Writing a Preliminary Assessment (The example of the Initial Environmental Examination)

Writing a Preliminary Assessment

(The example of the Initial Environmental Examination)

[DATE][SPEAKERS NAMES]

ENCAP EA-ESD Training Course: Writing the Preliminary Assessment (IEE). Visit www.encapafrica.org.

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Review:the Preliminary Assessment in the EIA process

Screen the activity

Based on the nature of the activity what

level of environmental

review is indicated?

Conduct a Preliminary Assessment

A rapid, simplified EIA study using simple tools

(e.g. the USAID IEE)

ACTIVITY IS OF MODERATEOR UNKNOWNRISK

SIGNIFICANT ADVERSE IMPACTS

POSSIBLE

SIGNIFICANT ADVERSE IMPACTS

VERY UNLIKELY

ACTIVITY IS LOW RISK (Of its nature, very unlikely to have significant adverse impacts)

ACTIVITY IS HIGH RISK (Of its nature, likely to have significant adverse impacts)

Phase IIPhase IUnderstand proposed activity

Why is the activity being proposed?

What is being proposed?

BEGIN FULL EIA

STUDY

STOP the EIA process


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Review: Purpose of a Preliminary Assessment

Provide documentation and analysis that:

• Allows the preparer to determine whether or not significant adverse impacts are likely

• Allows the reviewer to agree or disagree with the preparer’s determinations

• Sets out mitigation and monitoring for adverse impacts

The purpose of any preliminary assessment is to. . .

The IEE is USAID’s

preliminary assessment


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The Initial Environmental Examination (IEE)

In this presentation, we use the IEE as an example of a preliminary assessment

Basic IEE outline

1. Background & Activity Description1. Purpose & Scope of IEE2. Background3. Description of activities

2. Country & Environmental information

1. Locations affected2. National environmental policies

& procedures

3. Evaluation of potential environmental impacts

4. Recommended threshold decisions & mitigation actions

1. Recommended threshold decisions & conditions

2. Mitigation, monitoring & evaluation

Note: The IEE is very similar to preliminary assessments required by other donors and governments.

!


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Overview: Steps in Preparing an IEE

A. Get

ready

B. Conduct

Environmental Analysis

C. Write Conclusions,

Mitigation and Monitoring Plan

D. Finalize &

submit

Assemble informationReview screening results

Sections 1-3 of the IEE

Section 4 of the IEE

Attach supplemental informationComplete facesheet, sign & submit


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Step A:

GET READY!

A. Get

ready

B. Conduct




D. Finalize &

submit


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Step A: GET READY!

Check screening results

Project or IR nameProposing organization

Activity number of sites

location (if multiple sites,

where distributed)

e.g., budget,

size in Ha unit note Exe

mp

t

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e.g. rehabilitation of market access rd5 to 8 Central Region 5 km

average segment length

X

123456789

10111213141516

indications of typical quantity & scale @ each sitesite information screening result Recommended IEE Threshold Decision

First, review the screening results as recorded in your

summary table.

P r o j e c t o r I R n a m eP r o p o s i n g o r g a n i z a t i o n

A c t i v i t y n u m b e r o f s i t e s

l o c a t i o n ( i f m u l t i p l e s i t e s ,

w h e r e d i s t r i b u t e d )

e . g . , b u d g e t ,

s i z e i n H a u n i t n o t e Exempt

Categoric

al Excl

usion

IEE requi

red

IEE requi

red &

high-risk

if categor

ical exclu

sion,

provide R

eg 216

citation

Negative

dete

rmination

Negative

dete

rmination

w/ co

nditions

Positive

determin

ation

Deferral

e . g . r e h a b i l i t a t i o n o f m a r k e t a c c e s s r d5 t o 8 C e n t r a l R e g i o n 5 k m

a v e r a g e s e g m e n t l e n g t h

X

123456789

1 01 11 21 31 41 51 6

i n d i c a t i o n s o f t y p i c a l q u a n t i t y & s c a l e @ e a c h s i t es i t e i n f o r m a t i o n s c r e e n i n g r e s u l t R e c o m m e n d e d I E E T h r e s h o l d D e c i s i o n

Note which activities the IEE must cover & which categorical exclusions it must justify.


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Step A: GET READY! Review, research & gather information

Assemble keyinformation

Review screening results

Review Chapter 4 of EPTM

May include biophysical, economic & social information, maps and photos. Figure out who you should talk to!

(Per previous slide)

(“Writing the IEE”) The EPTM also contains sample IEEs

Research likely impacts & mitigation

Consult the Small Scale Guidelines or other resources to understand the key impacts & mitigation measures typical for your activities.


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Step B:Conduct theEnvironmental Analysis

(Sections 1-3 of the IEE)

A. Get

ready

B. Conduct




D. Finalize &

submit


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IEE Section 2:Country and

Environmental Information

IEE Section 3: Evaluation of

Environmental Impact Potential

IEE Section 1: Background and

Activity Description

A. Purpose & scope of the IEEOriginal IEE or IEE amendment?Are all activities covered?Are there other, related IEEs?

B. BackgroundWhy are the activities desirable and appropriate ?

Were alternatives considered and rejected? Why?

C. Description of ActivitiesMay require quantitative information

Step B: Conduct the Environmental Analysis Write “Background & Activity Description”

For more detail about the contents of each section, see the annotated IEE outline in the EPTM (annex C)

!


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Activity Description A. Locations affected

Describe the affected biophysical and socioeconomic environment(s) succinctly. Relevant information only!

B. National environmental policies & proceduresDescribe applicable host country

environmental regulations or policies

Step B: Conduct the Environmental Analysis Write “Country & Environmental Information”

Organize this section by location or activity, whichever is most convenient

!


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Activity Description

Describe the potential impacts of EACH activity, including:

all applicable environmental components (e.g., air, water, soils, flora and fauna, cultural)

Direct, indirect & cumulative impacts

Adverse AND beneficial impacts

IF AN ACTIVITY HAS NO POTENTIAL IMPACT, NOTE THIS!

Step B: Conduct the Environmental Analysis Evaluate potential environmental impacts

Use tools such as checklists, matrices, networks or overlays to assist in evaluating impacts.

!


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Step C:Write Conclusions, Mitigation & Monitoring Plan

(Section 4 of the IEE)

A. Get

ready

B. Conduct




D. Finalize &

submit


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Step C: Write Conclusions, Mitigation and Monitoring Plan

Note: Judging the significance of impacts

Section 4 of the IEErequires you to judge the SIGNIFICANCE of impacts.

Significance depends largely on 2 factors: Context of the impact

(environmental context AND policies, laws & local values)

Intensity of the impact

In part, this is often a VALUE JUDGMENT

What do we mean by context &

intensity?

?


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Evinces public concern or controversy.

May set a precedent for how similar situations are addressed in future.

Affects protected habitats, land or ecosystems.

Affects habitats, land or ecosystems which may not be protected, but which are particularly valued for aesthetics, recreation, cultural reasons.

Affects resource availability critical to subsistence & livelihood.

Disrupts local customs.

Is subject to law, policy or regulation that treat the impact as a matter of particular concern.

Has a high or unknown potential impact public health and safety.

Contextual factors that tend to

increase the significance of

adverse impacts include:

When the impact. . .


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A shallow well serving a primary school is located 10m away.

The planned site contains a sacred stone, tree or shrine.

National law requires that any potential impacts on groundwater is considered significant and requires district approval.

How can CONTEXT affect the significance of impacts?An improved pit

latrine is planned at a new market site.

The most significant potential impact of latrines is usually the potential for groundwater contamination.

Construction impacts are typically minimal.

Example: Context & Intensity

What about INTENSITY?

A 10-seat latrine is planned to serve 1000 persons/day


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BEFORE YOU WRITE. . .

What are the impacts

of constructing my market

access road?

DON’T WRITE YET!Step back and consider: Based on your analysis. . .what

recommendation seems likely for EACH activity WITHOUT mitigation and monitoring not already part of the activity design?

What may change once mitigation and monitoring is added?

OK. . .NOW proceed to write the mitigation and monitoring plan


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A.Recommended threshold decisions and conditionsIncludes justifications for any categorical exclusions.

B.Mitigation, monitoring and evaluationRemember, mitigation & monitoring plans should specify what, who, how much, when and why!



Step C: Write Conclusions, Mitigation and Monitoring Plan Write the mitigation & monitoring plan

Write mitigation and monitoring BEFORE making recommended determinations!

WHY? Because mitigation should reduce the significance of impacts!

!

IEE Section 4: Recommended

Threshold Decisions and

Mitigation Actions


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A.Recommended threshold decisions and conditionsIncludes justifications for any categorical exclusions.

B.Mitigation, monitoring and evaluationRemember, mitigation & monitoring plans should specify what, who, how much, when and why!

Step C: Write Conclusions, Mitigation and Monitoring Plan Write the mitigation & monitoring plan

Once mitigation and monitoring is specified, you are ready to make your recommended determinations.

REMEMBER, each activity receives one of 4 determinations. . .

IEE Section 4: Recommended

Threshold Decisions and

Mitigation Actions


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Recommendation Reg. 216 terminology

Implications(if IEE is approved)

No significant adverse environmental impacts

NEGATIVEDETERMINATION

Activity passes environmental review

With specified mitigation and monitoring, no significant environmental impacts

NEGATIVEDETERMINATIONWITH CONDITIONS

The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented

Significant adverse environmental impacts are possible

POSITIVEDETERMINATION

Do full EAor redesign activity

Not enough information to evaluate impacts DEFERRAL

You cannot implement the activity until the IEE is finalized

Based on IEE section 3 & 4.b, make a recommendation for EACH activity. . .

Step C: Write Conclusions, Mitigation and Monitoring Plan Recommended Determinations in the IEE


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Step C: Write Conclusions, Mitigation and Monitoring Plan Justifying categorical exclusions

If your screening results indicate that some activities qualify for categorical exclusions, these exclusions must be justified in section 4.A.

To justify a categorical exclusion, you should cite the language in Reg. 216.2(c)(2) that creates the exclusion

For example. . .“Per 22 CFR 216.2(c)(2)(i), A categorical exclusion is recommended for training activities.

XXX intends to train farmers belonging to producer organizations in financial and business management. These activities will have no effect on the environment.”

216.2(c)(2)(i) reads. . .“Education, technical assistance or training programs, except to the extent such programs include activities directly affecting the environment.”


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Step D:Finalize & submit the IEE

A. Get

ready

B. Conduct




D. Finalize &

submit


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First, enter the recommended determinations in your summary table

Project or IR nameProposing organization

Activity number of sites

location (if multiple sites,

where distributed)

e.g., budget,

size in Ha unit note Exe

mp

t

Cat

ego

rica

l E

xclu

sio

n

IEE

req

uir

ed

IEE

req

uir

ed &

h

igh

-ris

k

if ca

tego

rical

ex

clus

ion,

pr

ovid

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eg 2

16

cita

tion

Neg

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eter

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Neg

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eter

min

atio

n

w/ c

on

dit

ion

s

Po

siti

ve

det

erm

inat

ion

Def

erra

l

e.g. rehabilitation of market access rd5 to 8 Central Region 5 km

average segment length

X

123456789

10111213141516

indications of typical quantity & scale @ each sitesite information screening result Recommended IEE Threshold Decision

Step D: Finalize & submit the IEE

Finish your summary table

Activity unit note Exe

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IEE

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e.g. rehabilitation of market access rd5 to 8 Central Region 5 km X

123456789

10111213141516

screening result Recommended IEE Threshold Decision


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Step D: Finalize & submit the IEE Attachments & facesheet

Submit

Finish summary table

Attach supplemental information

(Per previous slide)

Attach maps, photos, site descriptions & any other information that will help the reviewer make a decision.

Complete facesheet

Be sure to transfer recommended determinations from your summary table.


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Some final advice

In reality, IEE preparation is

usually an ITERATIVE

process

A. Get

ready

B. Conduct




D. Finalize &

submit

Talk to more people.Revise & continue!

Know your activities as well as possible before you begin: Do desk research, visit the field, talk with colleagues.

Start to draft the IEE. Identify missing information.

Writing a Preliminary Assessment (The example of the Initial Environmental Examination)

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