Tracking Id: Lac-Iee-18-02

TRACKING ID: LAC-IEE-18-02

initial environmental examination

PROJECT/ACTIVITY DATA

Project/ Activity Name: / Build Back Safer
Amendment (Y/N): / N
Implementation Start/End: / July 1, 2017 to June 30, 2018
Solicitation/Contract/Award Number:
Implementing Partner(s): / Organization of American States (OAS)
Geographic Location(s): / Southern Haiti
Tracking ID/link: / LAC-IEE-17-53
Tracking ID/link of Related RCE/IEE (if any): / NA
Tracking ID/link of Other, Related Analyses: / NA

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: / $5,639,498
Amendment Funding Amount: / Amendment Funding Date:
Other Affected Unit(s): / N/A
Lead BEO Bureau: / LAC
Prepared by: / Varghese Jacob, USAID/GH; Abdel Abellard, USAID/Haiti
Date Prepared: / June 23, 2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: / IEE
Environmental Determination(s): / Negative with Conditions
Additional Analyses/Reporting Required: / PIO Environmental Analysis
Analysis Expiration Date: / September 2018

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE IEE

USAID/ Haiti is planning to engage in a post- hurricane humanitarian relief and recovery activity which ensure access to safe and appropriate living spaces, and improved water and sanitation infrastructure for vulnerable households in Southern Haiti. The target communities are Port -a-Piment, Chardonnieres, and Les Anglais which are most impacted by the Hurricane. This activity will be done through a Public International Organization (PIO) grant to Organization of American States (OAS). The duration of this activity will be one year. This assistance is needed immediately as the next hurricane season is fast approaching and emergency repair works need to be completed to minimize the impact of the upcoming hurricane and rainy season. This activity contributes to Pillar A of the Haitian Development Strategy and will seek to improve the sustainability of results through the use of local resources and aligned with local priorities of the Government of Haiti. Sub-awards will be made to qualified local partners and expected to train qualified local youth in construction and other trade and provide work opportunities to them in the rehabilitation projects which will improve the future employability of the participants.

PROJECT/ACTIVITY SUMMARY

Some of the recovery/reconstruction works have been already implemented by the Government of Haiti and other international donors. However, additional support is needed to meet the urgent economic and social needs of the affected population. A set of integrated, multi-sectoral activities are being proposed to improve the lives of the people who are still impacted the most by the hurricane. The proposed activities include:

Provide assistance to rehabilitate up to 5,000 hurricane damaged houses and provide access to transitional shelters as needed
Rehabilitate key water infrastructure that was damaged by the hurricane
Provide training to about 4,500 households in better hygiene practices
Improve livelihoods of 600 families through training participation in rehabilitation activities

These activities are expected to ensure access to safe, habitable living space to the needy, improve access to safe water, improve sanitation and hygiene conditions and provide income opportunities to participants.

ENVIRONMENTAL DETERMINATIONS

This activity addresses the immediate needs of the vulnerable population of the Southern Haiti who still have not been recovered from the devastation of Hurricane Matthew. The Mission will support the restoration of hurricane damaged homes along with training and employment opportunities to the affected population and training in better hygiene to reduce the risk of waterborne diseases. Assistance programs are carried out under the foreign policy guidance according to 22 CFR 216 and will ensure identification of environmental consequences and application of appropriate environmental safeguards as well as identifying environmental limiting factors that constrain the restoration activities.

Upon approval of this document, the determinations become affirmed, per Agency regulations (22CFR216).

The following table summarizes the environmental determinations applicable to the specific projects/activities.

Table 1: Environmental Determinations

Project/Activity and Sub Project/ Activity # / Recommended Determination
Activity 1 - Repair of Partially Damaged Homes / Negative with Conditions
Activity 2 - WASH Rehabilitation / Negative with Conditions
Activity 3 – Training in Better Hygiene / Categorical exclusion pursuant to 22CFR216.2(c)(2)((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.)
Activity 4 – Improve Livelihoods / Negative with Conditions

BEO SPECIFIED CONDITIONS OF APPROVAL

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

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 this IEE.

USAID APPROVAL of initial ENVIRONMENTAL examination

PROJECT/ACTIVITY NAME: Build Back Safer

Approval: / ______
Jene C. Thomas, Mission Director / ______
Date
Clearance: / ______
Abdel Abellard, Mission Environmental Officer / ______
Date
Clearance: / ______
Robert Clausen, Regional Environmental Advisor / ______
Date
Clearance: / ______
Rory Donohoe, OIEE Office Chief / ______
Date
Clearance: / ______
Brandy Witthoft, PCPS Office Chief / ______
Date
Clearance: / ______
Chris Ryder, Resident Legal Officer / ______
Date
Concurrence: / ______
Diana Shannon, Bureau Environmental Officer / ______
Date

1.0 PROJECT AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of IEE

The purpose of this document, 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 USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22CFR216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

1.2 Project Overview

The Office of Infrastructure Engineering and Energy (OIEE) seeks the Mission Director’s approval of a PIO Grant to the Organization of American States (OAS) for a post- hurricane humanitarian relief and recovery activity which ensure access to safe and appropriate living spaces, and improved water and sanitation infrastructure for vulnerable households in Southern Haiti, as proposed jointly by the Organization of American States (OAS) and the Pan American Development Foundation (PADF). OAS is listed as a Category One Public Regional Organization by Delegated Cooperation Secretariat (DCS) according to ADS 308.3.1.1

1.3 Project Description

Proposed activity period is 12 months with an estimated cost is $5.8million. This activity contributes to Pillar A of the Haitian Development Strategy and will seek to improve the sustainability of results through the use of local resources and aligned with local priorities of the Government of Haiti. Sub-awards will be made to qualified local partners and expected to train qualified local youth in construction and other trade and provide work opportunities to them in the rehabilitation projects which will improve the future employability of the participants.

After the disastrous impact of the Hurricane Matthew, a post disaster needs assessment of the target communities, Port -a-Piment, Chardonnieres, and Les Anglais, revealed that over 80% of the homes were affected and 1,624 homes were completely destroyed. The loss of housing is compounded by the concerns related to the protection of women and children against separation, violence and abuse. Another assessment which was conducted in May 2017 concluded that over 5,000 homes in these communities are still in bad conditions and need immediate repairs to withstand the approaching rainy season. In Water and Sanitation sector, the damages impacted over 8,900 people and WHO reports 2,098 suspected cholera cases in these communities. Without interventions in this sector, the cholera and other water-borne diseases is likely to increase. The delay in the repairs will cause the situation to be worsened during the upcoming rainy season.

Some of the recovery/reconstruction works have been implemented by the Government of Haiti and other international donors. However, additional support is needed to meet the urgent economic and social needs of the affected population. OAS/PADF proposes a set of integrated, multi-sectoral activities to improve the lives of the people who are still impacted the most by the hurricane. The proposed activities include:

Provide assistance to rehabilitate up to 5,000 hurricane damaged houses and provide access to transitional shelters as needed
Rehabilitate key water infrastructure that was damaged by the hurricane
Provide training to about 4,500 households in better hygiene practices
Improve livelihoods of 600 families through training participation in rehabilitation activities

Table 2: Defined or Illustrative Projects/Activities and Sub-Activities

Activity 1 - Repair of Partially Damaged Homes:
Roof and other structural repairs will be done to about 5,000 hurricane damaged homes with adequate bracings, wall studs and roof cladding etc. to make it structurally sound to withstand any future shocks and hurricanes.
Activity 2 - WASH Rehabilitation
WASH intervention will link water supply and sanitary infrastructure to repair and rehabilitate existing structure and provide extensions to accommodate as many residential units as possible.
Activity 3 – Training in Better Hygiene
A campaign will be implemented to change the hygiene behavior in target communities using a participatory approach which will reduce the spread of diseases in the community.
Activity 4 – Improve Livelihoods
Local contractors and suppliers will be used for the construction and for materials as far as possible and Cash for Work opportunities will be provided to community members who are participating in the rehabilitation project. In addition, training opportunities will be afforded to local youth in construction and related activities so that they will be qualified to get a job and have sustainable income after the completion of the project.

2.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

No new construction is being proposed under this activity other than the rehabilitation of the hurricane damaged homes and water and sanitation infrastructure. The repairs are to the existing residential structure including the roof. All proposed activities will comply with the PIO’s environmental procedures, including an assessment of potential environmental impacts.

2.1 Recommended Environmental Determinations

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22CFR216. Specified conditions, detailed in this IEE, become mandatory obligations of implementation, per ADS 204.

Table 3: Recommended Determination

TRACKING ID: LAC-IEE-18-02

2.2 Climate Risk Management

In accordance with Agency policy, ADS Chapter 201 and the Mandatory reference 201mal, below is a brief narrative of the risk assessment methodology and the Project or Activity-Level Climate Risk Management Summary Table for the Build Back Safer. This activity will focus on the emergency recovery and rehabilitation of about 5000 homes damaged by Hurricane Matthew to minimize the impact of the approaching rainy and hurricane season. It does include only minimum new construction. Most of the repairs are for the structure including walls and roofs.

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
Activity 1:
Provide Assistance to rehabilitate hurricane damaged homes-repair of roofs, windows, walls, etc.. / Heavy Rains & Wind/Floods-Risk that new materials will be damaged and construction work is stopped if additional hurricanes arise / Medium / Approaching rainy and hurricane season may impede the rehabilitation efforts. However, all necessary precautions will be taken to minimize the impact of the weather on the proposed activities. For instance work planning will include emergency plan. / OAS will follow their standard policies and procedures in environmental impacts. Site visits will be organized to evaluate any unanticipated impact. Immediate and decisive actions will be taken to mitigate any negative impacts.
Materials would be stored in safe and dry areas when not being used.
Work will be stopped during storm events.
The Activity will consider incorporation of DRR and flexible means of implementation (e.g., geography, timing).
Activity can provide shelter from Rains for the workers and postpone work during periods of floods. / Provide training to workers and family members on Disaster Risk Management and Climate Risk methods to provide safe working conditions and for families to maintain new repairs.
Activity 2:
WASH Rehabilitation / Heavy Rains and flooding-Risk that water and sanitation materials and facilities are damaged and that water systems become contaminated during repairs.
Drought-Risk that water needed for WASH operation is not sufficient and can cause activity to be halted / Medium / Non Provide training to workers and family members on Disaster Risk Management and Climate Risk methods to provide safe working conditions and for families to maintain new repairs. e
Activity 3:
Provide Training in better hygiene practices / Heavy Rains and Flooding can disrupt the training activities. / Low / None
Activity 4 – Improved Livelihoods / Heavy Rains and Flooding can disrupt training activities. As well, these events may hinder workers from arriving or doing the job. / Medium / None

TRACKING ID: LAC-IEE-18-02

3.0 CONDITIONS AND MITIGATION MEASURES

3.1 PIO-Specific Conditions

When 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 strives to rely upon the PIO’s application of its own environmental policies to the activity proposed and include appropriate language in the PIO agreement. Therefore environmental conditions to ensure adequate environmental review of the planned activities 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. As a result, the following conditions should be implemented:

●The Organization of American States (OAS), a Public International Organization will be implementing this activity and they will provide evidence of adequate environmental and social safe-guards that will be used in designing, implementing and monitoring these activities.

● USAID, represented by the Agreement Officer Representative (AOR), will review OAS’ environmental and social safe-guards for adequacy, work with OAS to ensure effective implementation, including ensuring sub-awards have the capability to and fully implement the safe-guards, and monitor the interventions through review of project reports and through periodic site visits.

●If the PIO chooses to employ USAID’s environmental compliance procedures, the AOR with work with the PIO to ensure, consistent with 22CFR216, a comprehensive assessment is undertaken of potential environmental impacts and risks of its activities, the impacts and risks are documented, and corresponding mitigation measures identified, implemented and monitored.

3.2 Award Conditions

●The A/COR, in coordination with the Agreement Officer, will ensure all awards and sub-awards, include environmental compliance requirements.

3.3 Post-Award Conditions

●Post-Award Briefings: The AOR and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide post-award briefings for the PIO on environmental compliance responsibilities.

●Workplans and Budgeting: The AOR will ensure the PIO integrates environmental compliance requirements in work plans and budgets to comply with requirements, including the mitigation and monitoring plan, implementation and monitoring.

●Staffing: The AOR, in coordination with the PIO, will ensure all awards and sub-awards have staffing capacity and capabilities to implement environmental compliance requirements.

●Records Management: The AOR will maintain environmental compliance documents in the official project/activity file and upload records to the designated USAID environmental compliance database system.

●Host Country Environmental Compliance: The AOR will ensure the PIO complies with applicable and appropriate host country environmental requirements unless otherwise directed in writing by USAID. However, in the case of a conflict between the host country and USAID requirements, the more stringent shall govern.

●Work Plan Review: The AOR will ensure the PIO verifies, at least annually or when activities are added or modified, that activities remain with the scope of the IEE. Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.

●IEE Amendment: If new activities are introduced or other changes to the scope of this IEE occur, an IEE Amendment will be required.