TRACKING ID: LAC-IEE-17-40


Request for Categorical Exclusion

PROJECT/ACTIVITY DATA

Project/ Activity Name: / Transport Operations for Haiti – Elections 2015
Amendment (Y/N): / YES
Implementation Start/End: / June 29, 2015– September 30, 2017
Award Number: / AID-521-IO-15-00001
Implementing Partner(s): / UNOPS
Geographic Location(s): / Haiti
Tracking ID/link:
Tracking ID/link of Related RCE/IEE (if any): / LAC-IEE-16-30 (Umbrella IEE for Governance)
Tracking ID/link of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):
(e.g. Mission or Bureau or Office) / USAID/Haiti
Funding Operating Unit(s):
(e.g. Mission or Bureau or Office) / USAID/Haiti
Funding Account(s): / PIO Letter of Credit
Funding Amount: / $12,553,841.00
Amendment Funding Amount: / $0 / Amendment Funding Date: / NCE: March to September 2017
Other Affected Unit(s): / n/a
Lead BEO Bureau: / LAC
Prepared by: / Christopher Shields, Sr. Advisor, EPP Haiti
Date Prepared: / May 12, 2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type:
Environmental Determination(s):
Additional Analyses/Reporting Required:
Analysis Expiration Date:

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE REQUEST FOR CATEGORICAL EXCLUSION

The IEE-16-30 "Pillar D: Governance" covering a previous iteration of this activity (TEC of $5.8 million) was approved in April 2016. In June 2016, the Total Estimated Cost for the awardwas increased to $12.5 million to allow for an expansion of the workalready listed in the IEE. No Amendment to the IEE was made at that time. The intervention described herein was not foreseen in the Pillar IEE and because of the nature of the new work, the project managers have chosen to request a categorical exclusion rather than an amendment to the pillar IEE.

The purpose of this document, therefore, is to describe the ballot destruction intervention, which has been added to AID-521-IO-15-00001, Transport Operations for Haiti – Elections 2015and request a categorical exclusion with the conditions that: a) UNOPS has the appropriate environmental safeguards in place, b) USAID will assist in monitoring adherence with the safeguards. The award has received a No Cost Extension (NCE) to continue through September 30, 2017 and is solely implemented by UNOPS. The addition of the new intervention is pending the Environmental Threshold Decision from this Request for Categorical Exclusion.This document is in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), and provides a preliminary review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions, for the activities detailed below. The Threshold Decisions based on this document, are formal Agency decisions on whether the proposed actions are major actions significantly affecting the environment, and therefore, provides a brief statement of the factual basis as to whether an Environmental Assessment or an Environmental Impact Statement is required for the activities managed under the scope of this document.

PROJECT/ACTIVITY SUMMARY

Two interventions already covered under the LAC-IEE-16-30 (and given Categorical Exclusion) will also continue under the NCE:

  • Continued efforts related to strengthening the 2015-2016 Electoral Investment; and
  • Strengthening Administrative and Electoral Operations Management.

One new intervention has been added to the activity. During the period of NCE, UNOPS will support the ConseilÉlectoralProvisiore(CEP) in the destruction and recycling of the electoral materials for the 2010, 2015, and 2016election cycles, such as surplus ballot papers, vote tabulation forms and voting station materials which cannot be reused. The intervention is based on the jointneeds assessment carried out between the CEP and various international partners and proposes to shred the materials and recycle these as ingredients in charcoal briquettes.Though the precise details are yet to be defined, the intervention is anticipated to be implemented in four steps: 1) the moving of the shipping containers from the UN storage yard to one of the UN compounds in Port-au-Prince; 2) separation of the materials to be destroyed; 3) shredding of the ballot materials; and 4) the repurposing of the shredded materials, most likely into briquettes.

With regard to this intervention, ADS 308.2.11.c is applied, which states that for the reasons outlined in ADS 308.3.11.b and because of the nature of the UNOPS award, program contributions not for the purpose of carrying out a specifically identifiable project or projects, as well as all general contributions, will normally be categorically excluded from environmental analysis under §216.2(c)(2)(vi).

The interventions to be effected through the UNOPS award contributes to the USG Haiti Strategy, under Pillar D: Governance, Rule of Law, specifically Sub-intermediate result 1.3: Strengthen electoral and legislative processes to build governing legitimacy.

In awarding cost-type grants to PIOs with their own environmental policies, for interventionsthat are not exempt analysis under §216, USAID relies on UNOPS’s application of its own environmental policies to the activity proposed and include appropriate language in the UNOPS agreement. Any environmental conditions proposed to ensure adequate environmental review of the destruction of election materials from the election cycles of 2016, 2015, and 2010 should have due regard to both the independence and sovereignty of UNOPS and the purpose and intent of the environmental impact assessment requirements of USAID. The Agreement Officer Representative will review the environmental safeguards that UNOPS intends to apply in the intervention of this intervention. Periodic monitoring of compliance with these safeguards through review of documentation and field site visits is required.

ENVIRONMENTAL DETERMINATIONS

Project/Activity and Sub Project/ Activity # / Recommended Determination for Categorical Exclusion
Destruction and Recycling of election materials / 22 CFR 216.2(c)(2)(vi) Contributions to international, regional or national organizations by the United States which are not for the purpose of carrying out a specifically identifiable project or projects
ADS 308.3.11.c. Application of USAID Environmental Regulations. For the reasons outlined in section 308.3.11.b and because of the nature of the awards, program contributions not for the purpose of carrying out a specifically identifiable project or projects, as well as all general contributions, will normally be categorically excluded from environmental analysis under 22 CFR 216.2(c)(2)(vi). In awarding cost-type grants to PIOs with their own environmental policies, for activities that are not exempt or categorically excluded from environmental analysis under 22 CFR 216, USAID should strive to rely upon the PIO’s application of its own environmental policies to the activity proposed and include appropriate language in the PIO agreement. Any environmental conditions proposed to ensure adequate environmental review of the activity proposed should have due regard to both the independence and sovereignty of the PIO and the purpose and intent of the environmental impact assessment requirements of USAID. (See ADS 204, Environmental Procedures and 22 CFR 216)

BEO SPECIFIED CONDITIONS OF APPROVAL

The following conditions will be followed during implementation of this award:

-The Public International Organization, in this case, UNOPS will provide evidence of adequate environmental safeguards that will be used in designing, implementing and monitoring this intervention.

-USAID, represented by the Agreement Officer Representative, will assist in monitoring the intervention through review of project reports and through periodic field monitoring visits.

IMPLEMENTATION

In accordance with 22CFR216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the Environmental Analysis, and any BEO Specified Conditions of Approval.


1.0 PROJECT AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of RCE

The purpose of this document is to request a categorical exclusion for the one additional interventionadded to award #AID-521-IO-15-00001, the Transport Operations for Haiti – Elections 2015, which has received a No Cost Extension (NCE) to continue an additional six months through September 30, 2017.

The IEE-16-30 "Pillar D: Governance" covering a previous iteration of this award (TEC of $5.8 million) was approved in April 2016. In June 2016, the TEC for the awardwas increased to $12.5 million reflecting an expansion of the workalready listed in the IEE. No Amendment to the IEE was filed at that time.

This document seeks to establish that all proposed interventions belong to classes of actions eligible for categorical exclusions as set out in Agency regulations (ADS 308) and the Code of Federal Regulations (22CFR 216.2(c)) and that there are no foreseeable significant direct or indirect environmental impacts that would preclude them from receiving a categorical exclusion. Upon approval of this document, the categorical exclusions are affirmed for the award. This analysis also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal_101216). This RCE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

1.2 Project Overview

Under the terms of the NCE, UNOPS will support the CEP in the destruction of the electoral materials for the 2010, and 2015-2016 elections. A joint needs assessment was carried out between the CEP and various international partners to determine the pressing need to safety destroy the ballot material to avoid leakage of the documents outside the custody of the CEP.

1.3 Project Description

During the NCE, UNOPS will support the CEP in the destruction of the electoral materials for the 2016, 2015 and 2010 election cycles proposes to destroy leftover election materials from the 2016, 2015 and 2010 election cycles which cannot be used again, such as surplus ballot papers, vote tabulation forms and voting station materials. The activity is based on the joint needs assessment carried out between the CEP and various international partners and proposes to shred the materials and recycle as charcoal briquettes, though the precise nature of the method has not yet been determined.

2.0 ENVIRONMENTAL ANALYSIS

2.1 Justification for Categorical Exclusion

The interventionsunder the Transport Operations for Haiti – Elections 2015 awardare among the classes of actions listed in 22CFR216.2(c)(2) and have no foreseeable significant direct or indirect adverse effect on the environment. Therefore, under 22CFR216.2(c)(1), neither an IEE nor an EA will be required for these activities. Instead, a categorical exclusion is recommended for the projects/activities described above in Section 1.3 as follows:

Table 3: Recommended Determination for Categorical Exclusion

Project/Activity and Sub Project/ Activity # / Recommended Determination for Categorical Exclusion
Destruction and Recycling of election materials / 22 CFR 216.2(c)(2)(vi) Contributions to international, regional or national organizations by the United States which are not for the purpose of carrying out a specifically identifiable project or projects.
ADS 308.3.11.c. Application of USAID Environmental Regulations. For the reasons outlined in section 308.3.11.b and because of the nature of the awards, program contributions not for the purpose of carrying out a specifically identifiable project or projects, as well as all general contributions, will normally be categorically excluded from environmental analysis under 22 CFR 216.2(c)(2)(vi). In awarding cost-type grants to PIOs with their own environmental policies, for activities that are not exempt or categorically excluded from environmental analysis under 22 CFR 216, USAID should strive to rely upon the PIO’s application of its own environmental policies to the activity proposed and include appropriate language in the PIO agreement. Any environmental conditions proposed to ensure adequate environmental review of the activity proposed should have due regard to both the independence and sovereignty of the PIO and the purpose and intent of the environmental impact assessment requirements of USAID. (See ADS 204, Environmental Procedures and 22 CFR 216)

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TRACKING ID: LAC-IEE-17-40

2.2 Climate Risk Management

The following climate risk management matrix has been developed for this intervention. Continual monitoring of the intervention will focus on potential impact on greenhouse gas emissions and vulnerability to variations in climate.

Table 4. Project or Activity-Level Climate Risk Management Summary Table

Defined or Anticipated Project Elements (Purpose/ Subpurpose, Area of Focus, or Activity/ Mechanism, etc.) / Climate Risks List key risks related to the project elements identified through either the strategy or project level climate risk assessment / Risk Rating Low/ Moderate/ High / How Risks are Addressed at Project Level Describe how risks have been addressed at the project level. If a decision has been made to accept the risk, briefly explain why. / Further Analysis and Actions for Activity Design/ Implementation Describe CRM measures to be integrated into activity design or implementation, including additional analysis, if applicable / Opportunities to Strengthen Climate Resilience Describe opportunities to achieve development objectives by integrating climate resilience or mitigation measures
Project/Activity 1:Destruction of election materials / GHG emissions due to machinery operation
Flooding of shredding and briquette-making area / Medium
Low / Lower emission machinery will be sought
Machinery and storage areas will be protected from flood-prone areas / A site visit will be organized to inspect the machinery and the area to be used. / The use of the shredded materials as ingredients in cooking briquettes will be a net benefit to Haiti’s forests because of the mitigation of deforestation.

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TRACKING ID: LAC-IEE-17-40

3.0 LIMITATIONS OF THE CATEGORICAL EXCLUSION

The categorical exclusions recommended in this document apply only to projects/activities and sub-activities described herein.

Other projects/activities that may arise must be subject to an environmental analysis and the appropriate documentation prepared and approved, whether it be a new Request for Categorical Exclusion, an amendment, or other type of document.

It is confirmed that the projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22CFR216.2(d).

3.1 Mandatory Inclusion of Environmental Compliance Requirements in Solicitations, Awards, Budgets, and Work Plans

USAID will ensure the environmental compliance requirements are incorporated into solicitations, awards, budgets, and work plans, including relevant limitations of Section 3 above. In addition, climate risk management requirements will also be incorporated.

3.2 General Implementation & Monitoring Requirements (if applicable)

USAID will ensure that the following requirements are met:

  • Review environmental safeguards of the Implementing Partner to ensure adequacy for the purposes of reducing the impact of the interventions in this award
  • Provide briefings for Implementing Partner (IP) on environmental compliance responsibilities
  • Conduct periodic monitoring through document review and field site visits
  • Ensure integration of compliance responsibilities in prime and sub-contracts and grant agreements; Ensure compliance with applicable partner country requirements
  • Ensure annual review of project activities to ensure that scope is still covered by categorical exclusion

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