COVER SHEET: INITIAL ENVIRONMENTAL EXAMINATION PROGRAM/ACTIVITY DATA:
COVER SHEET: INITIAL ENVIRONMENTAL EXAMINATION PROGRAM/ACTIVITY DATA: Program/Activity Number: Cooperative Agreement # AID‐668‐A‐11‐00002 Country/Region: South Sudan Program/Activity Title: Support to Independent Community Radio Network in South Sudan (SICRNSS) Project (Cost Extension) Funding Begin: September 30, 2011 Funding End: September 30, 2013 (proposed) LOP Amount: $9,766,299 (proposed) IEE Prepared By: Mark Stoughton, GEMS/The Cadmus Group mark.stoughton@cadmusgroup.com Current Date: 12 September 2012 IEE Expiration Date: End‐of‐project or December 31, 2014, whichever is sooner Submitted By (Project Point‐of‐Contact): [Pui Man Wong] IEE Amendment (Y/N): N Note: This IEE is not an amendment, but rather supercedes and replaces the following IEEs covering the SICRNSS project and Eye Radio/Sudan Radio Service project: SouthSudan_SICRNSS_IEE_093011.pdf SouthSudan_SudanRadioService_IEE_062510.pdf SouthSudan_SudanRadioService_IEE_amend_022912.pdf ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable) Categorical Exclusion: X Negative Determination: X Positive Determination: Deferral: ADDITIONAL ELEMENTS: (Place X where applicable) CONDITIONS X PVO/NGO: SUMMARY OF FINDINGS Program Summary. SICRNSS, implemented by Internews, is an ongoing project of USAID/South Sudan under the Mission’s Democracy and Governance sector program. SICRNSS promotes participatory development, governance and democratic accountability, peace building, cultural tolerance, and effective communication SICRNSS Cost Extension IEE Page 1 between state actors, civic actors, and local communities by supporting independent media development, community radio and access to information in South Sudan. The other component of media programming for USAID/S Sudan has been the Eye Radio Project (previously Sudan Radio Service). Eye Radio, implemented by Education Development Center, Inc., has become a valuable part of South Sudan’s struggle for peace and development and a symbol of independent media, first through short‐wave broadcasting and later through the establishment of the Juba‐based 98.6 FM radio station. The current Eye Radio project ends on 25 September 2012. On 7 September 2012, Internews submitted a cost extension request to USAID that would (1) extend the current SICRNSS project by 3 months to a new end date of 30 September 2013; (2) incorporate the existing Eye Radio project and its activities into SICRNSS; and (3) towards these ends, increase funding in the amount of $4.9million. Purpose of IEE. This IEE provides a single source of 22 CFR 216 Threshold Determinations and Conditions for the Support to Independent Community Radio in South Sudan project (SICRNSS) under the cost extension, including the Eye Radio activities. IEEs being replaced and superceded as of 26 September 2012. Such IEE’s remained valid for all activities begun before 25 September 2012. For new activities begun after 26 September 2012, this new IEE governs. Sudan Radio Service IEE of 25 June 2010 Sudan Radio Service IEE amendment of 2 Dec 2011 SICRNSS IEE of 28 Sept 2011 Recommended Determinations and Conditions. The following table summarizes the recommended determinations assigned to categories of activities that SICRNSS will carry out as of the effective date of this IEE through end‐of‐project. (Note that these are NOT identical to SICRNSS program objectives, but do capture all activities programmed under those objectives.) For each, a link is provided to the activity descriptions, analysis of potential environmental impacts, and activity‐by‐activity determinations and conditions within the body of the IEE. Intervention Category A. Direct operation of 4 existing community radio stations, and potentially 2 new community radio stations Recommended Determination(s) Negative Determination with Conditions B. Potential construction of 2 new community radio stations in Tambura (Western Equatoria) and Kapoeta (Eastern Equatoria Negative Determination with Conditions Click here C. Completion of Technical Upgrades to 4 Community Radio Stations Negative Determination with Conditions Click here D. Operation of Eye Radio Juba Station/Compound & Repeater Network; Broadcast Quality Monitoring Negative Determination with Conditions Click here E. Potentially, Complete Installation of the Eye Radio repeater network Negative Determination with Conditions Click here Categorical Exclusion Click here F. Webcasting & Website Development/Maintenance SICRNSS Cost Extension IEE Link to full analysis Click here Page 2 G. Newsgathering and Program Production Categorical Exclusion Click here H. Journalist and Media Outlet Training Categorical Exclusion Click here I. Audience Research and Feedback Categorical Exclusion Click here Negative Determination with Conditions Click here J. Governance, Management and Operations Capacity Building and Strategic/Operational Assessment and Planning for Community Radio Stations and Eye Radio/Eye Media General Implementation and Monitoring Conditions. In addition to the specific conditions enumerated under individual activities, the negative determinations recommended in this IEE are contingent on full implementation of a set of general monitoring and implementation requirements set out in section 4 of the IEE. These concerns include the following: 1. Communication of environmental compliance to implementing partner. 2. Development of an EMMP. 3. Integration and implementation of EMMP. 4. Integration of compliance responsibilities in prime and subcontracts and subgrant agreements. 5. Assurance of sub‐grantee and sub‐contractor capacity and compliance. 6. USAID Sector Team monitoring responsibility. 7. New or modified activities. 8. Compliance with Host Country Requirements. SICRNSS Cost Extension IEE Page 3 APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED: CLEARANCE: Mission Director CONCURRENCE: Africa Bureau Environmental Officer ADDITIONAL CLEARANCES: Mission Environmental Officer Program Officer Regional Legal Advisor Deputy Mission Director Regional Environmental Advisor USAID/East Africa SICRNSS Cost Extension IEE Signed: ______________________ Date: ___________ William Brands Signed:______________________ Date: ___________ Brian Hirsch Signed: cleared by email Harry Bottenberg Date: 9‐14‐2012 Signed: ______________________ Date: ___________ Marcia Musisi‐Nkambwe Signed: ______________________ Date: ___________ Christopher Kelly Signed: ______________________ Date: ___________ Alex Deprez Signed: ______________________ Date: ___________ David Kinyua Page 4 INITIAL ENVIRONMENTAL EXAMINATION PROGRAM/ACTIVITY DATA Program Title/Activity #: Support to Independent Community Radio Network in South Sudan (SICRNSS) Project Cooperative Agreement # AID-668-A-11-00002 Country/Region: South Sudan Program classification per Foreign Assistance Standardized Program Structure and Definitions Functional Objective 1. Conflicts in Flashpoint Areas Mitigated 2. Effective, Inclusive, and Accountable Governance Strengthened 3. Governing Justly and Democratically Program Areas 1.1 Improved capacity for conflict mitigation and management at the local level 1.2 At‐risk populations engage in productive economic and social activities 1.3 Government presence and services extended at the local level 2.3 Citizens’ engagement with government institutions increased 2.3 Political Competition and Consensus‐ Building 2.4. Participatory Constitutional Development Supported 2.4 Civil Society Program Elements & Sub‐elements 2.3.1 Citizen access to balanced information and civic education expanded 2.3.2 Elections and Political Processes 2.3.2.3 Public Awareness and Voter Education 2.3.2.4 Enfranchisement Inclusion and Access 2.3.2.5 Citizen Engagement and Participation in Elections and Political Processes 2.4.2 Media Freedom & Freedom of Information 2.4.2.2 Professional & Institutional Capacity 2.4.2.5 Media Outlets and Infrastructure 1 BACKGROUND AND ACTIVITY/PROGRAM DESCRIPTION 1.1 Purpose and Scope of IEE This IEE provides a single source of 22 CFR 216 Threshold Determinations and Conditions for the Support to Independent Community Radio in South Sudan project (SICRNSS). As described in section 1.2, SICRNSS is being extended and new activities, formerly constituting the Sudan Radio Service/Eye Radio project, are being added. IEEs being replaced and superceded are: Sudan Radio Service IEE of 25 June 2010 5 Sudan Radio Service IEE amendment of 2 Dec 2011 SICRNSS IEE of 28 Sept 2011 As with all IEEs, in accordance with 22 CFR 216, this IEE reviews the reasonably foreseeable effects of SICRNSS activities on the environment. On this basis, this IEE recommends Threshold Decisions for these activities. This IEE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally‐sound activity design and implementation. 1.2 Project Background SICRNSS, implemented by Internews, is an ongoing project of USAID/South Sudan under the Mission’s Democracy and Governance sector program. SICRNSS promotes participatory development, governance and democratic accountability, peace building, cultural tolerance, and effective communication between state actors, civic actors, and local communities by supporting independent media development, community radio and access to information in South Sudan. The other component of media programming for USAID/S Sudan has been the Eye Radio Project (previously Sudan Radio Service). Eye Radio, implemented by Education Development Center, Inc., has become a valuable part of South Sudan’s struggle for peace and development and a symbol of independent media, first through short‐wave broadcasting and later through the establishment of the Juba‐based 98.6 FM radio station. Listenership for the Juba station has grown dramatically since it opened in 2010 with a reach of over 1.1 million people and is expected to increase further after the installation of translator/repeater towers across the country. The current Eye Radio project ends on 25 September 2012.1 On 7 September 2012, Internews submitted a cost extension request to USAID that would (1) extend the current SICRNSS project by 3 months to a new end date of 30 September 2013; (2) incorporate the existing Eye Radio project and its activities into SICRNSS; and (3) towards these ends, increase funding in the amount of $4.9million. 1.3 Description of Activities The expanded and extended SICRNSS project resulting from this cost extension will be organized around six program objectives: 1. Develop and strengthen the network of community radio stations, the various radio programs, radio station advisory boards, and the capacity of local South Sudanese radio journalists. 1 Sudan Radio Service Project (SRS)/Eye Radio was implemented by the Educational Development Center (EDC) under cooperative agreement # HAD‐A‐A‐03‐00105‐00 through an Associate Award under the Digital Opportunities through Technology (DOT‐EDU) Leader with Associates (LWA) Award. 6 2. Assist in strengthening the Government of South Sudan’s core institutions by providing broadcast and feedback linkages with civil society groups and individual citizens, creating transparent and inclusive government policies, laws and regulations. 3. Increase citizen engagement with government institutions by providing balanced news and information on civic education, government activities, peace and development, anti‐corruption and women’s and minority issues. 4. Provide coverage of political party activities and assist in connecting parties to citizens through public fora and listener feedback mechanisms. 5. Cover all activities leading to an interim and then permanent constitution and elections in order to inform and involve citizens and citizen groups in those processes. 6. Continue previous SRS priorities including: building the capacity of South Sudanese journalists and media partners, advance cross‐cutting objectives like gender, and inform South Sudanese on matters relating to health, agriculture, educational issues and culture. These objectives each subsume multiple, overlapping activities and do not provide a suitable, transparent framework for environmental review. For this reason, planned activities are for the purposes of this IEE organized into the following categories, which do provide a transparent basis for environmental review and assignment of threshold determinations: A. Direct operation of 4 existing community radio stations, and potentially 2 new community radio stations (see next item) B. Potential construction of 2 new community radio stations in Tambura (Western Equatoria) and Kapoeta (Eastern Equatoria) C. Completion of Technical Upgrades to 4 Community Radio Stations D. Operation of Eye Radio Juba Station/Compound & Repeater Network; Broadcast Quality Monitoring E. Potentially, Complete Installation of the Eye Radio repeater network F. Webcasting & Website Development/Maintenance G. Newsgathering and Program Production H. Journalist and Media Outlet Training I. Audience Research and Feedback J. Governance, Management and Operations Capacity Building and Strategic/Operational Assessment and Planning for Community Radio Stations and Eye Radio/Eye Media 7 2. COUNTRY AND ENVIRONMENTAL INFORMATION (BASELINE INFORMATION) 2.1 Locations Affected Existing Community Radio Station Locations. The location of the four existing SICRNSS community radio stations are illustrated in Figure 1, below; GPS coordinates are provided in Table 1. Previous review of station sites via satellite imagery shows no complicating factors that would tend to increase the environmental impacts and risks associated with construction of, modifications to, or operation of these small facilities: e.g. none are near permanent or seasonal streams/water bodies, none are in undisturbed landscapes, and all are in relatively flat terrain. The sites, in short, are typical of settled areas within their ecological‐climatic zones; these are described in the September 2007 Southern Sudan Environmental Threats and Opportunities Assessment, available at http://pdf.usaid.gov/pdf_docs/PNADL108.pdf. Figure 1: SICRNSS Community Radio Station Locations. Leer Turalei Malualkon Nasir N08°18'16.67" E030°07'55.49" N 9 º 05' 30.04'' E 28 º 25' 50.73'' N09 00' 49.79" E 027 37' 23.54" N 8º 36’, 46.67’’ l E 33º 3’, 1.34’’ Table 1: Community Radio Station GPS Coordinates 8 Leer Turalei Malualkon Nasir Figure 2: Satellite photos of Community Radio Station Locations Existing Community Radio Station Plans/Designs. The stations/compounds are all built to a similar plan, with a studio/office building of approx. 14m x 9m, a 70m antenna, a guard house, generator, and latrines, in a fenced compound of approx. 40m X 40m. A Studio/Office plan and photo is provided as Figures 3 & 4 below. Stations and community resource centers share a compound in some instances; these compounds are slightly larger. Following recent upgrading, station broadcast power is ap 2000W. The stations do not have on‐site water supplies and for potable water rely on jerrycan or tanker deliveries. 9 Figure 3: Typical plan for studio/office building Figure 4: Malualkon community radio station and resource center (shared compound). Radio station studio/office is at left and the resource center in the middle; the latrine block can be seen at far right. Proposed Sites of Potential New Community Radio Stations. Funding permitting, 2 new community radio stations may be constructed by SICRNSS: Tambura, Western Equatoria: Population/potential audience: 93,000 estimated for a radius of 80‐100km around Tambura. 10 Tambura is located in the upper‐northern part of Western Equatoria close to the South Sudanese border with Central Africa. Tambura is the main urban centre of Tambura and Ezo Counties. The area is home to the mainly agricultural Zande though within Tamura County there are as well Fertit while the nomadic pastoralist Mbororo are present throughout the region. With the recent resurfacing of the Yambio‐Tambura road the infrastructure and access has improved significantly. The second access road is coming from Wau in Bahr El Ghazal. The region has been affected by the Lord’s Resistance Army attacks since 2008, while there are at times simmering conflicts between the Zande population and the Mbororo, both causing significant streams of internally displaced in the region. At times there have been conflicts between SPLA soldiers and the local population, though of late this seems to have reduced. Kapoeta, Eastern Equatoria: Population/potential audience: 316,000 estimated for a radius of 80‐100km around Kapoeta. Kapoeta is the main urban center of greater Kapoeta in Eastern Equatoria. The region is divided into Kapoeta East, West, North, Kapoeta and Bud County and is home to three pastoralist communities, the Buya, Diding and Toposa who have a history of feuding and cattle raiding. Poor communication and the lack of infrastructure hampers development and access to basic services. There are multiple areas of conflict both between the communities within the region and between the populations in Greater Kapoeta and the neighboring Turkana living across the Kenyan border and the Karamojong living in Uganda. Conflict is often fuelled by cattle raiding while exacerbating factors include scarce resources, the presence of arms, the changing role of ‘chiefs’, perceptions of justice systems and unsuccessful peace meetings. Eye Radio Compound and Station (98.6FM). The station and compound were constructed under the Sudan Radio Service project, largely in 2010. The compound occupies a 120m x 60m plot centered on 4° 48’43.37” N, 31° 33’24.39” E (+/‐ 10m). In addition to the studio and broadcast tower, the walled compound includes offices and training rooms, latrines, generator & fuel storage, and a borehole. A plan of the compound and a sketch map of and description of the surrounding area are included in the Environmental Review Form and Report developed by EDC during the design process and annexed to this IEE. 98.6 FM, the University of Juba housing and the SSBL brewery were early “anchors” in an area that is seeing substantial formal infill development In addition to this formal development, comparison of March 2009 satellite imagery with current photos of the site show that substantial informal infill settlement has occurred in the immediate area of the site in recent years. Undeveloped land in the area retains the ground cover typical of the Juba area away from the Mountain Nile (grasses and “scrub” with scattered trees), The most prominent features of the site are a seasonal stream (channel maximum size approx. 3m wide by 1m deep) that crosses the rear plot towards the rear (see sketch map; Section F) and a number of large, partially buried boulders. The stream follows a generally NNE path for approx. 170m before joining another, larger seasonal stream that in turn 11 discharges to the Mountain Nile approx 5km to the east. The stream provides drainage for an area of at least 2 sq km upstream (west and slightly north) of the site. Juba is in a malarial zone. Satellite imagery indicates that the stream bed along its length retains standing water for at least part of the year, and this is expected to provide mosquito breeding habit. SRS secured a broadcast license, a 30‐yr lease which includes development permission for the land, and a building permit, completing host country regulatory requirements. Eye Radio’s news‐gathering activities are South Sudan‐wide. Its internet broadcasts have worldwide reach. The coverage of the FM signal will cover all the state capitals (see list below) once the full network of transmitter/repeater stations are installed. Eye Radio’s repeater network consists of transmitters (all less than 1 KW) installed on existing MTN cell phone towers in each state capital: 1. Yambio, Western Eqaitoria 2. Torrit, Eastern Equatoria 3. Wau, Western Bahr el Ghazal 4. Rumbek, Lakes 5. Bor, Jonglei 6. Malakal, Upper Nile 7. Bentiu, Unity 8. Kwajok, Warrap 9. Aweil, Northern Bahr el Ghazal (Juba is reached via the existing Main Station ‐98.6 SRS FM, described above.) Installation should be completed under the existing EDC/Eye Radio project, but may need to be completed by Internews/SICRNSS. When completed, 98.6FM will reach all state capitals. 2.2 Applicable Host Country Environmental Policies and Procedures Construction and operation of radio stations requires obtaining a lease on a suitable plot, a building permit, and, for radio stations, a broadcast license, and a frequency assignment. Plots for radio stations are in each case obtained from state governments. To date and to our knowledge, no South Sudanese environmental requirements have pertained to project activities. Leases, building permits, broadcast licenses and frequency assignments were secured for each of the four community radio stations and 98.6FM and its repeater transmitters. South Sudan is expected to enact an environmental policy into a law. Depending on timing, this could impose environmental review, permitting, or operational requirements on construction of new community radio stations, if this activity goes forward. 12 3. POTENTIAL ENVIRONMENTAL IMPACTS AND RECOMMENDED DETERMINATIONS, INCLUDING CONDITIONS As noted in section 1.3, the SICRNSS cost extension proposal is organized around 6 objectives, each of which subsume multiple, overlapping activities. For purposes of this IEE, entailed activities under these objectives are re‐organized into the following categories, which provide a straightforward, transparent basis for environmental review and assignment of threshold determinations. Analysis in this section addresses each activity category in turn, describing the entailed activities, assessing potential adverse environmental impacts, and setting out a recommended determination (and if appropriate, attendant conditions) for each category. A. Direct operation of 4 existing community radio stations, and potentially 2 new community radio stations (see next item) B. Potential construction of 2 new community radio stations in Tambura (Western Equatoria) and Kapoeta (Eastern Equatoria) only if in line with construction policy C. Completion of Technical Upgrades to 4 Community Radio Stations D. Operation of Eye Radio Juba Station/Compound & Repeater Network; Broadcast Quality Monitoring E. Potentially, Complete Installation of the Eye Radio repeater network F. Webcasting & Website Development/Maintenance G. Newsgathering and Program Production H. Journalist and Media Outlet Training I. Audience Research and Feedback J. Governance, Management and Operations Capacity Building and Strategic/Operational Assessment and Planning for Community Radio Stations and Eye Radio/Eye Media Category A: Direct Operation of 4 Existing Community Radio Stations/Compounds, and Potentially of 2 New Community Radio Stations (see next item) Description/Entailed Activities. The community radio station sites and compound/station design plans are described in section 2.1 Station/compounds operation includes operation of the broadcast antenna and equipment, as well as small‐scale studio/office operations Potential Adverse Impacts & Considerations Regarding Recommended Determinations. The potential impacts of station/compound operation fall into 4 categories; each is discussed in the table below. Aspect Potential Broadcasting By definition, radio broadcast antennas emit non‐ionizing radio‐frequency (RF) radiation. Very high‐ intensity RF radiation can induce heating in body tissues; it is possible for such heating effects to reach dangerous levels, particularly in organs such as the eyes and testes. The science of other “non‐heating” effects, particularly at moderate field intensities, is uncertain, with some studies suggesting increased 13 cancer and developmental risks and immunological effects, among others. However, these issues and risks do not apply to these community radio stations, due to the combination of (1) relatively low transmission power (2000W after upgrades, see activity Category C, below); (2) antenna height (70m), and (3) the inverse square law that governs RF field intensity, and which assures that, given this combination of broadcast power and antenna height, ground‐level RF radiation risk is negligible. Waste streams & Pathogens Compound operation will generate a set of waste streams (e.g. gray water, latrine discharge, solid waste). In general, if improperly managed, such wastes can contaminate ground and surface water, create breeding habitat for disease vectors, etc. For example, if latrine design or a maintenance failure permits insects or other disease vectors free in‐and‐ out access to the pit/tank, pathogens in human waste can be spread within the compound and to the nearby community. Similarly, spilling latrine waste during pump‐out releases contained pathogens into the environment. Storing solid waste (usually a mixture of food scraps, packaging, and paper) in open containers creates breeding habit for and attracts disease vectors such as rodents. However, experience shows that such impacts controllable below the level of significance with basic good design and management practices; this is particularly true given the low volumes of such wastes produced by the radio stations. Runoff and standing water In general, failure to design or maintain appropriate drainage structures can result in standing water within the compound or on adjacent lands, which is of particular concern as malaria is endemic in most of Southern Sudan. Local erosion, including damage to adjacent fields, and sedimentation of surface waters can also result. As no sites are near permanent or seasonal streams/water bodies, and site areas are small, sedimentation of surface waters is unlikely to be a significant concern. The creation of standing water is a concern, but is readily controllable with design and maintenance of appropriate drainage structures. Generator Fumes, noise pollution, and potential fuel spillage Generators and fuel storage present a risk of fuel leaks which can contaminate soils and surface waters. Generators do contribute to air pollution, though the overall effect of a single well‐maintained generator on air quality on and immediately adjacent to the compound should be minimal. Generators noise may have adverse Effects on abutters if any. Under the previous IEE, Internews procured fuel‐efficient generators with noise‐suppression, which should reduce both air and noise pollution Recommended Determination. Pursuant to the analysis above, “Direct operation of community radio stations” is recommended for a Negative Determination, subject to the following conditions: SICRNSS shall assure that a. Latrines shall be maintained in clean and orderly condition, including intact screens on septic vent stack(s) (if applicable) and tight‐fitting seals on pump‐out points. b. Drainage structures shall be kept free of obstruction and otherwise maintained in sound condition. c. Solid waste being held for collection or transport to a dump site shall be stored in sealed containers. d. The compound shall be maintained free of litter and debris. e. No work shall be undertaken on the antenna while live f. Generators, including noise suppression features, shall be well‐maintained. 14 g. Design features of the station/compound specified for “Community Radio Station Construction” (below) are fully maintained and any deficits in existing stations with respect to these features must be corrected within 6 months of the effective date of this IEE. Category B: Potential Construction of 2 New Community Radio Stations in Tambura (Western Equatoria) and Kapoeta (Eastern Equatoria) Summary of entailed activities. Funding permitting, SICRNSS may construct 2 additional community radio stations, bringing the total to 6. Prospective sites for these stations are described in section 2.1, above. The stations would be built to the general plan of the other stations, also described in 2.1. Potential Adverse Impacts & Considerations Regarding Recommended Determinations. The potential impacts of new station construction fall into 3 categories; each is discussed in the table below. Disturbance to natural landscape/ habitat/ watershed Construction typically necessitates clearing, grading, trenching and other activities that can result in near‐ complete disturbance to the pre‐existing landscape/habitat within the plot. If the plot contains or is adjacent to a permanent or seasonal stream/waterbody, grading and leveling can disrupt local drainage. In the absence of complicating factors, USAID AFR Bureau has concluded that construction involving a total “disturbed area” of less than 1000m2 is of its nature extremely unlikely to create significant adverse impacts of any kind. Radio station plot sizes are larger than 1000 m2, but significant adverse impacts to landscape/habitat /watersheds are very unlikely, for the following reasons: o No radio station site is located in or adjacent to a protected area. o No site is located adjacent to a seasonal or permanent stream or water body. o In each case, the plot designated by governmental authorities for the station lies within a landscape already disturbed by human activity, and one being allocated for future development. These factors strongly diminish the environmental value of maintaining the landscape and habitat of the plot in its baseline condition. Offsite impacts of materials sourcing Construction requires a set of materials often procured locally: e.g. timber, fill, bricks, sand and gravel. Unmanaged extraction of these materials can have adverse effects on the environment. For example, stream bed mining of sand or gravel can increase sedimentation and disturb sensitive ecosystems; purchase of timber from unmanaged or illegal concessions helps drive deforestation. While Internews has direct control over its general contractors (GC), construction materials are often procured by the GC from sub‐vendors. In the case of timber, these sub‐vendors are often the terminus of a long and untraceable supply chain. It should also be noted that radio stations are small construction projects, and as such their adverse impacts related to materials sourcing should be quite limited. However, for new construction Internews can and should undertake reasonable due diligence to assure no significant adverse impacts from materials sourcing can be attributed to Internews, and to reduce indirect impacts through mitigation such as requiring its general contractor to certify extraction of material is not from ecologically sensitive area and to procure chain‐of‐custody‐certified timer. Runoff and standing water Runoff from cleared ground or materials stockpiles during construction can result in sedimentation/fouling of surface waters, particularly if the site is located in close proximity to a stream or water body. Construction may result in standing water on‐site, which readily becomes breeding habitat for mosquitoes and other disease vectors; this is of particular concern as malaria is endemic in much of Southern Sudan. Both impacts are controllable below the level of significance with basic good construction practices. 15 Recommended Determination. Pursuant to the analysis above, “construction of 2 new community radio stations” is recommended for a Negative Determination, subject to the following conditions: 1. Siting; intent to provide potable water. Any plan to provide potable water via well or borehole AND/OR intent to build on any site that: a. is within 30m of a permanent or seasonal stream or water body, OR b. would require displacement of existing settlement/inhabitants, OR c. has an average slope in excess of 5%, OR c d. is currently heavily forested will require completion of the formal AFR subproject/sub grant review process, as set out by the AFR Environmental Review Form (see Attachment 2). The ERF must be duly approved by USAID prior to any irreversible commitment of resources. SICRNSS must then assure implementation of any mitigation and monitoring conditions specified by the approved ERF. In addition, if potable water will be provided via a well or borehole, a Water Quality Assurance Plan needs to be submitted and reviewed by the MEO within three months of the award to ensure that the water provided will be safe to drink (Attachment 3). This will include testing of water for Arsenic and coliform bacteria. 2. Station/compound design elements. All stations/compounds must include/conform to the following design elements. a. Latrine/septic tank design prevents in‐and‐out access for insects or other disease vectors from the pit or holding tank. b. Latrines are accompanied by hand wash stations. c. All sources of gray water (e.g. kitchen sinks (if any) and hand wash stations) discharge to either (1) a seepage pit or sump at least 15m from any source of groundwater or surface water tapped for domestic use, or (2) to an impermeable pump‐out tank. d. Latrines or the terminus of any septic leach field must be at least 30m from any source of shallow groundwater or surface water tapped for domestic use, OR discharge to an impermeable pump‐out tank. e. Siting, grading and/or drainage structures prevent runoff from the compound from creating standing water on the compound or adjacent land during the raining season (instances of generalized flooding excepted). f. Septic pump‐out point, if any, shall feature a concrete apron and drain with return to the septic tank. g. Concrete aprons with berms or gutters/sumps shall be placed under generators, fuel storage, and fuel pump‐in point (if different) sufficient in each case to capture at least a 20 liter spill. Advisory note: While not a condition, SICRNSS is strongly encouraged to consider on‐compound tree‐planting and comfort‐enhancing/energy conserving green building features, including as briefed in the Schools chapter of the Environmental Guidelines for Small‐Scale activities in Africa (www.encapafrica.org/egssaa.htm). These include, but are not limited to: Use of a half‐wall design (with mosquito netting) for common areas; use of verandas, cross‐ventilation, and under‐eave vents; 16 rainwater harvesting for irrigation of plantings and general cleaning; and supplemental use of wind or solar energy. Category C: Completion of Technical Upgrades to 4 Community Radio Stations. Description/Entailed Activities. SICRNSS is implementing a set of technical upgrades to the 4 community radio stations to increase their broadcast area/audience; with these upgrades, the listening area should expand to a 100km radius around each station. For each of the 4 stations, the upgrades consist of: Increasing transmitter power from 250W to 2000W Increasing mast height by 10m, to 70m Installation of high‐gain circular dipole antennas Upgrade of generators to 10kVA + additional batteries and higher‐capacity inverter Installation of AC and improved ventilation to support operation of higher‐power equipment. As of the effective date of this IEE, upgrades to the station in Nasir are fully completed; masts are extended and generators installed in all the stations; and transmitter equipment for other stations has just arrived and is still in Juba, but is scheduled imminently for transport to Malualkon and Tualei. (These technical upgrades were addressed by the SICRNSS IEE of 30 Sept 2011 and will remain in effect..) Potential Adverse Impacts & Considerations Regarding Recommended Determinations. Potential adverse impacts of station operation with these upgrades are addressed under Category A, above: “Direct Operation of Community Radio Stations.” Accordingly, this analysis deals only with the impacts of the upgrade process itself. Essentially, the remaining upgrade process consists simply of installing upgraded transmitter equipment; limited light construction to construct/augment concrete pads and construct or modify shelters for the generators has already been carried out. Equipment installation presents no foreseeable adverse environmental impacts. If installation involves working at height, however, associated occupational safety risks arise. These can be controlled by assuring that installation personnel are qualified for work at height and have appropriate safety gear. Recommended Determination. Pursuant to the analysis above and with reference to the annexed ERF/Report1, “Completion of Technical Upgrades to 4 Community Radio Stations” is recommended for a Negative Determination, subject to the condition that any installation work at‐height is undertaken by workers with appropriate qualifications and experience, and with appropriate safety equipment, including fall‐arrest harnesses. 17 Category D: Operation of Eye Radio Juba Station/Compound & Repeater Network; Broadcast Quality Monitoring Description/Entailed Activities. The Juba Station/Compound is described briefly in section 2.1 of this IEE (“locations affected”) and more fully in the annexed Environmental Review Form and Report (ERF/Report) developed by EDC to satisfy environmental compliance requirements during the compound design process. (Attachment 4 to this IEE.) As is clear from station/compound plan and description, physical operation of the station and compound includes both FM radio broadcasting, and studio, office and classroom/training operations. The 9‐station repeater network is likewise described under section 2.1. Installed on existing cellphone towers in the various state capitals, the repeater network very significantly increases the broadcast reach of Eye Radio. Project staff and hired or volunteer monitors may assess broadcast quality/signal strength with measuring equipment and/or with subjective “audibility” evaluations. Potential Adverse Impacts & Considerations Regarding Recommended Determinations Station operation. The ERF/Report developed by EDC during the station/compound design process assessed both the potential impacts of construction and of operation, including risks posed by radio‐frequency radiation during broadcast operations. It concluded that adverse environmental impacts of both operation and construction would be held well below the level of significance with a set of basic, well‐specified mitigation measures. Rather than repeat this analysis, the ERF/Report is simply annexed to this IEE. (Attachment 4) Repeater Network. Repeater transmitters by definition emit non‐ionizing radio‐frequency (RF) radiation. Very high‐intensity RF radiation can induce heating in body tissues; it is possible for such heating effects to reach dangerous levels, particularly in organs such as the eyes and testes. The science of other “non‐heating” effects, particularly at moderate field intensities, is uncertain, with some studies suggesting increased cancer and developmental risks and immunological effects, among others. However, these issues/risks do not apply to the repeater transmitters, due to the combination of (1) the low transmission power (1KW or less); (2) their installation on existing cell towers, where they constitute a small portion of the total RF radiation load, and (3) the inverse square, which means that RF field intensity at the tower base from such transmitters will be low. Recommended Determination. Pursuant to the analysis above and with reference to the annexed ERF/Report, “Operation of Eye Radio Juba Station/Compound & Repeater Network” is recommended for a Negative Determination, subject to the following conditions: SICRNSS shall assure 1. The stream bed within the Juba compound is maintained free of obstructions to flow. 18 2. No work will be allowed on antennas when live 3. Solid waste being held for collection at the Juba compound will be stored in sealed containers at least 10m from water supply points. 4. Drainage systems at the Juba compound shall be kept free of obstruction and otherwise maintained in sound condition. 5. Any increase to station or repeater power during the period of USAID funding would require demonstration that the RF field strength remains compliant with US and any South Sudan standards 6. The following required design features of the Juba compound shall be maintained: STREAM. Total stream capacity cannot be diminished by the development of the compound. (Stream channel on average is 3m x 1m) If the septic system features a seepage field, the discharge terminus must be at least 30m from the streambed and any shallow well, on or off property. Stream must remain substantially in the same channel GRADING, SEPTIC & DRAINAGE. If construction results in substantially increased slope of any land within 10m of the stream, that slope must be protected with berms, plantings, etc.) Site grading and drainage shall be designed and constructed to prevent accumulation of standing water Aprons must be installed and drainage provided at water supply point(s)—no standing water allowed. No direct gray or brown‐water discharge to stream is allowed. All drainage with the exception of storm runoff and water point drainage must be channeled to the septic system. If septic tank design is a pump‐out tank without leach field, assure impermeable tank construction or min 30m separation between tank and stream and nearest shallow well. Septic vent stack(s) will be screened and the system otherwise sealed. (e.g. access hatch covers must be tight‐fitting.) Septic pump‐out point shall feature a concrete apron and drain with return to the septic tank. Pump‐out point must be a minimum of 10m from the public water supply point. FUEL & GENERATORS. Concrete aprons with berms or gutters/sumps shall be placed under generators, fuel storage, and fuel pump‐in point (if different) sufficient in each case to capture at least a 20 liter spill. BOREHOLE & WATER SUPPLY. The borehole must feature a sanitary seal and concrete well apron. The public supply point must feature a fence with gate or other barrier that reliably excludes livestock. RF SAFETY. Access to the antenna will be physically restricted by fence with lockable gate Category E: Potentially, Complete Installation of the Eye Radio Repeater Network Description/Entailed activities. Installation of the repeater network is scheduled for completion by EDC prior to the 25 September 2012 end date of the Eye Radio project, but this work is currently behind, and may need to be completed by Internew/SICRNSS. Installation work includes physically mounting the transmitters on existing cell towers, and installation and hook‐up of all associated cabling and control equipment. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Installation simply adds components to existing infrastructure (cell towers and cell tower base compounds) and 19 does not involve breaking new ground or erecting new structures. There are thus no potential adverse environmental impacts associated with installation. There are, however, occupational safety risks that arise from working at height and around live equipment. These can be controlled by assuring that installation personnel are qualified for work on cell towers and have appropriate safety gear. Recommended Determination. Pursuant to the analysis above and with reference to the annexed ERF/Report1, “Completion of Installation of the Eye Radio Repeater Network” is recommended for a Negative Determination, subject to the condition that installation work is undertaken by workers with appropriate qualifications and experience for work on cell towers, and with appropriate safety equipment, including fall‐arrest harnesses. Category F: Webcasting & Website Development/Maintenance Entailed activities: Eye Radio currently broadcasts worldwide via www.sudanradio.org Current website content is limited; Internews will further develop the website, increasing availability of website content in audio and script form for audiences in South Sudan and abroad as well as for rebroadcast by media partners. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Webcasting and web development belong to categories of activities eligible for categorical exclusion under 22 CFR 216.2(c)(2)(v)—document and information transfers. There is no contraindication to categorical exclusion as webcasting and website development/maintenance have no foreseeable significant adverse impacts. Recommended Determination. Pursuant to the analysis above, Webcasting & website development/maintenance are recommended for a categorical exclusion per 216.2(c)(2)(v). Category G: Newsgathering and Program Production Entailed activities: Beyond its FM station compound in Juba, Eye Radio/Media maintains small bureaus in other cities. The purpose of these offices and bureaus is to support newsgathering and provide facilities for program production. Newsgathering for community radio stations are centered in the areas they serve, and program production occurs at the stations themselves. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Newsgathering and Program Production conform to classes of activities eligible for categorical exclusion under 22 CFR 216.2(c)(2)(v) (Document and information transfers) and (i) (Education, technical assistance or training programs). There is no contra‐indication to this categorical exclusion, as: 20 News gathering and program production themselves have no foreseeable significant adverse effects on the environment, whether direct or indirect. While large scale office operations may have significant adverse impacts (e.g. water consumption, wastewater discharge), SICRNSS’ office/bureau operations are small‐scale and exist purely in support of the news‐gathering and program production activities. Any USAID activity operating under these categorical exclusions requires modest support to physical infrastructure (e.g. classrooms, office space); the existence of this infrastructure does not invalidate the categorical exclusion. Recommended Determination. Pursuant to the analysis above, “Newsgathering and Program Production” is recommended for Categorical Exclusion. Category H: Journalist and Media Outlet Training Entailed activities/description. SICRNESS/Eye Radio‐Media provides journalistic training to its own staff (e.g. new hires, special training for many staff in election coverage) and interns/volunteers, as well as journalistic training workshops and internships open to staff of other media organizations and government journalists. At its Juba compound, the project will continue to develop the certificate course in broadcast journalism initiated under the Sudan Radio Service project in collaboration with the University of Juba. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Training in and of itself has no foreseeable significant adverse environmental impacts, nor is the training targeted at building capacity for or stimulating activities with potential significant adverse effects on the environment. Recommended Determination. Journalist and Media Outlet Training conforms to a class of activities eligible for categorical exclusion under 22 CFR 216.2(c)(2)( i) (Education, technical assistance and training). As noted above, no contraindication to this categorical exclusion exists. Accordingly, a categorical exclusion is recommended. Category I: Audience Research and Feedback Description/Entailed Activities. The project will convene focus groups to solicit focused input from representative audience groups; conduct quantitative national audience surveys using a contracted firm or firms to undertake sample design, recruit, manage and train enumerators and oversee data entry and analysis; and conduct other forms of audience research. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Audience research/feedback, including focus groups, have no foreseeable direct or indirect adverse environmental impacts, and conform to classes of activities eligible for categorical exclusion under 22 CFR 216.2(c)(2)(iii) (Analyses, studies, academic or research workshops and meetings). 21 Recommended Determination. Pursuant to the analysis above, “Newsgathering and Program Production” is recommended for Categorical Exclusion per 22 CFR 216.2(c)(2)(iii). Category J: Governance, Management and Operations Capacity Building and Strategic/Operational Assessment and Planning for Community Radio Stations and Eye Radio/Eye Media Description/Entailed Activities. Activities in this category are intended to strengthen and better integrate the management and governance of the Community Radio Network (CRN) and Eye Media/Radio, transition to the organizations to greater independence, and develop more robust and sustainable revenue bases. They are also intended to assure that relevant staff in these organizations have the technical skills necessary to operate and maintain the physical infrastructure and broadcast equipment. Activities in this category will include, but are not limited to: Rapid Assessment of Eye Media and Eye Radio 98.6 FM in the areas of financial management, business model and marketing planning, human resources, technical and institutional capacity, radio programming and content, technical systems, and governance structures Development of independent advisory boards for the community radio stations and a national community network board (which may or may not be merged with the Eye Media Board) Strengthening of the Eye Media Advisory Board Development of business, staffing, marketing and sales plans and related training on these plans and in necessary underlying skills/capacities (e.g. accounting) for appropriate staff Sub grants and other mechanisms that will, in a monitored and stepwise fashion, give community stations and Eye Media/Radio increased responsibility for financial and operations management. On‐the‐job technical training to Eye Radio staff to enable them to operate and maintain the Juba Station and the repeater network; analogous training for CRN staff. Potential Adverse Impacts & Considerations Regarding a Recommended Determination. Activities in this category conform to classes of activities eligible for categorical exclusion under 22 CFR 216. However, such a categorical exclusion may be awarded only if no adverse impacts of these activities are foreseeable. Environmentally sound operations of the Community Radio Network and Eye Radio in the future depend on the extent to which the measures for sound environmental management of station/compound operations as set out under Categories A and D, above are implemented by independent management. 22 The training, capacity‐building, and independence planning carried out this activity category have a direct bearing on whether these environmental management measures are implemented by future independent management. Recommended Determination. Pursuant to the analysis above, “Governance, Management and Operations Capacity Building and Strategic/Operational Assessment and Planning for Community Radio Stations and Eye Radio/Eye Media” is recommended for a Negative Determination subject to the condition that technical capacity‐building, hand‐off plans and capacity‐building for independent operation incorporate, wherever relevant, the measures for sound environmental management of station/compound operations as set out under Categories A and D, above. 4. IMPLEMENTATION AND MONITORING In addition to the specific conditions enumerated above, the negative determinations recommended in this IEE are contingent on full implementation of the following general monitoring and implementation requirements: 1. Communication of environmental compliance to implementing partner. The AOR shall provide this IEE to Internews immediately upon award of the cost extension, making particular note of the requirements of this section. 2. Development of EMMP. Within 3 months of award of the cost extension, Internews shall develop and submit for AOR & MEO review and approval an Environmental Mitigation and Monitoring Plan (EMMP) documenting how the project will implement and verify the implementation of all conditions established by this IEE. (See Annex 1 for a template of a standardized EMMP ) 3. Integration and implementation of EMMP. Internews shall integrate the EMMP into SICRNSS project work plan and budgets, implement the EMMP, and report on its implementation as an element of regular project performance reporting. Sub‐contractors and sub‐grantees shall integrate implementation of IEE conditions, where applicable, into their own project work plans and budgets and report on their implementation as an element of sub‐contract or grant performance reporting 4. Integration of compliance responsibilities in prime and subcontracts and subgrant agreements. a. The USAID/Sudan sector team shall assure that the cost extension award and any future contracts or agreements shall reference and require compliance with the conditions set out in this IEE, as required by ADS 204.3.4.a.6 and ADS 303.3.6.3.e. b. Internews shall assure that future sub‐contracts and grants agreements, and/or significant modifications to existing agreements, reference and require compliance with relevant elements of these conditions. 4. Assurance of sub‐grantee and sub‐contractor capacity and compliance. Internews shall assure that sub‐grantees and subcontractors have the capability to implement the relevant requirements of this IEE. Internews shall, as and if appropriate, provide training to sub grantees and 23 subcontractors in their environmental compliance responsibilities and in environmentally sound design and management (ESDM) of their activities. 5. USAID Sector Team monitoring responsibility. As required by ADS 204.3.4, the USAID sector team will actively monitor and evaluate whether the conditions of this IEE are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in this IEE. If new or unforeseen consequences arise during implementation, the team will suspend the activity and initiate appropriate, further review in accordance with 22 CFR 216. USAID Monitoring shall include regular site visits. 6. New or modified activities. As part of its Work Plan, and all Annual Work Plans thereafter, Internews, in collaboration with the USAID AOR, shall review all on‐going and planned activities to determine if they are within the scope of this IEE. If SICRNSS adds new activities or makes substantial modifications to existing activities, an amendment to this IEE addressing these activities shall be prepared for USAID review and approval. No such new activities shall be undertaken prior to formal approval of this amendment. Any ongoing activities found to be outside the scope of this IEE shall be halted until an amendment to the documentation is submitted and written approval is received from USAID. 7. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes Internews, sub grantee and subcontractor responsibility for compliance with all applicable host country laws and regulations. Internews, sub grantees and subcontractor must comply with host country environmental requirements unless otherwise directed in writing by USAID. However, in case of conflict between host country and USAID regulations, such case should be brought to USAID’s attention and the latter shall govern. 24 Attachment 1 Project Name Environmental Mitigation and Monitoring Plan (EMMP) The EMP must be completed by each organization carrying out activities under the USAID/South Sudan SICRNESS Program. It will include the organization’s own report plus the EMPs of any sub‐awardees, to capture the entire range of activities funded by the USAID/South Sudan SICRNESS Program under the award. The USAID/South Sudan SICRNESS Program, implementing partners are responsible for ensuring that each sub‐awardee completes and submits the EMP to the prime in a timely fashion. The EMPs are reviewed and approved by the COR/AOR and the Mission Environmental Officer. The EMMP consists of 3 parts: 1. The Environmental Verification Form 2. The Mitigation Plan for specific environmental threats carried out by the implementer 3. The Reporting Form The EMMP Environmental Verification Form This form indicates the categories of activities carried out by implementing partners (or their sub‐ awardees) and serves to ‘trigger’ USAID expectations of mitigation measures. The EMMP Mitigation Plan Implementing partners will use the Mitigation Plan to describe the specific actions they will undertake under each category of activity when screening reveals potential environmental threats as outlined in Section 3 of this IEE. In these cases, mitigation will be undertaken. The Mitigation Plan also identifies the person responsible for monitoring compliance with mitigation and the indicator, method and frequency of monitoring. 25 The EMMP Reporting Form This form reports on the results of applying the mitigation measures described in the Mitigation Plan and identifies outstanding issues with respect to required conditions. In some cases, digital photos will be the best way to document mitigation and should be included in the report. USAID/South Sudan ‐‐‐‐Project Name‐‐‐‐ EMMP Part 1 of 3: Environmental Verification Form Name ___________________________________ Date of Screening:____________________________ ____ Funding Period for this award: FY____ Name of Prime Implementing Organization:__________________________ ____ FY____- Current FY Resource Levels: FY_______________ Name of Sub-awardee Organization (if this EMP is for a sub): _____________________________________ ___ This report prepared by: Name:_______________ Date: ____________ Geographic location of USAID-funded activities (Province, District):_________________________ Date of Previous EMP for this organization: _________________ (if any) 26 Indicate which activities your organization is implementing under this funding: Key Elements of Program/Activities Implemented 1 education, technical assistance or training programs analyses, studies, academic or research workshops and meetings; document and information transfers; Studies, projects or programs intended to develop the capability of recipient countries to engage in development planning, except to the extent designed to result in activities directly affecting the environment (such as construction of facilities, etc.); Yes No 2 Development and dissemination of improved agricultural production technologies for selected crops and livestock 3 Increased agricultural production 4 Seeds, Germplasm, Exotic Species 5 Dissemination of biotechnology products 6 Small‐scale construction or rehabilitation of buildings and water & sanitation infrastructure 7 Sub‐Grants 27 USAID/South Sudan ‐‐‐‐Project Name‐‐‐‐‐ EMP Part 2 of 3: Environmental Mitigation and Monitoring Plan . Category of Activity Describe specific environmental threats of your organization’s activities (based on analysis in Section 3 of the IEE) Description of Mitigation Measures for these activities Who is responsible for monitoring Monitoring Indicator Monitoring Method Frequency of Monitoring USAID/South Sudan, ‐‐‐‐Project Name‐‐‐‐ EMP part 3 of 3: Reporting form List each Mitigation Measure from column 3 in the EMP Mitigation Plan (EMP Part 2 of 3) Status of Mitigative Measures List any outstanding issues relating to required conditions Remarks 29 Certification I certify the completeness and the accuracy of the mitigation and monitoring plan described above for which I am responsible and its compliance with the IEE: Signature Date Print Name __________________________ Organization BELOW THIS LINE FOR USAID USE ONLY USAID/South Sudan, ________ Program, Clearance of EMP: Cognizant Technical Officer: ___________________ Date: ____________ Mission Environmental Officer: ______________________ Date: ____________ As appropriate: REA, BEO [depending on nature of activity, which potentially may require an EA] Note: if clearance is denied, comments must be provided to applicant Attachment 2: Environmental Review Form for SICRNESS Program subprojects/sub grants Follow, but do not submit, the attached instructions. A. Applicant information Organization Parent grant or project Individual contact and title Address, phone & email (if available) Proposed subproject /subgrant (brief description) Amount of funding requested Period of performance Location(s) of proposed activities B. Activities, screening results, and findings Findings With specified mitigation, significant adverse impacts are very ulikely Significant Adverse impacts are possible (Step 6 of instructions. Complete for all moderate/unknown and high-risk activities ONLY) significant adverse impacts are very unlikely Moderate or unknown risk* Very Low Risk Proposed activities (Provide DESCRIPTIVE listing. Continue on additional page if necessary) High-Risk* Screening result (Step 3 of instructions) 1. 2. 3. 4. 5. 7. *These screening results require completion of an Environmental Review Report 2 C. Certification: I, the undersigned, certify that: 1. The information on this form and accompanying environmental review report (if any) is correct and complete. 2. Implementation of these activities will not go forward until specific approval is received from the C/AOTR. 3. All mitigation and monitoring measures specified in the Environmental Review Report will be implemented in their entirety, and that staff charged with this implementation will have the authority, capacity and knowledge for successful implementation. (Signature) (Print name) (Date) (Title) Note: if screening results for any activity is “high risk” or “moderate or unknown risk,” this form is not complete unless accompanied by an environmental review report. BELOW THIS LINE FOR USAID USE ONLY Notes: 1. For clearance to be granted, the activity MUST be within the scope of the activities for which use of the ERF is authorized in the governing IEE. Review IEE before signature. If activities are outside this scope, deny clearance and provide explanation in comments section. The Partner, C/AOTR, MEO and REA must then confer regarding next steps: activity re-design, an IEE or EA. 2. Clearing an ERF containing one or more findings that significant adverse impacts are possible indicates agreement with the analysis and findings. It does NOT authorize activities for which “significant adverse impacts are possible” to go forward. It DOES authorize other activities to go forward. The Partner, C/AOTR, MEO and REA must then confer regarding next steps: activity redesign, an IEE or EA. Clearance record C/AOTR Clearance given (print name) (signature) (date) (print name) (signature) (date) (print name) (signature) (date) (print name) (signature) (date) Clearance denied USAID/South Sudan MEO Clearance given Clearance denied Regional Env. Advisor (REA) Clearance given Clearance denied Bureau Env. Officer (BEO)* Clearance given Clearance denied C/AOTR, MEO and REA clearance is required. BEO clearance is required for all “high risk” screening results and for findings of “significant adverse impacts possible. The BEO may review” Note: if clearance is denied, comments must be provided to applicant (use space below & attach sheets if necessary) 3 17 Jan 2005 Supplement to the Environmental Review Form for Natural Resources Activities Additional Screening Criteria for Natural Resource Activities under SICRNESS Progam Purpose This supplement provides additional questions to ascertain whether these proposed activities should be categorized as “very low risk:” If the answers to ALL the questions that follow are “NO,” then the proposed natural resource-based activity is considered “very low risk.” If the answer to ANY question is “YES,” the activity CANNOT be considered “very low risk.” Screening criteria Will the activities… YES Natural Resources Accelerate erosion by water or wind? Reduce soil fertility and/or permeability? Alter existing stream flow, reduce seasonal availability of water resources? Potentially contaminate surface water and groundwater supplies? Involve the extraction of renewable natural resources? Lead to unsustainable use of renewable natural resources such as forest products? Involve the extraction of non-renewable natural resources? Restrict customary access to natural resources? Reduce local air quality through generating dust, burning of wastes or using fossil fuels and other materials in improperly ventilated areas? Affect dry-season grazing areas and/or lead to restricted access to a common resource? Lead to unsustainable or unnecessarily high water extraction and/or wasteful use? Ecosystems and Biodiversity Drain wetlands, or be sited on floodplains? Harvest wetland plant materials or utilize sediments of bodies of water? Lead to the clearing of forestlands for agriculture, the over-harvesting of valuable forest species? Promote in-forest bee keeping? Lead to increased hunting, or the collection of animals or plant materials? Increase the risks to endangered or threatened species? Introduce new exotic species of plants or animals to the area? Lead to road construction or rehabilitation, or otherwise facilitate access to fragile areas (natural woodlands, wetlands, erosion-prone areas)? 4 NO Will the activities… YES Cause disruption of wildlife migratory routes? Agricultural and Forestry Production Have an impact on existing or traditional agricultural production systems by reducing seed availability or reallocating land for other purposes? Lead to forest plantation harvesting without replanting, the burning of pastureland, or a reduction in fallow periods? Affect existing food storage capacities by reducing food inventories or encouraging the incidence of pests? Affect domestic livestock by reducing grazing areas, or creating conditions where livestock disease problems could be exacerbated? Involve the use of insecticides, herbicides and/or other pesticides? Community and Social Issues Have a negative impact on potable water supplies? Encourage domestic animal migration through natural areas? Change the existing land tenure system? Have a negative impact on culturally important sites in the community? Increase in-migration to the area? Create conditions that lead to a reduction in community health standards? Lead to the generation of non-biodegradable waste? Involve the relocation of the local community? Potentially cause or aggravate land-use conflicts? 5 NO Environmental Review Report A. Project Title B. Environmental Situation Succinctly describe location, siting, surroundings (include a map, even a sketch map). Describe the affected environment, including essential baseline information available for all affected locations and sites, both primary and ancillary activities. This description should be as specific and "local" as possible to the project under review ‐‐ not generalities about environmental conditions across the vast landscape of Sudan. Photographs of project site very helpful. C. Standards Select the relevant SPHERE or EGSSAA standards against which this project will be judged. Be specific. The SPHERE standards are available at www.sphereproject.org and the EGSSAA standards are available at www.encapafrica.org/SmallScaleGuidelines.htm. D. Activity Description Provide both quantitative and qualitative information about actions needed during construction, how intervention will operate and any ancillary development activities that are required to build or operate the primary activity (e.g., road to a facility, need to quarry or excavate borrow material, need to lay utility pipes to connect with energy, water source or disposal point or any other activity needed to accomplish the primary one but in a different location). If various alternatives have been considered and rejected because the proposed activity is considered more environmentally sound, explain these. E. Evaluation of Activities, Environmental Impact Potential, and Proposed Mitigation Actions Using the table provided, identify all potential impacts for each activity. These must include all phases (planning & design, construction and handover, operation, and decommissioning). Explain direct, indirect, induced and cumulative effects on various components of the environment (e.g., air, water, geology, soils, vegetation, wildlife, aquatic resources, historic, archaeological or other cultural resources, people and their communities, land use, traffic, waste disposal, water supply, energy, etc.) Indicate also positive impacts and how the natural resources base will be sustainably improved. Identify actionable mitigation actions to avoid, reduce or compensate for negative impacts, such as restoration of borrow or quarry areas, replanting of vegetation, compensation for any relocation of homes and residents. 6 Mitigation actions should be assigned to the responsible party, for example the construction contractor, the implementing partner, the beneficiaries. Project Phase and Activity Potential Environmental Impact Mitigation Action Planning and Design Construction and Handover Operation Decommissioning G. Monitoring. Briefly describe how regular project monitoring will be extended to include monitoring of the mitigation actions described in this environmental review report. H. Findings. Summarize findings into one of four categories, and check appropriate box on Environmental Review Form: Very low risk activities Activities determined to have no significant adverse impacts Activities determined to have no significant adverse impacts, given specified mitigation and monitoring Activities determined to have significant adverse impacts 7 Attachment 3 USAID/South Sudan SICRNESS Project Water Quality Assurance Plan Potential environmental impacts: The human health benefits of water and sanitation activities are enormous, and generally far outweigh any potential negative impacts of such activities. Still, the potential for adverse environmental impacts from water and sanitation activities exists, and it is the responsibility of program designers and implementers to avoid such impacts to the extent possible. Potential adverse impacts from water and sanitation activities can be summarized as follows: Potential adverse impacts from water supply activities: 1. Depletion of fresh water resources (surface and groundwater) 2. Chemical degradation of the quality of potable water sources (surface and groundwater) 3. Creation of stagnant (standing) water 4. Degradation of terrestrial, aquatic, and coastal habitats 5. Increased human health risks (e.g. from arsenic content in groundwater) Potential adverse impacts from sanitation activities: 1. Increased human health risks from contamination of surface water, groundwater, soil, and food by excreta, chemicals and pathogens 2. Ecological harm from degradation of stream, lake, estuarine and marine water quality and degradation of land habitats Water and Sanitation conditions: To mitigate potential effects of inadequate drinking water quality, the Implementing partners shall: 8 a) Prepare a Water Quality Assurance Plan that describes monitoring criteria, monitoring frequency, and measures for ensuring the safe provision of water to recipients. The Water Quality Assurance Plan shall describe how the partner intends to ensure safe drinking water in the project. The Water Quality Assurance Plan shall include: A) Water Quality Assurance Plan (1) Water quality standards and criteria that partner intends to meet (this should include WHO and host country water quality standards and monitoring requirements; this section can be updated for each country when the partner begins operations in a country. For information on WHO standards, see http://www.who.int/water_sanitation_health/dwq/gdwq0506.pdf for guidance on meeting WHO recommendations.); (2) Measures to ensure partners continue to meet the above water quality standards and criteria; (3) Frequency of testing and monitoring, by contaminant; (4) Responsible parties for testing and monitoring; (5) Location of laboratory to be used; (6) Measures for host‐country and USAID reporting; (7) Measures to correct any water quality issue that is found out of compliance; and (8) Notification measures (to USAID, host‐country, and school/community) that will be taken if the water quality at a borehole is found to be out of compliance. B) Equipment Inspection and Maintenance Plan (1) Equipment maintenance requirements and schedule (2) Responsible parties for maintenance (3) Maintenance reporting requirements While the Partner may propose alternative means of ensuring that water quality does not present a risk to human health, the analyses and standards that the Partner proposes should be based on sound risk assessment and should be science‐based. 9 The table below provides a summary of standard recommendations that should be followed to minimize potential impacts of inadequate water quality. Design Use a “sanitary seal” on top of the well casing to prevent any Disinfection Maintenance Water Quality Assurance Public notification contaminants from going directly down the borehole through the casing. The area around the borehole should be sloped away from the casing to prevent contamination from surface run‐off. Locate the fill line into the storage tank above the overflow with an air gap of at least 2 pipe diameters or 6 inches (152.4 mm). Vent the storage tank with a u‐shaped, down‐facing opening that is screened to keep air‐borne contaminants, bugs and birds out of the tank. Direct overflow away from the borehole. Also, ensure an air gap above the overflow outlet. Protect the communal tap from back‐siphoning with a check valve or another anti‐siphon device. Use an erosion chlorinator to treat the water automatically as it enters the tank. This is proposed as the most effective and cost‐ effective approach to water quality assurance. Inspect tanks daily to ensure that the hatch is closed, the vent and screens are intact, etc. Clean tank at least annually and more frequently if there is noticeable sediment in the tank. If the system is not chlorinated, we recommend monthly cleanings. Select a good quality groundwater source. Install the system correctly, clean and disinfect system, and test water quality again after installation is complete. Install disinfection equipment. Maintain system properly. Monitor for a disinfection residual. Advise the public, in a thoughtful and careful manner, about the possible risks associated with long‐term consumption. 10 Attachment4 EnvironmentalReviewForm&Report forSRS‐FMConstructionandOperation(10Feb2010) 11
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