@ AFGHANISTAN P clJ.' .:JAJJ- f.rF<:,-- OO('L Office of Afghanistan & Pakistan Affairs (OAPA) Initial Environmental Examination (IEE) PROGRAM/ACTIVITY DATA Country Code and SO: 306-05 Strategic Objective Name: Country or Region: Expand and Improve Access to Economic Infrastructure Afghanistan Activity Name: Funding Period: LOP duration Amount: IEE Prepared by: IEE Date: IEE Amendment (YIN): Gardez-Khost Road Marking and Signage Installation 1/1/2017 - 8/13/2017 $250,000 Hekmatullah Zafarzai 10/20/2016 N ENVIRONMENT AL ACTION RECOMMENDED Categorical Exclusion Positive Determination Negative Determination With Conditions 1'r [X] Deferral Negative Determination Exemption [ ] [ ] [ ] Climate Change Vulnerability Risk None[] Low [X] Medium[] High[] 1.0 PURPOSE, BACKGROUND AND ACTIVITY DESCRIPTION 1.1 Purpose and Background The purpose of this IEE, in accordance with 22 CFR 216, is to provide the first review of reasonably foreseeable effects on the environment, as well as the recommended Threshold Decision for the Gardez-Khost Road Marking and Signage Installation contract. On November 25, 2009 the Bureau Environmental Officer (BEO) approved an environmental assessment (EA) for the Gardez to Khost Rehabilitation project, prepared by the implementer as it met the requirements of22 CFR 216.3(5). This EA included an Environmental Mitigation and Monitoring Plan (EMMP). We recommend the use of this EA as a guiding environmental document for Gardez-Khost Road Marking and Signage Installation contract, and amend the EMMP as needed. Gardez Khost road rehabilitation was completed in three sections. Section 1 (km 0 - km 27) was completed in January 20 11 , and Section 3 (km 65 - km 101 ) was completed in November 20 10.
Transcript
@ ~T~!~Q AFGHANISTAN P clJ.' OAf~-(7- .:JAJJ- f.rF<:,-- OO('L
Office of Afghanistan & Pakistan Affairs (OAPA)
Initial Environmental Examination (IEE)
PROGRAM/ACTIVITY DATA
Country Code and SO: 306-05 Strategic Objective Name: Country or Region:
Expand and Improve Access to Economic Infrastructure Afghanistan
The purpose of this IEE, in accordance with 22 CFR 216, is to provide the first review of reasonably foreseeable effects on the environment, as well as the recommended Threshold Decision for the Gardez-Khost Road Marking and Signage Installation contract.
On November 25, 2009 the Bureau Environmental Officer (BEO) approved an environmental assessment (EA) for the Gardez to Khost Rehabilitation project, prepared by the implementer as it met the requirements of22 CFR 216.3(5). This EA included an Environmental Mitigation and Monitoring Plan (EMMP). We recommend the use of this EA as a guiding environmental document for Gardez-Khost Road Marking and Signage Installation contract, and amend the EMMP as needed.
Gardez Khost road rehabilitation was completed in three sections. Section 1 (km 0 - km 27) was completed in January 2011 , and Section 3 (km 65 - km 101) was completed in November 2010.
Final inspections were completed and Section 1 and Section 3 were transferred to the Government of the Islamic Republic of Afghanistan (GIRoA) to operate and maintain. Section 2 (km 27-km 65) was completed in December 2015. With the completion of Section 2, the 101 km Gardez to Khost Rehabilitation project was considered completed and was transferred over to GIRoA. Rehabilitation of all three sections were covered under approved original IEE, tracking OAPA-13-DEC-0007, approved in December 6, 2012 and IEE Amendment 1, tracking number OAPA-14-DEC-AFG-0014, approved in December! 7, 2013.
Because road signage and marking was not included in the contract for the completion of road Section 2, a separate contract will be awarded, hence the need for a separate, stand-alone IEE.
1.2 Activity Description
USAID/ Afghanistan has recently completed construction of asphalt paved Gardez-Khost Road Section 2 (km 27-km 65) in two phases with all necessary drainage and protection structures. Currently this section of the road lacks pavement marking and road signs, which poses a safety threat to the road users. In response to recognizing this deficiency, USAID/Afghanistan will provide pavement marking and road sign installation according to the design drawings, technical specifications, and site requirements.
The pavement markings consist of center lines, edge lines, no passing lines, continuity lines, pedestrian crosswalk lines, raised curb markings, chevron markings and any other markings required as per site condition. The road sign installation includes determining road sign location and type as per site requirement, and installment of the road signs accordingly.
The approved EMMP for G-K Road Section 2 shall be reviewed and amended by contractor, and submitted to USAID Contracting Officer's Representative (COR) and Mission Environmental Officer (MEO) for review and written approval.
2.0 RECOMMENDED TRHESHOLD DECISIONS
The table on p.3 lists activities covered in this IEE as well as the recommended threshold decisions.
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Activities Effect on Natural or Physical Determination and Reg. 216 actions required
Environment
Negative Determination with Conditions Conditions: • Contractor will ensure that all signs and markings are in accordance with any applicable
Afghan laws and regulations. COR will review and approve.
• The specifications for paint, glass-beads, thermoplastics, polymer tape or any other material for road surface markings shall be reviewed by COR and MEO before purchase order is placed.
• Contractor will ensure that appropriate environmental standards and best industry practices for monitoring and mitigation plans, as established in the G-K Road EA of 2009 and the EMP for G-K Road Section 2, are followed.
• Contractor will review and amend the EMMP for G-K Road Section 2 in consultation with the COR and MEO, within 30 days of signing the award. Contractor shall follow the EMMP format in Annex I.
• Contractor will follow best practices and standard operating procedures for applying Road
Insignificant effect with proper road markings and setting up road signs to ensure sustainability and minimize
Marking and environmental impact. Signage
mitigation measures • Contractor will make sure that all waste materials are disposed in an environmentally
Installation sound and safe manner.
• Contractor shall employ best practices in storage of chemicals, fuels and other materials to prevent spillage.
• Contractor shall employ best practices in dust and noise controlling during road marking and signage installation.
• Contractor will ensure that all equipment is used in an environmentally sound and safe manner and properly disposed of at the end of its useful life in a manner consistent with best management practices according to U.S., European Union or equivalent standards acceptable to USA.ID.
• No paints or material containing lead, arsenic, antimony or other hazardous elements in levels above acceptable industry standards shall be used. See for instance http://www.fhwa.dot.gov/publications/research/safety/09039/05.cfm
• Contractor is required to ensure that all applicable environmental safety and quality certificates and permits conforming with Afghan and/or international standards are available.
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3.0 ENVIRONMENTAL RECOMMENDATIONS
Recommended Action: Negative Determination with Conditions
Gardez-Khost Road Marking and Signage Installation activities are not anticipated to induce any significant (adverse) impacts on the natural or physical environment but will have a substantial beneficial impact on the social characteristics of the project area. Some potential impacts however, could occur as a result of dust and noise development during operations, improper waste disposal, poorly maintained or adjusted machinery or use of paint with hazardous elements above industry standards. These potential impacts can be appropriately managed or mitigated by the measures by adherence to an EMMP that can in part be based on mitigation measures outlined in the EA)for the Gardez to Khost Rehabilitation project.
Recommended Action: Using of approved Environmental Manual 2009
On November 25, 2009 the Bureau Environmental Officer (BEO) approved the EA for the Gardez to Khost Rehabilitation Project, prepared by The Louis Berger Group, Inc., Black & Veatch (LBG/BV), as it met the requirements of22 CFR 216.3(5)1
• USAID/Afghanistan recommends the continued use and approval of the existing November 2009 EA. This EA describes in great detail major environmental issues, community and social demographics, environmental compliance, proposed mitigations for various construction activities expected throughout the life cycle of construction. The information contained in the EA is as relevant today as it was in 2009. The project location, topography, hydrology, soils, socio economic considerations and other environmental conditions are equal and or similar to when the EA was first approved in 2009. We recommend the use of this EA as a basic guiding document for minimizing waste, controlling and noise, and safety for road users. The EMMP contained in the EA will need to be refined in consultation with the MEO and COR, to incorporate best industry practices for road signage and markings. For instance, there are a number of paints from especially China that contain unacceptable levels of lead, arsenic and antimony.
At the post award conference the COR and MEO will explain to the Contractor all approved conditions.
4.0 CLIMATE CHANGE RISK SCEENING
Afghanistan is extremely vulnerable to the impacts from global climate change. Temperatures have been rising and are expected to rise even more and there is an increase in the frequency of extreme weather events such as droughts and rainstorms which may affect water availability and affect crop and livestock production, and also damages the paved roads, damage infrastructure for energy, transportation, water, health education, communication, housing and other services. To minimize the negative in1pacts of climate change, USAID is required by Executive Order 13677 to incorporate climate change risk screening for all new projects as of October 1, 2016.
1 http : //pd f. usaid . gov/pdf_ docs/PBAAE158 . pdf
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Climate change is expected to have limited or low impact on the sign installation and marking for G-K Road. First of all, the activity will be completed within one year so the time that the project is exposed to climate impacts is limited. The main risk would be from rain washing off lines that have just been painted or road signs damaged by floods. Best practices in the road construction sector dictate that painting lines on the road swface must not be done dming times of rainfall or when rain is expected; road signs should be well seemed and not be placed in locations where rain water might flow during heavy rainfall. These practices are part of the standard operating procedmes and climate risk is therefore deemed to be of low risk for this activity.
5.0 LIMITATIONS OF THE IEE
This assistance does not cover activities involving: 1. Assistance for the procmements (includes payment in kind, donations, guarantees of
credit) or use (including handling, transport, fuel for transpmt, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides (where pesticides cover all insecticides, fungicides, and rodenticides, etc. covered under the "Federal Insecticide, Fungicide, and Rodenticide Act" FIFRA.) or activities involving procmement, transport, use, storage, or disposal of toxic materials
2. Procmement or use of genetically modified organisms (GMOs) will require preparation ofbio-safety assessment (review), in an amendment to the IEE approved by BEO/OA
3. PADCAorGDAprograms 4. Procurement or use of Asbestos and Lead Containing Materials (ALCM) (e.g., piping,
roofing), Polychlorinated Biphenyl' s (PCB) or other hazardous materials prohibited by US EPA as provided at: http://www.epa.gov/asbestos and/or under international environmental agreements and conventions, e.g. Stockholm Convention on Persistent Organic Pollutants as provided at: http://chm.pops.int
5. Procurement, use or recommendation for use of Ammonium Nitrate (AN) and Calcium Ammonium Nitrate (CAN) fertilizers.
6. No pesticides shall be used without an approved and updated Pesticide Evaluation Report and Safe Use Action Plan.
6.0 REVISIONS
Pursuant to 22 CFR 216.3(a)(9), if new information becomes available which indicates that activities to be funded by the Program might be "major" and the Program's effect "significant," or if additional activities are proposed that might be considered "major" and their effects significant, this IEE will be reviewed and revised by the originator of the project and submitted to the Bmeau Environmental Officer (BEO) for approval and, if appropriate, an environmental assessment will be prepared. It is the responsibility of the USAID/ Afghanistan Contract Officer ' s Representative (COR) to keep the Mission Environmental Officer and the BEO/OAPA informed of any new information or changes in the activity that might require revision of the IEE. APPROVAL OF RECOMMENDED ENVIRONMENTAL ACTIONS
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IEE, Gardez-Khost Road rehabilitation sign installation and marking activity
CLEARANCES:
COR
Officer Director, OI
Mission Environmental Officer
Regional Environmental Advisor SCA & OAP A
Resident Legal Officer
Deputy Mission Director
Mission Director
APPROVAL:
Bureau Environmental Officer/OAP A
DISTRIBUTION: MEO, COR, OAA, RLO
Hekmatullah Zafarzai
Teresa Miller
Harry Bottenberg
cleared by email Andrei Barannik
John"Greg" Butler
Michael McCord
Herbert Smith
Gord9n Weynand
Date:
11/8/2016
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APPROVAL OF RECOMMENDED ENVIRONMENT AL ACTIONS
IEE, Gardez-Khost Road rehabilitation sign installation and marking activity
CLEARANCES:
~ Date:
COR JI jq /2@t6
Officer Director, Of ~r t2/~ {_l!2r!A:i I
Mission Environmental Officer ~ Jf j(Jjl).or£ Harry Bottenberg
Bureau Environmental Officer/OAPA ~'{,J~ 1Lct/ £6 Gordon Weyriand
DISTRIBUTION: MEO, COR, OAA, RLO
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Annex I Project Name
Environmental Mitigation and Monitoring Plan (EMMP)
The EMMP must be completed by each organization carrying out activities under the USAlD/Afghanistan XXX Program. It will include the organization's own report plus the EMMPs of any sub-awardees, to capture the entire range of activities funded by the USAID/ Afghanistan XXXX Program under the award. The USAID/Afghanistan XXXX Program, implementing partners are responsible for ensuring that each sub-awardee completes and submits the EMMP to the prime in a timely fashion. The EMMPs are reviewed and approved by the COR/AOR and the Mission Environmental Officer.
The EMMP consists of 3 parts: l. 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 subawardees) and serves to 'trigger' USAID expectations of mitigation measures.
The EMMP Mitigation Plan Implementing pa1tners will use the Mitigation Plan to describe the specific actions they will unde1take 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 as described in Section 5, Table 4 of this JEE. The Mitigation Plan also identifies the person responsible for monitoring compliance with mitigation and the indicator, method and frequency of monitoring.
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.
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USA ID/ Afghanistan ----Project Name----
EMMP Part 1of3: Environmental Verification Form
Date of Screening: ______________ _
Name of Prime Implementing Funding Period for this award: FY __ - FY __ Organization: _____________ _
Current FY Resource Levels: FY ______ _ Name of Sub-awardee Organization (if this EMMP is for a sub): This report prepared by:
Name: Date: ____ _
Geographic location of USAID-funded activities (Province, District): __________ _
Date of Previous EMMP for this organization: (if any)
Indicate which activities your organization is implementing under this funding:
Key Elements of Program/Activities Implemented Yes
I • 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.);
2 Development and dissemination of improved agricultural production techno]ogies for selected crops and livestock
3 Increased agricultural production
4 Seeds, Germplasm, Exotic Species
5 Dissemination of biotechnology products
6 Small-scale constrnction or rehabilitation of buildings and water & sanitation infrastructure
7 Sub-Grants
No
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USAID/Afghanistan ----Project Name--
EMMP Part 2 of3: Environmental Mitigation and Monitoring Plan
Category of Describe specific Activity environmental threats of Description of Mitigation Who is Monitoring Monitoring Frequency
your organization's Measures for these activities as responsible for Indicator Method of activities (based on required in Section 5 of IEE monitoring Monitoring
analysis in Section 3 of the IEE)
USAID/ Afghanistan, ---Project Name---
EMMP part 3 of 3: Reporting form
List each Mitigation Measure from column 3 in the EMMP Mitigation Status of Mitigative Measures List any outstanding issues relating to Remarks
Plan (EMMP Part 2 of3) reauired conditions
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Certification PROJECT NAME
I cet1ify the completeness and the accurncy 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 TIDS LINE FOR USAID USE ONLY
USAID/Afghanistan, Program, Clearance ofEMMP:
A/COR 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
11/9/2016 USAID Mail - Re: Gardez-Khost IEE Amendment 2
Harry - reviewed - looks OK - I'd suggest to add: "At the post award conference the COR and MEO explain to the IP all approved conditions." With this, pis have the IEE duly signed in the Mission, put "cleared by e-mail" on REA line and send it to Gordon Weynand, BEO/OAPA, ceed Erin Laws, for his review and concurrence. W/r, Andrei
On Tue, Nov 8, 2016 at 4: 18 AM, Harry Bottenberg <[email protected]> wrote: I Sorry, Andrei, can you review again. We went back and redid this as a stand-alone IEE since the COR and CO clarified recently that this will be a separate contract and I want this I EE to be very clear, so I strengthened the language here and there. Also added climate. There is actually a whole field of science around road signage and markings, there appear to be all sorts of potential issues with the marking paints (or other material e.g. epoxy, glass beads) since manufacturers especially from China like to add lead, arsenic and antimony to improve paint or marking
' physical properties e.g. durability. USDOT is following certain standards. See for instance http://www.fhwa.dot.g ov /publications/research/safety /09039/05. cfm. See also https ://en. wikipedia. org/wiki/Road _surface _marking. USAI D GEMS's rural roads environmental guidance does not address signage and markings (or road safety).
By the way, the G-K Environmental Assessment doesn't say much at all about road safety and signage (nor the EMP embedded in the EA).. There may be some general guidelines that the road signage activity can use, e.g. about
I traffic control , waste disposal, dust control etc. Therefore, the EMMP (or EMP as called in the EA) would definitely need to be tailored to the activity.
I Finally I still don't quite understand how USAID can hand over a road (section) to the Afghan government without
1 proper signage and markings. I hope the other road sections have proper road safety measures in place.
harry '
1 On Sun, Nov 6, 2016 at 5:18 PM, Andrei Barannik <[email protected]> wrote:
Dear Mustafa and Harry -I
As I mentioned, Mike suggested to talk to CO to check whether this is a new activity, which he thought it might be, and then, it may require a new IEE.
I I If not, as I cleared it earlier, I do it one more time. We can also add a sentence I
j stipulating that the COR engages MSP consultant to do environmental compliance monitoring.
I
W/r, Andrei
On Sun, Nov 6, 2016 at 3:25 AM, Mohammad Mustafa Sultani <[email protected]> wrote: ' Dear Andrei,
