmental impact, that subcontractors develop mitigation measures, and as

18

necessary, specify monitoring and reporting. The contractor will ensure that all sub-contract agreements contain flow-down language to establish environmental compliance responsibilities.

4.3 Mitigation, Monitoring, and Evaluation All project activities will incorporate those best practices and environmental mitigation measures

presented in the USAID Sector Environmental Guidelines for Water.

Mitigation and monitoring for activities that receive a Negative Determination with Conditions must follow the more specific conditions outlined in sections 4.1 and 4.2. As discussed there, all activities that are not categorically excluded from environmental review must also develop an Environmental Mitigation and Monitoring Plan (EMMP), the template for which can be found in Annex 1. All activities that receive either (a) a Negative Determination with Conditions or (b) a Positive Determination must include mitigation measures to reduce or eliminate the impact of potential environmental impacts, and a monitoring plan to verify that the mitigation measures implemented are effective. The EMMP review system templates in Appendix A include tools to help environmental documentation preparers develop mitigation measures and monitoring protocols sufficient to assure that no project activities result in significant negative environmental impacts.

For activities that receive a Positive Determination, an Environmental Assessment is required. The format for an EA, including requirements for mitigation and monitoring, are included in 22 CFR §216.6. The mitigation measures and/or recommendations from an EA, PERSUAP, and/or PEA should be compiled in Table 3 of an EMMP that will then be used for monitoring the implementation and effectiveness of the mitigation measures. The scoping for the EA must be approved by the MEO/BEO before the full EA proceeds, and the full EA must be approved by the MEO/BEO before activities commence.

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ANNEX 1: ENVIRONMENTAL MITIGATION AND MONITORING PLAN TEMPLATE

ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP)Guidelines and Template for Implementing PartnersWhat is an EMMP? An Environmental Mitigation and Monitoring Plan (EMMP) is a document that identifies the potential environmental impacts of some USAID-funded activities, as well as measures required to be taken to mitigate those impacts. It also serves as a monitoring and reporting tool for both USAID and its implementing partners. EMMPs are legally required before certain USAID-funded activities may proceed. Why are EMMPs required? All projects funded by USAID must comply with its Environmental Procedures. These procedures are legally required under the U.S. Code of Federal Regulations (22 CFR 216), which are further explained in USAID’s Automated Directives System (ADS 204). You can access these regulations and rules online.2 USAID’s Environmental Procedures ensure that the environmental consequences of USAID-funded activities are identified and considered before deciding to proceed with the activities, and that appropriate safeguards are adopted to mitigate potential environmental effects. EMMPs are one way to accomplish this goal.

When is an EMMP required? According to USAID’s Environmental Procedures, each activity must first have an approved Initial Environmental Examination (IEE) in place. Sometimes the IEE is specific to the activity, while other times it is more general and covers several activities or groups of activities. Either way, the IEE provides an initial analysis of the possible environmental effects of the activity or activities. It also includes an Environmental Threshold Decision (ETD). The ETD specifies what activities can proceed without further environmental review, what activities can proceed with environmental mitigation measures in place, and what activities require more detailed environmental analysis before a final decision can be made. Generally, the ETD in an IEE might include the following determinations for certain activities:

Categorical Exclusion – This means no further environmental review is necessary.

Negative Determination – This means no further environmental review is necessary.

Negative Determination with Conditions – This means that activities can only proceed if environmental mitigation measures are in place. If there is a Negative Determination with Conditions, then an EMMP will be required.

Positive Determination – This means that activities require further detailed environmental analysis in what is called an Environmental Assessment (or a Programmatic Environmental Assessment). Many times an Environmental Assessment results in a determination that some activities can proceed only if specific environmental mitigation measures are in place, so often an EMMP will be required here, too.

2 22 CFR 216 is available at: https://www.usaid.gov/our_work/environment/compliance/22cfr216. ADS 204 is available at: https://www.usaid.gov/sites/default/files/documents/1865/204.pdf. 20

Again, an EMMP is usually required if there is (1) a Negative Determination with Conditions, and/or (2) a Positive Determination (but only because the Positive Determination first requires an Environmental Assessment, and that assessment might in turn require an EMMP). However, you have to read the IEE to be sure! You can access all approved IEEs online.3

Can activities begin before an EMMP is completed and approved? If an IEE or Environmental Assessment requires an EMMP for certain activities, those activities cannot begin before an EMMP is approved by the USAID Contracting/Agreement Officer’s Representative (C/AOR), the USAID/Haiti Mission Environmental Officer (MEO), and the USAID Regional Environmental Advisor (REA). It is best to develop an EMMP as early as possible in the program cycle to avoid implementation delays.

What is required after the EMMP is completed and approved? Once the EMMP is complete and approved, it is the implementing partner’s responsibility to implement it, monitor environmental effects, and report on all of this to the Contracting/Agreement Officer’s Representative. It may be necessary to modify the EMMP if it is not working or can be improved. Generally, implementing partners should include a section on the EMMP within all performance reports, such as quarterly reports. You can do this simply by including Table 3 of the EMMP, and adding a narrative summary if needed.

How do I develop an EMMP? An EMMP template follows. It includes detailed guidance and tips for completing an EMMP, but you are free to adapt the EMMP if needed. The EMMP template includes four sections:

Narrative – Activity Description, Environmental Baselines, Summaries of Environmental Effects and Mitigation Measures, and Special Considerations

Environmental Screening Table (Table 1) – This serves as a quick checklist to assess possible environmental effects

Environmental Mitigation Table (Table 2) – This provides a detailed overview of specific activities, what their possible environmental effects are, and mitigation measures

Environmental Monitoring Table (Table 3) – This provides a list of mitigation measures, as well as monitoring and reporting information to ensure those measures are implemented

What are Sector Environmental Guidelines? In general, USAID Sector Environmental Guidelines can serve as a good starting point for populating information in an EMMP. These guidelines provide background on possible environmental effects for projects in individual sectors. You can access the guidelines online.4

Are there additional requirements to address in an EMMP? You should read your IEE, and any Environmental Assessment or Programmatic Environmental Assessment that was developed to cover your projects. Contact your Contracting/Agreement Officer’s Representative if you don’t’ have these as these documents often include specific requirements or environmental mitigation measures that must be incorporated into your EMMP.

3 USAID’s searchable environmental compliance database, which includes approved IEEs, is available at: http://gemini.info.usaid.gov/egat/envcomp/. 4 USAID Sector Environmental Guidelines are available at: http://www.usaidgems.org/sectorGuidelines.htm.21

Still have questions? You can email the USAID/Haiti Environmental Compliance Team at port-au-princeusaidenvironmentalcompliance@usaid.gov. Please be sure to include your Contracting/Agreement Officer’s Representatives on all communications.

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ENVIRONMENTAL MITIGATION and MONITORING PLAN (EMMP)

Program, Project, and/or Activity Title: _______________________________________________ Award Number: ________________________________________________________________

Implementing Partner(s): _________________________________________________________

IEE Number: ___________________________________________________________________ Funding Period: FY______ - FY______ Funding Amount (US$): ___________________________ Report Prepared by: Name: ___________________________ Date: ____________ Notes/Comments: _____________________________________________________

Note to Implementing Partner(s) If an EMMP is required, NO activities may be implemented until this EMMP

is approved by USAID All mitigation measures in this EMMP must be implemented and

monitored Implementing partners are required to report on this EMMP by submitting

updated versions of Table 3 and any relevant narrative in all performance reports that are required in the relevant agreement. Generally, this includes quarterly and annual performance reports.

USAID Approval of EMMP (for internal use):

________________________________________________ _________Contracting/Agreement Officer’s Representative Date

________________________________________________ _________USAID/Haiti Mission Environmental Officer Date

________________________________________________ _________USAID/Caribbean Regional Environmental Advisor Date

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Environmental Mitigation and Monitoring Plan Narrative

1. Background, Rationale and Results Expected: Briefly summarize the program, project, and/or activity so the reader understands the overall purpose, scope, and goals. Be concise, but complete.

2. Activity Description: In plain language, provide a detailed description of what activities will be implemented so that the reader understands what will be done. Be concise, but complete. Provide both quantitative and qualitative information about actions needed during the activity (e.g. specific actions of construction-size, location, and type of materials to be used), types of agriculture production (full till mechanized, organic etc.), how the intervention will operate, and any connected activities that are required to implement the primary activity (e.g., road to a facility, need to quarry or excavate borrow material, need to lay utility pipes to connect with energy, water source or disposal point or any other activity needed to accomplish the primary one but in a different location). If various alternatives have been considered and rejected because the proposed activity is considered more environmentally sound, explain these.

Example: New construction of a 900 square meter youth center located in XXX town within 40 meters of the River XXX. Construction will be of block and cement with rebar reinforcing. Construction will include a new two stall toilet and sinks using town water source from pipes. A 20 square meter biodigester will be used to capture waste and methane gas piped to the youth center kitchen for use as cook fuel. Biodigester will be underground and built of concrete by molds. Electrical wiring for the youth center will be installed with the power source by solar panels on the zinc roof and batteries/electrical circuits located attached to the center in a closed and locked storage room

3. Environmental Baselines: Briefly describe the area in which the program, project, and/or activity will take place so that the reader understands what the current environmental conditions are like. Be concise, but complete.

As applicable, provide information on the existing land uses, ecosystem conditions, sensitive areas such as wetlands or forests, infrastructure, roads, agricultural systems, air quality, water resources, surrounding activities, occurrence of wildlife, weather patterns and expected climate changes, gender dynamics, etc. Include maps, pictures, or video links as appropriate. Succinctly describe location, site details, and surroundings.

4. Potential Environmental Impacts: Based on the activities you described in in the Activity Description and the environmental conditions you described in the Environmental Baselines, describe the potential environmental effects or impacts. These can be provided in a list form, or you can describe them in narrative, or both. Be complete, but concise. These should then be used as part of the basis to complete Table 2 later on in this EMMP. They should track each other.

As appropriate, explain direct, indirect, and cumulative effects on various components of the environment (e.g., air, water, geology, soils, vegetation, wildlife, aquatic resources, historic, archaeological or other cultural 24

resources, people and their communities, land use, traffic, waste disposal, water supply, energy, climate change adaptation, climate change mitigation, etc.). Indicate positive impacts and how the natural resources base will be sustainably improved.

For example, any activity that increases human presence in an area, even temporarily, will increase noise, waste, and the potential for hunting, timber harvesting, etc.

5. Environmental Mitigation Measures: Based on the list or description of Potential Environmental Impacts you provided above, provide a list or description of environmental mitigation measures that will be implemented to reduce or prevent those impacts. These should then be used as part of the basis to complete Table 2 later on in this EMMP. They should track each other. You will also have to complete Table 3, which will document your specific plan for implementing and monitoring these mitigation measures.

6. Gender:While gender considerations are not directly an environmental concern, they are required in USAID planning and programming. Therefore, please describe how gender considerations have been incorporated into the activity.

7. Climate Change Integration:Please describe the possible impact of climate change on the program, project, and/or activity, as well as how the program, project, and/or activity might impact climate change. Demonstrate how both are considered and addressed within this program, project, and/or activity. This is required under Executive Order 13677 “Climate-Resilient International Development.”

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Environmental Screening Form (Table 1)

This Environmental Screening Form is used to screen activities to ensure that an EMMP is the most appropriate method for addressing environmental concerns. It allows USAID to screen for additional or

different environmental effects that may not have been considered fully in previous reviews of the program, project, and/or activity. Anything listed as “High Risk” will be further investigated by USAID before a

determination on how to proceed is finalized.

Column AColumn B

(answer if you checked “yes”)

YES NOHigh Risk

(difficult to mitigate impact)

Medium Risk

(can be properly mitigated)

INFRASTRUCTURE (Buildings, roads, WASH, etc.)

1 Will the intervention involve construction and/or reconstruction/rehabilitation of any type of building? For new construction, if less than 1,000 m2 = medium risk, if greater than 1,000 m2 = high risk.

2 Will the intervention involve building penetrating roads, road rehabilitation and maintenance or other road related infrastructure (drainage, bridges, etc.)? If penetrating road construction/rerouting = high risk2, if repair/rehabilitation (improving drainage, resurfacing of existing roads) = medium risk.

3 Will the intervention involve construction or rehabilitation of water and sanitation infrastructure (irrigation systems, potable water, water harvesting, septic systems etc.)? Potable water systems require testing for bacteria, arsenic and other heavy metals.

4 Will the intervention involve construction or rehabilitation of any other infrastructure such as landfills, incinerators, energy infrastructure, etc.

5 Will the intervention involve any kind of construction at all and/or engineering design? If YES, then a USAID Engineer must approve designs per USAID/Haiti Mission Order #36.

6 Does the intervention require adherence to national building code or other regulatory standards? Mitigation measures in Table 2.

N.A. N.A.

7 Does the intervention require local or national planning permissions (i.e. zoning, building permits, etc.)

N.A. N.A.

BIOPHYSICAL

8 Will the intervention involve the use of pesticides of any kind?

9 Will the intervention involve changes in water quality (pollution, sedimentation, stagnation, salinization, temperature change, etc.)

10 Will the intervention affect surface or groundwater quantity

11 Will the intervention involve training and/or implementation of agricultural practices/production including animal husbandry?

12 Will the intervention involve aquaculture systems?

13 Will the intervention involve the use or disposal of hazardous materials (used engine oil, paint, varnish, lead-based products, fluorescent light bulbs/mercury, batteries, asbestos or other hazardous or special management waste)? Consider effects to both the biophysical environment and human health.

14 Will the intervention involve implementation of timber management,

extraction of forest products, clearing of forest cover, and/or conversion of forest land by cutting of trees >20cm diameter at base height (DBH)?

15 Is the intervention in or near (within 50m) any sensitive terrestrial or aquatic areas including protected areas, wetlands, critical wildlife habitat (including nesting areas), and threatened or endangered species?

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16 Will the interventions proposed generate airborne particulates (dust), liquids, or solids (i.e. discharge pollutants) or potentially violate local air standards?

17 Will the intervention create objectionable odors?

18 Will the intervention occur on steep slopes (greater than 15%)?

19 Will the intervention contribute to erosion?

20 Will the intervention change existing land use in the vicinity?

21 Is the proposed intervention incompatible with land type (i.e., annual crops on steep slopes, infrastructure on poorly drained soils)?

22 Will the intervention affect unique geologic or physical features?

23 Will the intervention have potential effects to inhabitants, natural landscapes, or flora/fauna downstream from the intervention site?

24 Will the intervention have a direct or indirect effect, or include actions with mangroves, coral reefs and other marine/coastal ecosystems?

GLOBAL CLIMATE CHANGE

25 Are interventions or outcomes vulnerable to changes in the weather or climate such as changes in precipitation patterns, increased temperatures or sea level rise?

26 Does the intervention exacerbate climate change vulnerabilities (i.e., drought, flooding, decrease water supply)?

27 Will the intervention create greenhouse gas emissions from decomposing waste, burning of organic matter, or use of fossil fuels etc. (consider duration and scale)

SOCIO ECONOMIC

28 Will the intervention contribute to displacement of people, housing or businesses?

29 Will the intervention affect indigenous peoples and/or unique cultural or historical features?

30 Will the intervention expose people or property to flooding?

ENVIRONMENT & HEALTH

31 Will the intervention create conditions encouraging an increase in illness, diseases, or disease vectors (waterborne, STDs or other)?

32 Will the intervention generate hazards or barriers for pedestrians, motorists or persons with disabilities?

33 Will the intervention involve the use, storage, handling or disposal of syringes, gauzes, gloves and other biohazard medical waste?

34 Will the intervention expose workers to occupational hazards?

35 Will the intervention increase existing noise levels?

GENDER

36 Does the intervention inhibit the equal involvement of men and women?

37 Do the intervention results disproportionately benefit/impact men and women?

OTHER

38 Does the intervention/activity involve a sub-award component? N.A. N.A.

39 Is an operations and maintenance plan required? (generally applies to infrastructure, equipment, road rehabilitation, or water and sanitation action = Yes)

N.A. N.A.

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RECOMMENDED ACTION (Check Appropriate Action): (Check)(a) The intervention has no potential for significant effects on the environment. No further environmental

review is required.(b) The intervention includes mitigation measures and design criteria that if, applied will avoid a

significant effect on the environment. EMMP Required.(c) The intervention has potentially significant adverse environmental effects; therefore, an

Environmental Assessment is required to gather additional analysis before implementation may begin. NOTE: This may apply if any potential effects listed above are marked as “High Risk.”

(d) The intervention has significant adverse environmental effects that cannot be mitigated. Proposed mitigation is insufficient to eliminate these effects and alternatives are not feasible. The intervention is not recommended for implementation.*For sub awards, do not fund.

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Environmental Mitigation Table (Table 2)

Enter the Question/Row # of the potential negative impacts with check marks in Column A (Table 1) and complete table below for mitigation measures to reduce or eliminate the issue. In the Sub-Activity or Component Column, list the main actions to be implemented. Under each action, list the tasks (Steps) that are needed to implement this action.

# of the question from Table 1

Action or component with the different tasks required to implement the action.

Description of Impact Environmental Mitigation Measures*

1 Component – e.g., Construction and maintenance of latrine

Step 1- design

Step 2- location

Step 3- purchase of materials

Step 4- build latrine

Step 5- site clean-up/disposal of construction waste

Step 6- use of latrine/operations and maintenance

9 Component – e.g., Purchase and construction of a water storage system

Step 1

Step 2

Step 3

Etc.

* Indicate which mitigation measures will be used from the USAID Sector Environmental Guidelines or other pertinent guidelines, see http://www.usaidgems.org/sectorGuidelines.htm. Details on exact monitoring plan are illustrated in Table 3.

Environmental Monitoring Table (Table 3)REPORTING NOTE: Implementing partners are required to report on this EMMP by submitting updated versions of Table 3 and any relevant narrative in all performance reports that are required in the relevant agreement. Generally, this includes quarterly and annual performance reports.

Program, Project, and/or Activity: Award Number: Monitoring Period or Quarter: Date:

#Description of

Mitigation Measure (same as in Table 2)

Responsible Party for

implementing and

monitoring mitigation measures

Monitoring MethodsEstimated

Cost of implement-

ing mitigation measures

and monitoring

Results

Recommended Adjustments

Indicators of

implemen- tation

Methods FrequencyDates

MonitoredProblems

EncounteredMitigation

Effectiveness

1 1

2

3

4

2 1

30

2

3

4

3 1

2

3

4

4 1

2

3

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ANNEX 2: CLIMATE RISK SCREENING AND MANAGEMENT

OUTPUT MATRIX: CLIMATE RISKS, OPPORTUNITIES, AND ACTIONS* = A required element, according to the Mandatory Reference

1.1: Defined or

Anticipated Project

Elements*

1.2: Time-frame

1.3: Geo-

graphy2: Climate Risks*

3: Adaptive Capacity

4: Climate Risk Rating* 5: Opportunities 6.1: Climate Risk

Management Options

6.2: How Climate Risks Are Addressed

in the Activity

7: Next Steps for Activity

Implementation*

8: Accepted Climate Risks*

Component 1: Increasing Access to Sustainable Water Services

Sub-tasks 1.1 and 1.2: Water Infrastructure Engineering Services and Construction

Subtask 1.3: Technical

Assistance for Water Service

Providers

20 years Tier 1 cholera priority

communes and

Hurricane Matthew affected

areas

Urban and peri-urban

areas

Unpredictable rainfall patterns, flooding and

droughts, combined with deforestation, may impact

watersheds leading to variations in water supply available to urban areas

TEPACs (Communal Water and Sanitation

Technician) available to

quickly gather needed data

High On-going groundwater resource mapping, and efforts to combine data

Priority commune action plans related to cholera elimination will enable targeting of investments

to minimize risks

USAID investing in reforestation in one of the target areas, enabling co-

investment that could reduce flooding risks

Support water service providers to create long term plans to ensure availability of

raw water supplies

Any new systems constructed will take climate variability

into account

Work to minimize non-revenue water to maximize

system efficiency

Support water service providers to create long term plans to ensure availability of

raw water supplies

Any new systems constructed will take climate variability

into account

Work to minimize non-revenue water to maximize

system efficiency

Include all selected activities in work

plans, and in quality assurance and quality

control plans activities for construction

None

Increased frequency and severity of flooding may

damage or destroy infrastructure –

particularly given low quality and poor

maintenance of existing infrastructure

HighEnsure that all water systems or extensions constructed or rehabilitated are resilient to

flooding risks

Work with water service providers to ensure high quality operations and

maintenance

Ensure that all water systems or extensions constructed or rehabilitated are resilient to

flooding risks

Work with water service providers to ensure high quality operations and

maintenance

Increased flooding may reduce water quality, High

Develop water quality assurance plans for all new or

Develop water quality assurance plans for all new or

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contaminate water sources and increase risks of waterborne disease

rehabilitated water systems

Work with water service providers to implement water

safety plans to ensure on-going testing of water quality

Work with government systems to strengthen water

quality monitoring and regulation

Ensure more robust supply chain for chlorine to treat

water regularly

rehabilitated water systems

Work with water service providers to implement water

safety plans to ensure on-going testing of water quality

Work with government systems to strengthen water

quality monitoring and regulation

Ensure more robust supply chain for chlorine to treat

water regularly

Component 2: Increasing Access to Sustainable Sanitation Services

Sub-Task 2.1: Support to Sanitation Enterprises

15 years Tier 1 cholera priority

communes and

Hurricane Matthew affected

areas

Urban and peri-urban

areas

Increasing precipitation and storm events may lead

to inundation and overflow of new latrines

and septic systems, increasing public health

risks.

Storms/extreme events may result in population

dislocation, internal migration; overburdening

sites with limited sanitation services

Medium USAID has supported SMEs to strengthen supply chains and business practices

USAID investment in housing in locations close

to priority sites could provide case studies in

how facilities have been used

Market latrine products that minimize possibility of latrine overflow in flood prone areas

Incorporate issues relative to latrine flooding into any

training, capacity building for latrine providers

Provide training/messaging on latrine siting for

households that account for climate risks and prevent

water contamination

Market latrine products that minimize possibility of latrine overflow in flood prone areas

Incorporate issues relative to latrine flooding into any

training, capacity building for latrine providers

Provide training/messaging on latrine siting for

households that account for climate risks and prevent

water contamination

Include all selected activities in work

plans, and in quality assurance and quality

control plans activities for construction

None

Sub-Tasks 2.2 & 2.3: Waste Treatment & Fecal Sludge Management

20 years Tier 1 cholera priority

Increased frequency and severity of flooding may

damage or destroy

High

Limited current availability of fecal

sludge treatment creates window of opportunity to

Ensure that all waste water treatment plants constructed

or rehabilitated are resilient to flooding risks

Ensure that all waste water treatment plants constructed

or rehabilitated are resilient to flooding risks

Include all selected activities in work

plans, and in quality

None

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Engineering Services and Construction

communes and

Hurricane Matthew affected

areas

Urban and peri-urban

areas

infrastructure, in particular given low quality of

sanitation infrastructure

Flooding etc may inhibit collection and transport of

fecal waste

develop more resilient infrastructure and demonstrate best

practices to DINEPA

DINEPA in early stage of setting up regional

sanitation units (OREPA level)

Spanish funding waste treatment lab capacity at Titayen waste treatment

center

Existing pit emptying structure (bayakous)

Work to professionalize/ formalize FSM providers (e,g,

bayakous) and strengthen regulation to expand use of

services

Technical assistance to regional sanitation units to standardize latrine and FSM quality in response to climate risks

Work to professionalize/ formalize FSM providers

(e,g, bayakous) and strengthen regulation to expand use of services

Technical assistance to regional sanitation units to

standardize latrine and FSM quality in response to climate

risks

assurance and quality control plans activities for construction

Component 3: Improving the Enabling Environment for Sustainable Implementation, Operation, and Maintenance of Water and Sanitation Services

Sub-Task 3.1: Technical

Assistance to National and Sub-National Governments

5 years National, Regional

and Municipal

levels

Increased natural disasters inhibit government ability to develop and follow long

term plans

NA Low DINEPA/donor coordination increasing,

including support on hydro-geological

mapping

Engagement with government could lead to more focus on need for higher quality sanitation

to prevent water contamination during

floods

Caribbean Water and Wastewater Assn is setting up twinning partnership between DINEPA and other

operators

Include potential extreme events into strategic plans for long term management of services

Twinning and/or mentorship programs to bring learning from successful water and sanitation services

Include potential extreme events into strategic plans for long term management of services

Twinning and/or mentorship programs to bring learning from successful water and sanitation services

Ensure through work-planning and activity

management processes that

required activities are undertaken

None.

34

Sub-Task 3.2: Knowledge

Dissemination & Learning

5 years National, Regional

and Municipal

levels

NA NA Low Dissemination of activity learning could lead to more focus on climate

resilient water and sanitation infrastructure

NA NA NA

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