What If I Must Go Beyond a Preliminary Assessment? (the example of a USAID EA under Reg. 216) [DATE][SPEAKERS NAMES]

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Our focus thus far To this point, we have focused on Phase I of the EIA process... Understand proposed activities Screen Conduct preliminary assessment (if needed) Scope Evaluate baseline situation Identify & choose alternatives Identify and characterize potential impacts of proposed activity and each alternative Develop mitigation and monitoring Communicate and document Phase I: Initial inquiries Phase II: Full EIA (if needed) Our focus!

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Now, we focus on the full EIA The “full EIA” is Phase II of the EIA process: Scope Evaluate baseline situation Identify & choose alternatives Identify and characterize potential impacts of proposed activity and each alternative Develop mitigation and monitoring Communicate and document Phase II: Full EIA (if needed) New focus! When is a full EIA needed? When screening indicates an activity is high risk* When a preliminary assessment indicates that significant adverse impacts are possible 1 2 *But we still recommend doing a preliminary assessment!

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Review: Phase 1 Screen the activity Based on the nature of the activity what level of environmental review is indicated? Conduct a Preliminary Assessment A rapid, simplified EIA study using simple tools (e.g. the USAID IEE) ACTIVITY IS OF MODERATE OR UNKNOWN RISK SIGNIFICANT ADVERSE IMPACTS POSSIBLE SIGNIFICANT ADVERSE IMPACTS VERY UNLIKELY ACTIVITY IS LOW RISK (Based on its nature, very unlikely to have significant adverse impacts) ACTIVITY IS HIGH RISK (Based on its nature, likely to have significant adverse impacts) Phase II Phase I Understand proposed activity Why is the activity being proposed? What is being proposed? BEGIN FULL EIA STUDY STOP EIA process

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Review: the IEE Remember, the IEE is USAID’s “Preliminary Assessment”  A positive determination triggers an full EIA RecommendationReg. 216 terminology Implications (if IEE is approved) No significant adverse environmental impacts NEGATIVE DETERMINATION Activity passes environmental review With specified mitigation and monitoring, no significant environmental impacts NEGATIVE DETERMINATION WITH CONDITIONS The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented Significant adverse environmental impacts are possible POSITIVE DETERMINATION Do full EA or redesign activity Not enough information to evaluate impactsDEFERRAL You cannot implement the activity until the IEE is finalized

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit USAID: 2 types of full EIA study Reg. 216 specifies 2 types of full EIAs: Used to assess the environmental effects of a specific project or action, e.g.  An EA to assess a single dam or irrigation project  An EA to assess impacts of a gas or oil pipeline The Environmental Assessment (EA) Programmatic Environmental Assessment (PEA)* Used to assess the environmental effects of a class of similar actions, e.g.,  dams, irrigation projects and related water resource development,  sustainable forest management plans *The term in Reg. 216 is “Program Assessment” Reg 216 discusses only the content of the EA in detail. However, the regulation states: “To the extent practicable,the form and content of the PEA will be the same as for EAs.”

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit How is an EA different than an IEE?  Analysis of environmental impacts is much more detailed  Alternatives must be formally defined. The impacts of each alternative must be analysed, and the results compared. (216.6(c))  USAID must consult with the host country government during preparation and regarding the results (216.6(e)) ! ! !

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit First steps in preparing an EA Prepare Scoping Statement Prepare TORs Assemble Team 2 BEO review The purpose of scoping is to determine the the significant issues the EA will address. The deliverable for the scoping process is the scoping statement. The statement includes:  Scope and significance of issues to be analyzed  Issues that do not need to be addressed  Schedule and format of EA, expertise needed Public consultation is not required by Reg However, good EIA practice requires public consultation during scoping. !

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit First steps in preparing an EA Prepare Scoping Statement Prepare TORs Assemble Team 2 BEO review The scoping statement must be submitted to and approved by the Bureau Environmental Officer (BEO). STRONGLY RECOMMENDED: Consult with the BEO before beginning the Scoping process. Terms of Reference for the EIA team are based on the types of issues and analysis required by the scoping statement Assemble a team based on the TORs. Frequently requires contracting with one or more experts, or an EIA consulting firm.

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit The EA outline Reg. 216 specifies that an EA will contain the following elements: 1. Summary 2. Purpose 3. Comparison of alternatives* 4. Affected Environment 5. Environmental Consequences 6. List of Preparers and appendices Appendices (as indicated) *Reg. 216 uses the term: “Alternatives Including the Proposed Action”

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Contents of the EA sections Summary Purpose Comparison of alternatives Affected Environment Environmental Consequences List of Preparers Major conclusions Areas of controversy Issues still to be resolved. Describes the development need or objective that the proposed actions (and its alternatives) are intended to address

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Contents of the EA sections Summary Purpose Comparison of alternatives Affected Environment Environmental Consequences List of Preparers Includes the no action alternative Explain why certain alternatives were not considered Present the alternatives considered NOTE: This is a summary of the analysis presented in “Environmental Consequences” Include mitigation actions Compare the environmental impacts of these alternatives. Identify the preferred alternative

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Contents of the EA sections Summary Purpose Comparison of alternatives Affected Environment Environmental Consequences List of Preparers “ Succinctly” describe the environment of the area(s) to be affected Note that different alternatives may affect different geographic areas or aspects of the environment. The description here must cover all alternatives Descriptions shall be “no longer than is necessary to understand the effects of the alternatives” !

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Contents of the EA sections Summary Purpose Comparison of alternatives Affected Environment Environmental Consequences List of Preparers Includes the proposed action and the no action alternative Impacts of alternatives are not compared. Should include* Any adverse effects and their significance (including those that cannot be avoided) Relationship between short-term uses of the environment and maintenance/ enhancement of long-term productivity Conflicts with other policies, plans or controls for the areas under consideration Recommended mitigation measures Presents the environmental impacts of each alternative * See (c)(5) for full list

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit NOTE: WHEN ASSESSING IMPACTS, TOO MUCH INFORMATION IS AS BAD AS NOT ENOUGH Provide the most detailed analysis for the more significant impacts.. Summarize or reference for lesser impacts ! * See (c)(4)

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Contents of the EA sections Summary Purpose Comparison of alternatives Affected Environment Environmental Consequences List of Preparers Names and qualifications of the EA Team Annexes can be useful in organizing the EA so that only the most critical information for decision-making is in the body of the EA

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Coordination with host country procedures What are the implications?  USAID projects must satisfy BOTH Reg. 216 AND host country procedures  One EIA document should be created to satisfy both procedures  Will require discussions in the scoping process with host country EIA regulatory agency. The large majority of host countries now have EIA policies and procedures Most projects that require an EA under Reg. 216 will also require a full EIA under host country procedures & 12

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit Gaps in the Reg. 216 EA requirements  Reg. 216 does not have language that emphasizes the importance of a detailed mitigation and monitoring plan  However, Mitigation and Monitoring Plans are essential to making the EA effective  Remember, Mitigation and Monitoring plans assign responsibilities and establish schedules/time lines and reporting requirements.