~~~~!2 1 BANGLADESH INITIAL ENVIRONMENTAL EXAMINATION

For USAID Bangladesh Development Objective 4: Responsiveness to Climate Change Improved

PROGRAMJ ACTIVITY DATA:

Country Code:

Program Objective:

Program Area:

Program Element:

Country/Region:

Program! Activity Titles:

Funding Begin: 2012

388

Economic Growth

4.8 Environment

4.8.1 Natural Resources and Biodiversity 4.8.2 Clean Productive Environment

Bangladeshi ANE

004: Responsiveness to Climate Change Improved

Funding End: 2017 LOP Amount: $125,000,000 (est)

CE/IEE Prepared by: Ashiqur Rahman, EG Office Date: July 18,2013

lEE Amendment (YIN): Y If "Yes," Number@DateofOriginaIIEE: Asia 12-18, December 12, 20 11; Asia 11-170, September 8, 2011; Asia 12-225 October 18, 2012

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion: [8] Deferral : 0 Negative Determination With Positive Determination: 0 Conditions: [8]: Exemption: 0

1.0 Background:

1.1 Purpose and Scope of lEE:

The purpose of this amendment is to document potential environmental impact of the USAID/Bangladesh 004 ongoing and new activities, as well as develop a single lEE document providing environmental compliance guidance to all on-going and planned activities under this DO for FY 2013 - 2017.

1.2 Background:

Bangladesh's large and growing human population, its heavily exploited natural resource base, and a high and persistent level of poverty are integrally related. Poverty in Bangladesh is mainly rural, and is most prevalent within natural resource dependent and landless communities. Rural poverty is estimated as 53%, compared to 37% in urban areas. Natural capital, represented by the nation' s renewable natural resources (notably

~~~~!2 1 BANGLADESH including its biodiversity resources), is considered central both to poverty alleviation and to future economic growth. The Sundarbans alone provide employment to an estimated 112,000 people (Khan, 2001). Additionally, approximately 335,000 people are now involved in social forestry activities in rural areas. These people plant trees on Government land, guard them until maturity, and share the profit from harvested trees with the Government. As such, sustainable management of the bio-diverse natural capital is central to poverty reduction in the Bangladeshi context.

Bangladesh is a focus country for three U.S. Presidential Initiatives: Feed the Future, Global Health, and Climate Change. Under the Climate Change initiative USAID improves Bangladesh's resilience to natural disasters, promotes renewable energy and energy efficiency, preserves the country's biodiversity, and promotes low carbon development. USAID's Global Climate Change and Development Strategy issued in 2012, sets out principles, objectives and priorities for USAID climate change assistance from 2012 through 2016. The overarching mission is to help developing country partners speed their transition to climate­resilient, low-emission, sustainable economic growth. This mission governs all underlying objectives and activites, together aiming to help countries slow the pace of greenhouse gas emissions while investing in resilient, sustainable growth and development

In order to support the most vulnerable people in Bangladesh in obtaining climate-resilient livelihoods, landscapes must be sustainably managed to reduce threats to biodiversity and to adapt to climate change. Strengthened governance for co-management of resources, improved knowledge and capacity about climate impacts and ecological systems, sound and integrated management plans alongside their implementation, and diversified livelihoods are critical elements of social, economic, and ecological resilience.

Bangladesh's energy sector faces a crisis resulting from severe power shortages, skyrocketing natural gas consumption, and rural energy poverty. The gap between electricity supply and demand is nearly 2000 MW during peak hours and is growing steadily at 10% every year. This issue is exacerbated by problems of poor planning, low energy prices, and a weak regulatory environment, which significantly compromise the financial viability of the energy sector and reduce incentive for investment in energy efficiency and renewable energy sources.

USAID Bangladesh energy activities will support energy sector development for energy security, economic growth, and climate change mitigation. Building on achievements of past USAID/Bangladesh energy sector development programs on the past work and achievements USAID funded activities will work with the Bangladesh Energy Regulatory Commission (BERC), energy utilities, and energy end-users focusing on increasing energy efficiency and promoting renewable energy sources while capitalizing on emerging climate change and energy sector priorities and opportunities.

In 2010, the U.S. Government launched a new initiative entitled "Enhancing Capacity for Low Emissions Development Strategies" (EC-LEDS), with Bangladesh as one of the first partner countries. USAID and GOB have been successfully implementing EC-LEDS' activities under the MOU signed in September 2011. In line with the USAID/Bangladesh's Country Development Cooperation Strategy (CDCS), the program activities will meet Development Objective 4 (DO 4): Responsiveness to Climate Change Improved - by focusing on improving Bangladesh's social, ecological and economic resilience to climate change and other stresses.

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~~~e.J!! I BANGLADESH USAID/Bangladesh CDCS Development Objective 4 Results Framework

Climate Change and Environment Results Framework CRITICAl ASSUMPTIONS: • National response to natural

disasters and environmental ri sks remains manageable

• GOB commitment to cl imate change

I 004: Responsiveness to I remains strong

Climate Change Improved • International commitment to global

climate change remains strong

t t 1R4.l: Improved Manalamant of 1R4.2: Enhancad Adapt" on Capacity 1R4.3: Strencthan. d Capadtyto

Natural Resource. a Resilienca to Shocks Reduce Emlulons

-i:'E~h~~~;d'c;;;~i;';f~;'K;""'l : ......................................... :. Increased Incomes from • Improved Enabli ng · : Stakeholders (OO) r--1 Environmentally Sustainable r- Environment for l ow

II: "j ! Activities (FTF} Emissions Strategies ~ l ' Stre~ened Resource :I : ............ _ ............... _ .......... VI Management Systems :- Increased Climate Resiliency through H · Increased Adoption of G ~ Technotogles Adopted {FTFJ Renewable Energy .! .. ~ • Stre...,mened l egal and Policy • Framework (/Xi}

f ~ ~ • Improved Energy Efficiency .. • • Improved Local Governance of and Conservation :I - Ie- Uvelihood Assets fOG} --

I Cross-cuttinllssu •• : Promotelandar aquahty, lood ,overnene. and employment opportunitlu for youih .... -_. Note fM In REO _0' " u..ts with other DO 0'_ ~"" IG«S c:::~ . eoHJ.S I G«S

2.0 Country Environmental Information:

With recent economic growth averaging over 5 percent, Bangladesh has succeeded in reducing the incidence of poverty to 40 percent of its population of nearly 150 million and shows promise of meeting several of its Millennium Development Goals. Nevertheless, the country faces huge challenges in further reducing poverty, alleviating pressure on natural resources and in reversing decades of environmental degradation.

Bangladesh suffers from environmental problems of every kind - pollution of air and water and deterioration of the quantity and quality of its natural resources: soil, water, forests, biodiversity and fisheries . Inadequate management of human use of the environment is impacting human health, causing economic damage and irreversible biodiversity losses. The World Bank has estimated that economic costs of environmental degradation amount to 4.3 percent of gross domestic product.

Indoor air pollution, from stoves burning dirty fuels, has been flagged as a major threat to human health but air pollution from vehicles and industries is also significant. While safe drinking water is now available to 80 percent of the population, adequate sanitation is much more limited. Solid waste collection and disposal is a widespread problem. Ambient water quality is unsatisfactory around major cities and industrial clusters.

Floodplains constitute one of the nation's most valuable natural resources. Fish supply 60 percent of Bangladesh ' s animal protein consumption and are of particular importance to the poor. Capture fisheries have

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@~~~!2 1 BANGLADESH been in decline for some time, as a result of physical obstructions, overfishing, pollution and inadequate management policies and institutions.

Bangladesh has limited remaining natural forest cover, at about 10 percent ofland area, and almost all of that area is now seriously degraded, as a result of extreme population pressure for fuel wood and other forest products, as well as inadequate management. Community forests in the Chittagong Hill Tracts and private forests (homestead lots), however, bring the forest cover up to 35 percent of land. There has been a recent expansion in the number of forest protected areas from 14 to 21, although, as a percentage of land covered, they are still only 1.6 percent of the nation's territory, one of the lowest rates of coverage in the world.

Given that Bangladesh is mostly below 10m above sea level, it is especially vulnerable to the possible impacts of sea level rise and the other expected impacts of global climate change. A recent UNDP policy study corroborates Bangladesh's high vulnerability to adverse effects of global climate change and projects that extreme events (cyclones, floods, droughts) will become more frequent and/or severe over the coming decades. Impacts will likely be severe on agriCUlture, moderate on the forest sector, and low to moderate on inland fisheries. The lack of institutional capacity to address these changes is also highlighted by UNDP.

Nevertheless, over the last 35 years, the Government has invested over $10 billion to make the country less vulnerable to natural disasters. These investments (supported by development partners), include programs for flood management, construction of coastal polders, cyclone and flood shelters, raising roads above flood level and installing warning systems. However, addressing climate change adaptation and mitigation will require scaling up of investments and sound environmental management, including natural ecosystems management. This is the purpose of the Bangladesh Climate Change Strategy and Action Plan (BCCSAP) (GoB 2009), which sets out six pillars/themes and 64 projects, mainly in the adaptation area.

Several international donors are supporting Bangladesh to address climate change issues. Development Partners (Denmark, the European Union, Sweden, Switzerland, Australia, the United Kingdom, and USAID) and GOB established a $189 million Bangladesh Climate Change Resilience Fund (BCCRF), an innovative multi-donor trust fund" program to support the implementation of the BCCSAP. GIZ's Sustainable Development and Biodiversity Conservation in Coastal Forests (SDBC) works in selected areas to safeguard and conserve biodiversity, and rehabilitate embankments. Rural Electrification and Renewable Energy (RERED) II project, a multi-donor trust fund with the World Bank, supports rural electrification through the use of solar renewable energy that includes Solar Home System, solar mini-grids and solar irrigation pumps. European Union is implementing Sundarbans Environmental and Livelihoods Security (SEALS) to support ecosystem productivity and the environmental and social integrity in the Sundarbans and reduce disaster risk of the targeted communities.

2.1 National Environmental Policies and Procedures:

In the context of the environment, the Government of Bangladesh formulated an Environment Policy in 1992. The objectives of Environment Policy are to:

• Maintain ecological balance and overall development through protection and improvement of the environment;

• Protect the country against natural disasters; • Identity and regulate activities which pollute and degrade the environment; • Ensure environmentally sound development in all sectors; • Ensure sustainable, long term and environmentally sound use of all national resources; and, • Actively remain associated with all international environmental initiatives to the maximum possible

extent.

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(§)~~!\J!2 1 BANGLADESH The Government of Bangladesh has also adopted a number of supplementary policies where environment and development issues have been addressed. Important policy documents in this respect are the Forest Policy (1994), the Fisheries Policy (1998), the Water Policy (1998), the New Agriculture Extension Policy (1995), The Energy Policy (1995). Besides these sectoral policies, the National Conservation Strategy (NCS) and especially the National Environment Management Action Plan, 1995 (NEMAP) have been formulated to provide action plans to respond to environmental issues and promote sustainable development.

The Bangladesh Environmental Conservation Act (1995) established the Department of Environment (DoE) and signaled a move towards ecosystem approaches and regulation of developments harmful to those ecosystems, particularly pollution control and mitigation and requirements for Environmental Impact Assessments. Under it, the Environmental Protection Regulations (1998) cover regulations, compliance and enforcement. The Act includes provisions for declaring Ecologically Critical Areas (ECAs) to restrict potentially harmful activities in these areas. Ten such areas have since been declared.

The Forest Act of 1927 sets the frame for forest management and vests considerable power in the hands of the Chief Conservator of Forests to determine the use of forest lands and to penalize illegal users. While allowing for designating use rights in forests for villages, the act does not give a role to neighboring communities in any decision making, including minority communities that often had use and settlement rights in forest areas or for civil society in general. The Bangladesh Wildlife (Preservation) Order of 1973 (later amended and gazetted as the Bangladesh Wildlife (Preservation)(Amendment) Act of 1974) is mainly concerned with regulating hunting but also sets out the scope for declaring protected areas as wildlife sanctuaries or national parks; notably, these are not limited to forests, nor is the Order limited to Forest Department implementation. New rules for management of Protected Areas (PAs) and for social forestry now under discussion should go a long way to institutionalizing the concept of co-management (see below).

The Protection and Conservation of Fish Act, 1950, and related Protection and Conservation of Fish Rules, 1985, which cover not only fish but also amphibians and aquatic reptiles, prohibit fishing by harmful methods, pollution and other activities detrimental to fisheries, and enable declaration of closed seasons and other rules. More recently, the Conservation, Restoration and Filling Control Act of2003 aims to address problems of siltation, encroachment and pollution of surface waters (rivers, canals, beels, floodplains) as well as aquifers.

Bangladesh has ratified a number of international environmental conventions including: Convention on Biological Diversity, CITIES, Convention on the Conservation of Migratory Species of Wild Animals, Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, Ramsar Convention, UNFCC and others. (Source: http://www.moef.gov.bdlhtml/protocollprotocol_main.html)

3.0 D04 Activity Description:

Table 1: D04 on-going and planned activities and their potential effect on environment

Activity Data Description Effect on Determination and required Reg. environment 216 actions

Bilateral Climate Resilient CREL promotes sound natural resource T A - no effect CE for T A. Special considerations Ecosystems and management and biodiversity conservation by specified in the Section 4.1 Livelihoods (CREL) working with community-based organizations and " Implementer 's Procedures" bullet 2 to LOP: 2012-2017 GOB agencies. It will build resiliency to climate be followed. LOP: Budget $35M risks and enhance adaptation to climate change Agreement: AID-388-A- impacts through improved livelihoods and Procurement of NDC for procurement of equipment. 1200007 management of critical ecosystems in priority equipment - no Actions specified in Table 2 Section 2

regions of the country. significant adverse must be followed. effect

Interventions will include TA . procurement of vehicles and IT. small infrastructure projects. Infrastructure, ND for infrastructure, grants, and ecoMtems and habitats restoration activities. and grants, ecosystem ecosystemprojects. Actions specified

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(i)~~~Q I BANGLADESH grants for livelihoods activities. projects - potential in Table 2 Section 3 must be followed.

for an adverse effect

Catalyzing Clean Energy CeEB supports energy sector development for T A - no effect CE for T A. Special considerations in Bangladesh (CCEB) energy security, economic growth, and climate specified in the Section 4.1 LOP: 2012-2017 change mitigation. CCEB works with selected " implementer' s Procedures" bullet 2 to LOP: Budget $15M energy sector organizations and end-users for be followed. Agreement: AIO-388-C- strengthening regulatory climate, increasing energy 13-00001 efficiency (EE) and promoting clean energy Procurement of NOC for procurement of equipment.

development (including improved cookstoves). equipment - no Actions specified in Table 2 Section 2 significant adverse must be followed.

Interventions will include TA. procurement of effect vehicles and IT. grants and EE interventions.

Grants and EE NOC for grants and EE project. projects - potential Actions specified in Table 2 Section 3 for an adverse must be followed. effect

Bengal Tiger Bagh will promote sound natural resource T A - no effect CE for T A. Special considerations Conservation (Bagh) management, support reducing illegal wildlife specified in the Section 4.1 Activity LOP: 2014- trafficking, minimizing human-wildlife conflict, "Implementer's Procedures" bullet 2 to 2017 expanding the knowledge base for wildlife be followed LOP: $12M conservation, and improving livelihoods for Agreement: TBO conservation. The activity will contribute to Procurement of NOC for procurement of equipment.

conserving populations of Royal Bengal Tigers and equipment - no Actions specified in Table 2 Section 2 other charismatic species and to maintaining the significant adverse must be followed. integrity of their habitat. effect

Interventions will include TA . It may include Small scale NOC for infrastructure and grants procurement of vehicles and IT. small scale infrastructure, projects. Actions specified in Table 2 infrastructure projects. ecosystems and habitats grants, ecosystem Section 3 must be followed restoration activities. and grants for livelihoods projects - potential activities. for an adverse

effect

PIO Bangladesh Climate USAID is contributing to $189M multi-donor trust T A - no effect CE for T A. Special considerations Change Resilience Fund managed by the World Bank. USAIO's specified in the Section 4.1 (BCCRF) contribution at this time is <7%. "Implementer's Procedures" bullet 2 to LOP: 2012-2017 The fund supports implementation of the GOB's be followed. LOP: Budget $13M Bangladesh Climate Change Strategy and Action Agreement: AIO-388- Plan (BCCSAP). USAID is not a voting member at Infrastructure NOC for infrastructure projects. 10-12-00004 this time. projects - potential AOR and MEO will review World

for an adverse Bank project' s safeguard Interventions may include TA and infrastructure effect documentation and environmental and proJects. social compliance procedures

including environmental mitigation and monitoring measures established under the BCCRF to ensure consistency with 22 CFR 216; AOR and MEO will review BCCRF technical capabilities to ensure compliance and enforcement of established environmental procedures; AOR and MEO will review project reports to ensure funds are spent in a fiduciary and environmentally compliant manner.

Rural Electrification and USAID is a minor donor contributing to multi- T A - no effect CE for T A. Special considerations Renewable Energy donor fund ofes!. $213M managed by the World specified in the Section 4.1 Development (RERED Bank. USAIO's contribution at this time is <4%. " Implementer' s Procedures" bullet 2 to II) The fund supports implementation of the BCCSAP. be followed. LOP: 2013-2017 USAID's contribution may support the

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(i)~~~!? 1 BANGLADESH LOP Budget: $8M development of solar renewable energy in rural off- Infrastructure NDC for infrastructure projects. Agreement: AID-388- grid areas focusing on Solar Home Systems, solar projects - potential AOR and MEO will review World 10-12-00003 mini-grids and solar irrigation pumps. for an adverse Bank project's safeguard

effect documentation and environmental and Interventions include TA and infrastructure social compliance procedures projects. including environmental mitigation

and monitoring measures established under the BCCRF to ensure consistency with 22 CFR 216; AOR and MEO will review RERED technical capabilities to ensure compliance and enforcement of established environmental procedures; AOR and MEO will review project reports to ensure funds are spent in a fiduciary and environmentally compliant manner.

Chinagong Hill Tracts US AID is currently a major contributor to the T A - no effect CE for T A. Special considerations (CHT) Watershed Co- UNDP-managed program that will support specified in the Section 4.1 Management Activity improved forest and watershed management in "Implementer's Procedures" bullet 2 to under Adaptive CHT, policy reform in the natural resources be followed. Environmental sector, capacity building for community based Governance for the Poor NRM, and livelihoods activities. Procurement of NDC for procurement of equipment. Programme (AEGP) equipment - no Actions specified in Table 2 Section 2 LOP: 2013-2017 Interventions will include TA. The project may significant adverse must be followed. LOP: Budget $8M include procurement o/vehicles and equipment. effect Agreement: TBD small m/rastructure projects, ecosystems and

habitats restoration activities, and grants for Infrastructure, NDC for infrastructure and small livelihoods activities. grants, ecosystem grants projects . Actions specified in

projects - potential Table 2 Section 3 must be followed for adverse effect

Strengthening the USAID is currently a major contributor to the T A - no effect CE for T A. Special considerations Environment, Forestry, F AO-managed program to support development specified in the Section 4.1 and Climate Change And implementation of the Bangladesh "Implementer's Procedures" bullet 2 to Capacities of the Environment, Forestry and Climate Change be followed. Ministry of Environment (EFCC) Sectors Country Investment Plan (CIP) and Forests and provide T A to build MoEF capacity to Procurement of NDC for procurement of equipment. LOP: 2013-2016 efficiently address environmental, forestry and equipment - no Actions specified in Table 2 Section 2 LOP: Budget $8M climate issues. significant adverse must be followed. Agreement: TBD effect

Interventions will include TA. procurement 0/ vehicles and IT. and may include small scale office Office rehab works NDC for office rehabilitation works. space rehabilitation works. - potential for Actions specified in Table 2 Section 3

adverse effect must be followed

Field Support (FS) USFS IAA Capacity Strengthen forest mapping, remote sensing tools, TA - no NDC Building for remote and human and institutional capacity with the significant adverse Washington lEE # EGAT 14-11 sensing Forest Department's Resource Information effect conditions must be followed LOP: 2012-2013 Management Systems (RIMS) unit to inform land hnp://gemini.info.usaid.gov/egat/envco LOP Budget: $IM use planning and the Bangladesh Reducing mp/repository/pdf/37376.pdf

Emissions from Deforestation and Forest Degradation program. Interventions include capacity building and technical assistance to the Forest Department of the Ministry of Environment and Forests of Bangladesh.

Interventions are limited to TA and purchase of IT equipment and software.

USDOI IAA - Promoting_ The U.S. Department of the Interior's Promoting T A - no effect CE for T A. Special considerations

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~~~~2 1 BANGLADESH Eco-tourism in Protected Sustainable Eco-tourism Development in National specified in the Section 4.1 Areas Protected Areas project will work with the "Implementer's Procedures" bullet 2 to LOP: 2013-2014 Bangladesh Forest Department and other key be followed. LOP Budget: $IM stakeholders to enhance management of the

country's selected protected areas, in particular, Procurement of NDC for procurement of equipment. focusing on developing the protected areas as equipment - no Actions specified in Table 2 Section 2 ecotourism destinations to enhance the livelihoods significant adverse must be followed. oflocal communities. effect

Interventions will include TA, procurement of Infrastructure, NDC for infrastructure, grants, and equipment, small infrastructure projects, grants, ecosystem ecosystem projects. Actions specified ecosystems and habitats restoration activities, and projects - potential in Table 2 Section 3 must be followed. small grants. for adverse effect

USEPA IAA - Technical USEPA technical assistance strengthens the GOB's T A - no effect assistance for capacity to estimate and track greenhouse gas Washington lEE # EE 36-12 Bangladesh GHG (GHG) emissions. USEPA will build a sustainable Procurement of conditions must be followed inventory national inventory system in Bangladesh. equipment - no http: //geminLinfo.usaid.gov/egat/envco LOP: 2012-2014 signi ficant adverse mp/repository/pdf/3850 I.pdf LOP Budget: $IM Interventions are limited to TA and purchase of IT effect

eqUIpment and applications,

NREL Bangladesh Wind The activity supports wind resource mapping in Potential for Washington lEE conditions must be Resource Assessment targeted areas of Bangladesh and will develop an adverse effect. followed. Washington is currently LOP: 2012-2014 action plan to implement wind power projects. The drafting the lEE. LOP Budget: $1 M interventions will include T A, purchase of Agreement: AEG-P-OO- equipment, such as met tower, anemometer, IT 09-00003 equipment.

4.0 Recommended Threshold Decisions and Mitigation Actions:

Most D04 interventions (est. 70%) are of a true technical assistance nature and, therefore, will impart no negative impact on the physical or natural environment. These T A activities thus qualify for a Categorical Exclusion (CE) per 22 CFR 216.2 (c )(2)(i) as "education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment", 22 CFR 216.2 (c) (2)(iii) as "analyses, studies, academic or research workshops and meetings", and 22 CFR 216.2 (c )(2)( v) as "document and information transfers". Special considerations specified in the Section 4.1 "Implementer' s Procedures" bullet 2 to be followed.

Procurement of computers and other electric and electronic equipment, and materials under all program tasks fall under Negative Determination with Conditions. The proposed action is that the implementer should provide evidence that equipment and materials are procured from certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to usa, European Union or equivalent standards.

A threshold decision of Negative Determination with Conditions pursuant to 22 CFR 216.3 (a) (2) (iii) is recommended for some D04 activities, particularly with respect to ecosystems and habitats restoration activities, small scale infrastructure, alternative income generation/livelihoods activities, small grants, and others noted in Table 1 that may have negative impact on environment unless due diligence is followed .

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(i) ~~~J!2 1 BANGLADESH Evaluation of potential environmental impacts and actions required from the D04 activities is summarized in the Table 2 below:

Table 2: No Activities Effect on Reg 216 Determinations and Actions

NaturallPbysical Required Environment

I All activities that don't have an effect on No effect Categorical Exclusion: Special the natural or physical environment. This considerations specified in the Section 4.1 includes: education, technical assistance, " Implementer' s Procedures" bullet 2 to be training programs except to the extent such followed. programs include activities directly affecting the environment (such as construction of facilities, assistance in use of crop protection products, pesticide use demonstration, etc.); consultations, participant training, document transfers and information dissemination, analysis, studies, research workshops.

II Procurement of computers and other Insignificant Negative Determination with Conditions: equipment and materials. equipment and materials are procured from

certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent GOB legislation and in their absence with best management practices according to USG, European Union or equivalent standards

III Ecosystem restoration, small-scale Minor to moderate Negative Determination with Conditions. infrastructure, livelihood activities, sub- effect Environmental Due Diligence (EDD) in form grants and sub-contracts, and other of Environmental Review and Assessment activities that normally don' t have a Checklist (lEE Annex I) is required to significant impact on the environment identi fy environmental effects, if required as

a result of the EDD review develop Environmental Manual and Mitigation and Monitoring Plans. If significant adverse effects are expected, a Scoping Statement (SS) and Environmental Assessment (EA) shall be conducted by the implementer prior to start of activities. SOWfferms of Reference (TOR) for Scoping Statement and EA Report must be reviewed by Mission Environmental Officer (MEO) and approved by Asia BED. For details, please see Section 4.1 " Implementer's Procedures".

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(§)~~~!2 1 BANGLADESH 4. 1 Implementer's Procedures:

Implementing partners will follow the following procedures for all relevant activities and will demonstrate their compliance with these procedures in their quarterly and annual performance reports. As part of its initial Work Plan, and all Annual Work Plans thereafter, the implementer, in collaboration with the USAID AgreementlContracting Officer's Representative (N COR) and MEO shall review all ongoing and planned activities under the award to determine if they are within the scope ofthe approved lEE; and classify them in accordance with Table 2.

• The implementer shall have sufficient resources to implement environmental compliance measures and will have to budget for those at the RF NRFP stage.

• All program activities will seek to raise environmental awareness, promote regional and national environmentally and socially sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of environmental compliance and governance, in accordance with the UNECE Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters with reference to it: http://www.unece.org/env/pp/welcome.html

• The implementer will include environmental compliance considerations into all aspects of the program implementation and will promote and train local counterparts on environmental requirements and standards across all of the program's activities. Such proposed activities will be included into annual work plans, and results will be reported in annual performance reports.

• Prior to the launch of each activity that received NDC determination in this lEE (Table 1 & Table 2 Section III) the implementer must recruit a qualified, MEO-approved environmental impact professional(s) (EIP) who will conduct an Environmental Due Diligence (EDD) review described below and develop other required environmental compliance documentation, recommend environmental actions to be taken by the program, train project personnel (including sub-grantees and sub-contractors), coordinate implementation of mitigation measures, monitoring, and reporting. Should the EIP lack special technical knowledge to identify any special environmental impact, the implementer will consult with a specialist in the relevant area. (Sample TOR for the EIP is attached to this lEE)

• Prior to the launch of each activity that received NDC determination in this lEE (Table 1 & Table 2 Section III) including sub-grants and sub-contracts, the implementer's EIP will conduct an Environmental Due Diligence (EDD) review with the Environmental Review and Assessment Checklist (ER Checklist) (attached to this lEE) and Leopold Matrix (attached to this lEE) as an inherent part of the EDD. The EDD must be conducted by the MEO approved environmental expert. The EDD process will document existing environmental concerns and foreseeable environmental effects resulting from the activities. If the EDD results in a finding of potential significant environmental impact, a Scoping Statement (SS) and Environmental Assessment (EA) will be done by the implementer prior to start of activities. TOR for Scoping Statement, Scoping Statement and EA Report must be reviewed by MEO and approved by Asia BEO.

• If EDD review determines that small scale construction activities can follow best practices and standard conditions and no further assessment is required, each small scale construction activity should be conducted in a manner consistent with good design and implementation practices described in USAID Environmental Guidelines for Small-Scale Activities in Africa, 2nd edition as provided at: http://www.encapafrica.org/egssaa.htm; IFC Environmental, Health and Safety Guidelines as provided at: http://www.ifc.org/ifcextlsustainability.nsf/ContentlEnvironmentalGuidelines; World Health Organization guidelines as provided at http://www.who.intlpublications/guidelineslenvironmental_healthlenlindex.html; and Standard Conditions for Small-Scale Construction, Small-Scale Road Rehabilitation, Small- Scale Water and Wastewater Activities (attached to this lEE).

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~~~~Q I BANGLADESH • Based on EDD results and mitigation measures from Environmental Guidelines for small-scale

Activities, IFC EHS Guidelines, World Bank PPAH, and other documents as referenced above, implementer will develop Program Environmental Manual (EM) and Environmental Mitigation and Monitoring Plan (EMMP) for activities that may have negative environmental impact. EM will establish criteria for eligibility, selection and screening against potential environmental risk (low, moderate, and high). This documentation will then be approved by the AlCOR and MEO, in consultation with the Regional Environmental Advisor for Asia (REAlAsia).

• Host country laws and regulations for environmental protection and management will be followed in implementing the activities. For activities categorized as "potential risks'" or "definite risks" of adverse environmental impact, the implementing partner will be required to obtain a letter from the local or regional office for environmental protection stating that the office: a) has been contacted by the implementing partner concerning the project activities; b) will maintain contact with the project; and c) will be aware of the potential environmental impacts of the project to help ensure that no detrimental impact will result from this project.

• For such activities prior to their implementation the implementer will conduct public consultations and will seek concurrence from the national duly authorized environmental agency on EMMPs.

• In all cases, implementation will adhere to corresponding host country environmental laws and policies, generally outlined in the National Environmental Policy of 1992, the National Environmental Management Action Plan of 1995 (and its 2000 and 2002 amendments), and the National Conservation Strategy of 1992. National environmental policies are available at the following link: http://www.moef.gov.bd/html/policy/policy .html

• Sub-contracts or grants from the implementing partner to other organizations must incorporate provisions stipulating compliance with 22 CFR 216 and ADS 204 and the lEE.

• Monitoring will be conducted during the project (beginning with a baseline) to determine the environmental impact (positive and/or negative) of all project activities. The implementer shall use only qualified staff for overseeing the mitigation and monitoring work. Monitoring shall occur as defined in the EMMP and on an as-needed basis. The implementer will ensure that the environmental procedures are implemented, potential impacts mitigated, and indirect and cumulative effects are considered for each activity. If negative environmental impacts are discovered through regular monitoring and evaluation of project activities, immediate actions will be taken to rectify the situation.

• Mitigation and Monitoring reports will be submitted to the Agreement/Contracting Officer's Representative (AiCOR) and MEO prior to and at the completion of each relevant activity at every affected project site, and not at the end of the project or not on a semi-annual or annual basis. Reporting will include photographic documentation and site visit reports which fully document that all proposed mitigation procedures were followed throughout implementation of the subject work.

• The implementer's performance reports to USAID shall contain a section specific to Environmental Compliance and include project summaries along with environmental impacts, success or failure of mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the project, mitigation measures or monitoring procedures. If the activities implemented do not have any negative impact on the environment, this should be documented as well. The implementer's annual report will include an annex containing a table indicating the title, date of award, and category of each activity.

Resource Allocation, Training and Reporting requirements:

• The D04 team will work with the USAID contracting office to include environmental compliance requirements specified in this lEE into RFAlRFPs to ensure that applicants and bidders budget for appropriate resources, staff, mitigation and monitoring, and reporting procedures. The lEE will be included in the RF AlRFP package.

• Agreement/contract with the implementing partner will include environmental compliance and reporting language per the lEE.

II

~~~~Q I BANGLADESH • NCORs together with MEO or hislher designee will explain all environmental conditions to the

implementers at the post-award conference. • The NCOR of each project, in consultation with the MEO or REA and corresponding implementing

partner(s), will actively monitor and evaluate whether environmental consequences not foreseen by this lEE arise during implementation, and will modify or halt activities as appropriate. If additional activities are added to a project but are not described in this lEE, an amended lEE must be prepared.

• It is NCOR responsibility to ensure that Implementing Partners follow th~ environmental compliance requirements specified in this lEE.

5.0 Limitations of the lEE

This lEE covers all known or unknown activities under the USAID/Bangiadesh D04 portfolio through FY2017 as long as the nature of the activities and D04 LOP budget remain as described in this lEE.

This lEE does not cover activities involving:

Assistance for the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under FIFRA - 'Federal Insecticide, Fungicide, and Rodenticide Act'. Note that the activities affected cannot go forward until a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) is approved by the Bureau Environmental Officer. Procurement, use or recommendation for use of ammonium nitrate (AN) and calcium nitrate (CAN) fertilizers. Activities involving support to wood processing, agro-processing, industrial enterprises, and regulatory permitting. A Pollution Prevention Assessment is necessary if the project goal is to have environmentally sustainable production and sales of value-added agricultural products by enabling producers and processors to get ISO, HACCP and other certifications which will be a key factor for the enterprise in competing regionally and globally. The PPA will be reviewed and approved by the Bureau Environmental Officer prior to start of activities. Assistance, procurement or use of genetically modified organisms (GMOs) will require preparation of biosafety assessment (review) in accordance with ADS 20 1.3. 12.2(b) in an amendment to the lEE approved by the Asia BEO. DCA or GDA programs Procurement or use of Asbestos, Lead and Mercury Containing Materials (ALMCM) (i.e. piping, roofing, etc), Polychlorinated Biphenyls (PCB) or other toxiclhazardous materials prohibited by US EPA as provided at: http://www.epa.gov/asbestos and/or under international environmental agreements and conventions, e.g. Stockholm Convention on Persistent Organic Pollutants as provided at: http://chm.pops.int.

Any of these actions would require an amendment to the lEE duly approved by the Asia BEO.

Revisions: Pursuant to 22CFR216.3(a)(9), if new information becomes available which indicates that activities to be funded under the 004 portfolio might have "major" and "significant" effect, or if additional activities are proposed that have not been assessed under this lEE that might be considered "major" and their effects significant, this categorical exclusion and negative determination will be reviewed and revised and submitted to the Bureau Environmental Officer (BEO) for approval and, if appropriate, an environmental assessment will be prepared. It is the responsibility of the USAID Agreement/Contracting Officer's Representative (NCOR) to keep the Mission Environmental Officer and the BEO informed of any new information or changes in the activity that might require revision of this lEE.

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~~§~!! I BANGLADES CLEARANCE for lEE D04: Responsiveness to Climate Cbange Improved

EG Office Director (A)

Mission Environmental Officer

Program Office Directo~

Regional Environmental Adviser: (Asia, Mid-East, & OAPA)

Deputy Mission Director (A):

Mission Director:

APPROVAL:

&~ Mark Teg feldt Date: 7/'[,3/ 3

~ Date: ~ ~ 1; .?J) ~ ~arabadze a';A~ wi e" r5 ~ - Date: '-9 -11) /..1

Thomas Kress

_cleared by email __ Date: _July 18, 2013_ Andrei Barannik

Date: ~ .{v~ ,~

Date: 1Poh'l13 7

ANE Bureau Environmental Officer (A): Date: John Wilson

Approved: Disapproved:

Copy to: project file; MEO tracking; OAA

File location: P:\EG Office\OO Administration\Program\lnitial Environment Examination (IEE)\20 13\EG

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