l/~E fi1r ''Small-scafc i11frastrucl1/l'e constr11ctio11, re11qvatio11 and i111pro1•e111e11t l'rogra111 "

USAID EGYPT FROM THE AMERICAN PEOPLE

INITIAL ENVIRONMENTAL EXAMINATION

PROGRAM/ ACTIVITY DATA:

l>rc;igram/Actiyity Number: ( 236 - 0270 )

Country/Region: Egypt

DO: A more competitive and inclusive Egyptian economy through growth in selected sectors

Program/Activity Title: Egyptian Utilities Management (EUM) Assistance Agreement; Small-scale infrastructure constructiou. renovation and improvement nrogram

Project/ Activity I mplcmcntatiou: Through ___ =S=-c1"'"'>t=e=m=b ..... e.._r =2~0~19,___

Funding Year Begins: PY2014 Funding Year Ends: FY2018

LOP Amount: $38 million ---~~~~~----

Prepared By: _ _ _ _,_M=a=tc-=...t -=C~u~•t=is~ __ Currcnt Date: 5-26-14

Expiration Date: _September 2019 __

Amendment (YIN): Yes CEUM. JEE Amendment #13, ME 10-27)

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Negative Determination: Negative Determination with Conditions: X

Positive Determination: _ _ _ Deferral :

Categorical Exclusion: x

ENVIRONMENTAL ACTION RECOMMENDED:

1. The construction of small-scale interventions to expand access to clean potable water and adequate sanitation for undcrscrved communities: Ncgati\'c Determination with Conditions pursuant to 22 CFR, Part 216.3 (a)(2)(iii).

2 . The construction of water treatment and distribution systems to provide clean potable water: Ncgath·c Determination with Conditions pursuant to 22 CFR, Part 216.3 (a)(2)(iii).

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//~£fur "Small-smle i11.fras1ruc111re co11str11ctio;1, renol'atio111111d improvement Program "

3. The construction of wastewater collection systems: Negative Determination with Conditions pursuant to 22 CFR. Part 216.3 (a)(2)(iii).

4. The construction of additional ponds for the expansion of the existing wast~water stubili7.ation ponds at Luxor City: Negative Determination with Conditions pursuant to 22 CFR, Part 216.3 (a)(2)(iii).

5. Construction monitoring and engineering support: Categorical Exclusion pursuant to 22 CfR, Part 216.2 (c)(2)(i).

I. BACKGROUND AND ACTIVITY/PROGRAM DESCRIPTION

J. I Background

The objective of the EUM Assistance Agreement was to improve access to water and :mnitation through addr~ssing three program elements: safe water access. basic sanitation, and water and sanitation policy and governance.

The original activities under the EUM stm1cd in J 997 and provided several decentralized improvements in the water and wastewater sector for select Governorates. These improvements inch1ded among multi several activities: 1) the constrnction of water treatment systems that used slow sand filtration to trei1t Nile or canal water to provide clean potable water to communities, and 2) the construction of waste\Vater collec:tion systems.

No major negative impacts on natural. physical or economic resources were identified in environmental assessments (EAs) reports that were performed for similar ac\ivities under EUM (ME-EA-07-157, ME-EA-07-143). No cross-spectral impacts have been identified. The cumulative impacts of the proposed projects will be improved water/wastewater services. which will protect or improve upon existing levels of domestic hygiene. The environmental mitigation measures that were placed on the activities were all 'systematic' that is, they related to the construction and functioning of the activities. None of the conditions were site-specific. This conclusion came out from EAs that were prepared by 1-lorza Environmental Sen1ices at the sta11 of the EUM program and lately by Camp Dresser and McKee (CDM) in 2007 (as referenced previously above). In subsequent amendments to the IEE. the mitigation conditions previously identified were used and the activities were given a Negative Determination with Conditions (Amendment I 0 "ME I 0-27''. Attachment I).

In the post-revolution period, the Embassy 1md USAID, with inter-agency oversight from Washington. identified sh01t-term job creation as one of the highest priorities for the use of foreign assistance funding to help Egyptians weather the rapidly worsening condition of the Egyptian economy. Tourism receipts, foreign direct investment. and therefore foreign exchange reserves plummeted after the revolution. Unemployment grew rapidly and reached 12.6% in 2012, its highest level i11 10 years. lt was determined at that time that the quickest way to create short-term jobs would be to use implementation mechanisms in the existing portfolio rather than new projects. In 2011. the Mission decided to increase funding to the Small Scale Infrastructure Activity (an existing mechanism ~mder the Egyptian Utilities Managcmcht (EUM) Assistance Agreement) to stimulate short-term job creation in the water and wastewater sector. This was an implementation mechanism that could be expanded quickly. had a proven track record. used

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IEE Ji.Jr '"Sma/1-scall! i11jrc1.1·1r11r;fl(re com1r11ctiu11, rl!IW\'alivn und improvement Program ..

labor intensive construction methods, and could provide immediate short-term employment in parts of the country that were badly hurt by the economic downturn.

In April 2011. the scope of this activity was expanded to include even smal lcr scale activities that were labor intensive and would provide short term employment. Activities described in Amendments I I and 12. were aimed at small-scale construction. renovation and improvements to Weller/wastewater infrastructure. Activities also included the installation of limited lengths of water /wastcwnter pipe lines in order to connect houses in urban/rural arel'!s to existing working systems. These under-served communities were located on the periphery of existing older urban/rural areas, and had not yet been connected to central water/wastewater systems. Interventions for each urban/rural town ranged from $20,000 to $160,000. Individually distinct interventions were grouped under blanket Fixed Reimbursable Agreements (F ARAs, see paragraph below for a more detailed explanation) for each of the relevant Governorntes. The Bureau Environmental Officer approved the IEE amendment for this activity with an environmental threshold decision of "Negative Determination with Conditions ME 11-64 Egypt IEE SOl6 ELIM, (Amendm~nt 11). That amendment had a $7 million ceiling. and was subsequently amended to a $40 million ceiling (Amendment I 2 "ME 11-91 ").

The EUM small-scale program used f ARAs \Vi th Governorates in Upper Egypt. These FARAs were implemented by public Water Holding Companies. The f.'ARAs generally ranged from $250,000 to $5,500,000, and funds were paid to the implementer when milestones were met. A milestone in this context was defined as completion of the above mentioned interventions in a particular urban or rural town within a Govemorate.

1.2 Changes to the Preyious IEE in this Amendment

This IEE Amendment will raise the ceiling of the activity by an additional $38 million. and extend it to September 2018. This amendment expiration date (September 2019) goes one year beyond the activity date in order to cover any anticipated delays that could occur during implementation. The same interventions carried out in the previous amendments will be continued. with an additional intervention described below. These interventions will take place in Upper Egypt in the Governorates of Beni Suef, Minia. Assiut, Sohag. Qena, Luxor and Aswan.

A new element has been added to this activity that will provide construction monitoring and engineering suppo11, which falls under 22CFR 216.2 (c)(2)(i) categorical exclusion. The proposed scope of work includes the following tasks:

• Provide quality assurance. • Review and report to USA IP on FARA 's milestones completion. • Perform a final inspection of all constructed facilities. inform USA ID and the GOE

utilities. in writing, of all issues that may affect the project and suggest methods of resolution.

• Certify all requests to USA ID from the GOE implementing agencies for reimbursement of work completed, and provide confirmation that said work has met the conditions of C\11 cohtracts and agreements covering the work.

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• Review nc\v proposals anti ¢Os\ estimates and provide recommendation to USAID and the GOE implementing agencies.

• Insure adequate reporting on the USAID performance indicators. • Ensure that all construction activities are iinplemented in compliance with USAID

environmental requirements.

1.3 Evaluation of Project/Program Issues with respect to Environmental Impact Potential

1. The construction of Small-Scale Interventions: Funding may be used to support specific water/wastewater activities including the installation of limited lengths of water/wastewater pipe lines and the installation of waterf\.vastewater house connections in urban/rural areas to existing working distribution and collection systems. Interventions \vi thin each f ARA will be small­scale and range in cost from $25.000 to $150,000. The cumulative negative impact of these can be avoided or mitigated if the recipient adopts proper implementation precautions and mitigation measures. Therefore, the Mission. pllrsuant to 22 CPR, Part 216.3 (a)(2)(iii) recommends that a Negative Determination with Conditions be recorded for this activity provided that the implementer follow the procedures in section 1.4

Th<: construction activities for the Small-Scale Interventions will include shallow excavating, laying of small sizl;! UPYC pipelines and backfilling. The activity will include erection of few small size valve chi:11nbers.

The study. design and construction documents for all small-scale interventions will be developed by a qualified Engineering Design/Construction Management Contractor (ED/CMC). who will also provide construction management services for the construction phase of the project. The CMC shall assure that all contractors follow good construction practices. building codes and regulations, all required safety precautions and mitigation me~sures.

2. The construction of Water Treatment and Distribution Systems: Currently, the source of water for these communities is groundwater. Analytical results of water samples collected from area wells indicate that most arc not in compliance with Egyptian potable water quality standards for turbidity. total hardness, nitrates. iron, or manganese.

The components of the Potable Water Treatment Facilities include: I. Raw water intake( on the Nile River) or ground water wells; 2. Raw water pump station; · 3. A building to house the water filters; 4. Chlorine building; 5. A reservoir to store treated water; 6. Treated water pump station: and an administrative building

The construction activities for the Potable Water Treatment Facilities will include excavating. concrete operation. and minor mechanical installations. The building pads for each vary from approximately I 00 x 50 meters to 30 x 30 meters. and occupy previously disturbed land that is not archcologically or environmentally sensitive. and has long been used for agriculture. A large number of the proposed facilities will be located inside the boundaries of

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existing potable water facilities sites. As a precaution, the construction contract will also include a clause to ensure that if any antiquities are found, excavation will immediately be stopped. The Ministry of Antiquities (MA) will be contacted to evaluate the site and provide instructions.

The study, design and construction documents for all water system activities will be developed by a qualified Engineering Design/Construction Management Contractor (ED/CMC). who will also provide constrnction management services for the construction phase of the project. The CMC shall assure that all contractors follow good construction practices. building codes and regulations, all required safety precautions and mitigation measures based on previous EAs. It is anticipated that these activities will, therefore, have no significant impact on the natural and physical environment. Therefore, the Mission, pursuant lo 22 CfR, Part 2 I 6.3 (a)(2)(iii) recommends that a Negative Determination with Conditions be recorded for these activities, provided that the implementer follow the procedures in section l .4.

3. The construction of Wastewater Collection Systems: Construction of wastewater collection and conveyance systems in villages will greatly reduce dependence on inappropriate on-site wastewater systems and greatly reduce exposure of residents to untreated septic waste. As such, the proposed projects are anticipated to result in beneficial, Jong-term environmental improvement with significant improvements for human health.

The components of the Wastewater Collection Systems include: 1. Collection pipeline systems, with small diameter pipes (200 mm to 450 mm), and

manholes; 2. Small-scale wastewater pump stations; and 3. High density polyethylene force mains with a diameter up to 500 mm.

The construction activities for the Wastewater Collection Systems will include excavating small trenches (2-4 meters deep). installing UPVC pipes (200-450 millimeters in diameter). installation of high density polyethylene force mains. erection of manholes, and pump station caisson of 5 meters in diameter (about 8 meters deep).

The study, design and construction documents for all wastewater collection system activities will be developed by a qualified Engineering Design/Construction Management Contractor (ED/CMC), who will also provide construction management services for the construction phase of the project. The CMC shall assure that all contractors follow good construction practices, building codes and regulations, all required safety precautions and mitigation measures.

The proposed pump station sites and selected route of the off-site force main occupy previously-disturbed urban areas that are not archeologically or environmentally sensitive. As a precaution. the construction contract will also include a clause to ensure that should any antiquities be found at the site, excavation will immediately be stopped. The MA, the GOE ent ity charged managing antiquities sites, will be contacted to evaluate the site and provide instrnctions. Therefore, the Mission, pursuant to 22 CFR, Part 216.3 (a)(2)(iii) recommends that a Negative Determination with Conditions be recorded for these activities, provided that the implementer follow the procedures in section I .4.

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4. The construction of additional ponds for the expansion of the existing wastewater stabilization ponds at Luxor City: The existing wastewater facility was constructed under a previous USAID program (Sccondflr)' Cities). The planned expansion will increase the capacity of the facility, to inch1de additional facultative and maturation ponds. Infrastructure of the facility already exists as well as anaerobic ponds. Land for expansion is available and water reuse areas (wooded lots) are already established. An EA was performed before the initial site constn1ction in 1997, and found: "The Environmental Assessment did not identify any significant adverse impacts from the proposed project, but did recommend that special care be taken during construction to protect buried antiquities. Additionally the Environmental Assessment indicated that the treated effluent from the proposed stnbilization pond may be reused in the future for agricultural irrigation." These same mitigation measures as well as those specified below will be followed in the expansion of the facility.

The sttidy. design and construction documents for all wastewater activities will be developed by a qualified Engineering Design/Construction Management Contractor (ED/C'MC). who will also provide construction management services for the construction phase of the project. The ED/CMC will conduct an assessment of the current condition and performance of the existing plant, and will provide recommendation for works (rehabilitation or replacements) that should be taken into account at the design phase of the additional ponds. An updated EA, particularly of the adjacent land use, will be part of this expe¢ted assessment. The CMC shall assme that all contractors follow good construction practices, building codes and regulations, all required safety precautions and mitigation measures identified in previous EAs. It is anticipated that these activities will, therefore, have no significant impact on the nati1ral and physical environment. Therefore. the Mission, pursuant to 22 CFR, Part 216.3 (a)(2)(iii) recommends that a Negative Determination with Conditions be recorded for these activities, provided that the implementer follow the procedures in section 1.4.

5. Construction monitoring and engineering support: The proposed scope of work includes: provide quality assurance, review and report to USA ID on FARA 's milestones completion, perform a final inspection of all constructed facilities, inform USAID and the GOE utilities, in writing, of all issues that may affect the project and suggest methods of resolution, certify all requests to USAID from the GOE Implementing agencies for reimbursement of work completed that said work has met the conditions of all contrncts and agreements covering the work, review new proposals and cost estimates and provide recommendation to USAID and the GOE implementing agencies, insure adequate reporting on the USA!D performance indicators. and ensure that all construction activities are Implemented in compliance with US/\ID environmental requirements. These activities \.viii have no impact on the nattlral or physical environment and. therefore. qualify for a Categorical Exclusion pursuant to 22 CFR 216.2 (c)(2)(i): "Education. technical assistance or training programs except to the extent such programs include activities directly affecting the environment."

1.4 EnvirQhmcntal Review and Mitigation Measures

The implementer will prepare an Environmental Document Form (EDF, Attachment 3), prior lo the start of construction activities. This fonn must be approved by the Mission Environmental Officer (MEO) before construction starts. The mitigation measure listed below will be used as a

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guide. Additionally the implementer will prepare an Environmental Mitigation and Monitoring Plan (EMMP, Attachment 4) for each activity, and is subject to review and oversight by the /\ORJCOR in consultation with the MEO.

Potential Impacts/Mitigation Measures: Several potential impacts will be mitigated by udequate constrnction specifications and supervision by the CMC, who will have the primary responsibility for monitoring construction and safety. The following impacts and mitigation measures were identified through the previously approved Environmental Assessments by Harza Environmental Services. Inc. in 2002 and Camp Dresser and McKee International in 2007:

• Dwelling Safety During Excavation: Adequate shoring of excavation and other construction safety measures will guarantee the safety of dwellings located close to excavation sites;

• Pedestrians and Traffic: Adequate safety measures for pedestrians and traffic will be adopted during construction (barriers, lights, etc.):

• Workers safety: adequate safety for workers will be adopted during construction (hordhats, snfety boots, etc.);

• Construction Waste: The contractor will ensure the adequate disposal of construction waste (in municipal or specially designated dumps);

• Noise; Proper mufflers on eqtiipmcnt and machinery will be inst;illed. also, in re~identinl areas. the working hours will be controlled (sunrise to sunset). Work in sites adjacent to schools will. as much as possible. avoid activities of disturbing nature during school days and exams times:

• Equipment Pollution: Pollution will be mitigated from equipment and machinery (oil. coolant, brake fluid , etc.);

• Disruption to Traffic and Circulation: The contractor, in coordination with the local authorities, will set alternative traffic plans to minimize impacts on traf'fic during excavation and construction;

• Dust Control: The contractor will set a plan to minimize and control dust during construction;

• Minimizing Difficulty of Access: The contractor will maintain adequate access to houses and commercial buildings through careful construction planning to maintain adequate buffers between open trenches and buildings;

• Risk Management Phm and a Dilapidation Sun·cy: The CMC will help the contractor develop a Risk Managemenl Plan and a Dilapidation Survey to ensure the safety of neighboring residents and adjacent buildings during construction; and,

• Raw water analysis: As part of its operational quality GOntrol plan, water public companies will conduct water testing for arsenic and any other potential pollutants.

2. THRESHHOLD DECISION

2. J Negative Determination with Conditions ($ 36 Million/ 95% npp1·ox.)

In accordance with 22 CFR 216.3 (a)(2)(iii);

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"The cognizant Bl1reau or Office will record a Negative Determination if the proposed action will not have a significant effect on the environment."

• Construction of water/wastewater pipelines. • Construction of potable water systems • Construction of wastewater systems

Environmental phm of action:

The following clements comprise the environmental plan of action for the activities: NOTE: The implementer inust include the cost of mitigation am.I monitoring in their budget.

I. Upon Approval of Funding by USAID • Complete environmental screening questionnaire (Attachment 2) for each

activity to be funded. • Complete the EDF and EMMP forms (Attachments 3 and 4), using the

mitigation measures identified in section 1.4, and have them approved by the /\ORJCOR.

• Modify, as needed, contract documents to inform contractors of their environmental responsibilities as listed above,

• Purchase, as a cost to the project, continuous chlorine gas detectors and an alarm system for chlorination buildings and chlorine storage areas.

2. Prior to Construction Contact the local office of the Ministry of Antiquities prior to construction. and

determine the appropriate measures for notification of and participation by the Ministry during construction.

3. Dul'ing the Construction Activity • Collect and analyze wntcr sumplcs for monitoring plant performance and any

discharges. • The Activity Manager will ensure that construction contracts will include the

conditions, prevention measures. and mitigation measures listed above including periodic upclates (quarterly) to USAID to ensure environmental compliance.

• The CMC will provide appropriat<; supervjsion in cooperation with the Assiut and Sohag Potable Water and Sanitation Companies. Construction activities will follow good engineering. construction. and safety practices to mitigate impacts on the physicul and natural environment.

2.2 Catcgoricnl Exclusion ($ 2 Million I 5% appr(>x.)

In accordance with 22 CFR 216.2 (c)(2)(i)~ "(i) Education, technical assistance, or training programs except to the extent such programs

include activities directly affecting the environment (such as construction of facilities, etc.);

• Technical Assistance-construction monitoring and engineering support

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3. REVISIONS

In accordance with 22 CFR 2 l 6.3(a)(9,) if a project is revised or new information becomes available, including during preparation of an EDF, which indicates that a proposed action might be "major" and its effects "significant," the Determination will be reviewed and revised by the originator(s) of the program and projects and submitted through the MEO to the Bureau Environmental Officers, ME, for approval and, if warranted, an environmental assessment will be launched and scoping statement and environmental assessment report prepared. The scoping and EA process. if determined necessary during scoping, will follow and comply with 22 CFR 216.3(a)(4).

Attachments: Attachment 1 - IEE Amendment ME l 0-27 Attachment 2 - Environmental Screening questionnaire sheet Attachment 3 - EDF Form Attachment 4 - EMMP Form

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IEE/or "Small-scale infrastructure co11str11ctio11, renovation and improvement Program"

CLEARANCES AND APPROVAL OF RECOMMENDED ENVIRONMENTAL ACTIONS: EUM, IEE Amendment# 13

Office of Economic Growth Director

Mission Environmental Officer

Regional Envirorunental Advisor, Middle East

Program Office Director

Regional Legal Advisor

CONCURRE.NCE:

~Deputy Mission Director

ME Bureau Environmental omc~i:.

CC: Project files MEO tracking

/; I Date

r /f .,--/ :Loi 4 Date

Alexandra Hadzi-Vidanovic Date

\-!1·1'~ ·~~'?l.tVVVt··---- -~ I '2- l I I q ( James Harmon ----"--D-at_e.__ __ _

/VY\~ 1 Maram Talaat

-----·--- ----'

<Lzr/;v Date

"!1(~1 Da~

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Attachment 3 Environmental Documentation Form (Example)

INSERT ACTIVITY NAME

AA II If . ,pp cant n ormat1on Contractor/gr Parent grant or an tee( organiz project ation)

individual Address, phone contact and and email (if title available)

activity (brief Amount description)

- - - -Location of Start and end activity date of activity

BA I I I d d d . ct v t es, screen ng resu ts, and recommen e eterm nat on

TABLE 1 Screening result Recommended

(Step 3 of Determinations

instructions) (Step 6 of instructions. Complete for all moderate and

high-risk activities)

Proposed Sub-activities ~ .m .ll: c -o c: E ~ ~ts II)

~~ts ~~ ~~ -l ~ a:: - Cl> ns ~~

Q) .c !E Q) ns ·o co !E Cl> c >a 'O~

~.~~ g Q) .2> c ~ 2>_.-oE ~~ 0 .!!? C> a.~ 0 ·~ ~ a:: :f (/) c <( ·-(/) co ·- tJ> c ns

1. Excavation: from 1.0 to 4.5 m (max x x width:1.2 m)

2. Laying UPVC pipelines from 4" to 22" x x diameter

3. Backfill x x 4. Construction of small valve chambers x x (1 .5x1 .5x2m)

5. Construction of small house x x connection chambers (0.8x0.8x1 .Om)

6. Construction of small Manholes x x (1 .5mDx4.5m max.)

7. Reinforced Concrete Construction x x

IEE/or ''Small-scale infrastr11ct11re construclion, renovation and improve111e111 Program"

C. Summary of recommended determinations (check all that apply)

p D

x

D

The activity contains . ..

Very low risk sub-activities

After environmental review, sub-activities determined to have no significant adverse Impacts

After environmental review, sub-activities determined to have no significant adverse impacts, given appropriate mitigation and monitoring

After environmental review, sub-activities determined to have significant adverse impacts

D. Certification: I, the undersigned, certify that:

(equivalent regulation 216 terminology)

categorical e)!c/usion(s)

negative determlnatlon(s)

negative determinatlon(s) with con(litions

positive detennination(s)

1. The Information on this form is correct and complete

2. • These design elements and best practices will be followed in implementing this activity,

except with the approval of USAID.

• Any specific mitigation or monitoring measures described in the attached information will be implemented in their entirety.

• Compliance with these conditions will be regularly confirmed and documented by on-site inspections during the activity and at its completion.

(Signature)

BELOW THIS LINE FOR USAID USE ONLY Approval

USAID Project (print name) Officer 0 Approved D Rejected

USAID MEO or (print name) DMEO D Approved 0 Rejected

(Date)

(signature)

(signature)

USAID comments: (if documentation is rejected, comments must be provided to applicant)

/Eli.f or "Sma/1-scafo i1ifras1r11ct11re cuns1r11clio11. renovation and improvement Program"

Attachment 4

Environmental Mitigation & Monitoring Plan (EMMP)

• An EMMP should either be included in or developed for (1) all IEEs that have at least one "Negative Determination with Conditions" (or for activities for which an environmental review has been completed pursuant to an IEE requirement) and (2) all Environmental Assessments (EAs).

• If the EMMP is not developed as part of the IEE, the implementing partner should usually lead development of the EMMP, subject to review and oversight by the MEO and COTR/AOTR.

• In all cases, the tasks identified in the EMMP are incorporated into the implementing partner's Work Plan, budget, and reporting.

• The following EMMP format is recommended. It can be adapted, as necessary.

Environmental Mitigation and Monitoring Plan

Activity Title: Implementer:

Mitigation Monitoring

Monitoring and Party(ies) Indicative Activity Measure(s)

lndicator(s) Reporting Responsible Budget Frequency

List all If mitigation Specify For example: If appropriate, activities in measures are indicators to separately IEE that well-specified (1) determine "monitor specify the received a in the IEE, if mitigation is weekly, and parties 11negative quote directly in place and report in responsible determination from IEE (2) quarterly for mitigation, with successful. reports. If for monitoring conditions." If they are not XXX occurs, and for

well-specified For example, immediately reporting. Do not list in the IEE, visual inform USAID any other define more inspections activity activities in specifically for seepage manager." separate here. around pit rows. latrine;

sedimentation at stream crossings, etc.)