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USAID PAKISTAN FROM THE AMERICAN PEOPLE

Initial Environmental Examination (IEE), Amendment No. 7 USAID/Pakistan Federally Administered Tribal Areas (FATA) Project

Project/Activity Data:

Activity/Project Title: J Solicitation #:N.A. Federally Administered Tribal Areas (FATA) Project

Conb·act/Award Number (if known):

Geographic Location: Pakistan; 391

Originating Bureau/Office: USAID Pakistan, Office of Stabilization and Governance DCN and date of Original document: IEE ANE 07-40 Pakistan IEESO 10, FATA FDP, approved on June 1, 2007

Supplemental IEE: DCN and ECD link(s) of Amendment(s): Amendment No. 1, ASIA 09-102

DY es ~No Pakistan IEE-ETD, FDP, approved on Aug 11, 2009; Amendment No. 2 ,

Amendment: Asia 10-56 FDP-NWFP 2, approved on February 10, 2010; Amendment

~Yes 0No No. 3, OAPA-11-SEP-PAK-0040, approved on August 17, 2011;

Programmatic IEE: Amendment No. 4, OAPA-13-DEC-PAK-0004, approved on December

0Yes ~No 14, 2012; Amendment No. 5, OAPA-13-FEB-PAK-PAK-0008, approved on February 13, 2013; and Amendment No. 6, OAPA-14-APR-PAK-0019, approved on April 7, 2014. Amendment No. : 7

Funding Amount: $2,086,940,000 Life of Project Amount: $2,086,940,000

Implementation Start/End: June 30, 2007 to December 31, 2023

Prepared By: Carlos Lamadrid Date Prepared: January 27, 2017

Expiration Date (if any): December 31, 2023 Reporting due dates (if any): N .A.

Environmental Media and/or Human Health Potentially Impacted (check all that apply): None n Air ~ Water ~ Land I><! Biodiversity D Human Health n Other n Recommended Threshold Determination: ~ Negative Determination ~ with conditions D Deferral ~ Categorical Exclusion D Exemption D Positive Determination D USG Domestic NEPA action

Climate Change: ~GCC/ Adaption 0GCC/Mitigation ~ Climate Change Vulnerability Analysis (included)

Adaptation/Mitigation Measures: Included for four new activities

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Initial Environmental Examination (IEE), Amendment No. 7 USAID/Pakistan Federally Administered Tribal

Areas (FAT A) Project

SUMMARY OF FINDINGS:

1.0 Background and Project/Activity Description: 1.1 Purpose and Scope of IEE

The purpose of this Initial Environmental Examination Amendment Number 7 of the IEE: ANE 07-40 Pakistan IEE SO 10, and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP, Amendment No. 2: Asia 10-56 FDP-NWFP 2, Amendment No. 3: OAPA-11-SEP-PAK-0040, Amendment No. 4: OAPA-13-DEC-PAK-0004, Amendment No. 5: OAPA-13-FEB-PAK-~ 0008, and Amendment No. 6: OAPA-14-APR-PAK-0019 is to duly reflect on:

a) Change in the activity name from" Federally Administered Tribal Areas (FATA) Development Program (FDP)" to "Federally Administered Tribal Areas (FATA) Project;"

b) Add four new activities; c) Increase the funding level from $2,000,940,000 to $2,086,940,000; and d) Extend its Life of Project (LOP) from December 31, 2018 to December 31, 2023.

This IEE Amendment, in accordance with 22 CFR 216, provides a review of the reasonably foreseeable effects on environment, and recommends decisions of Threshold Determinations for the new activities under the FATA Project (or the Project). This Amendment provides a brief statement of the factual basis for a Threshold Decision and recommends Categorical Exclusion and Negative Determination with Conditions for the new Project activities.

The scope and nature of all previously approved activities remain the same. All previously approved threshold determinations, conditions, limitations, and stipulations for revision remain in force.

1.2 Background

Over the last decade, more than 59,000 lives have been lost in terrorism-related violence in Pakistan. Such violence and extremism may be a nation-wide problem in Pakistan, but research shows that the manifestations and causes of violence are local phenomena that are not consistent from place to place, and that youth of age 15-29, who account for 30 percent of Pakistan's population, are the prime targets of radicalization efforts by violent extremists. Accordingly, to reduce violent extremism, increase security and development, experts advocate that violence prevention efforts need to be inclusive of local stakeholders and demand-driven in order to adapt interventions to the local context and promote local ownership. Experts also suggest that effective violence prevention initiatives must be taken into account, and focus eff01ts on Pakistan's youth.

The Project describes the Mission's five-year plan to achieve Intermediate Result ("IR") 3.2 "Increased Resilience in Targeted Communities Vulnerable to Violent Extremism" of the

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Mission's Strategic Framework. The Project has three overarching objectives, which constitute the Project components: 1) Improving Sub-national Governance; 2) Increasing Broad-based Citizen Engagement in Community Decision-making; and 3) Enhancing Tolerance Within and Across Communities.

1.3 Description of New Activities

The IEE is being amended to add three new activities that support IR 3.2: "Increased Resilience in Targeted Communities Vulnerable to Violent Exh·emism." These activities are described below.

1.3.1 FATA Conflict Prevention and Community Resilience (CPCR) Activity The breakdown of confidence and trust between local communities and the Government of Pakistan (GOP) institutions has led to increased vulnerability to violent exh·emism (VE) in FAT A and the Khyber Pakhtunkhwa (KP) province. In an effort to rebuild that confidence and reduce the space for VE groups, a new Public International Organization (PIO) grant will be established to work in FATA to implement the following interventions:

1. Empower communities with information about the FATA reform agenda. The activity will collaborate closely with the USAID FATA Refo1ms Support Activity (see below) to support a FAT A citizenry that is well infom1ed on issues of political reform, including the role and function of new governance and legal authorities, timeline and milestones of the FATA reform process, and information about citizens' rights under the constitution. Public awareness and understanding of reforms will be achieved through community dialogue (town halls), events, and campaigns that leverage mainstream media (radio, television and print) to promote knowledge of the reforms.

2. FATA communities employ non-violent dispute and grievance resolution mechanisms to achieve their priority needs. This civil society focused intervention will represent the "demand" side of community-government relations, and, as such, will coordinate closely with USAID's FATA Reforms Support Activity. Interventions will include the following:

a. Provision of small grants to non-governmental organizations (NGOs) and/or community-based organizations (CBOs) to identify and address community concerns;

b. Facilitate CBO networking at local, regional and national levels; c. Facilitate CBO engagement with local government officials for collaborative

effo1ts in resolving prioritized community grievances; d. Limited direct small-scale infrastructure activities (i.e., health clinic or school

refurbishment, drinking water systems, feeder roads) with a total Life of Project cost of $15 million.

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3. Develop an evidence-based approach to understanding and countering violent extremism. The activity will conduct research on the drivers and pathways of violent religious extremism and use this information to design interventions to strengthen local approaches to prevent and mitigate susceptibility to extremism. Interventions will include the following:

a. Conduct a thorough desk study on factors of generalized societal violence and conflict in FATA;

b. Conduct an empirical data study on the drivers and pathways associated with violent extremism at local levels as possible;

c. Provide small grants to support targeted community interventions to increase community resistance to extremism. For example, to provide youth and other residents with opportunities to develop leadership and technical skills, and engage in community activities- such as theater performances, sporting activities, and community leadership.

1.3.2 FAT A Reforms Support Activity The proposed FATA Reforms Activity will support the FA TA Secretariat and other relevant stakeholders in three areas. First, it will assist the GOP in implementing political and governance reforms proposed by the Prime Minister's Committee (the Committee) to develop recommendations on the future status of FATA. The FATA Secretariat and other government entities in Pakistan do not have the institutional capacity to implement complex reforms. The Committee's recommendations will be of a higher level, and actual implementation will require substantial work, including development of legislation, policies, and procedures. Civil servants working in FATA will require training in implementation of the new laws, regulations, and procedures. The government will also require support to recruit new civil servants, judges, prosecutors, and other essential personnel. As the Committee recommended a merger of FAT A with KP in five years, implementation must be coordinated with the KP government. In short, the FAT A Secretariat and other stakeholders will need extensive support to ensure that the reforms are properly and timely implemented.

Second, one of the components of the FATA Reform Plan is the development of a ten-year socio-economic plan for FAT A. This plan is intended to provide major infrastructure including dams and irrigation projects, mineral development programs, and integrated plans for health, education, vocational training, and industrial zones. The FAT A Reform Plan has also recommended increased transfer of financial resources from the federal government to FAT A. USAID, through the FATA Reforms Activity, will provide technical expertise to the relevant Pakistani entities in developing a plan based on proper needs analysis.

Lastly, the Activity will also assist the relevant GOP institutions in developing a local governance system as provided in the FATA Reforms Plan. The Activity will also assist Pakistani authorities to develop detailed legislation, subordinate legislation and rules and regulation for the proposed local governance system. In addition, the Activity will organize trainings for the newly elected officials and civil servants on the new system. Lastly, the

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Activity will assist the Pakistani government in launching a public awareness campaign, which will help in educating FA TA residents about the new structures.

1.3.3 FAT A Land Reforms Activity Land reform is a specific component of the GOPs reform package for FAT A. While the FAT A Reforms Activity supports the overall reforms agenda from the perspective of legal frameworks (e.g., legislation, policies, and procedures), there are specific technical issues regarding land reform that merit special focus. Keeping in view the issues with land registration management in the rest of Pakistan, and the efforts underway in all provinces to digitize the manual system, FATA Secretariat officials studied the systems in four other provinces. After an in-depth review of these systems and other off-the shelf products, they selected a system developed by the United Nation's Food and Agriculture Organization (FAO). The FATA Land Reforms Activity is a G2G mechanism that will enable the FAT A Secretariat to procure and implement the proposed system, which will be fully-digital, based on satellite imagery, and include a database for recording land ownership. This will ensure the integrity of the whole system and help minimize disputes. Additional technical assistance for capacity building can be coordinated with the FATA Reforms Program.

1.3.4 Humanitarian Coordination and Data Dissemination Activity

The Humanitarian Coordination and Data Dissemination activity is a planned assistance award that will bring together humanitarian actors to ensure a coherent response to emergencies in Pakistan, and to establish a framework within which each actor can contribute to the overall response effort. This is planned as a grant of $2,000,000 to one or more Public International Organizations. The grantee(s) will not be directly involved in service delivery but will coordinate response to humanitarian needs in KP and FAT A. The coordination efforts will ensure that government agencies and humanitarian actors meet the immediate needs of displaced and returning families (e.g., protection, food, water/sanitation, shelter, health, education, and community rehabilitation), while also building local capacity of civilian authorities as hwnanitarian assistance gives way to longer-term development efforts over the next few years.

1.3.5 Budget

The following table (Table 1) summarizes the budget for the proposed new activities. The cost of the new activities, $86 million, increases the Life of Project ceiling for the IEE to a new total of $2,086,940,000.

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Table-1 . New activities, their implementing mechanisms, LOP, and budget.

Activity Proposed Mechanism TEC 1 FAT A Conflict Prevention and

Community Resilience Activity PIO Grant $25,000,000 2 FAT A Land Reforms Activity G2G $34,000,000 3 FA TA Reforms Activity G2G $25,000,000 4. Humanitarian Coordination and Data PIO Grant $2,000,000

Dissemination Activitv Total $86,000,000

2.0 ENVIRONMENTAL LESSONS LEARNED FROM EXISTING ACTIVITIES:

The FATA KP Office is managing several activities with varying implementing partners under different implementing mechanisms. The implementing partners ranged from federal and provincial governments, NGOs, U.S. contractors, and PIOs. The implementing mechanisms varied from G2G, direct contracts, and grants. As a result of this mix of implementing mechanisms, and implementing partners, the DO team has gleaned a broad range of environmental compliance lessons. One of the main observations of the DO team is the difference in the competencies of the implementing partners to understand the requirements of environmental compliance. The following are a number of lessons learned from various activities under the project, shared by implanting partners and A/CO Rs.

Since 2007, the Office of Transition Initiatives ( OTI) has been working in FAT A, and KP province to build and strengthen relationships between the government and communities, and extend the writ of the government into tribal areas. A significant component of OTI's program is rehabilitating community infrastructure damaged by militancy or years of neglect. While implementing activities of this nature, OTI has learned a number of lessons surrounding environmental impacts, and environmental compliance. Rehabilitation of roads sometimes requires felling trees along the planned path. This is only done after obtaining the requisite permission from the provincial government. To mitigate erosion and other environmental impacts, OTI's implementing paitner now plants 20 saplings for every tree that is cut down. Working through the provincial Department of Forestry and other local officials, OTI provides its implementing partner with guidance on the types of trees that are appropriate in a given area.

OTI bas also implemented several grants providing medical equipment, including x-ray machines, to hospitals and clinics. OTI's implementing partner has drafted guidance specifically on x-ray equipment to ensure the safety of health workers and patients, and to mitigate the effects on the environment.

The experience in the FAT A-KP office has shown that the preparation of site-specific Environmental Documentation Form/Environmental Mitigation and Monitoring Plans (EDF/EMMPs), prior to activity implementation, is critical in addressing the requirements of

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approved IEE threshold decisions. These EDF/EMMPs become part of the Activity Agreement with the GOP.

In Government to Government (G2G) mechanisms, the Project Management Units (PMU) that implement activities tend to have weaker institutional capacity for environmental compliance that is reflected in the quality of documentation, monitoring, and compliance. Technical assistance in preparing EDF/EMMPs, and for attaining compliance with the terms and conditions of the EMMP had to be provided through a third party contractor due to the lower institutional capacity of personnel within the PMU. This also includes training for PMU staff for the preparation of environmental reporting documentation, and for environmental compliance monitoring, and mitigation activities. This is supp01ted by oversight monitoring through site visits and review of reports by the COR and MEO.

During implementing of the FAQ Internally Displaced People (IDP) activities, there was a risk of introducing animal diseases, and vectors responsible for zoonotic diseases when livestock, along with IDPs were repatriated to hosting areas. The animal vaccination and de-worming protocols introduced to minimize the risk of animal and zoonotic diseases, however, had the potential to generate a considerable amount of infectious medical waste. Incinerators designed for medical waste were introduced to destroy the waste and reduce the risk of disease transmission, and environmental impact.

For the implementation of construction activities, a strict protocol of preparation of EDF /EMMPs is observed as these activities usually have an environmental threshold determination of Negative Determination with Conditions. Field observations indicate that there is a coordination gap in implementation and monitoring ofEDF/EMMP compliance requirements. The activity manager ensures that there is better coordination between the key players, construction contractor, Architecture and Engineering (A&E) contractor, and implementing partner for oversight monitoring of compliance.

Activity managers, working with the Mission Environmental Officer, have increased environmental compliance awareness training to both FAT A KP Office, and implementing partner staff to confer a better understanding of the required mitigations and associated monitoring, inspection, and reporting requirements.

3.0 CLIMATE CHANGE INTEGRATION

3.1 Country Climate Change Information (Baseline lnformation)1

Pakistan has 11 climate zones due to its range of topographies and ecosystems, and each of these experiences different weather and climate patterns. Generally, the coastal areas of the country are d1y and hot and the northern uplands get progressively cooler. The winter months

1 Pakistan Climate Vulnerability Profile available at: https://www.climatelinks.org/resources/pakistan-climate­vulnerability-profile

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(December-February) are cool and dry. The country experiences monsoons from June through September, with a lesser degree of monsoon activity in October and November.

Temperature: Widespread changes in extreme temperatures have been observed in Pakistan over the last 50 years. Cold or frosty days and nights have become less frequent whereas hot days and nights, and heat waves have become more frequent. According to Pakistan' s Task Force on Climate Change, temperature is projected to increase from the 1960-1999 baseline by l.3°C by 2020, 2.5°C by 2050, and 4.4°C by 2080 under one scenario. Under another scenario, temperatures in Pakistan are projected to rise by l.45°C, 2.75°C and 3.87°C in 2020, 2050, and 2080, respectively.

Precipitation: Average rainfall in the arid and coastal plains of Pakistan has decreased by between 10 and 15 percent since 1960, while increasing during the same time period over

· northern Pakistan. Heavy rainfall events have increased, with the nine heaviest rains recorded in 24 hours all being-registered in 2010.

Sea Level Rise: The low-lying plains along the coast of Pakistan are exposed to the impacts of sea level rise, with conservative scenarios projecting an increase of 40 cm by 2100.

Extreme Events: Pakistan has experienced about 18 extreme weather events since 1990, including the historic 2010 floods, as well as droughts, cyclones, and landslides. Due to the heavy monsoon rains during the summer months, Pakistan often experiences severe flooding in the Indus River basin where much of the population lives on low-lying lands. Rain or otherwise­triggered landslides are common in the northern regions of Pakistan, particularly those connected to Azad Jammu Kashmir province. Lowland plains, especially those surrounding the urban areas of Karachi and Hyderabad, are vulnerable to the impacts of cyclones and storm surge. Fina1ly, sparse and erratic rainfall patterns can alter water tables, leading to drought conditions in the southern and central regions of Pakistan.

3.2 USAID Climate Risk Management Require,ments

In the revised ADS 201, dated January 23, 2017, Climate Risk Management is a required analysis for new projects (ADS 201.3.3.13), and activities (201.3.4.5). The Mandatory Reference for ADS Chapter 201, Climate Risk Management for USAID Projects and Activities, dated October 12, 2016, out1ines the process, and provides tools for so doing.

3.3 Project Activities And Recommended Climate Risk Management Actions:

The Project design team used "USAID's Climate Risk Screening Tool" to assess the potential climate risks for the project. The tool is essentially a matrix that systematically identifies the relevant sectors, regions, and timeframes for analysis, and assesses the potential climate change impacts, adaptive capacity and potential options to address those impacts.

Project activities will take place in FATA and KP. The assessment considered the potential impacts of climate (temperature, drought, precipitation and flooding, sea level rise and storm

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surge, and winds and other storms), across the geographical scope, over a ten-year time frame on the three proposed project activities, and small-scale infrastructure, a sub-component of two of the activities. The timeframe over which the activities were expected to confer benefits was determined to be zero to ten years with activities largely involving provision of technical assistance and training, and small-scale infrastructure activities. The infrastructure activities are not expected to exceed $500,000 per grant for a total life of project cost of $15 million. These investments can probably be amortized over five years but may have an effective life of up to ten years.

Specific questions related to climate risk for the governance, reforms, peace, security and stabilization, per Agency Climate Change Risk Screening Tool - Facilitator's Note, updated June 2016, were raised with regard to the project activities/components. The questions on conflict mitigation, peace and reconciliation, and local government and decentralization were particularly pertinent.

The analysis revealed that climate impacts such as extreme wet weather, storm surges, floods or droughts, would not significantly affect Project activities involving training and capacity building and policy formulation. However, climatic stresses and extremes could increase tensions within local communities such that community resilience in te1ms of its ability to: (1) withstand, and mitigate the stress of a potential shock; and (2) recover in a way that restores the community to a state of self-sufficiency and/or social functioning is reduced. These stresses could result in a sh01tage of resources (jobs, food, and shelter) creating stress that exacerbates tensions between various tribes and ethnic groups, thereby reducing the tolerance within and between communities. These climate stresses could also compromise the ability of local government to provide adequate community services, and fracture fragile relationships between local authorities and CBOs or between CBOs. The climate risk for these project activities was, however, determined to be low.

With respect to small scale construction and rehabilitation, it is possible that floods may pose a moderate risk to these activities.

The analysis proposed adaptation measures that can be incorporated into Project activity design to address climate risks, even for those activities where the risk was determined to be low. The analysis also showed that the Project activities offer the opportunity to increase the institutional capacity of local government and local community organizations to assess climate risks, plan, and implement adaptation measures. These opp01tunities should be incorporated in the Project activity design.

A summary of the conclusions from the analysis is presented in Table-2 below.

Table 2: Project-Level Climate Risk Management Summary Table

Illustrative Risks Risk How Risks Addressed Opportunities to Interventions Rating /Accepted Strengthen

Climate Resilience

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FAT A Conflict Flood, drought Low Implementing partner to Implementing Prevention and and extreme develop activities to partner to provide Community Resilience weather could increase climate impact training and

heighten tension awareness among conduct campaigns between rival communities to increase climate groups in the change awareness community among youth and

community groups

FAT A Reforms Support None Low The implementing Opportunity to partner shall ensure that develop climate climate change risks and change adaptation adaptation measures are plans, and incorporated in socio- incorporate climate economic plans resilience measures

into new policies

FATA Land Reforms None Low Local government and Opp01tunity to CBO awareness on improve the climate risks increased; institutional training provided to capacity of local increase local government for government ability to climate lisk assess risks and improve assessment and planning for adaptation planning rehabilitation

Small scale Structures may Moderate Implementing partner Opportunity to train infrastructure activities be damaged by may incorporate local artisans on

flooding engineeling solutions in engineering the rehabilitation of solutions to adapt buildings to withstand to climate risks the impacts of flooding

Humanitarian None Low None Opportunity to Coordination and Data discuss with the Dissemination Activity donor community

policies, and adaptation mechanisms to address climate impacts in humanitarian assistance.

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4.0 PROJECT ACTIVITIES AND RECOMMENDED THRESHOLD DECISIONS & MITIGATION ACTIONS (INCLUDING MONITORING AND EVALUATION): This TEE satisfies the conditions of the environmental procedures for project activities and delegation of environmental review responsibility to Missions. Except for the new activities described in Section - 1.3 above, the recommended threshold decision for the existing activities in the original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1 : ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remains unchanged. The Environmental Threshold Determinations for the new activities are recommended below.

4.1 Recommended Threshold Decisions for New Activities: 4.1.1 Categorical Exclusion as per 22 CFR 216.2(c)(2)(i), ), ($66 million, 76.8%) For FATA Reforms Program, FATA Land Reform, and FAT A Conflict Prevention and Community Resilience (CPCR) Project, besides those sub-activities that include infrastructure actions, a categorical exclusion is recommended as the proposed actions do not have an adverse impact on the natural or physical environment. The life of project value for the sum of these activities is 11ot to exceed $66 million (76.8% of LOP a11101111t). Such activities may include the following:

• Program management and other such administrative activities; • Technical assistance, capacity building or training activities [22CFR2 l 6.2( c )(2)(i)] • Public awareness/communication/outreach campaigns, media campaigns,

advocacy/information campaigns and Public information campaigns • Information and experience sharing sessions [22CFR216.2(c)(2)(iii)] • Studies required to support activities of the program [22CFR216.2(c)(2)(iii)] • Analyses, investigations, reviews, assessments, restructuring and business plans,

planning, studies (feasibility, monitoring, impact evaluation, and other social/technical/engineering studies, etc.), surveys, mapping, workshops, seminars, conferences, meetings, enterprise resource planning, consultations, GIS mapping, policy and governance assistance [22CFR216.2( c )(2)(iii)];

• Development of policy and management plan

4.1.2 Negative Determination with Conditions per CFR 216.3(a) (2)(iii), ($20 million, 23.2%)

a) Public International Organizations (PIO) Implementing Partners

A Negative Determination with Conditions per 22 CFR 216.3(a)((2)(iii), is recommended for all other activities that are not listed above for which a Categorical Exclusion is recommended. These activities are further defined in Section 4.3, Summary Threshold Determinations, Table 4, in this IEE. These activities may have potentially minor to moderate adverse impacts on the physical and natural environment. The Threshold Decision Conditions being: • PIO will comply with its own environmental compliance policies and report periodically to

USAID that it is done on individual UDA.ID-funded activities. • Environmentally sound design, monitoring and evaluation (M&E), and best management

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practices should be adopted to minimize erosion, debris and waste production, and proper disposal of debris and waste.

• All activities will be implemented in accordance with the Pakistani environmental regulations, standards, norms and guidelines and national obligations under ratified international environmental agreements (see: http://www.environment.gov.pk ).

• PIO is encouraged to review the Environmentally Sound Design (ESD) Sector Environmental Guidelines available at http://www.usaidgems.org/sectorGuidelines.htm. These guidelines discuss potential environmental impacts, mitigation measures, and monitoring measures for agriculture, livestock production, and small scale construction among other activities.

• PIO is encouraged to comply with President Obama's Executive Order 13677, dated September 23, 2014, "Climate-Resilient International Development" http://www.whitehouse.gov/the-press-office/2014/09/23/executive-order-climate-resilient­international-development requiring agencies engaged in international development to assess and evaluate climate-related risks and vulnerabilities and to adjust strategies, planning, programs, projects, investments, and overseas facilities, as appropriate, based on those assessments and evaluations.

• PIO is encouraged to review and comply with White House Memorandum, dated October 7, 2015, "Incorporating Ecosystem Services in Federal Decision Making" (https://www.whitehouse.gov/sites/default/files/omb/memoranda/2016/m-16-01.pdf).

b) Contractors and Grantees (other than PIOs) Implementing Partners

A Negative Determination with Conditions per 22 CFR 216.3(a)((2)(iii), is recommended for all other activities that are not listed above for which a Categorical Exclusion is recommended. These activities are further defined in Section 4.3 , Summary Threshold Determinations, Table 4, in this IEE. These activities may have potentially minor to moderate adverse impacts on the physical and natural environment. The Threshold Decision Conditions being:

The conditions being environmentally sound design, monitoring and evaluation (M&E), and best management practices to minimize impact on the environment during implementation and design life operation of the facility. The conditions will be refined for each NDC activity in an Environmental Documentation Form (EDF) and Environmental Mitigation and Monitoring Plan (EMMP) identifying potential adverse environmental risks and impacts, mitigation measures, monitoring and inspection schedule, and entities required to ensure compliance with the EMMP must be developed and approved by the Assistance/Contracting Officer Representative (NCOR) and Mission Environmental Officer (MEO)/Deputy MEO prior to commencement of the activity.

All activities that warrant a Negative Determination with Conditions (NDC) must meet the following conditions:

• A site and route-specific EDF and EMMP identifying potential adverse environmental risks and impacts, mitigation measures, monitoring and inspection schedule, and entities required to insure compliance with the EMMP must be developed and approved by the NCOR and MEO/DMEO prior to commencement of a NDC activity. Monitoring and mitigation activities

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must be incorporated into Annual Work Plans and Performance Monitoring Plans. Templates for the EDF and EMMP are attached to this IEE.

• Quarterly Reports will include a section entitled Environmental Compliance that provides details on EMMP indicators, mitigation efficacy, and unintended environmental consequences of activities.

• Environmentally sound design, monitoring and evaluation (M&E), and best management practices to minimize impact on the environment during implementation and operation of the facility by minimizing; erosion, debris, waste production, proper disposal of debris and waste.

The following additional references may help in the preparation of EDFs and their Environmental Mitigation and Monitoring Plans (EMMPs).

a) Environmentally Sound Design (ESD) Sector Environmental Guidelines, Small-Scale Energy, USAID. Discusses potential environmental impacts, mitigation measures, and monitoring measures for renewable energy projects using solar, wind, hydro, bioenergy (biogas and solid biomass), and geothermal resources. http://www.usaidgems.org/sectorGuidelines.htm

b) Guidance Manual for Developing Best Management Practices, USEP A - Best management practices (BMPs) are recognized as an important part of controlling releases of pollutants to receiving waters and reduce costs as well as pollution risks through source reduction and recycling/reuse techniques. http://www.epa.gov/npdes/pubs/owm0274.pdf

c) International Finance Corporation (IFC) Environmental, Health and Safety Guideline -http ://www.ifc.org/wps/wcm/connect/554e8d80488658e4b7 6af7 6a65 l 5bb l 8/Final%2B­%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES

d) European Bank for Reconstruction and Development (ERBD) Sub-Sectoral Environmental and Social Guidelines at: http://www.ebrd.com/about/policies/enviro/sectoral/

e) http://www.epa.gov/oecaagct/ag 10 l/printdairy.html f) http ://www.aphis.usda.gov/wps/portal/aphis/home

The implementer will use environmentally soun'd designs, specifications, and materials; monitor and evaluate environmental impacts during implementation; follow environmental impact mitigation measures detailed in the EMMP; use international best management practices (BMPs) acceptable to USAID; and submit to USAID reporting as detailed in the site specific EMMP. All applicable GoP environmental requirements will be satisfied prior to commencement of work, during implementation, and as required post-commissioning.

In accordance with the Agency policy and USAID/Pakistan Mission Order, 200.8, on Construction Oversight Procedures, dated December 12, 2013, adequate USAID engineering oversight must apply during construction. To minimize impact on environment and human health during construction and operation, to minimize erosion, waste generation, and ensure proper disposal of debris and waste an environmentally sound design, specifications, materials, and best management practices (BMPs) should be developed and applied.

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Implementing partner is required to comply with Executive Order 13677, dated September 23, 2014, "Climate-Resilient International Development" http://www.whitehouse.gov/the-press­office/2014/09/23/executive-order-climate-resilient-intemational-development requiring agencies engaged in international development to assess and evaluate climate-related risks and vulnerabilities and to adjust strategies, planning, programs, projects, investments, and overseas facilities, as appropriate, based on those assessments and evaluations.

Implementing partner is required to implement White House Memorandum dated October 7, 2015, "Incorporating Ecosystem Services in Federal Decision Making" to protect and enhance the economic and social benefits provided to communities by ecosystems and natural habitats. (https://www.whitehouse.gov/sites/default/files/omb/memoranda/2016/m-16-01 .pdf.).

If the completed EDF indicates the potential for significant adverse environmental and social impacts, an Environmental Assessment (EA) process will be launched in consultation with the MEO/DMEO and with the concurrence of the Regional Environmental Advisor-OAPA (REA­OAPA). The process will follow the requirements of 22 CFR 216.6 and will involve: 1) developing a scope of work for Scoping to be reviewed and approved by the BEO/OAPA; 2) Scoping shall involve public consultation with potentially affected people and key relevant stakeholders; 3) Scoping Statement shall be reviewed and approved by the BEO/OAPA, 4) draft EA report shall be subject to: public consultation with potentially affected people and key relevant stakeholders, and review and approval by duly national and/or provincial environmental authority, 5) EA report shall be reviewed and approved by the BEO/OAPA; 6) findings and recommendations of the EA report with an EMMP shall be presented in an amendment to this IEE, duly reviewed and approved in the Mission and by the BEO/OAP A.

All grants, contracts, and cooperative agreements with implementing partners will include a requirement to follow all recommendations ofthis IEE. The implementing partners will be responsible for training their staff, grantees, subcontractors and counterparts on the contract/cooperative agreement's environmental requirements and for ensuring their compliance with these requirements.

This dete1mination is recommended with the explicit commitment and understanding that ALL measures set out in this document constitute binding requirements and will be implemented in full.

4.2 Additional Conditions 4.2.1 Conditions Pertaining to Various Implementing Mechanisms As the Project will be using a number of different implementing mechanisms, the following table provides guidelines on the application of U.S. Government environmental compliance regulations, policies, and procedures for these mechanisms.

IEE Amendment-7 for FATA- PAD Page 14 of25

Table 3: Guidelines on Applicable U.S. Government Environmental Compliance Policies and Regulations for Various Implementing Mechanisms

Implementing Name of Requirements USAID References Mechanism Activity

Institutional FATA Reforms Title 22 of the Code of Federal 22 CFR 216, ADS contracts, Suppo1t Activity, Regulations, Patt 216 codifies USAID's 201, ADS 204 cooperative and FATA Land environmental procedures (cited as 22 agreements, Reforms Activity CFR 216) to ensure that environmental grants factors and values ·are integrated into the

A.I.D. decision making process.

ADS 204 provides policy directives and required procedures on how to apply Title 22 of the Code of Federal Regulations, Part 216 (22 CFR 216) to the USAID assistance process.

ADS 201.3 .. 4.5 .... the Initial Environmental Examination (IEE) may be completed for all activities in a PAD, while in other cases the IEE determination may be deferred to the activity design process. The Mission or Washington OU must determine the appropriate timing for completing the IEE. In all cases, the Mission or Washington OU should consult closely with their MEO or BEO and must complete a threshold determination prior to award and prior to the implementation of the activitv.

Government to FAT A Reforms Activities must be implemented in 22 CFR 216, ADS Government Support Activity, accordance with the requirements of 220, ADS 204

and FATA Land ADS 220, and in compliance with 22 Reforms Activity CFR 216 and ADS 204.

PIO Grants - FATA Conflict Per ADS 308.3.ll(c), Program 216.2( c )(2)(vi)ADS Program Prevention and Contribution-type PIO grants not for the 308, 308.3 .ll(c), Contribution Community purpose of carrying out a specifically 22CFR

Resilience identifiable project or projects, as well as (CPCR) Activity all general contributions, will normally

be categorically excluded from environmental analysis under 22 CFR 216.2( c )(2)(vi).

IEE Amendment-7 for FATA- PAD Page 15 of25

4.3 Summary Threshold Determinations A summary of the Threshold Determinations for the new activities are presented in Table 4 below.

Table-4: Summary Threshold Determinations for New Project Activities

Effects on Determination and

Activities natural or

Regulation 216 action physical environment

required

Categorical Exclusion

• Project I Program Management No adverse Categorical Exclusion

• Technical assistance, capacity building, education, effect on the per22 CFR training programs except to the extent such programs natural or 216.2( c )(2)(i) include activities directly affecting the environment. physical

• Financial, accounting, management and other capacity environment.

building.

• Working with public and private sector to promote extension and outreach services.

• Analysis, studies, workshops and meetings No adverse Categorical Exclusion

• Development of manuals and documents etc . effect on the per 22 CFR

• Studies required to suppmt activities of the program natural or 216.2( c )(2)(iii)

• Analyses, investigations, reviews, assessments, physical

restrncturing and business plans, planning, studies environment.

(feasibility, monitoring, impact evaluation, and other social/technical/engineering studies, etc.), surveys, mapping, workshops, seminars, conferences, meetings, policy reforms, enterprise resource planning, policy and governance assistance

• Human resource management, gender sensitization, work planning and budgeting.

• Preparation of environmental documentation including environmentally required studies.

• Document and information transfer INo adverse Categorical Exclusion

• Public awareness/communication/outreach campaigns, effect on the per22 CFR media campaigns, advocacy/information campaigns and natural or 216.2( c )(2)(v) Public information campaigns physical

• Discussion panel( s) organized to discuss on television I environment.

radio

• Public service announcements (PSAs) for television and radio produced.

IEE Amendment-7 for FATA-PAD Page 16 of25

Negative Determination

Provision of Minor to Negative Determination per 22 CFR 216.3 (a)(2)(iii) moderate The recipient will properly manage and dispose equipment furniture,

equipment, tools, machine, computers, IT equipment, multimedia

adverse (equipment, tools, machine, computers, IT equipment, multimedia effects on the equipment, laboratory equipment, electronic equipment, agricultural, natural or physical

agro-processing equipment or machinery, etc.) when its useful life ends. All such equipment will be disposed in an environmentally safe

environment. manner by a ce1tified company in accordance with Pakistani laws, and equipment, laboratory equipment, electronic equipment, agricultural, agro-processing equipment or machinery etc.

in their absence, in accordance with international best practices acceptable to USAID (alternatively, when procuring equipment from a licensed provider/dealer an agreement may be reached that such equipment will be returned to the dealer for its environmentally safe disposal). For procuring of electronic and miscellaneous equipment and furniture, the Implementers will adhere to USAID's general policies on commodity eligibility provided at http://www.usaid.gov/policy/ads/300/3 1251 m.pdf and will not finance unsafe or ineffective products, such as certain pesticides, food products, or pharmaceuticals and other commodities not eligible for financing under this policy.

FATA Conflict Prevention and Community Resilience (CPCR) Activity

Sensitize communities to the FATA reform process, including public information campaigns about citizens ' rights under the constitution.

No adverse effect on the natural or physical environment.

Categorical Exclusion per 22 CFR 216.2(c)(2)(v)

Support at-risk populations to engage in positive economic activities, allowing them to develop a value set that unde1mines the attraction of violent extremist groups and behaviors

No adverse effect on the natural or physical environment.

Categorical Exclusion per 22 CFR 216.2(c)(2)(i)

• Provision of small grants to non­governmental organizations (NGOs) and/or community-based organizations (CBOs) to identify and address community concerns

• Provide small grants to support targeted

Minor to moderate adverse effects on the natural or physical environment

IEE Amendment-7 for FATA- PAD

Negative Determination with Conditions per 22 CFR 216.3 (a) (2) (iii), the Conditions being: 1. PIO will comply with its own environmental compliance

policies and report periodically to USAID that it is done on individual UDAID-funded activities.

2. Environmentally sound design, monitoring and evaluation (M&E), and best management practices should be adopted to minimize erosion, debris and waste production, and proper disposal of debris and waste.

3. All activities will be implemented in accordance with the Pakistani environmental regulations, standards, norms and guidelines and national obligations under ratified

Page 17 of25

community international environmental agreements (see: interventions to htm://www.environment.gov.J2k ) . increase community 4. PIO is encouraged to review the Environmentally Sound resistance to Design (ESD) Sector Environmental Guidelines available extremism. For at h!ill ://www .usaidgems.org/sectorGuidelines.htm. These example, to provide guidelines discuss potential environmental impacts, youth and other mitigation measures, and monitoring measures for residents with agriculture, livestock production, and small scale opportunities to construction among other activities. develop leadership 5. PIO is encouraged to comply with President Obama's and technical skills, Executive Order 13677, dated September 23, 2014, and engage in "Climate-Resilient International Development" community htto://www.whitehouse.gov/the-12ress-activities-such as office/2014/09/23/executive-order-climate-resilient-theater performances, international-development requiring agencies engaged in sporting activities, international development to assess and evaluate climate-and community related risks and vulnerabilities and to adjust strategies, leadership. planning, programs, projects, investments, and overseas

• Limited direct small- facilities, as approp1iate, based on those assessments and scale infrastructure evaluations. activities (i.e., health 6. PIO is encouraged to review and comply with White House clinic or school Memorandum , dated October 7, 2015, "Incorporating refurbishment, Ecosystem Services in Federal Decision Making" drinking water (https://www.whitehouse.gov/sites/default/files/omb/memo systems, feeder randa/20 I 6/m-16-01.pdf) . roads) with a total Life of Project cost of $15 million.

FAT A Reforms Suppor t Activity

IEEAmendment-7 for FATA-PAD Page 18 of25

Assist government of Pakistan in No adverse Categorical Exclusion per 22 implementation of political and governance effect on the CFR 216.2( c )(2)(i) reforms for FAT A. This will require natural or substantial work, including development of physical legislation, policies, and procedures. environment. Trainings to Civil servants working in FA TA for the implementation of the new laws, regulations, and procedures. Support to the government of Pakistan to recruit new civi l servants, judges, prosecutors, and other essential personnel. Provide technical expertise to the relevant Minor to Pursuant to 22 CFR 216.3 Pakistani entities in developing a ten-year moderate (a)(2)(iii) a negative socio-economic FAT A Reform Plan based on adverse effects determination with conditions is proper needs analysis. This plan is intended on the natural or recommended. An implementing to provide major infrastructure including physical partner will develop a site specific dams and irrigation projects, mineral environment EDF with an EMMP. It will development programs, and integrated plans include environmental compliance for health, education, vocational training, and guidelines consistent with the industrial zones. recommendations and conditions

of this IEE, and aspects of Climate Risk Management, as warranted. The EDF/EMMP will be approved by the A/COR and DIMEO.

Assist government of Pakistan in developing No adverse Categorical Exclusion per 22 a local governance system - legislation, effect on the CFR 216.2( c )(2)(i) subordinate legislation and rules and natural or regulation for the proposed local governance physical system environment. Launching a public awareness campaign No adverse Categorical Exclusion per 22

effect on the CFR 216.2(c)(2)(v) natural or physical environment.

FATA Land Reforms Activity

IEE Amendment-7 for FATA- PAD Page 19 of25

Enable the FAT A Secretariat to procure and No adverse Categorical Exclusion per 22 implement the fully-digital system, based on effect on the CFR 216.2(c)(2)(iii) satellite imagery, and include a database for natural or recording land ownership physical

environment.

Technical assistance for capacity building for No adverse Categorical Exclusion per 22 FAT A Land Reforms Program effect on the CFR 216.2(c)(2)(i)

natural or physical

.

environment.

Humanitarian Coordination and Data Dissemination Activity

Coordination and information management No adverse Categorical Exclusion per 22 for the response to humanitarian assistance in effect on the CFR 216.2(c)(2)(iii) KP and FATA. natural or

physical environment.

5.0 USAID A/COR Responsibility The A/COR and activity managers of the FAT A Project are responsible to ensure that conditions set in the original IEE and its amendments are implemented, monitored, and as required reported. The conditions set in the original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remain unchanged.

6.0 Implementing Partner Responsibility The implementing partners of the FA TA Project activities are required to follow the conditions set in the original IEE and its amendments. This section of the original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remains unchanged.

7.0 Responsibility for Compliance This section of the original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK.-0019, remains unchanged.

8.0 Conditions for Approval: This section of original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK.-0019, is amended to include the additional conditions in this amendment.

IEE Amendment-7 for FATA- PAD Page 20 of25

9.0 Mitigation, Monitoring and Evaluation: This section of original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remains unchanged.

10.0 Allocation, Training and Reporting Requirements: This section of original IEE; ANE 07-40 Pakistan IEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remains unchanged.

11.0 Limitations of IEE: This section of original IEE; ANE 07-40 Pakistan TEE SO 10 and the Amendment No. 1: ASIA 09-102 Pakistan IEE-ETD FDP to Amendment No. 6: OAPA-14-APR-PAK-0019, remains unchanged.

12.0 Revisions In accordance with 22 CFR 216.3(a)(9,) if a project is revised or new info1mation becomes available, which indicates that a proposed action might be "major" and its effects "significant," the Determination will be reviewed and revised by the originator(s) of the program and projects and submitted through the MEO to the Bureau Environmental Officers, OAP A, for approval and, if warranted, an environmental assessment will be launched and scoping statement and environmental assessment report prepared. The scoping and EA process, if determined necessary during scoping, will follow and comply with 22 CFR 216.3(a)(4). It is the responsibility of the COR/PM to timely inform the MEO and BEO-OAP A of any changes in the scope and nature of approved activities, which may warrant the revision of the approved threshold decisions.

JEE Amendment-7 for FATA- PAD Page 21 of25

DCN: c IH' A- t 1- ti AY - f" A JC - rJoo I?

US Agency for International Development (USAID) I Pakistan Initial Environmental Examination (IEE), Amendment No. 7

USAID/Pakistan Federally Administered Tribal Areas (FATA) Project

CLEARANCE I APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE: ~--Activity Manager:

~1·id

FATA/KP Office Director (A): -b ~ ~

Mission Environmental Officer: ,;---~ Regional Envirorunental Advisor: Central, South Asia and OAP A

Howard Batson

cleared by attached email Andrei Barannik

Office Director: <\l.~-<-:---(OPM) Robert Birkenes

BEO Pakistan: _ __ ~~--~~~~"'"-'-~-------Gordon Weynand

Date:

Date:

Date:

Date: 01/31/2017

Date: 11 rvH\ 'f 'l.£) 11-______

Date: ------

Date: .f l.J t /17

Distribution: 1). Project files, 2). Mission TEE Data base, 3). OAA, 4). RLO

JEE A111end111ent-7 for FATA- PAD Page 22 of25

Attachment 1 Environmental Documentation Form (EDF)

USAID/Pakistan Federally Administered Tribal Areas (FATA) Project AA r t'fi t' . ,pp 1can m orma ion

Contractor/ grantee (organization) Parent grant or project Individual contact and title Address, phone and email (if available)

Activity (brief description) Amount

Location of activity Start and end date of activity

B A t' 'ti . C IVI es, screemne resu It s, an d recommen d d d t e e ermma ti on TABLE 1 Screening Recommended

result Determinations (Step 3 of (Step 6 of instructions.

instructions) Complete for all moderate and high-risk

activities) Proposed Sub-activities 7.:i ~ ...

"'=' 0 tf (/) ... 0

;:;a ;:;a ~"' ~d ~ i:l 0 p.. ~ v ~ j·~ ·o d' ... § ~ v (/) g, .g ~ ·v 0 ~ ;:;a ~ ffj ....

...:l .... (/) "' lC< (/) ·- ~ ~ c Q) ..c:: ·- .... -s . bO 'Eh t 6h > p.. "'=' "'v 0 bO

~~ ·-a > U5 ~ .§ v ::E l:E ::;:: ·9 ·v; ~ >

1. 2. 3. 4. 5. 6. (continue on additional page if necessary) C. Sum.mat of recommended determinations

n Ve low risk sub-activities D After environmental review, sub­

activities determined to have no si nificant adverse im acts

D After environmental review, sub­acti vities determined to have no

JEE Amendment-7 for FATA-PAD

negative determination(s)

negative determination(s) with conditions

Page 23 of25

appropriate mitigation and monitorin~

D After environmental review, sub-activities determined to have positive determination(s) shwificant adver se impacts

D. Cer tification: I, the undersigned, certify that: 1. The information on this form is correct and complete 2. The following actions have been and will be taken to assure that the activity complies with environmental requirements established for project under the Code of Federal Regulations 22 CPR 216:

These design elements and best practices will be followed in implementing this activity, except with the approval ofUSAID.

Any specific mitigation or monitoring measures described in the attached information will be implemented in their entirety.

Compliance with these conditions will be regularly confirmed and documented by on­site inspections during the activity and at its completion.

(Signature) BELOW TIDS LINE FOR USAID USE ONLY A roval

(Date)

USAIDAOR D Approved D Re"ected rint name st ature USAIDMEO D Approved D Re· ected rint name si ature USAID comments: (if documentation is rejected, comments must be provided to applicant)

IEE Amendment-7 for FATA- PAD Page 24 of25

Attachment 2

Environmental Mitigation & Monitoring Plan (EMMP) USAID/Pakist'an Federally Administered Tribal Areas (FATA} Project

• An EMMP should either be included in or developed for (1) all IEEs that have at least one "Negative Determination with Conditions" (or for activities for which an environmental review has been completed pursuant to an IEE requirement) and (2) all Environmental Assessments (EAs).

• If the EMMP is not developed as part of the IEE, the implementing partner should usually lead development of the EMMP, subject to review and oversight by the MEO andAOR.

• In all cases, the tasks identified in the EMMP are incorporated into the implementing partner's Work Plan, budget, and reporting.

• The following EMMP format is recommended. It can be adapted, as necessary.

Environmental Mitigation and Monitoring Plan: Activity Title: I I . P mp ementin2 artner:

Monitoring

Activity Mitigation Monitoring and Party(ies) Indicative Measure(s) Indicator(s) Reporting Responsible Budget

Frequency List all If mitigation Specify indicators For example: If appropriate, Provide best activities in measures are to ( 1) determine if "monitor separately estimate of IEE that well-specified in mitigation is in weekly, and specify the "Indicative received a the IEE, quote place and (2) report in parties Budget" for "negative directly from successful. quarterly responsible for the determination IEE For example, reports. If mitigation, for monitoring with lf they are not visual inspections XXX occurs, monitoring and and conditions." well-specified in for seepage immediately for reporting. repmting of Do not list any the IEE, define around pit latrine; inform USAID each activity other activities more sedimentation at activity for the full in separate specifically stream crossings, manager." duration of rows. here. etc.) referred

activity. This is not a budget for mitigation measures.

IEE Amendment-7 for FATA-PAD Page 25 of25

5/15/2017 USAID Mail - Review and Concurrence of IEE Amendment-7 for FATA Project.

Asim Aziz <aaziz@usaid.gov>

Review and Concurrence of IEE Amendment-7 for FATA Project. ........ .............. ····-·· ...... .. .... ·····~ ·--· -.... #----·· -···-··- , .. _ ... -·-·- ·- .. --··---·--·--- _ ... ~.~---- .. ·-·-·- - ··-·-·········-··-··· ··-------- ,. __ Andrei Barannik <abarannik@usaid.gov> Tue, Jan 31, 2017 at 8:17 AM To: Asim Aziz <aaziz@usaid.gov> Cc: Howard Batson <hbatson@usaid.gov>, Carlos Lamadrid <clamadrid@usaid.gov>, Guy Martorana <gmartorana@us aid. gov>

Dear Asim -

While on TDY and in the middle of the Indian ocean, reviewed - looks OK, but one comment:

as project goes from 2007 and Section 2.0 should distill and report: actual environmental implementation compliance and reporting by various partners on NDC activities, USAID oversight, any findings of the OIG audits for the said activities, including any environment-related findings and recommendations

Right now Sec 2.0 reads like "cut and paste11 from previous docs.

With the above comments addressed, pis have the Amnd duly signed in the Mission, put "cleared by e-mail" on REA line and send it to Gordon Weynand, BEO/OAPA (cced Erin Laws) for his review and concurrence.

Please seek OAA assurances that MEO/DMEOs meets with IPs for new activities at the 11 post award" conference and explain IEE conditions.

W /r from Male on thee way to Colombo, Andrei

Andrei D. Barannik Regional Environmental Adviser for Central and South Asia, and for Office of Afghanistan and Pakistan Affairs 1300 Pennsylvania Ave., NW, 5.06-29 Washington, D.C., 20523 Land line: 1.202.712.4161 ·

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. ·, 511512017 USAID Mail - Review and Concurrence of IEE Amendment-7 for FATA Project

Cell phone: 1.571 ;2t6.7243 i

E-mail: abarannik@4said.gov

USAID Searchable IEE Dat13base & USAID GEMS Projec t -- ! .,

.Ji .A. Please consid~rihe environment before printing this email

·. '

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