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Bureau for Food Sec urity Initial Environm ental Examin ation (I EE } Project Information: Activity/Project Title: Feed the Future Innovation Lab For Food Safety Contract/Award Number (if known) : RFA-OAA-18-XXXXXXX Geographic Location : Global Is this is an Amendment to an existing IEE? Yes, and this will be Amendment#: Original IEE Tracking#: BFS-18-02-001 BEO Approval Date: 2/28/2018 Title of Original document: Funding: Approximately $10m core, $1Sm buy-in, $1Sm AA Implementation Start/End: 01/08/2018 to 30/07/2023 Expiration Date (if any): Prepared By: Ahmed Kablan BFS Office: ARP I Date Prepared: 19 January 2018 Recommended Threshold Determination: 181 Negative Determination with Conditions _ Positive Determination [see 216.3(2)(iii)] _ Exemption [include rationale per 216.2(b)] 181 Categorical Exclusion [include rationale per 216.2(c)] _ Deferral [include rationale per 216.3(a)(l)(iii)] Guidance: Environmental Mitigation and Monitoring Plan (EMMP): If the Threshold Decision is a Negative Determination with Conditions. an EMMP will be developed by the Implementing Partner (IP) to mitigate the conditions described in this IEE. The EMMP will be completed before activities start. Periodic EMMP Reports shall be prepared by the IP to describe how well the monitoring and mitigation measures are working, and if any modifications are necessary. Guidance on BFS EMMP development is available at the BFS Environmental Compliance Tracking site. EMMP Reporting: 90 days after start of project. Gender Equality and Women's Empowerment: Per USAID policy, this IEE will consider the proposed activity in the full light of gender equity and women's empowerment related to environmental impact, not as a separate component, but as a core activity. Global Climate Change: A Climate Risk Management (CRM) narrative and table is included in section 3 of this document. This Document: The purpose of the Initial Environmental Examination, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the described activity, and to recommend determinations and, as appropriate, conditions, for these activities. Upon final approval of this IEE, these recommended determinations are affirmed as 22 CFR 216 Threshold Decisions and Categorical Exclusions, and conditions become mandatory elements of implementation. This IEE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. 1

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Bureau for Food Security

Initial Environmental Examination (IEE} Project Information: Activity/Project Title: Feed the Future Innovation Lab For Food Safety

Contract/Award Number (if known) : RFA-OAA-18-XXXXXXX

Geographic Location : Global

Is this is an Amendment to an existing IEE? • Yes, and this will be Amendment#:

Original IEE Tracking#: BFS-18-02-001 BEO Approval Date: 2/28/2018

Title of Original document:

Funding: Approximately $10m core, $1Sm buy-in, $1Sm AA

Implementation Start/End: 01/08/2018 to 30/07/2023 Expiration Date (if any):

Prepared By: Ahmed Kablan BFS Office: ARP I Date Prepared: 19 January 2018

Recommended Threshold Determination:

181 Negative Determination with Conditions _ Positive Determination [see 216.3(2)(iii)] _ Exemption [include rationale per 216.2(b)]

181 Categorical Exclusion [include rationale per 216.2(c)] _ Deferral [include rationale per 216.3(a)(l)(iii)]

Guidance: Environmental Mitigation and Monitoring Plan (EMMP): If the Threshold Decision is a Negative Determination with Conditions. an EMMP will be developed by the Implementing Partner (IP) to mitigate the conditions described in this IEE. The EMMP will be completed before activities start. Periodic EMMP Reports shall be prepared by the IP to describe how well the monitoring and mitigation measures are working, and if any modifications are necessary. Guidance on BFS EMMP development is available at the BFS Environmental Compliance Tracking site. EMMP Reporting: 90 days after start of project.

Gender Equality and Women's Empowerment: Per USAID policy, this IEE will consider the proposed activity in the full light of gender equity and women's empowerment related to environmental impact, not as a separate component, but as a core activity.

Global Climate Change: A Climate Risk Management (CRM) narrative and table is included in section 3 of this document.

This Document: The purpose of the Initial Environmental Examination, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the described activity, and to recommend determinations and, as appropriate, conditions, for these activities. Upon final approval of this IEE, these recommended determinations are affirmed as 22 CFR 216 Threshold Decisions and Categorical Exclusions, and conditions become mandatory elements of implementation. This IEE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

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IEE SUMMARY:

1. Project Context

Nutrient dense foods such as animal source foods, vegetables and fruits provide important protein and other macronutrients, and micronutrients can create multiple benefits towards food security goals, but also carry a higher risk of contamination with biological and chemical contaminants that could cause severe health (acute or chronic) problems and have negative impacts on nutrition specially for the most vulnerable groups (children under 5, pregnant and lactating women and elderly). Investments in food safety across the value chains can contribute to gains in incomes and nutrition of small-scale producer and low-income consumer households through consumption of safe and nutritious foods. Moreover; assurances of food safety are also a prerequisite for market access and commercial success in today's global food system.

2. Activity Description, Location, & Conditions

The Feed the Future Innovation Lab For Food Safety will design, lead and implement a program of food safety research and capacity building aimed at addressing the opportunities and challenges, other related opportunities and challenges, and will additionally serve as a resource to Missions and their partners on the role of food safety in inclusive economic growth, nutrition sensitive agriculture and a nutrition-sensitive approach, gender-sensitive and youth inclusive development, and resilience within the following Areas of Inquiry:

1) Improved food safety in Animal source food, fruits and vegetables, cereals and food security 2) Scaling up impacts through information flows and modernization 3) Strengthening food safety in the production and market systems and value chains, including through

establishing better traceability systems and improved agriculture technologies. 4) Increasing resiliency among smallholders especially women and youth 5) Increased understanding of preferences, needs and priorities of food safety along the value chains,

with attention to gender and youth, and application of that understanding to research project design and implementation

6) Reduced risks through improved detection, diagnostics, and food processing

The Food Safety Innovation Lab will foreseeably operate in any Feed the Future designated focus and aligned country. There is also the possibility that it will operate in other countries to conduct critical regional or global research that cannot be undertaken in Feed the Future focus countries but will provide benefits to Feed the Future focus country producers. The Innovation Lab will also undertake activities in the U.S. following U.S. environmental laws and regulations.

3. Potential Environmental Impacts Potential environmental impacts include:

I. Food scares due to the identification and dissemination of food safety hazards in the value chain II. Biosafety concerns due to research on and culturing infectious biological causes of food safety

hazards

Ill. Conducting of research on-farm or in a lab, involving the handling of mycotoxins (e.g. Aflatoxin) contaminated materials

IV. Conducting of research on-farm or in a lab, involving the handling of pathogens (e.g. salmonella) contaminated materials

V. Conducting of research on-farm or in a lab, involving the handling of toxic chemicals (e.g. pesticides) contaminated materials

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VI. Litter from packaged consumer goods and materials from test kits, instruments and materials used in research

Specific activities under this project may include impacts not foreseen at the time this IEE was prepared. Such activities will require an amendment to this IEE enumerating any potential adverse impacts as well as mitigating conditions.

4. Mitigation Conditions

The majority of activities will be research in nature or meetings, conferences, laboratory analysis, HICD activities, or training that will either fall under a categorica l exclusion (22CFR 216.2(c)(2)(iii)) or have a negative determination with conditions. All of the conditions will be to follow Best Management Practices, implement a PERSUAP (should pesticides be needed to achieve project goals), and train staff on proper laboratory practices.

Lab work may involve culturing and propagating infectious agents for the purposes of detection and diagnosis; this resembles a biosafety hazard and will be mitigated using appropriate labs equipped with appropriate biosafety level or equivalent certification and in accordance with USAID regulations and ADS 221

5. Threshold Determination

Activity

1) Improved food safety and food security;

2) Increased understanding of linkages between nutrition & food safety;

3) Increased understanding of food safety preferences, needs, and priorities along the value chain by gender, age group, or other disadvantaged groups, and application of that understanding to project design and implementation; and

4) Increased and inclusive value­added gains along the value chain, including bottlenecks in innovation adoption and scale-up and where these bottlenecks may be gender-

Recommended Determination

Negative Determination, subject to the following conditions: Specific Project Activities will require an Amendment to this IEE that fully define potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and

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related or affect youth in particular. mitigating conditions.

A negative determination, with conditions, is recommended for activities involving: • Food safety research on raw food materials that are contaminated with biological or chemical

contaminants, scale-up of any size. Any activity that later incorporates the use of controlled hormone, pesticides, fertilizer, or inoculants shall ensure that an approved PERSUAP is in place prior to use and that such use follows the policies of either the country of the location of the project or USAID, whichever is more restrictive. Best Management Practices will be utilized to minimize non­chemical related impacts on the environment.

• Clinical (medical) evaluations and people-based surveys. Such research shall receive Institutional Review Board approval of the sponsoring institution to implement relevant provisions of 45 CFR 46.116 in order to safeguard ethical conduct of research involving human subjects.

A categorical exclusion is recommended for all laboratory (including greenhouse, excluding mycotoxins, dangerous chemicals and pathogens), classroom, workshop, meeting, office, or training activities per 22CFR 216.2( c)(2)(iii).

APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE:

Office Director: _...;;b_.y.....;e;;.;.m,;,,;,a=i"--1 ___________ _ Date: _ _ 4=/-=-18=/-=2=01=8"--_

Jennifer (Vern) Long, Bureau for Food Security/Agriculture Research and Policy Office

AOR: ___ .....;A~·~k~. ____________ _

Ahmed Kablan, BFS/ARP

CONCURRENCE: ~

BFS Bureau Environmental Officer: ~---.---­

William Thomas

Additional Concurrences:

Research Division Chief: _____ =b...._y"""'e"'"'m-'-'a=il'-------

Nora Lapitan, BFS/ARP/Research Division

BFS Tracking#: BFS-18-02-001

Date: 4/18/2018

Date:

Date: 3/6/2018

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BFS Initial Environmental Examination (IEE)

1. Project Context

Food safety has become a rising priority under Feed the Future, amidst growing evidence that contaminated staple foods may cause substantial harm to human health and child development, and as development practitioners strive to promote nutrient-dense yet perishable foods, such as fruits, vegetables and animal­sourced foods (e.g., meat, milk, eggs and fish) to achieve nutrition and income gains, the risk of substantial harm through food-borne illness is even greater. The Food Safety Innovation Lab will focus on advancing the productivity frontier, reducing and mitigating risk, and improving human outcomes thrnugh nutrition, equity and economic opportunity for the poor. This will create multiple benefits towards the goals of the Global Food Security Act, specifically the Research Agenda of the Global Food Security Strategy. The goals are: 1) Address the most critical food safety and nutrition issues at global, regional, national, and subnational

levels; 2) Deliver a spectrum of innovations from international public goods, technologies, policies, and improved

natural resource management to financial products that can help households and small-scale producers manage risk; and

3) Deliver widespread impacts within and beyond our target counh·ies.

Improving the sanitaiy and phytosanitaty quality of food can also open new local and export market opportunities that enhance profitability. Technologies and practices that support correct handling and processing of staple and perishable foods at the household, farm and market level are therefore essential to maximize profits for farmers while also ensuring affordability and safety for consumers. Innovations that identify prevent and detect the foodborne pathogens and contaminants that pose the greatest risks will also help maximize nutrition and health outcomes.

2. Activity Description, Location, & Baseline

3. Activity Description

The Feed the Future Innovation Lab on Food Safety (Food Safety Innovation Lab) is a strategic portfolio of the following research areas: 1) improved food safety and food security; 2) increased understanding of food safety linkages to nutrition & how to deliver on nutrition targets; 3) increased understanding of food safety preferences, needs, and priorities along the value chain by gender,

age group, or other disadvantaged groups, and application of that understanding to project design and implementation; and

4) Increased and inclusive value-added gains along the value chain, including bottlenecks in innovation adoption and scale-up and where these bottlenecks may be gender-related or affect youth in patticular.

The goal of the Food Safety Innovation Lab is to reduce global hunger, malnutrition and povetty through science, technology & innovation. The Food Safety IL will develop sustainable and integrated food safety systems [BJElJ that contribute to improved nutrition and reduce health risks along the food value chain from production to consumption. The Food Safety Innovation Lab will focus on advancing the productivity frontier, reducing and mitigating risk, and improving human outcomes through nutrition, equity and economic oppo1tunity for the poor. The world population is projected to increase from 7.5 to 9.5 billion people by 2050 with a 70 percent increased demand for food and other resources; a 100 percent increased demand in the developing world. As the demand for more food production and manufacturing expands to meet the growing demand, the risk of food safety incidents also increases. The consolidation necessaty to scale up food production, combined with the lengthening of the supply chain as people move into urban centers farther from where food is grown,

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increases the likelihood and the severity of food-safety related illnesses caused by biological and chemical contaminants. In developed societies food safety concerns are high; however, the real tragedy of foodborne diseases is played out in the developing world. Unsafe water used for the cleaning and processing of food; poor food-production processes and food handling (including inappropriate use of agro-chemicals); the absence of adequate food storage infrastructure and cold chains; and inadequate or poorly enforced regulato1y standards- these all contribute to a high risk environment. Moreover, as a countty's economy develops the agricultural landscape changes. Intensive animal husbandry practices are put in place to maximize production, resulting in the increased prevalence of pathogens in flocks and herds. The tropical climate of many developing countries favors the proliferation of pests and naturally occuning toxins, and the risk of contracting parasitic diseases, including worm infestations. Only recently has systematic and comprehensive evidence on the health bmden of FBD in developing countries staited to become available. The landmark first assessment of the global burden ofFBD, conducted by the World Health Organization (WHO), considering 31 hazards for which there was enough information to allow global burden estimates, was published in 2015 . This shows that FBD has a health burden comparable to malaria, HIV/AIDS or tuberculosis. Most (98%) falls on developing countries and 40% on children less than five years of age. The global burden of FBD caused by the 31 known hazards considered in 2010 was 33 million disability adjusted life years (DALYs): children under five years bore 40% of this burden.

While opportunities for improved food security exist in both the developed and developing world, there are significant challenges to global agricultural systems in regard to globalization and marketing. Confronted with these challenges, agriculture and livestock production will have to produce foodstuffs in an economically sustainable manner on dwindling arable land and using shared water resources and other inputs. Significant opportunities exist for transforming agriculture system, increasing incomes and reducing risks. Research is needed to better understand how to reform and transform agriculture production and marketing systems to restore the productivity, profitability and resiliency while maintaining safe food production and processing.

4. Location

As a Feed the Future Innovation Lab, USAID wants to encourage broad participation among researchers around the world. As such, the Management Entity that is awarded the Food Safety Innovation Lab will first conduct a separate public RFA process to identify those research projects that will provide the highest expected return on value for USAID development goals. As such, the countries are not limited at this stage.

Though it has a global mandate and may expand work, as appropriate, to other geographies, the research will primarily be limited to Feed the Future focus and align countries and the U.S. Under some circumstances, research may be permitted in other countries if the project can demonstrate that the benefits of the research will contribute to the advancement food safety in Feed the Future focus countries and/or the U.S. and the research cannot be performed in a Feed the Future focus countty due to a lack of specialized skills or facilities. Under the existing Feed the Future focus countries, the likely countries where research will be conducted are Bangladesh, Guatemala, Honduras, Ethiopia, Ghana, Kenya, Mali, Nepal, Niger, Nigeria, Senegal and Uganda. Complementa1y research will be conducted in the U.S. at a Land Grant Universities which have in place documented environmental compliance controls (which are fully compliant with NEPA), and thus this IEE defers to those existing internal University regulations for any research conducted in the United States.

In addition to the research activities selected through the research RFA process, the ME itself will propose up to seven activities that will be considered as a part of the USAID RFA application. These activities must adhere to all other USAID rules and regulations, but they could be conducted in any counhy listed above.

5. Host Country Laws

Implementation will in all cases adhere to applicable host countty environmental laws and policies. The IP, sub-grantees and subcontractor must comply with host countty environmental regulations unless otherwise

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directed in writing by USAJD. However, in case of conflict between host country and USAJD regulations, the latter shall govern.

6. Potential Environmental Impacts

7. Adverse Impacts

Expected activities under the new Food Safety Innovation Lab foreseen impacts of the research activities could possibly include:

• Food scares as a results of the research findings • Mycotoxins contaminated crops disposal • Pathogen contaminated foods/crops disposal

• Litter from packaged consumer goods and materials from test kits, instruments and materials used in research

• Biosafety concerns due to research on and cultming infectious biological causes of food safety hazards

Specific activities under this project may include impacts not foreseen at the time this IEE was prepared. Such activities will require an amendment to this JEE enumerating any potential adverse impacts as well as mitigating conditions.

8. Climate Risk Management

As an agricultural research activity, the activities in Food Safety Innovation Lab are necessarily impacted by climate in both the sho1t and long term. In the short term, research is affected by natural weather patterns such as El Niflo, hurricanes, floods, droughts, hail, and extreme heat and cold. In the long term, slowly changing weather patterns and temperatures can impact the type of food safety risks associated with food production systems. Most often, these changes in climate result in food-borne illness outbreaks due to increased abundance of certain pathogens, inve1tebrate and vertebrate pests or environmental toxin due to drought or floods. As a research activity, the goal of the Food Safety Innovation Lab will be to improve food safety, nutrition, and food security for households and farmers so as to make food production safe and resilient when confronted with these climate changes.

The specific activities that are proposed by the winning applicant for the Management Entity of the Food Safety Innovation Lab and the later activities selected through an openly competed RF A process will undergo a CRM evaluation prior to approval.

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9. CRM Table Defined or Anticipated Climate Risks list key risks Risk Rating How Risks are Addressed at Project Further Analysis and Opportunities to Project Elements (Purpose/ related to the project Low/ Level Describe how risks have been Actions for Activity Strengthen Climate Sub-purpose, Areas of elements identified through Moderate addressed at the project level. If a Design/ Implementation Resilience Describe Focus, or Activities / either the strategy- or / High decision has been made to accept Describe CRM measures to opportunities to Mechanisms, etc.) project-level climate risk the risk, briefly explain why. be integrated into activity achieve development

assessment. design or implementation, objectives by including additional integrating climate analysis, if applicable. resilience or mitigation

measures. Improving food safety, Natural weather patterns (Moderate Some stages may require a scaled-up No other measures are The research activities nutrition, and food security such as El Nino, hurricanes, or High) effort in open fields, at household or anticipated. themselves are

floods, droughts, hail, frost informal market level. Research will dedicated to and extreme heat and cold. adapt to moving targets and risks. improving food safety Slowly changing weather that will increase patterns and temperatures resil ience of can impact the hazards in households and small-certain agro-production area scale producers. of a given standing crop of (livestock, fish, staples or fruits & vegetables).

Increased understanding of Increased nutrition Low All climate risks are accepted as they None Healthy people are linkages between nutrition understanding primarily are deemed to be non-impactful to more resi lient to & food safety comes from a clinical this research area. climate change. They

laboratory setting that is have more energy and primarily independent of strength to put into climate. practice resilience

measures. Increased understanding of Priorities may be biased Medium This is an acceptable risk because it Researchers in this field The outputs of this preferences, needs, and during surveys based on still highlights priorities of producers. should be fully cognizant of research wi ll lead to priorities on food safety current raw material crop Researchers need to be cognizant of their area of specialty and improved outcomes along the chain by gender, season needs. the challenges and limitations of this the best projects in that wi ll increase age group, or other type of research and inherent bias. response to the research household resilience. disadvantaged groups, and RFA will be selected and application of that then refined with input

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understanding to project design and implementation Increased and inclusive value-added gains along the value chain, including bottlenecks in innovation adoption and scale-up and where these bottlenecks may be gender-related or affect youth in particular

Human and Institutional Capacity Development

Natural weather patterns such as El Nino, hurricanes, floods, droughts, hail, and extreme heat and cold. Erratic weather patterns can impact the hazards in certain agro-production area might impact various groups differently. E.g. women in certain cultures may not be able to swim with floods. Exposure and vulnerability to shocks may vary by gender, age and social status Catastrophes due to fire, flood, hurricanes, etc. would interrupt many HICO activities temporarily. Structures that may be depended upon to provide research services could be damaged by climate related events. Exposure and vulnerability to climate shocks may vary by gender, age and social status

Moderate

Low

Risks must be addressed on an individual basis.

These risks are inherent to every USAID project. Under this mechanism, funding is not permitted for new construction. Existing structures may be retrofitted or remodeled as necessary and if approved by the AO. Any work that is performed will, to the extent t hat is practical, increase the structures ability to withstand such catastrophes.

from an advisory committee. Researchers will discuss potential climate risks with advisory committee and adjust research as necessary.

The ME will discuss with USAID AOR and AO any needs for changing existing st ructures to either comply with existing USAID policy or upgrade research facilities as necessary.

Most, but probably not all, activities in this area of research wil l lead to greater resilience t hroughout the whole food system.

Any modification to facilities will increase their resi lience to adverse climate events.

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10. Mitigation Conditions

11. Conditions by environmental impact risks

All risks listed below that could adversely impact the environment are considered medium risk and requir:e a negative determination, with conditions. Amendments to this IEE will require analysis to ensure all potential impacts are thoroughly covered.

A. Water contamination. Water could be contaminated through runoff of approved research materials and reagents such as hormones, pesticides and fertilizers, soil from the normal disturbance of the earth under tillage practices, and accidental discharge of approved laboratory chemicals used in approved laboratory research settings. To mitigate against such cases, researchers will follow agriculture best management practices (BMPs); such BMPs are available from USAID in the Sector Environmental Guidelines (available at http://www.usaidgems.org/sectorGuidelines.htm).

B. Loss of biodiversity. Biodiversity loss is not anticipated under the Innovation lab work. However, Researchers will follow agriculture best management practices (BMPs) when applicable; such BMPs are available from USAID in the Sector Environmental Guidelines (available at http://www.usaidgems.org/sectorGuidelines.htm).

C. Land conversion from native forest or grassland. Research will not be allowed to convert virgin forest or grassland to crop land for food safety research or any related activities.

D. Litter from packaged laboratory goods and materials. Some activities may involve the use of packaged laboratory products. Researchers will be encouraged through package markings to dispose of the waste in the most appropriate way possible.

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12. Threshold Determinations

Recommended Threshold Determinations

Per this analysis, the following determinations are recommended this activity:

Activity

1) Improving food safety, nutrition, and food security

2) Increased understanding of linkages between nutrition & food safety

3) Increased understanding of preferences, needs, and priorities on food safety along the chain by gender, age group, or other disadvantaged groups, and application of that understanding to project design and implementation

4) Increased and inclusive value­added gains along the value chain, including bottlenecks in innovation adoption and scale-up and where these bottlenecks may be gender­related or affect youth in particular

Recommended Determination

Negative Determination, subject to the following conditions: Specific Project Activities will require an Amendment to this IEE that fully define potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and mitigating conditions.

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

However, if Specific Project Activities diverge from the above Categorical Exclusion, an Amendment to this IEE will be required which fully defines potential environmental impact and mitigating conditions.

A negative determination, with conditions, is recommended for activities involving: • Agronomic field research of any plot size. Any activity that later incorporates the use of controlled

hormone, pesticides, fertilizer, or inoculants shall ensure that an approved PERSUAP is in place prior to use and that such use follows the policies of either the country of the location of the project or USAID, whichever is more restrictive. Best Management Practices will be utilized to minimize non­chemical related impacts on the environment.

• People-based surveys. Such research shall receive Institutional Review Board approval of the sponsoring institution.

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