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Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 1
INITIAL ENVIRONMENTAL EXAMINATION
FOR
USAID/NIGERIA DEVELOPMENT OBJECTIVE 2:
Economic Growth and Environment (EGE) Office & Portfolio
Program Title: USAID Nigeria Development Objective 2: Broadened, Diverse and Inclusive Private
Sector-Led Growth
Country/Region: Nigeria, West Africa
USG Foreign Assistance Framework Area Covered:
Functional Objective 4: Economic Growth
Program Area: 4.2: Trade and Investment
Program Element 4.2.1: Trade and Investment Enabling Environment
Program Element 3.2.2: Trade and Investment Capacity
Program Area: 4.3: Financial Sector
Program Element 4.3.1: Financial Sector Enabling Environment
Program Area: 4.4: Infrastructure
Program Element 4.4.1: Modern Energy Services
Program Element 4.4.3: Transport Services
Program Area: 4.5: Agriculture
Program Element 4.5.1: Agricultural Enabling Environment
Program Element 4.5.2: Agricultural Sector Capacity
Program Area: 4.8: Environment
Program Element 4.8.2: Clean Productive Environment
Funding Begin: October 01, 2013
Funding End: September 30, 2019
LOP Amount: $250 million (est.)
IEE Prepared By: Nduka Okaro, Nigeria Mission Environmental Officer, Walter Knausenberger,
AFR/SD Sr. Reg. Env Policy Adv., and James Jolley, The Cadmus Group
Current Date: December 13, 2013. Revision July 1, 2014
IEE End Date: December 31, 2019
IEE Amendment (Y/N): No, this updates and replaces the AO2 IEE “Nigeria_EGE_IEE_050710”
Other Relevant Environmental Compliance Documents: 1. “Pesticide Evaluation and Safer Use Action Plan: Maximizing Agricultural Revenue and Key Enterprises in
Targeted sites II (Nigeria MARKETSII PERSUAP_2013_2017)” approved 07/26/2013.
See http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39371.docx.
2. IEE for Nigeria Development Credit Authority (DCA) Renewable Energy. See
http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39936.docx
3. IEE for buy-in to USAID/E3 Renewable Energy Leader with Associates Agreement (LWA) with Winrock
International, see http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/2019.pdf. Superseded by this IEE.
4. RCE for buy-in to E3 Private Financing Advisory Network (PFAN), 2010-2015,
http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/37257.pdf. Superseded by this IEE.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 2
ENVIRONMENTAL ACTION RECOMMENDED: Categorical Exclusion: X Negative Determination: _X__
Positive Determination: potential Deferral _X___
ADDITIONAL ELEMENTS:
Conditions: X | EMMP: X DCA/GDA: X | PVO/NGO: X | Pesticides:* X
*22 CFR 216.3 (b)(1) applies. MARKETS II PERSUAP in place.
SUMMARY OF FINDINGS:
This Initial Environmental Examination (IEE) provides, in accordance with 22CFR216, the first review of
the reasonably foreseeable effects on the environment of all the activities of the USAID/Nigeria
Economic Growth and Environment (EGE) office, the Development Objective Two: “Broadened, Diverse
and Inclusive Private Sector-led Growth” and will be implemented under the Country Development
Cooperation Strategy (CDCS), October 2013 – September 2018. These activities are grouped under three
intermediate results IR 2.1: Agricultural Competitiveness Increased; IR 2.2: Energy Access
Increased and IR 2.3: Enabling Environment Improved.
The three intermediate results also align with USG Foreign Assistance Framework Economic Growth Objective
in five program areas of Trade and Investment; Infrastructure; Agriculture and Environment. It is expected that a
number of activities from the preceding Assistance Objective 2 (AO2): “Increased Rural Incomes and Jobs in
Assisted Areas” will continue under the new Development Objective. This IEE therefore evaluates both current
and anticipated Economic Growth and Environment Office activities. It also sets out project-level implementation
procedures intended to assure that the conditions in the IEE are translated into project-specific mitigation
measures, and to assure systematic compliance with this IEE during project and program implementation. These
procedures are themselves a general condition for approval of this IEE, and their implementation is therefore
mandatory.
The Nigeria Energy sector activities, interventions and transactions are part of the Agency’s five-year
Power Africa Initiative, which presently covers six bilateral countries and three regional offices.
USAID’s Power Africa program is the subject of an umbrella Programmatic IEE (P-IEE) conducted to
inform the planning and implementation of all of Power Africa in sub-Saharan Africa. Initially, the
Programmatic IEE for Power Africa covers all PA core Operating Units and classes of action at an
“umbrella” level. Further, the Nigeria EG sector’s IEE analysis of the specific energy activities being
planned and undertaken by USAID/Nigeria is consistent with the expected supplemental country-specific
analysis called for by the P-IEE, so that country-specific environmental review and environmental
mitigation and monitoring are undertaken at the appropriate points.
Scope. This IEE addresses the entire portfolio of activities anticipated under the USAID/Nigeria
Economic Growth & Environment (EGE) portfolio. Replacing and superseding the Mission’s previous
EG IEEs, it applies to all economic growth activities implemented under Nigeria’s 2013-2018 CDCS
Development Objective 2, except that (1) ongoing activities operating an approved environmental
mitigation and monitoring plan (EMMP) may continue operating under that EMMP; and (2), activities
funded via an existing buy-in mechanism will be subject to and implemented in accordance with the
approved IEE covering that mechanism. Further, the IEE for Nigeria Development Credit Authority
(DCA) Renewable Energy is still in force and consistent with this DO EGE IEE, as well as the
MARKETS II PERSUAP.
Based on the environmental review presented in this IEE, the following determinations are made:
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 3
Categorical Exclusion in pursuant to 22 CFR 216.2(c)(2) is recommended for the following activities in
support of agricultural competitiveness: improved energy access and improved enabling environment.
These activities will not have adverse effects on the environment as detailed in Table 1.
(i) Activities involving education, training, technical assistance or training programs except to the
extent such programs include activities directly affecting the environment (such as construction of
facilities, etc.);
(ii) Activities involving controlled experimentation exclusively for the purpose of research and field
evaluation and carefully monitored;
(iii) Activities involving analyses, studies, academic or research workshops and meetings;
(v) Activities involving document and information transfers; and
(viii) Programs involving nutrition, health care, or family planning services except to the extent designed
to include activities directly affecting the environment (such as construction of facilities, water
supply systems, waste water treatment, etc.);
Negative Determinations with conditions are recommended for the following sorts of activities:
Per 22 CFR 216.3 (a) (2) (iii):
Strengthen the capacity of local agro-business organizations to improve distribution
Formation of major seed and fertilizer alliances to increase supply of inputs
Promote use and adoption of available improved seed/varieties sustainable water/soil
management and post-harvest technologies
All pesticide-related activities referenced in MARKETS II PERSUAP
Commercialization and Post-Harvest Activities (food processing)
Construction of water catchments and small scale irrigation technologies to provide irrigation and
potable water
Small scale construction of food storage warehouses and cold storage facilities
Aquaculture
Provision of agricultural credit guarantees via NIRSAL
Technical assistance to DCA-supported SME loan facility for agricultural value chain
development
Technical assistance to Power Africa-related DCA loan portfolio guarantee (LPG), portable
guarantee (PG) or loan guarantee agreements between international and local commercial bank(s)
to support, e.g., (a) capital expenditure needs of recently privatized generation and distribution
companies in Nigeria, (b) financial risk mitigation in loaning to a solar leasing company (Amp
Ventures) seeking to deploy throughout Nigeria, and (c) others to be determined.
T.A. for GDA through PFAN
Sub-grant Activities (Project Development Facility and Innovation Funds).
Synopsis of Recommended Determinations. Activities Categorically Excluded from further
environmental review are not listed, for the most part. See Table 1 in IEE narrative.
Illustrative Activity ND/C Potential PD Deferral Link to
Analysis
IR 2.1 -- Agricultural Competitiveness Increased
Strengthening the capacity of local agro-business
organizations to improve private sector distribution
of inputs.
X Click here
Use and adoption of improved seed,
sustainable agriculture practices and potentially
X Click here
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 4
Illustrative Activity ND/C Potential PD Deferral Link to
Analysis
profitable post-harvest technologies.
Support activities addressing warehouse receipt,
agricultural commodity trading and accessible
market information systems; meeting market
standards.
X Click here
Support activities addressing public and private
investments that advance agricultural value chain
and efficient agricultural marketing such as storage
facilities, cold storage, packaging facilities, and
agricultural processing facilities.
.
X
Click here
Conduct value chain analysis of major targeted
commodities such as rice, maize, cassava, soybean,
sorghum and aquaculture.
X Click here
Construction of water catchments and small scale
irrigation technologies to provide irrigation and
potable water and
X Click here
Promotion of the production and utilization of
cowpeas, shea nuts, poultry, small ruminants,
vegetables or other nutritionally important and /or
marketable products
X Click here
Administer grant funds: (a) Innovation Fund
(b) Project Development Facility Fund
X Click here
Develop small-scale storage sheds to store crops
and other commodities for later sale or for use as
collateral towards credit or insurance
X e
Click here
Support food Processing and packaging to
significantly reduce in current wastage and ensure
extended access
X
Procurement, use, promotion of, or training use of
pesticides, including herbicides, and fungicides.
X X Click here
Activities involving the field testing or open release
of genetically modified organisms (GMOs)
X Click here
IR 2.2 -- Energy Access Activities
Assist in privatizing existing state energy
companies, developing the frameworks and
promoting projects for private investment in energy
resources exploration and production, processing
and conversion, transmission and transportation,
and distribution and delivery of energy to end-users
Cat. Ex.,
unless FI1
involved,
then ND/C
Click here
DCA loan guarantees and T.A.
Nigeria Promoting Renewable Energy and Energy
Efficiency Project.
Component 1: DCA instrument to provide partial
credit guarantees to local Banks to increase debt
financing to the clean energy sector.
X
X
Click here
1 FI = Financial intermediation
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 5
Illustrative Activity ND/C Potential PD Deferral Link to
Analysis
Component 3: T.A. for the successful
implementation of the Energy sector activities. .
X
Nigeria Promoting Renewable Energy and Energy
Efficiency Project.
Component 2: GDA with the Private Financing
Advisory Network (PFAN),
X
Click here
Participate in power generation while also building
the capacity of the electricity regulator to
effectively regulate and incentivize the private
sector participation in the power sector.
X
PD could apply, if
“participation”
includes support
of construction
Click here
IR 2.3 -- Enabling Environment Activities
Support Corridor Management Group (CMG) to
improve coordination along the Lagos—Kano—
Jibya transportation corridor connecting the port of
Lagos with the inland countries of Chad, Niger and
Burkina Faso.
Cat. Ex, but
if includes
FI, then
ND/C
If “support ”
includes support
of actual
construction, then
PD could apply
Click here
Provide technical assistance to the GON on voltage
management and liberalization of the power
sector.
If includes
FI, then ND
w conditions
: Click here
Provision of Agriculture credit guarantees by
working with the Nigeria Incentive-Based Risk-
Sharing System for Agricultural Lending
(NIRSAL).
X Click here
Provide technical assistance to financial institutions
who house the DCA guarantee for investment in
small and medium renewable and energy efficient
companies; agro processing, and warehousing
companies, and public and private facilities willing
to retrofit facilities with clean energy.
X Click here
Monitoring and Implementation
In addition to the project-specific conditions enumerated in Section 4, the negative determinations
recommended in this IEE are contingent on full implementation of the following general monitoring and
implementation requirements:
These require:
1. Implementing Partner briefings by DO team in collaboration with the MEO on Environmental
Compliance Responsibilities during the post award conference;
2. Development of environmental mitigation and monitoring plans (EMMPs) for projects with at
least one negative determination with conditions;
3. Each Implementing Partner shall integrate their EMMP into their project work plan and budgets,
implement the EMMP, and ensure a project reporting that tracks EMMP implementation.
4. Integration of compliance responsibilities in prime and sub-contracts and grant agreements;
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 6
5. Assurance of sub-grantee and sub-contractor have capacity to implement and monitor IEE & EA
conditions;
6. The extended EGE DO Team (incl. implementing partners) have environmental management
capacity to ensure compliance;
7. As part of its work plan and all annual work plans thereafter, IPs, in collaboration with their
COR/AOR, shall review all on-going and planned activities to determine if they are within the
scope of this IEE, and
8. Compliance with host country requirements.
Annexes:
Annex 1: List of the awards that are active @ September 30, 2013
Annex 2: Washington/Regional Related IEEs
Annex 3: USAID Africa Bureau Fertilizer Information Sheet
Annex 4: DCA Loan Agreement Conditions
Annex 5: Environmental Mitigation and Monitoring Plan (EMMP) Template Annex 6: Environmental Screening Form for Sub-grant/New Activities Proposed under USAID/Nigeria DO 2 Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small scale water supply
Annex 8: Category of Mandatory EIA studies in Nigeria
Annex 9: Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility
Policies
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 7
APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:
CLEARANCE:
Mission Director: ____________/s/________________ Date: _02/13/2014___
Michael T. Harvey
CONCURRENCE:
Africa Bureau Environmental Officer: ________/cleared/__________________ Date: __08/07/2014__
Brian Hirsch
Approved: ____X_______
Disapproved: ____________
Filename: Nigeria_DO2_Econ_Growth_Env_IEE_080714.
REA/WA Tracking Number: NG-13
ADDITIONAL CLEARANCES:
Economic Growth and Environment Director: _________/s/_____________ Date: __12/19/2013__
Sharon Pauling
Regional Environmental Advisor (USAID/WA): ______/s/_____________ Date: 02/09/2014___
Jody Stallings
Mission Environmental Officer: ______________/s/_________________ Date: ___12/16/2013___
Nduka Okaro
APPROVAL OJF ENVIRONMENTAL ACTION RECOMMENDED:
CLJEARl\NCE: ' I .
Mission Director: Date: .·; :.. :· =~· / ,.. " --------Michael Harvey
CONCURRENCE:
Brian Hirsch u Approved:
Disapproved: _ _ _ _ _
Filename: _ _ _=.;R=E=A=-/W~A..::.....;:T'""'r=ac=ki='=ng=-=-N=' u=m=b"-'e=r,;_: N.:...,;,,;:;G;;.....-..;,,;13=----------
OPTIONAL CLEARANCE:
General Counsel (Africa Bureau): __ _,_}J"""""4}_:/k.._ ..:._ _____ Date: I
ADDITIONAL CLEARANCES:
Date:_~ I/
Sharon Pa\iliug
Regional Environmental Advisor (USAID/WA): .;,, ;~.,. i-:,; :J,_·:;,y~..._,;... ·:.t ~ Date: o:;..: / c - I 7.. t/~· . , ~, ,. . ' - - - --
Jody Stallings
Mission Environmental Officer: ___ JL_cl_\ _ _ ~~t'i-_1 _____ _ Date: _ i _ / I:, l: _ _ -:i
Nduka Okaro
NG IEE 002 Page 5
C !L F.AR.i\N ("""'.:
~tission Oi~c, : r:
Mid::e~ T. ~·::- -~y
Africa Bureau Environmcn1:1I (),·:-ccr:
Brian Hi~oc 1:
Filename:
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Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 8
INITIAL ENVIRONMENTAL EXAMINATION
Program Number and Title: USAID Nigeria Development Objective 2 IEE: Broadened, Diverse
and Inclusive Private Sector-Led Growth
Country/Region: Nigeria, West Africa
1.0 BACKGROUND AND ACTIVITY DESCRIPTION
1.1 Purpose and Scope of the IEE
In accordance with 22 CFR 216, this IEE reviews the reasonably foreseeable effects of each activity on
the environment. On this basis, the IEE recommends Threshold Decisions and in some cases attendant
conditions for these activities. This IEE is specific to the Economic Growth and Environment (EGE)
Office as Development Objective Two (DO2) under the USAID Nigeria FY2014 – FY2018 CDCS. DO2
emphasizes USG activities in Nigeria to increase agriculture competitiveness necessary to support
sustainable, diverse, and inclusive economic growth. The interventions will support farmers, private
sector farm inputs dealers, agro-processors and expanding trade and transportation along a South-north
trade corridor. Household and community resilience as well as increasing energy access are supported.
The DO2 activities are grouped in three intermediate result areas, namely Agricultural Competitiveness
Increased; Energy Access Increased and Enabling Environment Improved. They also align with the
following Foreign Assistance Objective 4: Economic Growth; Program Areas 4.2 (Trade and Investment)
4.3 (Financial Sector), 4.4 (Infrastructure), 4.5 (Agriculture) and 4.8 (Environment).
This IEE synthesizes current and anticipated Economic Growth and Environment Office activities under
the office’s various programs and projects into a set of intervention categories, each of which contains a
number of entailed activities. Of the 14 current USAID/DO2 activities listed in Annex 1, 7 are either field
support, regional buy-in or centrally funded and the other 7 are directly managed within USAID/DO2
team. The field support and centrally funded activities fall under separate approved Initial Environmental
Examinations (IEEs). For example, field trials are addressed in the IEE approved by EGAT/ESP on July
19, 2010 for the Field trial of Bioengineered Cowpea Resistant to Maruca Pest and an amended version
approved by the Bureau for Food Security (BFS) Environment Officer on August 09, 2011. The Regional
buy-in of the West Africa Seed Program (WASP) IEE was approved by the Afr. Bureau Environment
Officer on July 06, 2012 (Annex II)
This IEE covers USAID/DO2 active awards or awards likely to be extended beyond September 30, 2013
by the following Implementing Partners (IPs):
1. Chemonics International Inc.
2. International Centre for Energy, Environment and Development (ICEED)
3. CARANA Corporation
4. Catholic Relief Services (CRS)
5. United States Department of Agriculture (USDA)
6. National Association of Regulatory Utility Commissioners (NARUC)
7. International Food Policy Research Institute
8. Nexant, Inc.
9. Monitor-Deloitte
10. Winrock
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 9
11. DCA with Eco Bank Nigeria
12. DCA with First Bank Nigeria and Zenith Bank Nigeria.
13. TBD (New Awards)
A list of the bilateral awards that are active and/or planned during the period May 2010-September 2014
is attached (Annex 1), and while additional bilateral activities may be designed during the next few years
as the program under the CDCS evolves, the majority of USAID DO2 activities will continue to be
implemented using the existing mechanisms.
The IEE also sets out project-level implementation procedures intended to assure that the conditions in
the IEE are translated into project-specific mitigation measures, and to assure systematic compliance with
this IEE during project and program implementation. These procedures are themselves a general
condition for approval of this IEE, and their implementation is therefore mandatory.
1.2 Background and Activity Description
Nigeria has enjoyed relatively strong economic growth over the past eight years but poverty remains a
major concern, with 61.2 percent of the population living below the poverty line. While oil accounts for
95 percent of export earnings and 85 percent of government revenues, agriculture, undoubtedly remains
the most important sub-sector in the Nigerian economy next to petroleum, employs 70 percent of the
population, but accounts for only 2.6 percent of exports. Many West African countries are landlocked and
rely heavily on neighboring countries for food. Due to Nigeria’s geographic location, fertile land, and
government commitment to strengthening the agricultural sector, the country can become an important
player in regional food security and trade. Further, economic growth in Nigeria remains constrained by
inadequate infrastructure and electricity, policies that inhibit private sector investment, insufficient water
and sanitation facilities, and poor access to quality education. While the bulk of the water and sanitation
activities are under the Investing in People Health Area, provision of the services to vulnerable
populations and agro-processors are covered in this IEE.
Rural areas suffer more from lack of basic infrastructure. This trend further exacerbates the decline in
living standards in rural areas and translates into increased levels of poverty. Poor rural road
infrastructure negatively impacts on agricultural profitability and productivity, the associated higher
transportation costs to carry goods to markets, limited access to inputs, and increased crop spoilage are of
great concern.
The Sustainable, diverse and Inclusive Economic Growth Development Objective builds on EGE’s draft
Multi-Year Feed the Future (FTF) Strategy (2013-2018) prepared in November 2012 and the analyses and
consultations conducted during its preparation. This draft strategy identified three “core investment
areas:” (1) transforming value chains, (2) addressing vulnerabilities, and (3) improving the enabling
environment. Over the past two decades agricultural yields have remained relatively stagnant, with
increases in production more due to expanding land under cultivation, rather than gains in yield. Yields
have remained very low; however, the increased yield observed in USAID targeted areas is indicative of
potentials for increased yield in Nigeria.
Nigeria’s lack of sufficient electrical power is one of the biggest hindrances to economic development.
Currently, Nigeria generates 50 percent below its installed capacity of 6,000 megawatts (MW) for a
population of more than 170 million people. This leads to chronic power shortages and widespread use of
inefficient small generators to meet energy demands. Businesses may spend between 30-40 percent of
their revenue on diesel to power generators. Without a significant increase in electricity supply, Nigeria’s
other efforts to create growth, reduce poverty and contribute to reducing conflict in the country will have
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 10
limited impact.
USAID Nigeria is one of six core Missions whose energy sector interventions and transactions are
contributing to the Agency’s five-year Power Africa Initiative to support economic growth and
development by increasing the supply of and access to reliable, affordable and sustainable power in sub-
Saharan Africa. USAID is providing targeted T.A. to the key energy sector actors such as the Nigeria
Ministry of Finance, PPP Unit, and the Transmission Company of Nigeria. It is also buying in to the
Power Africa Transactions and Reform Program (PATRP) contract.
The following is a description of each intermediate results and illustrative activities. Activities with
physical intervention on the environment will be implemented across the national six geo-political zones
and nearly 20 out of the 36 states in Nigeria. (Annex 1)
1.3 ACTIVITY DESCRIPTION
1.3.1 Agricultural Competitiveness Increased ( IR 2.1)
Increasing agriculture competitiveness is necessary to support broadened, diverse, and inclusive private
sector-led growth as most of the population depends on agriculture for employment. To become
competitive, agriculture productivity must increase. Interventions to support this include assistance to
farmers, support for private sector provision of farm inputs, and support to agro-processors. The focus
will be on the alignment of Mission activities with the priorities of the Nigerian government’s Agriculture
Transformation Agenda.
This specifically involves (1) working with target value chains, rice, cassava, sorghum, cocoa, and
aquaculture. (In addition, maize and soy will be treated as sub-value chains as they are major ingredients
of fish feed, the cost of which is a major constraint in aquaculture.) Interventions will provide
smallholders with access to better inputs, such as seed and fertilizer, adequate finance, better water
management, appropriate technology, and extension services, and link farmers with pre- and post-harvest
private sector processors and producers. (2) Supported in expanding agricultural trade by improvements
in custom and trade facilities; and provision of business development services, particularly for firms
wishing to export Nigerian products. (3) Increased household and community resilience, with a particular
focus on women’s contributions, supports agriculture competitiveness, as much of this depends upon the
ability of households and communities to increase their nutritional and financial well-being, allowing
them to respond better to external and internal shocks, increasing agricultural productivity and quality of
produce over time thereby entering commercial markets. (4) Private sector participation in all segments
of the agricultural value chain is critical to increasing competiveness. (5) Due to the large capital outlay in
funding feeder roads and large irrigation projects, USG interventions will be limited to preliminary
studies and design work in support of the feeder roads projects sponsored by the World Bank and AfDB.
Illustrative Activities:
Strengthening the capacity of local agro-business organizations to improve private sector distribution of
agricultural inputs, and formation of major seed and fertilizer alliances toward increase the supply of
quality seed, fertilizer, and other inputs to millions of small-holder farmers and stimulate productivity
increases.
Enhancement of the capacities of small and medium agro-enterprises, producer organizations/associations,
(male and female) through training to increase businesses and entrepreneurial skill, contract negotiations,
product management, and organizational governance.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 11
Promotion of the use and adoption of available improved seed/varieties of target crops; sustainable soil and
water management practices (e.g. drip irrigation, improved fallows, and inorganic and organic fertilizer
application, integrated pest management techniques, small irrigation technologies and management); and
potentially profitable post-harvest technologies.
Support activities addressing warehouse receipt, agricultural commodity trading and accessible market
information systems; meeting market standards; and public and private investments that advance
agricultural value chain and efficient agricultural marketing such as storage facilities, cold storage,
packaging facilities, and agricultural processing facilities.
Support the transfer and adaptation of proven technologies and human organization innovations to increase
market access, food or cash transfers in exchange for public works; and resource transfers and/or
agricultural inputs (e.g. seeds, tools, and livestock) which enable male and female producers to try new
technologies and production methods that would otherwise not be available to them
Conduct value chain analysis of major targeted commodities such as rice, maize, cassava, sorghum, and
aquaculture; expanding new multi-partner value chain alliances; and increasing business capacity of
agricultural firms.
Support construction of water catchments to provide irrigation and potable water and encourage farmers to
rear small stock that require less feed and support agro-processors water supply need within targeted
commodity value chains.
Support marketing campaigns to improve the visibility and raise awareness of Nigeria’s products and
branding. Production of marketing materials and educational guides needed to raise awareness and
understanding of market information systems.
Support nutrition education and awareness, introduction of more nutritious and fortified foods;
collaboration with the HIV/AIDS and Tuberculosis Office on the procurement and distribution of fortified
foods.
Promotion of the production and utilization of cowpeas, shea nuts, poultry, small ruminants, vegetables or
other nutritionally important and /or marketable products that do not require large land areas and are often
classified as poor people’s or women’s activities;
Procurement, use, promotion of, or training use of pesticides, including herbicides, and fungicides.
Conduct performance and impact evaluations of targeted value chain interventions and studies on
diversified economic opportunities to demonstrate innovations and technologies that reduce women’s labor
burden and/or increase productivity of labor.
Administer grant funds: (a) Innovation Fund to promote innovative applications (ideas, processes,
equipment, training, designs) that can be introduced into the commodity value chain to enhance
productivity, increase efficiency, improve a process or otherwise lead to some practical benefit to producers
or to agri-businesses (b) Project Development Facility Fund to provide technical assistance to enterprises
in creating a bankable export business plan, market assessments, bringing products up to international
standards, packaging and labeling requirements, food testing certification, SPS standards, transportation,
marketing and sales.
1.3.2 Energy Access Increased (IR 2.2)
Electricity access is considered to be a significant constraint to development of the private sector, and
unreliable and insufficient supply remains a significant bottleneck to economic growth and agriculture
competitiveness. An increase in demand for energy typically occurs as the commercial agriculture sector
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 12
grows. Nigeria’s capacity to produce clean renewable energy is also very limited.
Increasing energy access as measured by household and business access to affordable electricity and
volume of electricity generated and distributed, will be supported through extensive participation of the
private sector and through a diversification of energy sources, to include gas, hydro, wind and solar.
Finally, an improved Energy Sector enabling environment, as described as part of IR 3 below, will
provide the legal & regulatory, capacity strengthening and access to credit reforms to support further
attainment of these results.
These energy sector activities, interventions and transactions are contributing to the Agency’s five-year
Power Africa Initiative to support economic growth and development by increasing the supply of and
access to reliable, affordable and sustainable power in sub-Saharan Africa. USAID Nigeria is one of the
six core countries included in Power Africa, and is providing targeted T.A. to the key energy sector actors
such as the Nigeria Ministry of Finance, PPP Unit, and the Transmission Company of Nigeria. It is also
buying in to the Power Africa Transactions and Reform Program (PATRP) contract.
Illustrative Activities:
Assist in privatizing existing state energy companies, developing the frameworks and promoting projects
for private investment in energy resources exploration and production, processing and conversion,
transmission and transportation, and distribution and delivery of energy to end-users
Build the capacity of the Ministry of Petroleum Resources to work with the private sector to end gas flares
in the Niger Delta through the GON Accelerated Gas Development Project (AGDP).
Build the capacity of the electricity regulator to effectively regulate and incentivize private sector
participation in the power sector.
Provide technical support at the state level on the development of renewable energy resources and provide
support to Cross River state on a pilot small hydro project to encourage the generation of clean energy with
plans to expand it across other states with renewable energy resources.
Deployment of energy efficient cook stoves to secondary schools, build the capacity of artisans to produce
these stoves thereby creating employment,
Support an advocacy campaign for the adoption of policies that would create an environment for the stoves
to penetrate the market, and launch a tree planting campaign for afforestation.
Work with Commercial Banks through the use of the Development Credit Authority mechanism to
encourage debt financing for clean energy project.
Illustratively, in 2014, at least two energy sector DCA loan guarantees are being negotiated in Nigeria: (a)
DCA to provide a loan guarantee on a $95 M loan from Standard Chartered Bank to Zenith Bank Nigeria.
The proceeds of the loan will be used to support capital expenditure needs of recently privatized generation
and distribution companies in Nigeria. (b) DCA to provide a loan or portable guarantee (PG) on a ~$40 M
loan from a TBD commercial bank to Amp Ventures. Amp is a solar leasing company seeking to deploy
their model throughout Nigeria by partnering with banks, fueling stations and telecommunications
companies.
Work through the Climate Technology Institute private financing advisory network to mentor clean energy
project developers in preparing bankable business plans for equity financiers.
The Nigeria Promoting Renewable Energy and Energy Efficiency Project takes a three-pronged approach to
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 13
developing the renewable energy and energy efficiency markets in Nigeria. The first component of the program
establishes a Development Credit Authority (DCA) instrument to provide partial credit guarantees to local Banks
(initially Eco Bank and First Bank) in order to increase debt financing to the clean energy sector. The second
component is a Global Development Alliance (GDA) with the Private Financing Advisory Network (PFAN), which
will link investors/financiers and clean energy project developers to help produce ‘’bankable’’ project and equity
financing proposals. The third component will provide technical assistance for the successful implementation of the
Renewable Energy Project which will be implemented through an Associate Award (cooperative agreement) under
the USAID/E3 Renewable Energy Leader with Associates Agreement (LWA) with Winrock International.
The technical assistance component of the Renewable Energy Project under the LWA will develop (i) capacity of
financial institutions, particularly the DCA banks, to ensure optimal utilization of the DCA guarantee; (ii) capacity
of companies in the clean energy sector and those in selected sectors seeking to utilize renewable energy, to provide
a pipeline of potential deals for the DCA banks; (iii) capacity of government institutions to encourage the enactment
and implementation of appropriate legislation to incentivize private sector participation in the development of the
clean energy market, and (iv) capacity of vocational training institutes, to strengthen the cadre of non-qualified and
qualified professionals to install, operate, and maintain decentralized renewable energy investments.
1.3.3 Business Environment Reformed (IR 2.3)
An improved enabling environment is at the base of support to achieving the intermediate results and the
development objective. An important component will be the implementation of a policy framework that
encourages increased private sector investment in the agricultural and related sectors (water, energy,
transportation). The GON joined “Grow Africa” in June 2012 and the New Alliance for Food Security
and Nutrition in June 2013. Both initiatives are predicated on the essentiality of private sector investment
for sustainable increase in agricultural sector growth. The Mission’s activities supporting this
intermediate result will focus on policies that support private sector-driven development with the
government playing a regulatory role and building the capacity within the government to conduct
evidence-based policy analyses.
1.3.3.1: Agricultural Sector Enabling Environment:
Agricultural enabling environment in Nigeria has been considered confusing, conflicting, and
counterproductive. Changes in the policy environment are called for to increase private sector
investment. There is insufficient transparency and accountability, limited incentive to mitigate perceived
risk, and relatively high costs for supporting services (i.e. transportation, utilities, and security). Thus the
enabling environment to attract new investment in agriculture is weak, but could quickly improve with
appropriate government intervention. Along with government, , USG will continue to play an important
catalytic role in the policy development process by providing the analytical justification/framework for
changes in existing policies or for adoption of new policies that foster agricultural growth and improve
food security. A national Biosafety Bill, will pave the way for the safe handling, importation, and export
of genetically modified organisms, improved seeds, and consequently enhance Nigeria’s food security.
Enhanced capacity of GON to evaluate and address crucial biotechnology policy issues and to implement
an agricultural biotechnology program is critical.
Illustrative Activities:
Conduct a climate change vulnerability assessment to identify gaps and key areas for Mission cross cutting
intervention in adaptation.
Support the Famine Early Warning System Network (FEWSNET), an early warning system that monitors
food security, rainfall, production and postharvest losses in order to prepare for disaster and anticipate the
amount of food aid needed in case of drought.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 14
Support the GON’s Agriculture Transformation Agenda (ATA) through investment prioritization and the
preparation of state agricultural investment plans; conducting research and analysis in key policy areas
including input availability, land governance, water resources and irrigation; and improving knowledge
management and analyses for agricultural planning.
Support public education on key agricultural policies and progress toward developing and implementing
them. Use of media in creating awareness amongst all stakeholders regarding the policy process and the
implementation of policies key to the economic and social resilience. Creation of appropriate mechanisms
and opportunities for vulnerable populations to engage in policy dialogue.
Support the development of specific guidelines and regulations that ensure biotechnology laws are
functional; support the National Biosafety Management Authority (NBMA) to conduct evidence-based
reviews for decision-making; and developing and implementing a strategy for bio-safety outreach and
communication.
Build government capacity to develop agricultural statistics and information systems; introduce best
practices to improve commodity storage and handling to reduce post-harvest losses; and provide technical
assistance to develop a food safety policy.
Build public and private sector capacity to analyze the impact of trade and investment agreements on
economic growth, productivity, employment, poverty, gender equity, fiscal revenues, and other national
and individual male and female stakeholders’ interests.
Support institutions, policies and incentives aimed at ensuring that adequate, safe, and nutritious food is
available; markets function efficiently; and that low-income groups and those vulnerable to food insecurity
(e.g., female farmers with small land holdings, female-headed households, children, and HIV-affected) are
able to access and appropriately utilize that food.
Support public education on key policies and progress toward developing and implementing them. Use of
media in creating awareness amongst all stakeholders and creation of appropriate mechanisms and
opportunities for vulnerable populations to engage in policy dialogue.
Promote public forums at national, state and local government levels for all relevant stakeholders
(including youths and women) around commodity value chain issue and policy changes.
1.3.3.2: Agricultural Trade Enabling Environment:
The overall goal of trade enabling environment is to strengthen trade policy and trade facilitation
environments that promote development of Nigeria’s non-oil export (in particular agribusiness) sectors.
Its purpose is to facilitate creation of an inclusive system of trade policy formulation and implementation
through capacity-building for public and private institutions to drive trade facilitation and trade
competitiveness in Nigeria. A current activity, Nigeria Expanded Trade and Transport (NEXTT) is
supporting GON in three interrelated tasks: capacity building for trade policy formulation and
implementation; support for customs modernization; and support for institutional capacity building on
standards and food safety.
Illustrative Activities:
Support trade liberalization. Build the capacity of the public sector to meet requirements for accession to
the WTO and participating effectively in the WTO system and to meet other international agreements such
as the U.S. Free Trade Area agreements and Bilateral Investment Treaties
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Provide technical assistance in developing implementing regulations and policies for the new CEMA and
capacity building and training for the Nigerian Custom Service (NCS) to improve its ability to oversee the
new regulatory framework. Provide training in valuation and the use of tools such as scanners to help NCS
attain its goal of internalizing destination inspection services.
Provide training on benchmarking effectiveness of trade facilitation metrics and the implications of these
for customs modernization
Support Corridor Management Group (CMG) to improve coordination along the Lagos—Kano—Jibya
transportation corridor connecting the port of Lagos with the inland countries of Chad, Niger and Burkina
Faso.
Conduct analyses and issue reports supported as necessary by a team of technical experts that explain key
factors impeding or facilitating progress toward access and use of financial services by beneficiaries
1.3.3.3: Energy Sector Enabling Environment:
For energy, enabling environment work will include assistance to the energy sector, which will expand
efforts to privatize the electricity sector and increase independent power production. Reform efforts will
intensify regarding electricity transmission and revenue collection for distribution companies, and
additional efforts to capture flared gas for export and for the domestic market. Much of this will involve
continued attention to technical assistance for relevant governmental agencies responsible for the reform
and post-privatization, and for developing legal, regulatory and financial capacity, and the exploration of
financial backing in coordination with financial institutions for sound, bankable energy projects.
These activities, interventions and transactions are part of the Agency’s five-year Power Africa Initiative.
Illustrative Activities:
Provide technical assistance and training to policy makers in the power and oil and gas sector, embedding
an advisor into the Nigerian Bulk Electricity Trading Company to improve its capacity to negotiate, and
procure competitive electricity.
Create a renewable energy regulatory framework, a cost reflective tariff; and improve the regulatory
environment for private sector investments.
Support GON efforts to improve the policy and regulatory environment for clean energy production; reduce
gas flaring and make captured gas available for the generation of clean energy; provide technical assistance
to the GON on voltage management and liberalization of the power sector
Provide technical assistance to financial institutions who house the DCA guarantee; small and medium
renewable and energy efficient companies; agro processing, health care delivery and warehousing
companies, and public and private facilities willing to retrofit facilities with clean energy.
1.3.3.4: Financial Sector Enabling Environment:
Finally, the financial sector must become a full partner in supporting development. Access to credit will
be increased through partial loan guarantees to allow private banks to increase lending. In addition, work
with micro-finance institutions will expand micro-loans. Capacity strengthening for lenders will ensure
they understand the business environment that potential borrowers face in agriculture and energy, and
help ensure a proper flow of information to increase the number of bankable projects. This area will
require significant attention beyond what has been done to date, and will be a focus of this strategy
period. There exist a cross-cutting energy/agriculture loan portfolio guarantee with two guaranteed banks
was recommended addressing limited access to finance constraints in the renewable energy and
agribusiness sectors. The guarantee supports both banks’ expansion into funding projects in agribusiness
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 16
(non-renewable energy activities) and renewable energy activities involving solar, biomass, hydro, wind,
clean cook stoves, and energy efficiency activities by small- and medium-sized enterprises (SMEs),
thereby increasing access to finance on positive terms to creditworthy but underserved potential clients. Illustrative Activities:
Increased basic financial, education and entrepreneurial skill development through increased financial
capabilities of men and women in targeted zones, both for targeted and non-targeted value chains.
Continued Technical Assistance and training for producer groups though training and marketing
Provide technical assistance to financial institutions who house the DCA guarantee; small and medium
renewable and energy efficient companies; agro processing, health care delivery and warehousing
companies, and public and private facilities willing to retrofit facilities with clean energy.
Provision of Agriculture credit guarantees by working with the Nigeria Incentive-Based Risk-Sharing
System for Agricultural Lending (NIRSAL).
2.0 Country and Environmental Information (Baseline)
2.1 Nigeria’s Physical and Socio –Economic profile Nigeria has has a vast land area of about 923,770 square kilometers of which about 70 million hectares
are farmland. It is bounded by Cameroon and Chad Republic to the East, Niger Republic to the North
and Benin Republic to the West. The southern coastline is dominated by the delta of the River
Niger. Nigeria is the largest country in tropical West Africa but only the twelfth largest country in Africa,
however, a quarter of the continent’s people live in Nigeria, a greater population than any other African
country.
The nation features a great diversity of ecosystems - from the rainforest through dry savannah to dry lands
and flat coastal zones to plateaus and highlands. It boasts of a few large patches of natural lowland and
montane forests, important freshwater wetlands, savannas, high-altitude plateaus, mangroves, and coastal
areas under various climatic conditions, resulting in an internationally recognized abundance of
biodiversity. Unique primate species like the Cross River gorilla (Gorilla gorilla diehli), the drill
(Mandrillus leucophaeus), and a number of smaller guenons are found only in Nigeria and adjacent forest
areas. An extraordinary diversity of butterflies, amphibians, and other species has been tallied in Nigerian
habitats. Many crop species also originated here, and a diversity of land races still exists in the country.
Surrounding these remnant natural areas are villages, agricultural lands, and cities. As the most populous
country in Africa, Nigeria faces extreme pressures on biodiversity and tropical forests. Wildlife, trees, and
many other plants are over-harvested and poached, and the natural environment faces increased
degradation from expanding unsustainable agriculture, water pollution, air pollution, and a variety of
other anthropogenic factors. Desertification and climate change add to the stress. Lack of information
about the present status of most habitats and species, about the actual extent of protected areas, and about
other key data makes management difficult. Policymakers, managers, and technical staff at all levels need
better information and further training to better fulfill their functions related to biodiversity and forest
conservation and management.
Soils in Nigeria are variable due to variations in the geological for nations and climate. More predominant
in the country is the ultisols which covers about 46% of the total area of the country. Though it is of
moderate to low productivity, it performs very well under good management. Only 6% of the country is
covered by entisol - the high productive soil. Nigeria has also been classified into eight Land Resources
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Zones, namely: semi-arid, dry sub-humid. sub-humid, humid, very humid, ultra-humid, plateau and
mountain zones. Most, if not all of these ecological niches have witnessed pressure resulting from
uncontrolled socio-economic activities leaving a large proportion of the land barren.
The intensification of the use of fragile and marginal ecosystems has led to progressive degradation and
continued desertification of marginal agricultural lands even in years of normal rainfall. It is feared that
the damage by drought and population pressure may have resulted in the genetic loss of a vast array of
valuable plant species. Pressure on the dwindling resources in the arid prone areas has caused in a number
of devastating socio-political and sectarian conflicts in the country with concomitant death, injury and
heavy economic losses. Inappropriate agricultural practices, the destruction of watersheds, and the
opening up of river banks and other critical areas have led to silting of river beds and loss of water
courses. Uncontrolled use of agro-chemicals and the concomitant problems of chemical persistence in the
soil in humid areas and soil-crust formation in arid climates have contributed to salinization and
destruction of vast agricultural lands. National policy objective is to evolve sound planning and
management of land resources in the country.
Nigeria has enormous natural resources. It has about 34 different minerals across the country (including
gold, iron ore, coal, tin, uranium, phosphates, and limestone), 37.2 billion barrels of proven oil reserves
and 187 trillion cubic feet of proven natural gas. Also, there are opportunities for fertilizer and liquefied
gas production. With average production of about 2.3 million barrels of crude oil per day, Nigeria is the
largest exporter of crude oil in Africa and tenth largest in the world. The Nigerian economy is the largest
in West Africa and the second largest in sub-Saharan Africa, predominantly oriented toward the
production of agricultural products and crude oil. Agriculture accounts for about 30.9% of the GDP,
70.0% of employment but contributes only about 2.5% of export earnings. Crude oil and natural gas
account for about 15.0% of GDP, 71.0% of export earnings and 79.0% of government revenue.
2. 2 Nigeria Environmental Policies and Procedures
The goal of Nigeria’s national environmental policy is to achieve sustainable development based on
proper management of the environment. Primarily, the policy thrusts are to: secure a quality of
environment adequate for good health and well-being; conserve and use the environment and natural
resources for the benefit of present and future generations; restore, maintain and enhance the ecosystems
and ecological processes essential for the functioning of the biosphere to preserve biological diversity and
the principle of optimum sustainable yield in the use of living natural resources and ecosystems; raise
public awareness and promote understanding of the essential linkages between the environment, resources
and development, and encourage individual and community participation in environmental improvement
efforts; and co-operate in good faith with other countries, international organizations and agencies to
achieve optimal use of trans-boundary natural resources and effective prevention or abatement of trans-
boundary environmental degradation.
From ecological and economic standpoints, soil erosion is probably the most serious environmental
problem affecting the nation's soil and land resources. National policy objective is to evolve sound
planning and management of land resources in the country.
The National Energy Policy places emphasizes on the exploitation of Nigeria's renewable and alternative
energy sources - wind, solar and biomass, and provides guidelines for environmental protection in the
exploitation of Nigeria's fossil energy sources. It is yet to be enacted into law.
Environmental issue is administered by the Ministry of Environment at the Federal and States levels with
Environmental Health department at Local Government level. Established legislations relating to
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environmental management include;
The Harmful Waste (Special Criminal Provisions) Act, 1988
The National Environmental Standards and Regulations Enforcement Agency Act 2007
(NESREA ACT, repealed the Federal Environmental Protection Act of 1988) - which is being
developed into the National Environmental Management Bill
Environmental Impact Assessment Act of 1992 - National Environmental Protection
(Management Procedure on Environmental Impact Assessment) Regulations (The principal
legislation which made EIA mandatory for both public and private sectors for all development
projects).
Environmental Impact Assessment (EIA) Act Cap E12,LFN 2004 (which sets out the general
principles, procedures and methods of Environmental Impact Assessment in various sectors)
Pest Control of Production (Special Powers) Act, CAP P9 LFN 2004
Agriculture Act and its Plant (Control of Importation) Act, CAP A93 LFN 2004
Sea Fisheries Act Cap. S$ LFN 2004
Endangered species Act Cap. E9 LFN 2004
Relevant regulations are
National Environmental (Sanitation and Wastes Control) Regulations, 2009)
THE National Environmental Protection (Pollution Abetment in Industries and Facilities
Generating Waste) Regulations
The Nigerian Constitution allows States to make legislations, laws and edicts on the Environment. The
ESIA Decree No. 86 of 1992 also recommends the setting up of State Environmental Protection Agencies
(SMENV), to participate in regulating the consequences of project development on the environment in
their area of jurisdiction. SMENVs thus have the responsibility for environmental protection at the state
level within their states. The functions of the SMENV s include:
Routine liaison and ensuring effective harmonization with the FMENV in order to achieve the
objectives of the National Policy on the Environment;
Co-operate with FMENV and other relevant National Directorates/Agencies in the promotion of
environmental education;
Be responsible for monitoring compliance with waste management standards;
Monitor the implementation of the ESIA and the Environmental Audit Report (EAR) guidelines
and procedures on all developments policies and projects within the State.
2.3 Agricultural Policies
The Nigerian Agriculture Policy revised in 2001 seeks to attain self-sustaining growth in all sub-sectors
of agriculture, a structural transformation of the overall socio-economic development of the country and
the improvement of livelihoods. Its strategies also aim at achieving self-sufficiency and improvement of
technical and economic efficiency in food production through the introduction and adoption of improved
technologies of production, efficient utilization of resources and the enhancement of producer capacities.
Its macroeconomic policies include appropriate pricing and trade, exchange rate stability and accessible
agricultural land. Sub-sector specific policies covered food production, input supply, subsidy
administration and support services
The policy defined complementary and synergistic roles for all the stakeholders made up of the three tiers
of government: Federal, States and Local Governments; and the private sector in line with the Nigerian
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 19
Constitution provision for facilitative and promotional roles to all the tiers of government in the exclusive
and concurrent legislative lists. It assigned roles to the 3-tiers of Government and Private Sector.
The Federal, state and local governments were required to differently and collectively work towards the
enthronement of a sound policy framework and strategies for reasonable flow of resources into
agricultural and rural development, support rural/agricultural infrastructure development, research and
development of appropriate technology for agriculture (including biotechnology) as well as promote
markets for products, inputs development, regulations and support agricultural service delivery. Others
are to manage Nigeria’s land and water resources, pests and diseases control and bilateral and multilateral
Agreements on Agricultural Trade reached between Nigeria and the World Trade Organization (WTO).
The states were to particularly promote the primary production of all commodities (including direct state-
funded production), extension services and ensure access to land, irrigation and appropriate farm
mechanization systems, etc. Others include credits provision to smallholder farmers, maintenance of
buffer stocks of agricultural commodities, rural development (roads and water supplies) and control of
forest resources. The local governments should provide effective agricultural extension service and
mobilize farmers, cooperative organizations and local institutions for higher production and enhance land
access.
The private sector role in entrepreneurship investments into all aspects of agricultural production and
value chains was maintained. It expects the sector to drive agricultural input chain as well as agricultural
mechanization getting involved in enterprise-specific rural infrastructure and support research in all
aspects of agriculture.
3.0 Potential Environmental Impacts and Recommended Determinations, Including Conditions Some potential environmental issues and impacts are likely with the implementation of activities of the
Development Objective Two provided in this section 1.3. The details of the general potential
environmental impacts of agricultural interventions including small scale irrigation are discussed in this
section. General impacts likely to result from construction activities are also outlined. The list of potential
impacts is indicative rather than exhaustive; these potential impacts are referenced at several points in the
analyses of the various activity categories.
3.1 Environmental impacts of agriculture competitiveness activities
Introduction of new/ improved varieties: There are many ways in which the introduction of
non-native or exotic species negatively affects our environment and the diversity of life. New
crop varieties may constitute a major threat to native biodiversity and they can change an entire
habitat, placing ecosystems at risk and often crowd out or replace native species that are
beneficial to a habitat.
Increased use of high levels of complementary Inputs: Increased production system involves
the inputs such as irrigation, chemical fertilizers and pesticides to achieve maximum yields; this
however, is often accompanied by negative environment impacts. The negative effects of
intensive farming include soil degradation, salinization of irrigated areas, over-extraction and
pollution of groundwater, resistance to pesticides, erosion of biodiversity, etc. Inappropriate use
of pesticides in particular presents profound risk to human and environmental health. While less
potentially harmful to human health, the misuse of fertilizers presents distinct risk to the natural
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 20
environment, with ground and surface water resources most vulnerable to ‘nutrient loading’
through over-application and poor management of agricultural run-off.
Disturbance of natural vegetative covering: This disturbance may lead to increased soil erosion
and vulnerability to landslides. As the soil erodes, less rainfall is absorbed and the excess runs
off. This runoff removes the fertile topsoil necessary for crop production and can have disastrous
off-site consequences, including gully formation, landslides, siltation and sedimentation of water
bodies, downstream flooding, and damage to productive infrastructure. In Northern Nigeria,
particularly in arid and semi-arid areas, the wind can also erode away the soil.
Contamination of water sources: Intensive farming has also the potential for the contamination
of water sources. Surface runoff carries manure, fertilizers, and pesticides into streams, lakes, and
reservoirs, in some cases causing unacceptable levels of bacteria, nutrients, or synthetic organic
compounds. Similarly, water percolating downward through farm fields carries with it dissolved
chemicals, which can include nitrate fertilizers and soluble pesticides, these can contaminate
groundwater supplies. In addition, pesticides impoverish the soil by increasing its toxicity so that
they destroy even more of the soil’s micro-organisms, which progressively results in the loss of
organic matter and soil erosion. Faced with this problem, the farmers add more fertilizer and
further exacerbate the situation or are force farmers to abandon fields.
Dams and irrigation schemes: Such schemes may present a number of distinct environmental
risks. Stagnant water behind dams can create breeding habit for disease vectors. Dams raise local
groundwater levels (which, while sometimes a desired objective, can lead to increased
contamination of groundwater). Excess withdrawals to serve the irrigation schemes can result in
insufficient water for downstream ecosystems and users. Poorly managed irrigation schemes can
result in permanent adverse effects to soil quality (e.g., salinization); they are also pose high risk
of contaminating shallow groundwater and downstream surface waters with agricultural
chemicals. Irrigation can affect downstream water quality by reducing the amount of water
available to dilute contaminants and by potentially increasing agrochemicals pollution.
Agricultural Processing: Such processing has significant potential environmental and health
impacts associated with their operation. In operation, these facilities generate significant
quantities of wastewater and organic wastes. If provisions for waste management are not part of
the facility design and/or if these wastes are improperly managed, these wastes can contaminate
water supplies and/or provide ready habitat for disease vectors such as flies, mosquitoes and rats.
The result is an increase in disease, particularly oral fecal route diseases.
3.2 Environmental impacts of small scale construction activities
Disturbance to existing landscape/habitat: 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/water body, grading and leveling can disrupt local drainage.
Sedimentation/fouling of surface waters. 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. Such risks are particularly acute in the case
of dam construction or rehabilitation where construction is within the stream or riverbed.
Stagnant water: 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 Nigeria.
Adverse impacts of materials sourcing. Construction requires a set of materials often procured
locally: timber, fill, sand and gravel, bricks, etc. 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
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illegal concessions helps drive deforestation. Similarly, the operation of constructed facilities has
a well-known set of potential adverse impacts.
3.3 Environmental impacts of aquaculture activities
Reference is made in the IEE to activities to promote livelihood and income generating opportunities
through small scale aquaculture. Aquaculture work could be complex, and must rely upon specific
expertise to ensure effective implementation. These activities will also require proper impact analysis and
planning to incorporate appropriate mitigation measures into activity implementation. Aquaculture in fish
ponds requires adequate site selection and design to prevent contamination of ground waters from
seepage, impacts to wild fish and aquatic organisms, damage to sensitive wetland ecosystems, and
introduction of invasive fish species that can displace wild fish populations and degrade aquatic habitats,
etc.
Additional operational mitigation measures that maintain ponds clean and suitable for fish production are
also required to control nutrient loading, find disposal and re-use strategies for fish wastes, control pests
and disease, maintain adequate water circulation and oxygen levels, to mention a few. None of these
design considerations (and their associated environmental impacts) are addressed in the IEE. Additional
information for impact and mitigation planning related to fisheries and aquaculture can be found at the
USAID’s Sector Environmental Guidelines (Agriculture, Construction, etc.
http://www.usaidgems.org/sectorGuidelines.htm).
3.4 Sub-grant Activities
Environmental Screening and Review for sub-grant activities (all activities involving sub grant
activities) for all program areas that are likely to have sub-grants to local Non-Governmental
Organizations (NGOs) and Community Based Organizations (CBOs)
Any grants or other fund transfers made by organizations receiving USAID funds to other organizations
(e.g., sub grants) to support this DO’s activities must incorporate provisions that the activities to be
undertaken will be within the envelope of the environmental determinations and recommendations of this
IEE. This includes assurance that the activities conducted via those transfers fit within the description of
activities described in an approved IEE or IEE amendment covering this DO, and that any mitigating
measures required for those activities will be followed.
The instructions and the form can be found, under “Subsidiary Review,” at the following web site:
http://www.usaidgems.org/subsidiary.htm.
3.5 Energy Access Activities (IR 2.2) & Energy Sector Enabling Environment
Given the fact that energy provision, with its associated infrastructure (e.g., generating equipment,
transmission lines, and construction), can be associated with potentially significant adverse environmental
and social impacts, appropriate due diligence measures need to be provided for. A system of standards,
environmental review -- and invoking host country and lender environmental and social soundness
policies and procedures -- needs to be reinforced by transaction advisors at all levels of negotiation and
transaction policy support. For “late-stage” investments, EAs and ESIAs should already have been
produced, and should be located and reviewed by USAID for “sufficiency.” For early-stage transactions,
and likely future projects, loan providers and recipients may not yet be fully apprised of their
responsibilities with regard to ensuring that ESIAs for these projects are produced and mitigation
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 22
measures are factored into the funding.
NOTE:
The BEO may determine that pertinent activities financed by USAID/Nigeria, GoN, or other lenders and
donors satisfy the environmental and social due diligence requirements.
The following sorts of illustrative actions and mitigation provisions should be factored into energy sector
development and integration dialogue and investments:
1. Environmental, health and safety management must be fully integrated into these activities; EG shall
submit for MEO review and approval IP’s plans for achieving such integration prior to implementation of
these activities.
2. Firms receiving substantial TA shall, as a condition of receiving this support, be in compliance with all
pertinent host country requirements, or commit to compliance as an outcome of this TA.
3. Firms being considered for substantial individual TA must first undergo an initial environmental,
health and safety (EHS) review of their operations for general soundness and compliance with host
country requirements. This assessment must be the basis for compliance commitments and supportive TA
as required above. Assessments must be updated following conclusion of assistance. All such assessments
must be maintained in project files and summaries in quarterly or 6-month project environmental
compliance reporting.
4. A strengths/gaps assessment must be conducted of: (1) Host country EHS regulation and performance
standards for enterprises and activities in the oil and gas sector supply chain; and (2) the capability of
cognizant government entities to enforce these requirements. A particular focus must be standards
involving transport, maintenance, waste management, and any direct support to production.
5. Based on these strengths/gaps assessment, USAID must engage in suitable regulatory and enforcement
capacity-strengthening activities with appropriate Government entities. While it is acknowledged that
final decisions regarding regulations, policies and enforcement strategy lie with the Government, USAID
TA must emphasize, wherever practicable, the following known elements of successful SME regulatory
approaches: (1) public reporting of firm performance; (2) simplification and accessibility of regulatory
language; (3) treatment of enforcement and education/outreach as necessary, complementary activities.
3.6 Financial intermediation, international finance institutions (IFI), loan guarantees,
Development Credit Authority (DCA) commitments.
When loan portfolios or direct loan guarantees, include potentially high-risk sectors such as mining,
power and associated infrastructure (e.g., transmission lines), and construction, these sectors are often
associated with potentially significant adverse environmental and social impacts. The investments could
likely fund a range of future projects and as these loan providers and recipients are not fully known at the
time of this review and, thus, EAs and ESIAs for these projects may be unavailable.
The Operating Unit shall ensure that the Guaranteed Party or Parties have environmental screening
system sufficient to demonstrate compliance with host government environmental laws and to enable
USAID to make an assessment of the environmental impact of such activities and shall submit to USAID
their proposed policies and procedures to assure that the projects financed are environmentally sound and
comply with applicable laws and procedures.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 23
In the event a DCA or GDA is to be established, refer to guidance on the Global Environmental
Management Support (GEMS) website2, and consult with the respective PA Transaction Advisors,
Regional Environmental Advisors (REA) and Bureau Environmental Officer (BEO). Corporate
Environmental and Social Responsibility will be promoted.
A significant portion of Power Africa will be undertaking many activities upstream in the transaction
cycle: policy development, project feasibility, legal support, capacity building, financial intermediation,
etc., to address such projects in which the activities are just being defined. Clearly, at some point, an
environmental review or due diligence process would need to be followed when considering the
investments to be made with loans, and the like.
As Power Africa engages in new ways with MDBs & PIOs, private lenders, and many other partner
organizations, we will need to rely on their own respective due diligence procedures. A significant
portion of Power Africa will be undertaking many activities upstream in the transaction cycle: policy
development, project feasibility, legal support, capacity building, financial intermediation, etc., to address
such projects in which the activities are just being defined. Clearly, at some point, an environmental
review or due diligence process would need to be followed when considering the investments to be made
with loans, and the like.
USAID should seek to develop its guarantee deals with an "Equator Principles" Finance Institution, which
will have an Environmental and Social (E&S) Management System (ESMS) and an E&S due diligence
procedure, as well as E&S officers. An ESMS covers compliance, with an Exclusion list, national laws,
and performance standards. The Equator Principles for Environmental and Social Responsibility typically
only apply to the largest banks with large capitalization.
USAID/AFR’s BEO will establish a third Party Environmental Compliance Verification process for the
ESIAs produced to respond to host country requirements.
DCA agreements for Loan Portfolio Guarantees and for other guarantees where the purpose is
capitalization to facilitate direct on-lending should include the “model language” developed by USAID’s
Office of Development Credit. This language is reproduced in Annex 4. It is assumed that this language
is used for all LPG agreements and for other guarantee agreements used for capitalization to facilitate on-
lending.
The language provides for DCA credit guarantees/coverage to be withheld from environmentally “high
risk” activities (cases where Reg. 216 requires an EA and activities restricted by the FAA), except with
USAID prior review and approval. That is, if such a loan is made without first obtaining prior approval,
DCA provides no coverage in case of default.
What constitutes prior approval of loans for environmentally sensitive activities?
Individual loan approval: When the activity is configured so that USAID (or a USAID-funded
project) reviews and approves all loans, an Environmental Review Form (ERF) or similar process
must be completed for each loan in the portfolio. In this case, the approved ERF constitutes prior
approval, unless the ERF requires that an EA be conducted. (Note that environmental management
conditions specified in the ERF become loan conditions.)
Program approval: When the activity is NOT configured so that USAID (or a USAID-funded
project) reviews and approves all individual loans, AND host country environmental regulations and
2 http://www.usaidgems.org/Documents/complianceTopics/Cadmus_GDA_factsheet_19Dec06final_draft.doc
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 24
regulatory capacity are adequate, prior approval is granted once the Contracting Officer’s
Representative (COR) (in collaboration with the MEO) approve the lender’s environmental due
diligence and management plan.
Hybrid approach: When the activity is NOT configured so that USAID (or a USAID-funded
project) reviews and approves all individual loans, BUT host country environmental regulations and
regulatory capacity are NOT adequate, then the IEE may require that USAID be notified and grant
specific prior approval for all loan applications involving environmentally sensitive activities.
In this case, the Guaranteed Party should submit to USAID documentation sufficient to demonstrate
compliance with local environmental laws and to enable USAID to make an assessment of the
environmental impact of the activities that will result from the loan. This will normally take the form of
an EA meeting host country or USAID requirements, whichever is more stringent. Compliance with
mitigation measures specified in this EA or other documentation must be written into the loan agreement.
3.6.1. General environmental due diligence principles for Power Africa
Here are some general environmental due diligence principles that we would like to see considered by
Power Africa stakeholders across the board, and these may or may not apply to these DCA LGs:
a. Appropriate PA Operating Units shall ensure that the Guaranteed Party or Parties have environmental
screening system sufficient to demonstrate compliance with host government environmental laws and to
enable USAID to make an assessment of the environmental impact of such activities and shall submit to
USAID their proposed policies and procedures to assure that the projects financed are environmentally
sound and comply with applicable laws and procedures.
b. TA must explicitly incorporate in investment analyses potential environmental impacts and liabilities
and the costs of compliance with host country environmental requirements.
c. TA must advocate for the inclusion of environmental requirements, as appropriate, in contracts and
contract models.
d. Policy, investment and regulatory TA must fully integrate and advance strong energy sector
environmental and social performance as a core value.
e. Significant TA tasks for developing, reviewing or reforming energy resources policy, energy sector
investment frameworks, and energy sector regulation must involve outlining potential environmental and
social issues and impacts.
See the DCA conditions in Table 1, Energy Access Activities (IR 2.2) and Enabling Environment
Activities – IR 2.3.
3.6.2. An Illustrative DCA Loan Guarantee to Standard Chartered Bank to Zenith Bank of Nigeria
As an illustrative case, USAID’s DCA office will provide a loan guarantee (LG) on a $95 M loan from
Standard Chartered Bank to Zenith Bank Nigeria. The proceeds of the loan will be used to support capital
expenditure needs of recently privatized generation and distribution companies in Nigeria. Partners are
GuarantCo, Zenith Bank and Standard Chartered Bank. Both Standard Charter Bank (SCB) and Zenith
Bank are guided by corporate Environmental Policies (see Annex 9). These are high-level statements
which do reflect solid commitment on the part of both banks to adhere to environmental and social
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 25
management systems (ESMS)(Zenith Bank) and global environmental management system (GEMS) and
environmental and social credit risk assessment processes (Standard Chartered). Both banks assure us
that they do environmental and social risk analysis for borrowers and take measures to "avoid, mitigate
and manage risks" identified, beginning at a very early stage of the credit evaluation.
This is certainly encouraging. If possible, it would further be of value if USAID transactions advisors and
environmental staff could receive, as a courtesy, the actual ESMS and GEMS policy documents
themselves. In due course, it might be a good learning experience for USAID to see how this process is
effectuated in practice (e.g., select visits as part of an affirmative dialogue?).
In discussions with the DCA staff, we mapped out "bright line" provisions that would make as plain as
possible what USAID would like to see achieved by way of environmental and social due diligence by the
parties to the guarantee agreement, as well as by the "end user" of the on-lending (loan recipient). Those
would be stipulated in appropriate fashion in the respective guarantee agreements and covenants, viz.:
1. Corporate Environmental and Social Responsibility. Both lenders will have in place and
follow their own corporate internal and external Environmental and Social Management Systems
and apply them to their lending practices and evaluations of borrowers, and will take measures to
avoid, mitigate and manage" environmental risks. How exactly, would need to be defined. See
Annex 9.
2. Liquid fuel exclusion. Given USG priorities on low-emissions development (LEDS), we
would expect the lender (SCB) of the Guaranteed funds to have a Representation Letter ("rep")
from Zenith as a covenant that the Guarantee would exclude support to power generation that
involve liquid fuels, esp. diesel, and would favor renewable energy investments (the latter point
may need to be discussed as to its "fit.")
3. Decommissioning and disposal of surplus assets. Given the situation in which privatized
assets will be upgraded, and some systems decommissioned, we would like to see some
provisions assuring that waste generated from transmission system renovation (e.g., old
transformer PCBs disposal) would be appropriately disposed of (how exactly -- to be stipulated
later?). Regarding decommissioning and specifically the management of PCBs, it is agreed that
appropriate handling is important and preferable. However, given the relationship wherein DCA
is three steps removed from the "end user" of the loans, it is difficult to determine how this would
be directed, monitored, and resourced. This is where we will need to rely on Nigerian host
country oversight and compliance with national regulations.
4. End user responsibility. The "end user" of the on-lending (loan recipient) (two steps removed
from the Guarantee) will be expected by Zenith to comply with local laws, regarding any ESIAs,
permits, and the like, that may be needed. A system of verification should be worked out.
5. Deal-specific IEE. Consider appropriateness and value added of a "Deal-specific" IEE for
such capital expenditure mobilization investments.
4.0 Recommended Threshold Decisions & Mitigation Actions (Including Monitoring and Evaluation)
Categorical Exclusion in pursuant to 22 CFR 216.2(c)(2) is recommended for the following activities in
support of agricultural competitiveness: improved energy access and improved enabling environment.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 26
These activities will not have adverse effects on the environment as detailed in Table 1.
(i) Activities involving education, training, technical assistance or training programs except to the
extent such programs include activities directly affecting the environment (such as construction of
facilities, etc.);
(ii) Activities involving controlled experimentation exclusively for the purpose of research and field
evaluation and carefully monitored;
(iii) Activities involving analyses, studies, academic or research workshops and meetings;
(v) Activities involving document and information transfers;
(viii) Programs involving nutrition, health care, or family planning services except to the extent designed
to include activities directly affecting the environment (such as construction of facilities, water
supply systems, waste water treatment, etc.); .
Negative Determinations with conditions are recommended for the following activities: Per 22 CFR 216.3 (a) (2) (iii):
Strengthen the capacity of local agro-business organizations to improve distribution
Formation of major seed and fertilizer alliances to increase supply of inputs
Promote use and adoption of available improved seed/varieties, and sustainable water/soil
management and post-harvest technologies
All pesticide-related activities referenced in MARKETS II PERSUAP, which will govern all
pesticide use and capacity building
Commercialization and Post-Harvest Activities (food processing)
Construction of water catchments and small scale irrigation technologies to provide irrigation and
potable water
Small scale construction of food storage warehouses and cold storage facilities
Aquaculture
Provision of agricultural credit guarantees via NIRSAL
T.A. to DCA-supported SME loan facility for agricultural value chain development
Technical assistance to Power Africa-related DCA loan portfolio guarantee (LPG), portable
guarantee (PG) or loan guarantee agreements between international and local commercial bank(s)
to support, e.g., (a) capital expenditure needs of recently privatized generation and distribution
companies in Nigeria, (b) financial risk mitigation in loaning to a solar leasing company (Amp
Ventures) seeking to deploy throughout Nigeria, and (c) others to be determined.
T.A. for GDA through PFAN
Sub-grant Activities (Project Development Facility, Catalytic and Innovation Funds)
Table 1: Summary of the Recommended Determination and Conditions
Illustrative Activities Recommended Determinations
Agricultural Competitiveness Activities – IR 2.1
Strengthening the capacity of local
agro-business organizations to
improve private sector distribution
of inputs.
Formation of major seed and fertilizer
alliances (to increase the supply of
quality seed, fertilizer, and other inputs
to millions of small-holder farmers and
stimulate productivity increases.)
Negative determination pursuant to 22CFR216.3(a)(2)(iii) is
recommended subject to the conditions that: (1) training for technical
support providers must adequately address appropriate measures of
handling of equipment and fertilizers use of must conform to best
practices outlined in the Africa Bureau Fertilizer Fact Sheet(see Annex
3); and (2) all activities will conform to the relevant
aspects and provisions of the MARKETS II or other relevant
PERSUAPs.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 27
Illustrative Activities Recommended Determinations
Enhance the capacities of small and
medium agro-enterprises, producer
organizations/associations, (male and
female) through training to increase
businesses and entrepreneurial
skill, contract negotiations, product
management, and organizational
governance.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Promote use and adoption of
available improved seed/varieties of
target crops; sustainable soil and
water management practices (e.g.
drip irrigation, improved fallows,
and inorganic and organic fertilizer
application, integrated pest
management techniques, small
irrigation technologies and
management); and potentially
profitable post-harvest technologies.
Negative determination pursuant to 22 CFR 216.3(a)(2)(iii) is
recommended subject to the conditions that: (1) training for technical
support providers must adequately address appropriate measures of
handling of equipment and fertilizers use; (2) fertilizers be thoughtfully
employed according to best practice, promoting integrated soil fertility
management, within the context of the prevailing biophysical and socio-
economic conditions, as well as the desired outcomes. These must
conform to best practices outlined in the Africa Bureau Fertilizer Fact
Sheet (Annex 3); (3) all activities will conform to the relevant aspects
and provisions of the MARKETS II or other relevant PERSUAPs; (4)
good-practice design and operation standards must be implemented,
generally consistent with good-practice guidance of USAID’s Sector
Environmental Guidelines (Agriculture, Construction;
http://www.usaidgems.org/sectorGuidelines.htm); (5) introduce only
properly tested equipment and varieties approved by Government of
Nigeria. Existing Nigerian laws, regulations and policies be ascertained
and followed prior to dissemination of technologies; and (6) precautions
are taken to prevent dissemination of stress, disease or insect resistant
varieties outside the agro-climatic zones and agricultural technologies for
planting are not damaging to the environment and do not lead to soil
erosion and/or degradation.
Support activities addressing
warehouse receipt, agricultural
commodity trading and accessible
market information systems; meeting
market standards.
Negative determination per 22 CFR 216.3(a)(2)(iii) with conditions
that:
1) For activities related to enhancing market development systems, a
requirement will be to conduct internal analysis/review of potential
environmental impacts from increased production, harvesting and/or
value-added processing for proposed new product/market linkages (see
the GEMS Food Processing Cleaner Production Factsheet at
http://www.usaidgems.org/mse/foodProcessing.htm). TA will conform to
relevant aspects and provisions of the MARKETS II PERSUAP.
Support activities addressing public
and private investments that advance
agricultural value chain and efficient
agricultural marketing such as
storage facilities, cold storage,
packaging facilities, and agricultural
processing facilities.
Negative determination per 22 CFR 216.3(a)(2)(iii) with conditions
that:
1) Precautions are taken to prevent environmental damage from improper
waste management and disposal by conducting training and information
dissemination on proper management and disposal of wastes. 2) Any
small-scale construction shall be conducted in a manner consistent with
best practices as outlined in the Small Scale Construction chapter of the
USAID Sector Environmental Guidelines.
(http://www.usaidgems.org/sectorGuidelines.htm); and,
2) An environmental management course entitled “Improving Micro- and
Small Enterprise Success through Cleaner Production” is recommended
for Objective Development partners (www.encapafrica.org/sme.htm).
This provides an opportunity to provide leadership and innovation in
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 28
Illustrative Activities Recommended Determinations
environmental capacity-building for business service organizations that
assist SMEs.
3) Business development services for enterprises and cooperatives; and
pilots and demonstrations will (1) incorporate and promote sound
environmental management practices (see GEMS Food Processing
Cleaner Production Factsheet
http://www.usaidgems.org/mse/foodProcessing.htm); (2) convey--and, in
the case of demonstrations and pilots, comply with--Malawian
environmental and public health requirements pertaining to these
operations; and (3) conform to relevant aspects and provisions of the
2012 SEG PERSUAP.
Support the transfer and adaptation of
proven technologies and human
organization innovations to increase
market access, food or cash transfers in
exchange for public works; and
resource transfers and/or agricultural
inputs (e.g. seeds, tools, and livestock)
which enable male and female
producers to try new technologies
and production methods that would
otherwise not be available to them.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(2)(iii),
Conduct value chain analysis of
major targeted commodities such as
rice, maize, cassava, soybean,
sorghum and aquaculture.
Negative determination pursuant to 22CFR216.3 (a)(2)(iii) is
recommended subject to the condition that:
If aquaculture is to be promoted by EGE partners, the EMMP
must include detailed analysis of potential impacts and
mitigation measures to deal with likely impacts at program sites
and must be generally consistent with good-practice guidance of
USAID’s Sector Environmental Guidelines (Agriculture,
Construction; http://www.usaidgems.org/sectorGuidelines.htm).
Expanding new multi-partner value
chain alliances; and increasing business
capacity of agricultural firms.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i).
Construction of water catchments
and small scale irrigation
technologies to provide irrigation
and potable water and encourage
farmers to rear small stock that require
less feed and support agro-processors
water supply need within targeted
commodity value chains.
Negative determination pursuant to 22CFR216.3 (a)(2)(iii) is
recommended
subject to the following conditions:
1. Construction of Small Scale Irrigation (<50 Ha irrigated area):
a) The formal AFR subproject/sub grant review process, as set out by the
AFR Environmental Review Form (available at
http://www.usaidgems.org/compliance.htm) must be completed and
approved prior to construction of each site/system. The ERF must
specifically address the potential impacts identifies in the above analysis
of this activity
b) The environmental management conditions established by the ERF
process must be generally consistent with good-practice guidance of
USAID’s Sector Environmental Guidelines (Agriculture and Irrigation,
Construction; http://www.usaidgems.org/sectorGuidelines.htm).
c) The IP must assure implementation of any mitigation and monitoring
conditions specified by the approved ERF.
d) Complementary support to a user’s association or other management
entity must be provided or suitable capacity for managing the scheme
otherwise assured.
2. Construction of Water Catchments for Potable Water:
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 29
Illustrative Activities Recommended Determinations
For water supply activities, the IP will develop and implement a Water
Quality Assurance Plan that will ensure that all new and rehabilitated
USAID-funded water supplies provide safe drinking water, defined as
meeting local and WHO water quality standards.
This Plan must be approved by the MEO prior to initiation of
these activities.
The plan must include and assign responsibility to the IP for
initial water quality testing. When feasible, the program must
also set in place capacities and responsibilities to provide
reasonable assurance that ongoing water quality monitoring
occurs.
The standards for initial and ongoing testing— including types
of contaminants for which testing should be conducted, testing
methods, testing frequency, and issues such as public access to
results— should follow any applicable USAID guidance, as well
as local laws, regulations and policies.
The plan must include a response protocol in the event that the
water does not meet water quality standards.
The plan must include testing for Arsenic per Guidance Cable
State 98 108651 (if groundwater source) and fecal coliform.
Water violating the 10ppb Arsenic standard (if groundwater
source) or having detectable coliforms in any 100ml sample.
may not be supplied for public consumption.
At minimum, fecal coliform must be tested concurrently with
Arsenic (if groundwater source).
Support marketing campaigns to
improve the visibility and raise
awareness of Nigeria’s products and
branding. Production of marketing
materials and educational guides
needed to raise awareness and
understanding of market information
systems.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii)
Support nutrition education and
awareness, introduction of more
nutritious and fortified foods.
Collaboration with the HIV/AIDS and
Tuberculosis Office on the procurement
and distribution of fortified foods.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(viii)
Promotion of the production and
utilization of cowpeas, shea nuts,
poultry, small ruminants, vegetables
or other nutritionally important and
/or marketable products that do not
require large land areas and are often
classified as poor people’s or women’s
activities
Negative determination pursuant to 22CFR216.3 (a)(2)(iii) is
recommended
subject to the conditions that:
1) Sustainable practices are promoted through the identification and
promotion of the value chains.
2) Introduce only properly tested equipment and varieties approved by
Government of Nigeria.
3) Existing Nigerian laws, regulations and policies be ascertained and
followed prior to dissemination of technologies.
4) Precautions are taken to prevent dissemination of stress, disease or
insect resistant varieties outside the agro-climatic zones and agricultural
technologies for planting are not damaging to the environment and do not
lead to soil erosion and/or degradation.
Conduct performance and impact Categorical exclusion is recommended pursuant to
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 30
Illustrative Activities Recommended Determinations
evaluations of targeted value chain
interventions and studies on diversified
economic opportunities to demonstrate
innovations and technologies that
reduce women’s labor burden and/or
increase productivity of labor
22CFR216.2(c)(2)(iii)
Administer grant funds: (a)
Innovation Fund to promote
innovative applications (ideas,
processes, equipment, training, designs)
that can be introduced into the
commodity value chain to enhance
productivity, increase efficiency,
improve a process or otherwise lead to
some practical benefit to producers or
to agri-businesses;
(b) Project Development Facility
Fund to provide technical assistance to
enterprises in creating a bankable
export business plan, market
assessments, bringing products up to
international standards, packaging and
labeling requirements, food testing
certification, SPS standards,
transportation, marketing and sales.
Negative Determination with Conditions is recommended for all sub-
grant activities likely that have a direct effect on the environment.
1) Any grants or other fund transfers made by organizations receiving
USAID funds to other organizations (e.g., sub grants) to support this
DO’s activities must incorporate provisions that the activities to be
undertaken will be within the envelope of the environmental
determinations and recommendations of this IEE.
2) This includes assurance that the activities conducted via those
transfers fit within the description of activities described in an approved
IEE or IEE amendment covering this DO, and that any mitigating
measures required for those activities will be followed.
The instructions and the Environmental Review Form can be found,
under “Subsidiary Review,” at the following web site:
http://www.usaidgems.org/subsidiary.htm.
Suggested language to promote environmental compliance in
solicitations and awards can be found in the ADS 204 help document,
“Environmental Compliance: Language for Use in Solicitations and
Awards.” (http://www.usaid.gov/policy/ads/200/204sac.pdf). Sound sectoral guidance can be found in USAID Africa Bureau's
Environmental Guidelines for Small-Scale Activities in Africa: Use of
Environmental Screening form as apt:
http://www.encapafrica.org/compliance.htm.
Develop small-scale storage sheds to
store crops and other commodities
for later sale or for use as collateral
towards credit or insurance
Support food Processing and
packaging to significantly reduce in
current wastage and ensure extended
access
Support investment in water
supplies for food processing and
hygiene
Negative determination pursuant to 22CFR216.3 (a)(2)(iii) is
recommended subject to the following conditions
1. Construction management:
The construction/rehabilitation must be consistent with construction
management requirements:
(a) During construction, prevent sediment-heavy run-off from cleared site
or material stockpiles to any surface waters or fields with berms, by
covering sand/dirt piles, or by choice of location.
(Only applies if construction occurs during rainy season.);
(b) Construction must be managed so that no standing water on the
site persists more than 4 days;
(c) IPs must require their general contractor to certify that it is not
extracting fill, sand or gravel from waterways or ecologically sensitive
areas, nor is it knowingly purchasing these materials from vendors who
do so;
(d) IPs must identify and implement any feasible measures to increase the
probability that timber is procured from legal, well-managed sources.
2. Water Supplies:
The well construction should follow good design and implementation
practices (Annex 7). Consultation should be carried out with all adjacent
well owners and operators and host country authority and agreement
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 31
Illustrative Activities Recommended Determinations
reached on the location of the borehole to eliminate any potential
conflicts over water supply and withdrawals.
All wells should be securely sealed to ensure that no
microbiological contamination of ground water supplies occurs.
All wells should be constructed to ensure that no permanent
unmanaged standing water remains near the water supply area in
order to avoid the proliferation of water borne disease vectors
For water supply activities, the IP will develop and implement a
Water Quality Assurance Plan that will ensure that all new and
rehabilitated USAID-funded water supplies provide safe drinking
water, defined as meeting local and WHO water quality standards.
o This Plan must be approved by the MEO prior to initiation of
these activities.
o The plan must include and assign responsibility to the IP for
initial water quality testing. When feasible, the program must
also set in place capacities and responsibilities to provide
reasonable assurance that ongoing water quality monitoring
occurs.
o The standards for initial and ongoing testing— including types
of contaminants for which testing should be conducted, testing
methods, testing frequency, and issues such as public access to
results— should follow any applicable USAID guidance, as well
as local laws, regulations and policies.
o The plan must include a response protocol in the event that the
water does not meet water quality standards.
o The plan must include testing for Arsenic per Guidance Cable
State 98 108651 and fecal coliform. Water violating the 10 ppb
Arsenic standard or having detectable coliforms in any 100 ml
sample may not be supplied for public consumption.
o At minimum, fecal coliform must be tested concurrently with
Arsenic.
Procurement, use, promotion of, or
training in use of pesticides,
including herbicides, and fungicides.
Negative determination with conditions is recommended per
22CFR216.3(a)(2)(iii) for all continuing activities referenced in the
“Pesticide Evaluation and Safer Use Action Plan: Maximizing
Agricultural Revenue and Key Enterprises in Targeted sites II (Nigeria
MARKETSII PERSUAP_2013_2017)” approved 07/26/2013 (see link
on Face sheet) The condition is that the limitations and requirements
given in that assessment must be followed, and only those pesticides
identified and assessed in that PERSUAP may be used unless and until
that assessment is amended to include other products, and until that
amendment is approved by the Bureau Environmental Officer (BEO);
b. A deferral of a threshold determination, per 22 CFR
216.3(a)(7)(iii), is recommended for all pesticide-related activities NOT
referenced in the above PERSUAP. No pesticide import, distribution or
use is authorized for such activities unless and until a PERSUAP is
prepared in accordance with AFR Bureau guidance, fulfilling all
analytical elements required by 22CFR216.3(b), USAID’s Pesticide
Procedures, and until said assessment is approved by the BEO.
Activities involving the field testing
or open release of genetically
modified organisms (GMOs)
A deferral of a threshold determination, per 22 CFR 216.3(a)(7)(iii), is
recommended for the field testing or other release of genetically-
engineered plants, pending biosafety assessment of such testing and/or
release. Such field testing or other release cannot occur until USAID’s
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 32
Illustrative Activities Recommended Determinations
Biosafety Procedures in ADS 201 are completed with respect to the
particular uses intended, and until an IEE or amendment is completed for
those uses, reflecting the findings in the biosafety review. As noted in the
attached summary of those procedures, the grantee/contractor or host
country collaborator must submit to the USAID A/COR or DO Team a
letter or letters from the relevant authority in the host country approving
the transfer, testing and/or release of the GE product, including any
specific conditions imposed by the host country. USAID will not grant
approval of the transfer, testing or release in the absence of this letter or
letters of approval.
Once the USAID Biosafety Officer confirms that the biosafety
procedures have been completed for the intended actions involving GE
products, this IEE should be amended or separate IEE be put in place to
reflect the appropriate threshold decision for the GE product-related
activity(ies).
Energy Access Activities – IR 2.2
Assist in privatizing existing state
energy companies, developing the
frameworks and promoting projects for
private investment in energy resources
exploration and production, processing
and conversion, transmission and
transportation, and distribution and
delivery of energy to end-users
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii);
If “promotion of projects” includes financial intermediation, then
Negative Determination with conditions will apply:
1) IPs shall ensure that the Guaranteed Party or Parties have
environmental screening systems sufficient to demonstrate compliance
with host government environmental laws and to enable USAID to make
an assessment of the environmental impact of such activities and shall
submit to USAID their proposed policies and procedures to assure that
the projects financed are environmentally sound and comply with
applicable laws and procedures.
2) In the event a DCA or GDA is to be established, refer to guidance on
the GEMS website,
http://www.usaidgems.org/complianceTopics.htm, and consult with the
MEOs, REAs and BEO, as appropriate.
Build the capacity of the electricity
regulator to work with the private
sector to end gas flares in the Niger
Delta through the GON Accelerated
Gas Development Project (AGDP).
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii);
DCA loan guarantees and T.A.
Nigeria Promoting Renewable
Energy and Energy Efficiency
Project.
Component 1: DCA instrument to
provide partial credit guarantees to
local Banks (initially Eco Bank and
First Bank) in order to increase debt
financing to the clean energy sector.
Component 3: T.A. for the successful
implementation of the Energy sector
activities. .
A Negative Determination with Conditions is recommended pursuant
to 22 CFR 216.3(a)(2)(iii) for this DCA loan guarantee intended to
strengthen the Guaranteed Party’s ability to finance loans to increase
access to finance for energy sector investments, associated infrastructure
construction and equipment, subject to the conditions that:
a) Guarantee Agreement with appropriate environmental due
diligence provisions. If the DCA Issuance team and the lenders are
favorable to the principle, appropriate environmental due diligence
provisions could be incorporated into the DCA guarantee
agreement. That would give USAID a sense that sound
environmental practices will be promoted and encouraged. In the
case of the construction of a power facility, for example, subject to
negotiation with the host government (and only for technical
assistance, collaborative, information and advisory purposes), a
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 33
Illustrative Activities Recommended Determinations
The technical assistance component of
the Renewable Energy Project under
the LWA will develop (i) capacity of
financial institutions, particularly the
DCA banks, to ensure optimal
utilization of the DCA guarantee; (ii)
capacity of companies in the clean
energy sector and those in selected
sectors seeking to utilize renewable
energy, to provide a pipeline of
potential deals for the DCA banks; (iii)
capacity of government institutions to
encourage the enactment and
implementation of appropriate
legislation to incentivize private sector
participation in the development of the
clean energy market, and (iv) capacity
of vocational training institutes, to
strengthen the cadre of non-qualified
and qualified professionals to install,
operate, and maintain decentralized
renewable energy investments.
regime of environmental covenants could be incorporated into the
guarantee agreement that would require.
b) The Guaranteed Party shall provide for review by
USAID/Nigeria’s Mission Environmental Officer (MEO) and the
Regional Environmental Advisor (REA) a copy of its
environmental policies and procedures as a condition precedent to
this Guarantee Agreement.
c) The Guaranteed Party shall seek prior USAID approval and submit
evidence of environmental compliance before placing certain types
of loans under Guarantee coverage, to be specified appropriate
Guarantee Agreements with the involved bank(s).
d) The USAID/Nigeria Economic Growth Team will periodically
review the Guaranteed Party’s implementation of this requirement,
including during project monitoring visits.
e) Environmental compliance will comprise one of the performance
measures of the project’s mid and/or end-term technical evaluation
to be carried out by the USAID/Nigeria Economic Growth Team.
f) Small and Medium Size Enterprises accessing finance for energy
sector investments, associated infrastructure construction and
equipment, and the lending institution (i.e. the Guaranteed Party)
shall receive training and technical assistance in the use of
environment guidelines. The guidelines shall illustrate how
environmentally sound practices can be used to improve the
effectiveness and efficiency of the enterprise. Training of the
lending institution will include the concept of environmental due
diligence, awareness of the environmental hazards presented by
typical types of enterprises, and basic environmental management
appropriate to typical Small and Medium Size Enterprise activities.
Where technical assistance to the lending institution includes loan-
making procedures, basic environmental review will be built into
loan-making processes. This training and technical assistance will
support compliance with Nigerian law and implementation of good
practice as set out in this IEE.
g) Training with the partner banks on environmental compliance and
best practices: T.A. will be provided to the bank and loan managers,
risk assessment and due diligence officers to develop environmental
controls and checklists and train them on how to use these
checklists effectively as part of the loan process.
h) Mandatory reference: The USAID Sector Environmental
Guidelines --(http://www.usaidgems.org/sectorGuidelines.htm) --
and the Environmental Guidelines for Small Scale Activities in
Africa (www.encapafrica.org/egssaa.htm), specifically Section III
on Micro and Small Enterprises,
(http://www.encapafrica.org/egssaa.htm#III) , must inform
compliance with these conditions.
The following additional conditions are recommended when appropriate,
and are recommended as matter of policy when the parties to the DCA
guarantee agreement negotiate appropriate provisions. The Mission staff
managing the DCAs and the T.A. partner assisting with use of the DCA
will work with the banks to institute appropriate environmental controls
and the Mission is planning to do some training with the lenders and
borrowers that will facilitate the process.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 34
Illustrative Activities Recommended Determinations
i) The Guaranteed Party shall develop and provide for review and
approval by the USAID’s MEO and REA, a Compliance Plan
documenting how their project will implement and verify all IEE
conditions that apply to their activities. The Compliance Plan shall
identify how the Guaranteed Party shall assure that IEE conditions
that apply to activities supported under the loans are implemented.
j) The Guaranteed Party shall integrate their Compliance Plan into their
projects’ work plans and budgets, implement the Compliance Plan,
and report on its implementation as an element of regular project
performance reporting. The Guaranteed Party shall assure, through
training as described above, as well as the Compliance Plan that loan
recipients integrate implementation of IEE conditions, where
applicable, into their own project work plans and budgets and report
on their implementation as an element of loan performance reporting.
Nigeria Promoting Renewable
Energy and Energy Efficiency
Project.
Component 2: GDA with the Private
Financing Advisory Network
(PFAN), which will link
investors/financiers and clean energy
project developers to help produce
‘’bankable’’ project and equity
financing proposals.
A Negative Determination with Conditions is recommended
pursuant to 22 CFR 216.3(a)(2)(iii).
In the event a GDA is to be established, refer to guidance on the GEMS
website,
http://www.usaidgems.org/complianceTopics.htm, and consult with the
MEOs, REAs and BEO, as appropriate.
USAID funding will be provided only during the “pre-investment
phases” and will not provide for the follow-up engineering, construction
of production phases. ” However, since USAID investments will
introduce technologies and materials that are key to future commercial
operations, the pre-investment phase is pivotal to the conduct of the
remaining phases. As such, mitigation measures aimed at monitoring
and minimizing any potential negative impacts are included in the GDA
to assure that activities in which USAID is involved are environmentally
sound. Mitigation measures should be listed in the GDA agreement.
Participate in power generation
while also building the capacity of
the electricity regulator to effectively
regulate and incentivize the private
sector participation in the power
sector.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii) for capacity building activities.
If “participation in power generation ” includes support of actual
construction then Positive Determination will apply, per USAID’s 22
CFR Part 216.6 on Environmental Assessments:
1) Direct or indirect support to actual construction of power-related
infrastructure may require an Environmental Assessment, or certification
by USAID that an appropriate EA has been prepared.
2) Private sector investors in PPPs investing in major infrastructure will
likely need to support the preparation of appropriate host-country specific
Environmental and Social Impact Assessment documentation.
Enabling Environment Activities – IR 2.3
Conduct a climate change vulnerability
assessment to identify gaps and key
areas for Mission cross cutting
intervention in adaptation
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(iii);
22CFR216.2(c)(1)( v)
Warning System Network
(FEWSNET), an early warning system
that monitors food security, rainfall,
production and postharvest losses in
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(iii);
22CFR216.2(c)(1)( v)
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 35
Illustrative Activities Recommended Determinations
order to prepare for disaster and
anticipate the amount of food aid
needed in case of drought.
Support the GON’s Agriculture
Transformation Agenda (ATA)
through investment prioritization and
the preparation of state agricultural
investment plans; conducting research
and analysis in key policy areas
including input availability, land
governance, water resources and
irrigation; and improving knowledge
management and analyses for
agricultural planning.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(v)
Support public education on key
agricultural policies and progress
toward developing and implementing
them. Use of media in creating
awareness amongst all stakeholders
regarding the policy process and the
implementation of policies key to the
economic and social resilience.
Creation of appropriate mechanisms
and opportunities for vulnerable
populations to engage in policy
dialogue.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i),
22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(v)
Support the development of specific
guidelines and regulations that ensure
biotechnology laws are functional;
support the National Biosafety
Management Authority (NBMA) to
conduct evidence-based reviews for
decision-making; and developing and
implementing a strategy for bio-safety
outreach and communication.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Building government capacity to
develop agricultural statistics and
information systems; introducing best
practices to improve commodity
storage and handling to reduce post-
harvest losses; and providing technical
assistance to develop a food safety
policy.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Build public and private sector capacity
to analyze the impact of trade and
investment agreements on economic
growth, productivity, employment,
poverty, gender equity, fiscal revenues,
and other national and individual male
and female stakeholders’ interests.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Support institutions, policies and
incentives aimed at ensuring that
adequate, safe, and nutritious food is
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v);
22CFR216.2(c)(1)(viii)
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 36
Illustrative Activities Recommended Determinations
available; markets function efficiently;
and that low-income groups and those
vulnerable to food insecurity (e.g.,
female farmers with small land
holdings, female-headed households,
children, and HIV-affected) are able to
access and appropriately utilize that
food.
Support trade liberalization. Build the
capacity of the public sector to meet
requirements for accession to the WTO
and participating effectively in the
WTO system and to meet other
international agreements such as the
U.S. Free Trade Area agreements and
Bilateral Investment Treaties.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Provide technical assistance in
developing implementing regulations
and policies for the new CEMA and
capacity building and training for the
Nigerian Custom Service (NCS) to
improve its ability to oversee the new
regulatory framework. Provide training
in valuation and the use of tools such as
scanners to help NCS attain its goal of
internalizing destination inspection
services.
Provide training on benchmarking
effectiveness of trade facilitation
metrics and the implications of these
for customs modernization.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Support Corridor Management
Group (CMG) to improve
coordination along the Lagos—
Kano—Jibya transportation corridor
connecting the port of Lagos with the
inland countries of Chad, Niger and
Burkina Faso.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii) for pure capacity building,
T.A., etc.;
If “support” includes financial intermediation, then Negative
Determination with conditions will apply:
1) IPs shall ensure that the Guaranteed Party or Parties have
environmental screening systems sufficient to demonstrate compliance
with host government environmental laws and to enable USAID to make
an assessment of the environmental impact of such activities and shall
submit to USAID their proposed policies and procedures to assure that
the projects financed are environmentally sound and comply with
applicable laws and procedures.
2) In the event a DCA or GDA is to be established, refer to guidance on
the GEMS website,
http://www.usaidgems.org/complianceTopics.htm, and consult with the
MEOs, REAs and BEO, as appropriate.
If “support ” includes support of actual construction then a Positive
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 37
Illustrative Activities Recommended Determinations
Determination could apply:
1) Direct or indirect support to actual construction of transportation-
related infrastructure may require an Environmental Assessment, or
certification by USAID that an appropriate EA has been prepared.
2) Private sector investors investing in major infrastructure will likely
need to support the preparation of appropriate host-country specific
Environmental and Social Impact Assessment documentation.
Provide technical assistance and
training to policy makers in the power
and oil and gas sector, embedding an
advisor into the Nigerian Bulk
Electricity Trading Company to
improve its capacity to negotiate, and
procure competitive electricity.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Create a renewable energy regulatory
framework, a cost reflective tariff; and
improve the regulatory environment for
private sector investments.
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Support GON efforts to improve the
policy and regulatory environment for
clean energy production; reduce gas
flaring and make captured gas available
for the generation of clean energy;
Categorical exclusion is recommended pursuant to
22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
Provide technical assistance to the
GON on voltage management and
liberalization of the power sector.
For technical assistance on voltage management, Categorical exclusion
is recommended pursuant to 22CFR216.2(c)(1)(i);
22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)
If “liberalization” includes financial intermediation, then Negative
Determination with conditions will apply:
1) IPs shall ensure that the Guaranteed Party or Parties have
environmental screening systems sufficient to demonstrate compliance
with host government environmental laws and to enable USAID to make
an assessment of the environmental impact of such activities and shall
submit to USAID their proposed policies and procedures to assure that
the projects financed are environmentally sound and comply with
applicable laws and procedures.
2) In the event a DCA or GDA is to be established, refer to guidance on
the GEMS website, http://www.usaidgems.org/complianceTopics.htm,
and consult with the MEOs, REAs and BEO, as appropriate.
Provision of Agriculture credit
guarantees by working with the
Nigeria Incentive-Based Risk-Sharing
System for Agricultural Lending
(NIRSAL).
Negative Determination with conditions:
1) IPs shall ensure that the Guaranteed Party or Parties have
environmental screening systems sufficient to demonstrate compliance
with host government environmental laws and to enable USAID to make
an assessment of the environmental impact of such activities and shall
submit to USAID their proposed policies and procedures to assure that
the projects financed are environmentally sound and comply with
applicable laws and procedures.
2) In the event a DCA or GDA is to be established, refer to guidance on
the GEMS website,
http://www.usaidgems.org/complianceTopics.htm, and consult with the
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 38
Illustrative Activities Recommended Determinations
MEOs, REAs and BEO, as appropriate.
Support public education on key
policies and progress toward
developing and implementing them.
Use of media in creating awareness
amongst all stakeholders regarding the
policy process and the implementation
of policies key to the economic and
social resilience. Creation of
appropriate mechanisms and
opportunities for vulnerable
populations to engage in policy
dialogue.
Categorical exclusion is recommended pursuant to 22CFR216.2(c)(1)(i)
22CFR216.2(c)(2)(i), 22CFR216.2(c)(2)(v)
Provide technical assistance to
financial institutions who house the
DCA guarantee for investment in
small and medium renewable and
energy efficient companies; agro
processing, and warehousing
companies, and public and private
facilities willing to retrofit facilities
with clean energy.
This is consistent with the USAID
Nigeria Renewable Energy DCA IEE.
See Facesheet for link.
Negative Determination is recommended pursuant to 22 CFR
216.3(a)(2)(iii) for this DCA loan guarantee to Bank loans to increase
access to finance for the renewable energy, energy efficiency and
agribusiness Small and Medium Enterprises (SMEs) in Nigeria subject to
the conditions that:
The EGE team with support of the MEO shall ensure that the Guaranteed
Parties have environmental screening system sufficient to demonstrate
compliance with Nigeria Environmental Impact Assessment (EIA) Act.
Cap E12, LFN 2004 and to enable USAID to make an assessment of the
environmental impact of such activities and shall submit to USAID their
policies and procedures to assure that the projects financed are
environmentally sound and comply with applicable laws and procedures.
The Guaranteed Parties shall seek prior USAID approval and submit
evidence of environmental compliance before placing certain types of
loans under Guarantee coverage as specified in the Development
Guarantee Agreement annexed to this IEE. (Annex 4)
As a matter of desirable policy, if the DCA Issuance team is favorable to
the principle, appropriate environmental due diligence provisions can be
incorporated into the DCA guarantee agreement, that would give USAID
a sense that sound environmental practices will be promoted and
encouraged. In the case of the construction of a power facility, for
example, subject to negotiation with the host government (and only for
technical assistance, collaborative, information and advisory purposes), a
regime of environmental covenants could be incorporated into the
guarantee agreement that would require:
1. The current model agreement language on the types of activities which
are prohibited under 22 CFR 216 (see Annex 4 in the present IEE).
2. Adherence to the government’s and company’s own environmental
policies and action plan;
3. The right of USAID environmental officers to review the GoNs
solicitation for contractors and to offer comments to the environmental
provisions of such solicitation;
4. A similar right to review the environmental provisions of the contract
awarded to construct the marketplace;
5. The right to receive reports that are already required either under the
local government’s action plan, or under the construction contract; and
6. The right to access the project site at the same times as the project
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 39
Illustrative Activities Recommended Determinations
engineer would perform site visits.
In the case of Nigeria, three Ecobank files have been received from the
USAID Nigeria Mission to demonstrate the due diligence in place for the
Ecobank Agreement: a) the Guarantee Agreement, b) transaction report
summary, and c) Ecobank's Env & Social Assessment Polices &
Procedures.
5.0 Restrictions, Implementation and Monitoring
5.1 General Restrictions:
GMOs/LMOs: For purposes of compliance with USAID procedures, Genetically Modified
Organisms (GMOs) or Living Modified Organisms (LMOs) are defined as “living organisms
modified by genetic engineering techniques” and include, e.g., plants, microorganisms, live
animal vaccines (if used outside a contained area and not approved in the US), animals, and
insects. This IEE does not authorize support for laboratory- or field-based research involving
GMOs/LMOs, nor does it authorize support for multiplication or dissemination/open release of
GMOs/LMOs. Support for laboratory research involving GMOs/LMOs in contained facilities
would require an approved amendment to this IEE. Support for field testing or open release of
GMOs/LMOs would require successful review under USAID’s Biosafety Procedures followed by
an approved IEE amendment. Nigerian national requirements must be met in either case. See the
Biosafety Procedures Factsheet for more information:
http://www.usaidgems.org/Documents/complianceTopics/Biosafety_5Feb2010.pdf
PESTICIDES: All activities that fall outside of the category of controlled experimentation
exclusively for the purpose of research and field evaluation and entail the procurement or use, or
both, of pesticides shall conform with the “Pesticide Evaluation and Safer Use Action Plan:
Maximizing Agricultural Revenue and Key Enterprises in Targeted sites II (Nigeria MARKETSII
PERSUAP_2013_2017)” approved 07/26/2013, conducted in accordance with USAID Pesticide
Procedures (22 CFR 216.3). See Environmental Compliance Database:
http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39371.docx. Any pesticides NOT
covered by the existing MARKETS II PERSUAP will require an amended or new PERSUAP.
No new pesticide import, distribution or use is authorized for such activities not covered, unless
and until a PERSUAP is prepared in accordance with AFR Bureau guidance, fulfilling all
analytical elements required by 22CFR216.3(b), USAID’s Pesticide Procedures, and until said
assessment is approved by the BEO.
5.2 General Project Implementation and Monitoring
In addition to the specific conditions above, the negative determinations recommended in this IEE are
contingent on full implementation of the following general monitoring and implementation requirements:
1. IP Briefings on Environmental Compliance Responsibilities. The Economic Growth and
Environment Team shall provide each Implementing Partner (hereinafter IP), with a copy of this
IEE; each IP shall be briefed on their environmental compliance responsibilities by their
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 40
cognizant C/AOR. During this briefing, the IEE conditions applicable to the IP’s activities will be
identified.
2. Development of EMMP. Each IP whose activities are subject to one or more conditions set out
in section 3 of this IEE shall develop and provide for C/AOR review and approval an
Environmental Mitigation and Monitoring Plan (EMMP) documenting how their project will
implement and verify all IEE conditions that apply to their activities.
These EMMPs shall identify how the IP shall assure that IEE conditions that apply to activities
supported under subcontracts and sub-grants are implemented. (In the case of large sub-grants or
subcontracts, the IP may elect to require the sub-grantee/subcontractor to develop their own
EMMP.)
(Note: The AFR EMMP Factsheet provides EMMP guidance and sample EMMP formats:
http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf )
3. Integration and implementation of EMMP. Each IP shall integrate their EMMP into their
project work plan and budgets, implement the EMMP, and report on its implementation as an
element of regular project performance reporting.
IPs shall assure that sub-contractors and sub-grantees 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 sub-contracts and grant agreements.
a. The Economic Growth and Environment team shall assure that any future contracts or
agreements for implementation of health portfolio activities, and/or significant
modification to current contracts/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. IPs shall assure that future sub-contracts and sub-grant agreements, and/or significant
modifications to existing agreements, reference and require compliance with relevant
elements of these conditions.
5. Assurance of sub-grantee and sub-contractor capacity and compliance. IPs shall assure that
sub-grantees and subcontractors have the capability to implement the relevant requirements of this
IEE. The IP shall, as and if appropriate, provide training to sub-grantees and subcontractors in their
environmental compliance responsibilities and in environmentally sound design and management
(ESDM) of their activities. See Annex 6.
6. Economic Growth Team monitoring responsibility. As required by ADS 204.3.4, the Economic
Growth and Environment Team is responsible for on-going monitoring and evaluation of whether
the environmental components designed for the activity resulting from the 22 CFR 216 process are
being implemented effectively. This includes identifying and addressing new or unforeseen
environmental consequences arising during implementation.This will be achieved regular site visits
using the EGE field observation and pesticides use checklists.
7. New or modified activities. As part of its Work Plan, and all Annual Work Plans thereafter, IPs, in
collaboration with their C/AOR, shall review all on-going and planned activities to determine if
they are within the scope of this IEE.
If activities outside the scope of this IEE are planned, the Economic Growth and Environment
Team shall assure that an amendment to this IEE addressing these activities is prepared and
approved prior to implementation of any such activities.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 41
Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental
documentation shall be modified to comply or halted until an amendment to the documentation is
submitted approved.
8. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes
IP, sub-grantee and subcontractor responsibility for compliance with all applicable host country
laws and regulations. The IP, sub-grantees and subcontractor must comply with host country
environmental regulations unless otherwise directed in writing by USAID. However, in case of
conflict between host country and USAID regulations, the latter shall govern.
ANNEXES
List of Annexes:
Annex 1: List of the awards that are active @ September 30, 2013
Annex 2: Washington/Regional Related IEEs
Annex 3: USAID Africa Bureau Fertilizer Information Sheet
Annex 4: DCA Loan Agreement Conditions
Annex 5: Environmental Mitigation and Monitoring Plan (EMMP) Template Annex 6: Environmental Screening Form for Sub-grant/New Activities Proposed under USAID/Nigeria DO 2 Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small scale water supply
Annex 8: Category of Mandatory EIA studies in Nigeria
Annex 9: Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility
Policies
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 42
Annex 1. List of the awards that are active and/or planned as of September 30,
2013 and covered in this DO 2 EGE IEE for USAID Nigeria.
S/N Project
Name
LOP
Funding
($)
Objectives/Description Start
Date
End
Date
Geographic
coverage
(States)
Comment
TRADE & INVESTMENT: Trade and Investment Capacity
1 Nigeria
Expanded
Trade and
Transport
(NEXTT)
12,000,000 USAID’s Nigeria Expanded Trade
and Transport (NEXTT) program
aims to promote inclusive economic
growth and food security through an
integrated approach to trade and
transport competitiveness.
Oct,
2012
Sept,
2016
The eight-
state Lagos-
Kano-Jibiya
transportatio
n
corridor.
Lagos, Ogun,
Oyo, Kwara,
Niger,
Kaduna,
Kano &
Katsina
2 DCA
Loan
portfolio
guarantees
(LPGs)
985,526 The guarantee aims to support
banks’ expansion into funding
projects in agribusiness (non-
renewable energy activities) and
renewable energy activities
involving solar, biomass, hydro,
wind, clean cook stoves, and energy
efficiency activities by small- and
medium-sized enterprises (SMEs),
thereby increasing access to finance
on positive terms to creditworthy
but underserved potential clients.
Sept
2012
Sept
2017
National Addressed in
Nigeria
Renewable
Energy IEE
(see face
sheet) and the
present DO 2
IEE
Sub Total 16, 985,526
AGRICULTURE: Agricultural Enabling Environment
3
Nigeria
Strategy
Support
Program
(NSSP)
8,000,000
To assist the Ministry of Agriculture
and Rural Development’s
Department of Policy, Planning,
Analysis and Statistics will establish
a Comprehensive African
Agriculture Development Program
(CAADP) node at the Ministry
along with a research program
leading to evidence based policy
formulation.
Sept
30,
2010
Sept 30,
2014
National
4 Africa
Leadership
and Capacity
Building
Program
(Africa
LEAD)
450,000 Strengthen the ability of national
and regional public and private
sector organizations, private
producers’ and traders’ associations
to gain skills in a variety of
technical areas to support the
implementation of the CAADP at
country and regional levels.
Sept
13,
2010
Sept 30,
2013
National Likely to be
extended
into the
CDCS
years.
5 Nigeria
Agriculture
900,000 To enhance the capacity of GON to
develop the agricultural statistics
Feb
2009 - Sept
2013
National Likely to be
extended
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 43
S/N Project
Name
LOP
Funding
($)
Objectives/Description Start
Date
End
Date
Geographic
coverage
(States)
Comment
Capacity
Building
Program
and information systems, continue
promotion of food safety policy, and
other related agriculture policy
formulation.
into the
CDCS
years.
6 Program for
Biosafety
Systems (PBS)
200,000 To enhance the capacity of GON to
evaluate and address the crucial
issues related to policy and
implementation agricultural
biotechnology.
Results:
- Improved policy environment for
the safe use of biotechnology
- Improved capacity for
formulation, implementation and
regulation of biotechnology
- Increased Public Awareness and
Outreach
Sept
2010
–
Sept 30,
2013
National Likely to be
extended
into the
CDCS
years.
7 FEWSNET 820,000 To identify and disseminate
information on problems in the food
supply system that potentially leads
to famine or other food-insecure
conditions in Nigeria
Nov
30,
2009
Sept 30,
2013
15 Northern
States
8 FtF Private
Sector
Development
Program
[Monitor-
Deloitte]
1,000,000 To assist USAID Nigeria to develop
country private sector action plans
for agricultural development and
USAID /Washington to develop a
private sector engagement strategy
in support of the Feed the Future
(FTF) initiative.
Sept,
2011
Sept,
2014
USAID HQ
manages.
Sub Total 11,370,000
AGRICULTURE: Agriculture Sector Capacity
9 Maximizing
Agricultural
Revenue and
Key
Enterprises in
Targeted Sites
(MARKETS
II)
60,732,079 Promoting improved productivity,
value-added processing and
commercialized agriculture with the
aim of increasing sales and jobs for
agriculture-related businesses.
Focus Value Chains
April
18,
2012
April
17,
2017
14 states and
FCT selected
in
collaboration
with FMARD
PERSUAP
in place
10
Expanded
Access to
Services for
Agricultural
Enterprises
(EASE)
1,300,000
To increase profitability of small
agricultural enterprises.
1) Strengthened Enterprise
Management Skills of Small-scale
Rural Enterprise (11,000 Clients)
2) Strengthened Commodity Value
Chains (Maize; Rice Cassava; +)
3) Improve Access to Financial
Services to Small-scale Rural
Dec
02,
2009
Sept 30,
2013
Benue,
Nassarawa
Bauchi &
Sokoto
Award
closed Sept
30, 2013
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 44
S/N Project
Name
LOP
Funding
($)
Objectives/Description Start
Date
End
Date
Geographic
coverage
(States)
Comment
Enterprise (11,000 Clients)
11 Support to
Vulnerable
Households
(SVH)
14,999,625 The purpose of the Support to
Vulnerable Households for
Accelerated Revenue Earnings
project, referred to throughout this
document by the shorter Support to
Vulnerable Households project, is to
strengthen the participation of an
estimated 42,000 very poor
households in rural economic
growth and to improve their
livelihoods, nutrition and health.
July
02,
2013
July 01,
2018
Sokoto State
and Federal
Capital
Territory
(FCT)
Project may
extend to
Jigawa
State
Addressed
in this IEE
Sub Total 88,401,704
ENVIRONMENT: Clean Productive Environment
12 Nigerian
Energy and
Climate
Change
Project -
Enhancing
Sustainable
Utility
Regulation
(ENSURE) –
NARUC
750,000 To transform the Nigerian
Electricity Regulatory Commission
(NERC) into a transparent and
publically accountable energy
regulator, especially with regard to
creating an enabling environment to
incentivize private participation in
clean electricity generation.
Nov
30,
2009 –
July 8,
2015
National
Addressed
in this IEE
13 Nigerian
Energy and
Climate
Change
Project -
Africa
Infrastructure
Project (AIP)
[Nexant Inc]
5,250,000 NECC aim is to assist the
Government of Nigeria to: (a)
reduce GHG emissions by
improving policies and measures
aimed at stopping gas flares and
expand the use of gas to produce
electricity, (b) improve the policy
and regulatory environments for
energy efficiency (EE) and the
independent generation of clean
energy, (c) build the capacity of the
private sector to negotiate long term
financing for renewable energy
(RE) project and; (d) Identify and
implement commercially viable
renewable energy projects to
develop the market in Nigeria.
Nov
30
2009 –
March
30 2014
National Addressed
in this IEE
14 Energy
Efficient
Cookstove
Projects
[ICEED]
1,299,946 The overall goal is to create a
template for reducing greenhouse
gas emissions and health risks
among women by improving the
efficiency of the use of fuel wood in
institutions.
April
2012
April
2015
Niger and
Ebonyi
States
Addressed
in this IEE
Sub Total 7,299,946
Grand Total 112,687,176
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 45
Annex 2: Washington/Regional Related IEEs
S/
N IEE Title Source PDF
Link
Amount
($)
Award Number Start
Date
End
Date
Country Coverage
Washington Managed
1 Sustainable
Water and
Sanitation in
Africa
(SUWASA)
EGAT 53-08
20,000,000 EPP-1-04-00019-00 Sept
2008
Dec
2011
Sub-Saharan
Africa
2 Associate
Award to
IPM CRSP-
Food Security
Initiative
EGAT 43-08 2,000,000 EPP-A-00-04-00016 Sept
2008
Sept
2013
Sub-Saharan
Africa
3 John
Ogonowski
and Doug
Bereuter
Farmer-to-
Farmer
Volunte...
EGAT 10-09 75,000,000 Multiple (LWA) FY
2008
FY
2012
Uganda, Kenya,
Tanzania, Angola,
Malawi, Egypt,
Mozambique, Nigeria
Georgia, Moldavia,
Lebanon, Haiti,
Guyana, Nicaragua
and Dominica
Republic
4 CABIO
Initiative
Maruca
Resistant
Cowpea Field
Trial in N...
EGAT 29-09 40,000 EEM-G-00-03-000015 2003 2013 Institute of
Agricultural
Research, (IAR)
Zaria, Nigeria
5 Monitoring
Entrepreneurs
hip in
Muslim-
Majority
Countries
EGAT 30-10 3,000,000 AFR/SD 4.5
Agriculture
FY10 FY15 Egypt, Nigeria,
Bangladesh, Pakistan
6 African
Diaspora
Marketplace
(ADM)
EGAT 31-10 1,400,000 N/A FY10 FY12 Ghana, Ethiopia,
Kenya, Liberia,
Nigeria, Sierra Leone
and Uganda
7 CABIO
Initiative
Maruca
resistant
cowpea field
trial in N...
EGAT 46-10 40,000 EEM-G-00-03-000015 2003 2013 Institute of
Agricultural
Research, (IAR)
Zaria, Nigeria
8 AFR/SD
mFarmer
Initiative
AFR-
SD_mFarmer_
CE_072211
AFR/SD 4.5
Agriculture
Sept
2011
Sept
2014
Ethiopia, Ghana,
Mali, Nigeria,
Mozambique,
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 46
S/
N IEE Title Source PDF
Link
Amount
($)
Award Number Start
Date
End
Date
Country Coverage
Tanzania, Kenya,
Malawi
9 Confined
field trial of
bioengineered
cowpea
resistant to... BFS 14-11
40,000 EEM-G-00-03-000015 2003 2013 Institute of
Agricultural
Research, (IAR)
Zaria, Nigeria
10 African
Cocoa
Initiative
GDA BFS 14-12
5,000,000 N/A FY11 FY16 Cote D’Ivoire
11 Post-Harvest
Storing and
Drying GDA BFS 14-13
2,000,000 N/A FY12 FY15 Kenya, Nigeria
12 SEA for
Indoor
Residual
Spraying for
Malaria
Control in N.
GH-12-009 GHN-I-01-09-00012 May
2012
Sept
2015
Nigeria
West Africa Regional Managed
13 West Africa
Seed Program
(WASP)
USAID-
WA_WASP_I
EE_070612
624-12-00005 Burkina Faso, Ghana,
Mali, Nigeria,
Senegal, Niger,
Liberia
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 47
Annex 3: USAID Africa Bureau Fertilizer Information Sheet Background: Low soil fertility is a problem throughout most of Sub-Saharan Africa (SSA). Moreover, the drastic reduction in fallow
periods and the almost continuous cropping without soil fertility restoration has depleted the nutrient base of most soils.
By the mid-late 1990s, all SSA countries were demonstrating a negative annual nutrient balance 1. Countries that have
the highest nutrient loss rates are the ones where fertilizer use is low and soil erosion is high. These areas include the
East African highlands and a number of countries in West Africa.
Low soil fertility is also a driving force behind the conversion of natural areas for agricultural extension. It is generally
accepted that agricultural intensification is the only viable means to conserve key natural areas while increasing food
security for the continents growing population and generating economic growth through improved agricultural
productivity. Land degradation undermines the ability of countries to move in this direction, and the loss of soil nutrients
is the most important contributing factor to the land degradation process. The use of inorganic fertilizers is a critical part
of the strategy to stop land degradation, restore soil fertility and better manage the soil resources that are fundamental for
sustainable agricultural and economic development.
Fertilizers and USAID Environmental Procedures (22 CFR 216) –
Fertilizers are frequently lumped together with pesticides under the generic heading of “agro- or agrichemicals.”
From an environmental compliance perspective (22 CFR 216), as well as from a field-level implementation point of
view, this is inappropriate, because it implies that fertilizers require the same level of scrutiny reserved for
pesticides. Whereas pesticides are subject to clearly defined environmental review procedures [22 CFR
216.3(b)(1)], and an approval process to promote safer use and integrated pest management, such procedures do not
apply to fertilizers (procurement procedures do apply to quantity bulk purchase). As with any technology, however,
it is recommended that fertilizers be thoughtfully employed according to best practice, promoting integrated soil
fertility management, within the context of the prevailing biophysical and socio-economic conditions, as well as the
desired outcomes. This fact sheet was developed to assist in that regard.
Importance of Water Management to Nutrient Uptake –
Proper water management is important for maximizing crop use of nutrients. About 97% of crop nutrient uptake is
from soil solution (water-soluble nutrients), which makes water by far the most important nutrient or fertilizer
delivery medium. This also means that, for the most part, nutrient mobility is directly linked to water movement. In
sandy soils, nutrients move more quickly through the root zone and soil profile than in other soil types, and
excessive water application (or heavy rainfall) can lead to nutrient loss through leaching. Run-off is most serious on
loamy-sands or sandy loams that often have a strong surface crust formation. In heavier soils (clays), if nutrients are
not adequately incorporated into the soil, the chances for surface runoff in the event of heavy rains or over-irrigation
are increased. Sound water management is especially important in rainfed conditions (common throughout SSA).
Overall, good water management leads to a more efficient use of fertilizers and increased nutrient uptake and vice
versa.
General Soil Fertility Trends in Africa --
Farmers who have taken measures to conserve moisture or increase soil organic matter are more likely to use
inorganic fertilizer. When farmers in some areas have capital, they often invest first in increasing moisture
retention and/or increasing soil organic matter and secondly in inorganic fertilizer.
Farmers increase their use of fertilizer when investing more money in fertilizer is seen to be the best available
option. This increase may result from changes in any of the following: fertilizer price, crop price, fertilizer
availability, water availability, seed availability, knowledge about fertilizer use, or cropping pattern.
In West Africa, integrated soil fertility management is progressively adopted. It concerns the combined use of
soil amendments and inorganic fertilizer, leading in time to improved soil fertility and increased fertilizer use
efficiency and profitability. The nutrient losses to the environment are decreasing.
Given past and current use rates, USAID’s fertilizer-related activities in Africa are unlikely to cause
environmental problems.
Fertilizer Application guidelines --
Before applying fertilizers, obtain an assessment of soil conditions (fertility).
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 48
Indiscriminate use of chemical fertilizers should be avoided.
Different kinds of fertilizers are required in order to maintain a given level of soil fertility. This depends on
site-specific factors, including the soil type, the nutrient requirement of the crop and the various sources of
available nutrients. Nitrogen and Phosphorous are the most important nutrients lacking in SSA soils.
Fertilizer application has to be considered in the context of the overall farming system. This includes the use
of organic manure and residues, soil cultivation and crop rotation and water harvesting. Collectively, these
factors influence the efficiency of nutrient use.
When fertilizers are used, it is very important to apply the correct amount for the given situation. The
challenge to the farmer is to match as closely as possible the input of nutrients to the nutrient uptake of the
crop, thereby minimizing losses. Over fertilization is both costly (wasteful) and potentially harmful to the
environment. To apply the correct amount, the farmer has to define his production goal.
Potential negative environmental effects of fertilizers --
Excessive application of nutrients over time can cause pollution. Such losses may occur when nutrients run off the
land caused by heavy rainfall, are leached through the soil, beyond the root zone, eventually reaching the
groundwater, or escape into the atmosphere as volatile gases.
Aspects of environmental impact can be illustrated as follows:
(Taken from Incitec Fertilizers)
Nitrogen fertilizers: Inorganic nitrogen fertilizers are readily converted by soil organisms to nitrate in the soil. The
nitrogen in soil organic matter and organic fertilizers becomes available more slowly. Nitrates may be readily
leached if not used by crops or other vegetation. Leaching is particularly likely in sandy soils following heavy
rainfall. Leached nitrates may contaminate underground water. This is of concern if the water is to be used for
human or livestock consumption, as high concentrations of nitrate may affect health.
Nitrogen fertilizers can also accelerate the natural process of soil acidification. Some fertilizers (e.g. anhydrous
ammonia and urea) may initially raise the soil pH at the site of application but in the long term acidify the soils. This
occurs when ammonium is converted to nitrate. Acid produced in the nitrification process is used if the nitrate is
taken up by plants or soil organisms, but if the nitrate is leached beyond the root zone, acidification occurs. Soil
acidification reduces the availability of the trace element molybdenum, fosters the development of aluminum, iron
and manganese toxicity and increases nodulation failure in legumes. Lime may be required where acidity is a
problem (obtained from naturally occurring calcium carbonate) or the use of acid tolerant plant species can be
considered. An illustrative list of crops with acid tolerant varieties include: rice, cassava, mango, cashew, citrus,
pineapple and cowpeas.
Phosphorus fertilizers: Excess amounts of phosphorus have been associated with algal blooms and the
eutrophication of lakes and waterways. In most waters, phosphorous functions as a growth-limiting factor because it
is usually present in very low concentrations. Algae only require small amounts of phosphorous to live. Excessive
phosphorus over-stimulates the growth of algae, which could deplete the water of the dissolved oxygen that is vital
to other aquatic life. Phosphorus is relatively immobile in the soil, so conservation and cultural practices which
reduce soil erosion can significantly reduce phosphorus inputs into water bodies and the water table.
Phosphorus fertilizers contain various impurities from the phosphate rock and acid used in manufacturing the
fertilizer. Cadmium increases is the greatest concern as its compounds are toxic to human beings. Cadmium
increases are most noticeable in certain crops e.g. potatoes and leafy vegetables (lettuce and spinach) and in the
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 49
organs (kidneys and liver) of animals. Almost all phosphate fertilizers contain traces of cadmium, and the
concentration of cadmium varies considerably from source to source. At this time, there are efforts underway in
West Africa to develop viable processes to remove cadmium from phosphate rock. Exports of rock phosphate
represent a vital source of revenue for a number of developing countries in Africa.
Fertilizer Effects on Soil Biology: Good soil consists of 93% mineral and 7% bio-organic substances. The bio-
organic parts are humus (85%), roots (10%) and soil organisms (5%). Most of the soil organisms are decomposers
(bacteria and fungi), which are responsible for nutrient retention in soil. In order for nutrients to become available
they must be mineralized by the interaction of decomposers and organisms that feed on the decomposers (protozoa,
nematodes, micorarthropods and earthworms). Plant growth is dependent on microbial nutrient immobilization.
When the number of decomposers declines in soils, more nutrients are lost into the ground and surface water.
Heavy treatments of chemical fertilizers can kill decomposers and other soil organisms, which will lead to a
reduction in nutrient retention and possible surface and ground water contamination.
A summary of best management practices for soil fertility and health --
Practice Integrated Soil Fertility Management (ISFM) – the use of both organic and inorganic sources of
nutrients rather than either alone;
Use of legume cover crops (plus phosphorous) and green manures by fallow rotation or intercropping;
Promote agroforestry practices – in addition to soil conservation and production benefits, agroforestry
transfers/cycles nutrients from within the soil profile (deeper levels to surface);
Use conservation tillage rather than deep plowing (although conservation tillage can be harmful for
production systems in certain regions 2);
Use farm site manures and household wastes, with or without composting;
Choose crops and associated plants that have high nutrient use efficiency.
End Notes:
1. Henao, J. and Baanante, C. 1999. Estimating rates of nutrient depletion in soils of agricultural lands
of Africa. Technical Bulletin. IFDC – T 48. IFDC, Muscle Shoals, Alabama. 76p.
2. Hoogmoed, W. 1999. Tillage for soil and water conservation in the semi-arid tropics. Phd thesis,
Wageningen University, Holland.
Acknowledgement: This fact sheet was strengthened by a thoughtful technical review by Dr. Henk Bremen, Director
of Africa Division, International Center for Soil Fertility and Agricultural Development (IFDC), Lome, Togo.
June 2004.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 50
Annex 4: DCA Loan Agreement Conditions: First Order Screening
The Loan must not be used to finance any of the following without the prior written
approval of USAID:
(1) Pharmaceuticals,
(2) Pesticides,
(3) Logging equipment,
(4) Luxury goods (including alcoholic beverages and jewelry),
(5) Establishing or expanding any enterprise that will export raw materials that are likely to be in
surplus in world markets at the time such production becomes effective and that are likely to
cause substantial injury to U.S. producers,
(6) Activities which would result in the loss of forest lands due to livestock rearing, road construction
or maintenance, colonization of forest lands or construction of dams or other water control
structures,
(7) Activities which are likely to have a significant adverse effect on the environment, including any
of the following (to the extent such activities are likely to have a significant adverse impact on the
environment):
(a) programs of river basin development,
(b) significant irrigation or water management projects (including dams and impoundments),
(c) agricultural land leveling,
(d) major drainage projects,
(e) large scale agricultural mechanization,
(f) new lands development,
(g) resettlement projects,
(h) penetration road building or road improvement projects,
(i) construction of power plants or industrial plants, or
(j) large scale potable water and sewerage projects,
(8) Activities which are likely to involve the loss of jobs in the United States due to the relocation or
expansion outside of the United States of an enterprise located in the United States, or
(9) Activities which the Guaranteed Parties are aware are likely to reasonably contribute to the
violation of internationally recognized rights of workers.
Approval of loans to finance the purchase or use of pesticides, will be contingent upon the submission by the
Guaranteed Party and approval by BEO of a supplemental Initial Environmental Examination meeting USAID
Pesticide Procedures [22CFR216.3(b)].
Excerpt from approved IEE for Nigeria Development Credit Authority (DCA) Renewable Energy. See
http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39936.docx
Regarding the potential for financing investments will be ultimately result in construction of power-related
infrastructure
Nigeria Renewable Energy DCA:
Negative Determination is recommended pursuant to 22 CFR 216.3(a)(2)(iii) for this DCA loan guarantee
to First Bank and Ecobank loans to increase access to finance for the renewable energy, energy efficiency
and agribusiness Small and Medium Enterprises (SMEs) in Nigeria subject to the conditions that:
The EGE team with support of the MEO shall ensure that the Guaranteed Parties have environmental
screening system sufficient to demonstrate compliance with Nigeria Environmental Impact Assessment
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 51
(EIA) Act. Cap E12, LFN 2004 and to enable USAID to make an assessment of the environmental
impact of such activities and shall submit to USAID their policies and procedures to assure that the
projects financed are environmentally sound and comply with applicable laws and procedures.
The Guaranteed Parties shall seek prior USAID approval and submit evidence of environmental
compliance before placing certain types of loans under Guarantee coverage as specified in section
2.02(b) of the Development Guarantee Agreement annexed to this IEE. (Appendix A)
The Loan must not be used to finance activities which significantl y degrade national parks or similar
protected areas or introduce exotic plants or animals into such areas.
The EGE team must ensure that the activities of the guaranteed parties are actively monitored for
compliance with approved IEE recommendations and the USAID/Nigeria MEO will periodically review
the Guaranteed Parties implementation of these requirements through regular field visits.
Note added April 7, 2014, upon receipt from USAID Nigeria three Ecobank files regarding progress made since the
original IEE was submitted in November 2012: a) the Guarantee Agreement, b) transaction report summary, and c)
Ecobank's Environmental & Social Assessment Polices & Procedures. It appears that First Bank is dropping out of
the DCA.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 52
Annex 5: Environmental Mitigation and Monitoring Plan (EMMP)
An EMMP should be developed for all activities under this DO that have at least one “Negative
Determination with Conditions”
The implementing partner should usually lead development of the EMMP, subject to review and
oversight by the MEO and A/COR. 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. Note: The AFR EMMP
Factsheet provides EMMP guidance and sample EMMP formats is available at:
http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf )
USAID/Nigeria: Recommended EMMP template:
---------------------------------------------------------------------------
Environmental Mitigation and Monitoring Plan
Activity Title:
Implementing Partner:
Activity Mitigation
measure(s)
Monitoring
indicator(s)
Monitoring and
Reporting
Frequency
Party or Parties
responsible.
List all activities
in IEE that
received a
“negative
determination
with conditions.”
Do not list any
other activities.
If mitigation
measures are
well-specified in
the IEE, quote
directly from IEE
If they are not
well-specified in
the IEE, define
more specifically
here.
Specify
indicators to (1)
determine if
mitigation is in
place and (2)
successful.
For example,
visual
inspections for
seepage around
pit latrine;
sedimentation at
stream crossings,
etc.)
For example:
“monitor weekly,
and report in
quarterly reports.
If XXX occurs,
immediately
inform USAID
activity
manager.”
If appropriate,
separately
specify the
parties
responsible for
mitigation, for
monitoring and
for reporting.
USAID/Nigeria
EMMP Reporting form
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 53
List each Mitigation
Measure in the
EMMP
Status of Mitigative
Measures
List any outstanding
issues relating to
required conditions
Remarks
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 DO IEE:
Signature Date
Print Name
__________________________
Organization
BELOW THIS LINE FOR USAID USE ONLY
USAID/Nigeria Clearance of EMMR:
Agreement/Contracting Officer Representative (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
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 54
Annex 6: Environmental Screening Form for Sub-grant/New Activities
Proposed under USAID/Nigeria DO 2
Any Implementing Partner proposing an activity which is not covered by the existing USAID/Nigeria
DO2 IEE must complete the “Environmental Screening Form” UNLESS the project or activity is carried
out to address an emergency (e.g., international disaster assistance). Emergencies are determined by the
US Ambassador, not by the applicant. Per CFR §216.2(b)(1), most activities carried out under emergency
circumstances are considered EXEMPT from environmental procedures, except for the procurement or
use of pesticides.
The proposed activity cannot be approved and no funds may be committed until the environmental
documentation, including mitigation measures, is cleared by the A/COR and approved by the
USAID/Nigeria Mission Environmental Officer (MEO). USAID may request modifications, or reject the
documentation. If the activities are found to have significant adverse impacts, a full Environmental
Assessment must be conducted.
The instructions and the form can be found, under “Subsidiary Review,” at the following web site:
http://www.usaidgems.org/subsidiary.htm
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 55
Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small
scale water supply
Implementing Partner: Various
Activity Mitigation measure(s)
Monitoring indicator(s)
Monitoring and
Reporting Frequency
Party or Parties
responsible.
Construction of
small scale water
supply and
sanitation
infrastructure
Survey will be done to avoid siting of all
water supply and sanitation infrastructure
in sensitive ecological areas.
Construction sites will be carefully
selected to minimize damage to
vegetation that could cause erosion. Data
on soil type will be gathered to determine
the potential for significant erosion. Any
vegetation that is damaged during
construction will be replanted before the
conclusion of the project.
Construction procedures will follow
USAID guidelines and construction
workers will be monitored to ensure best
practices in construction are maintained
and followed.
Proper bedding materials will be used for
the pipes.
Proper drainage provided for runoff water
to avoid pools and stagnant water.
Photos, Reports
and
documentation
Onsite
monitoring &
supervision
Onsite
monitoring &
supervision.
Throughout
duration of
construction
activities
Implementing
Partner
Water Yield
Sustainability
Hydrogeological analysis will be
conducted prior to constructing the water
point to certify that the yield of each well
is sufficient for the anticipated demand.
Facilities will be strategically located to
ensure local warden is available to
regulate water use at the points to avoid
overuse or wastage.
Water and Environmental Sanitation
committees will monitor and repair leaks
from cracked containment structures,
broken pipes, faulty valves and similar
structures to eliminate sources of water
wastage. Plumbers will be trained by the
Implementing Partner of the Collaborating
State Water and Sanitation Agency to
oversee the maintenance and operation of
the water facilities.
Water Quality Depth of water table will be evaluated to
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 56
Activity Mitigation measure(s)
Monitoring indicator(s)
Monitoring and
Reporting Frequency
Party or Parties
responsible.
Assurance
ensure pit latrines are installed
appropriately such that the water table is
not contaminated.
Locations for latrines and boreholes will
be selected with feedback from
community members and local Water and
Environmental Sanitation Committees.
After drilling, boreholes will be cased
and filled with gravel to prevent
contamination
Water quality testing will be conducted
on all water points constructed to ensure
that government quality standards are
met and it is safe to drink, as well as to
establish a baseline so that any future
degradation can be detected. . Water
samples collected will be taken to
government laboratory or any competent
water testing authority for physical,
chemical and bacteriological analysis
before being put in for any human
consumption. The water quality
assessment will test for: pH value,
appearance, taste, turbidity, conductivity,
arsenic, iron, magnesium, nitrate, copper,
fluoride, free carbon dioxide, hardness,
alkalinity, silica, manganese, nitrate,
ammoniacal nitrogen, and
microbiological parameters.
Water quality assessments will include
tests for the presence of arsenic as
required by Guidance Cable State 98
108651 and articulated in the EGAT and
Africa Bureau guideline document titled,
“Guidelines for Determining the Arsenic
Content of Ground Water in USAID-
Sponsored Well Programs in Sub-
Saharan Africa.” The project team will
ensure that the standards and testing
procedures described in this guideline
document are followed for potable water
points developed or renovated as part of
project activities.
Activity will promote implementation of
a long-term monitoring system in
conjunction with the municipality:
Establish baseline of water quality
through testing for chemical and
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 57
Activity Mitigation measure(s)
Monitoring indicator(s)
Monitoring and
Reporting Frequency
Party or Parties
responsible.
biological contaminants in borehole
water (P&D)
Ensure regular testing of water quality
through incorporation of water testing in
handover plan to municipality and
community education (O&M)
Relevant local community rules and best
practices and procedures of promotion of
better environmental health will be
developed and adhered to. Verification
through site visits and photos would be
done to assure practices are in
accordance with local community rules
and “best practices”
Maintenance and
Sustainability
Plan
Community water and sanitation
committees will be established and
trained to manage, repair and maintain all
water and sanitation points, including
cost recovery and financial management.
The training will include proper
techniques for watering of livestock and
hygiene education.
Training in sanitation and hygiene for
water committees, communities, area
based development groups, and/or
municipal water board members will be
carried out to:
o Ensure community
mobilization and public
awareness of human health
risks associated with water-
borne disease vectors
o Encourage the development of
community responses that are
environmentally sound, cost
effective, and safe; and
Ensure control over the management of
the facilities and operations that USAID
is supporting.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 58
Annex 8: Select Project Categories for Mandatory EIAs in Nigeria
Project
Category
Project Type Other considerations
1 Agriculture/Agro allied
Industry/manufacturing
Food, Beverage, Tobacco processing.
Infrastructure: Ports, Housing, Airport,
Drainage and Irrigation, Railway.
Transportation; Resort and Recreational
development, Power Generation; Petroleum,
Mining, Quarries, Waste Treatment and
Disposal, Water Supply; Land Reclamation
and Brewery.
2 Agricultural/rural development
Reforestation/afforestation project; small scale
irrigation; small scale aquaculture, Saw
milling, Logging, Rubber processing, fish
processing
Industry/Infrastructure
Mini-hydropower development, any small
scale industry development e.g., textiles,
chemical industry, power transmission,
renewable energy development,
telecommunication facility, rural water
supply, Public hospitals, road rehabilitation.
Small scale tourism development. Any form
of quarry or mining.
If the project is located in:
environmental sensitive areas,
e.g., coral reefs, mangroves
swamps, small islands. Tropical
rainforest, area erosion prone to
soils like mountain slope, area
prone to desertification, wetlands
of national or international
importance, areas with
protected/endangered species,
areas of unique scenery, areas of
scientific interest, areas of historic
or archeological interest.
Moves to category 1
3 Institutional development, health family
planning, nutritional and education programs.
If project involves physical
interventions in the environment
Moves to category 2
Source: Federal Ministry of Environment, 1995.
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 59
Annex 9. Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility Policies
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 60
Environmental Policy
Standard Chartered is an international bank, leading the way in Asia, Africa and the
Middle East. We recognise that through our business operations, we inevitably
impact upon the natural and physical environment, either directly or indirectly.
We are committed to minimizing the environmental effects of our operations and
aim to achieve continual improvement in our management of environmental issues.
Because our operations span a wide range of countries with differing cultures,
climates, infrastructures and legal requirements, we have developed a number of
environmental commitments that can be applied universally across the organisation.
These are as follows:
Legal Compliance We aim to comply fully with all government legislation applicable in each country in
which we operate. Where no regulations apply, we will adopt our own International
Environmental Standards.
Energy and Resource Use We will seek to reduce our per capita consumption of resources, specifically: energy,
water, transportation services and paper, wherever practicable opportunities exist.
Hazardous Substances We areendeavouringto eradicate the use of ozone depleting substances and to
use only refrigerants with a low global warming potential in Standard Chartered
controlled premises.
Hazardous substance use is managed to ensure that releases are minimized both
during operation and at the end of life.
Procurement Our major operational centre procurement processes consider environmental
issues surrounding the production, consumption and disposal of products and
services.
Wherever practicable, we procure products derived from sustainable resources.
Wherever appropriate, we favour the use of suppliers who can demonstrate
environmentally sound business practices.
Banking Services We give due consideration to the presence of environmental and social risks in our
Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 61
banking transactions.
We expect our banking customers to comply with the prevailing environmental and
social regulations applicable to their sphere of operation.
Air Emissions and Waste Management We identify, record and monitor greenhouse gas emissions arising from our
activities, wherever our global environmental management system is
implemented and reliable means to do so exist.
When possible, targets for reducing our greenhouse gas emissions will be set and
progress towards them will be reported annually.
Wherever practical, we seek to minimize the production of wastes, and encourage
staff to participate in reuse and recycling initiatives.
We ensure that wastes that are not reused or recycled are disposed of in a
safe and responsible manner.
These commitments are implemented through appropriate management controls,
including our global environmental management system (GEMS) and our
environmental and social credit risk assessment processes. In order to measure our
progress, we set management and/or performance targets, and monitor and report
on our progress.
We welcome the participation of our staff, customers and the public in this
process. To facilitate this we are developing staff awareness through
training and internal communications, and invite feedback from other
stakeholders on our performance.
We will continue to prepare a publicly available environmental report annually,
and undertake periodic reviews of our policy and targets.
A Group Executive Director is responsible for environmental managements and
provides regular reports on progress to the Board.