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INITIAL ENVIRONMENTAL EXAMINATION AMENDEMENT #1PROJECT/ACTIVITY DATAProject/Activity Name: Health Systems Strengthening (HSS) Project Geographic Location(s) (Country/Region): Uganda/East AfricaAmendment (Yes/No), if Yes indicate # (1, 2...): Yes #1Implementation Start/End: October 2019- October 2025 If Amended, specify New End Date:Solicitation/Contract/Award Number: Multiple (3)Implementing Partner(s): Management Science for Health, TBDsBureau Tracking ID:Tracking ID/link: Tracking ID/link of Related RCE/IEE (if any): Uganda_ Health_ Systems
Stregthening_Project_IEE_082318 Tracking ID/link of Other, Related Analyses: NA
ORGANIZATIONAL/ADMINISTRATIVE DATA
Implementing Operating Unit(s): (e.g. Mission or Bureau or Office)
USAID/Uganda
Other Affected Unit(s): NALead BEO Bureau: AFRFunding Account(s) (if available): MultipleOriginal Funding Amount: For HSS Project: $ 406,372,310 If Amended, specify funding amount: Uganda Health Supply Chain: $500,000;
Waste Management Activity: $5 million;
Social Behavioral Change for Transformation: $10 million; and
Accountability and Risk Management Support Services: $19.9 million.
If Amended, specify new funding total: For HSS Project: $441,772,310
Prepared by: USAID/Uganda Health Systems Strengthening Project Management Team (HSS-PMT);
USAID/Uganda Mission Environmental Officer Date Prepared: July 4th, 2019
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ENVIRONMENTAL COMPLIANCE REVIEW DATAAnalysis Type: Environmental Examination DeferralEnvironmental Determination(s): Categorical Exclusion(s)
Negative with ConditionsPositiveDeferred (per 22 CFR 216.3(a)(7)(iv)
IEE Expiration Date: December 31, 2024Additional Analyses/Reporting Required:
EMMPs
Climate Risks Identified (#): Low ____X__ Moderate ___X___ High __ X ___
Climate Risks Addressed (#): Low ______ Moderate __X___ High __ X ___
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THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGSPROJECT/ACTIVITY SUMMARY USAID interventions will include expanded scope of Uganda Health Supply Chain (UHSC) and increasing its funding levels by $500,000. USAID is also increasing funding levels of Social Behavior Change for Transformation (SBC4T) activity by $10 million. In addition, USAID Uganda is adding the Waste Management Activity; and Accountability and Risk Management Support Services (ARMSS) activity.
a. UHSC Program:Expansion in scope and increase in Total Estimated Cost (TEC):
i) The Ministry of Health is desirous of constructing a 3-level storied office block that will accommodate a conference hall, Board room and offices. The facility shall be located at the Vector Control Centre along Buganda Road, in Kampala.The scope of work shall include construction of an extension block consisting of:
Conference Hall capacity of between 80 -100 people; A board room capacity of up to 30 people; Offices (at least'10 in number); Toilet facilities for male and female users; Access staircase, bridge and pedestrian walkways; Pantry/kitchen.
ii) Subsequent increase in funding by $500,000
b. Waste Management Activity:New activity included in the HSS project.i) The purpose of this activity is to; facilitate the health care waste
(HCW) disposal to required standards; improve the management of hazardous HCW/VMMC at USG supported health facilities; and consequently, enable market-based solutions for sustainable health care waste management in Uganda.
ii) TEC is $5 million (with potential for more funding over 5 years); total TEC estimate is $10 million.
c. SBC4T activity: Increase in TEC by $ 10 million.
d. Accountability and Risk Management Support Services (ARMSS)
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Modification of scope to provide overall audit and risk management support to local PEPFAR partners, including assessment and management of risk for the Antiretroviral (ARV)commodities; and increase in TEC by $19.9 million.
USAID has recommended a Categorical Exclusion Threshold Determination for this activity. The activity has no attached environmental management conditions.
ENVIRONMENTAL DETERMINATIONS Upon approval of this document, the determinations become affirmed, per Agency regulations (22 CFR 216). The following table summarizes the environmental determinations for the below HSS project/activities: TABLE 1: ENVIRONMENTAL DETERMINATIONS
ActivitiesCategorical Exclusion
Negative DeterminationWith Conditions
Positive Determination
Deferral1
Uganda Health Supply Chain (UHSC) Program √ √ - -Waste Management Activity √ √ - -
ARMSS √ - - -
Social Behavior Change for Transformation (SBC4T) activity
All details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
CLIMATE RISK MANAGEMENT All details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment. This additional analysis documents the results of the activity-level Climate Risk Management process for UHSC MoH office block expansion, Uganda Waste Management, SBS4T, and ARMSS activities, in accordance with ADS 201.
1 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities. USAID/IPs may utilize the Environmental Screening Tool to assess impacts of deferred activities.
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The analysis established that climate risks are high for construction of the office block and moderate for the waste management activity, and low for the rest.
In the original IEE and during climate risk screening for the Health Systems Strengthening PAD, climate risks were found to be low for health communication project elements, including SBS4T activities. Per ADS 201, no further climate risk analysis or action is required for the SBC4T activity.
However, for the health care waste management activity, extreme weather events like heavy rains and floods could cut off access roads to and from some health facilities in hard-to-reach areas. This could delay transportation and disposal of VMMC wastes. Climate-proofing of the transportation and disposal systems is therefore required. The activity will ensure that transportation and disposal plans are based on weather forecasts. This climate risk mitigation measure will be integrated into activity solicitation and implementation plans.
In addition, for construction of the office block, extreme weather events could likely impact the location (siting), functionality, and sustainability of resulting infrastructure and infrastructure services. Detailed risk analysis and risk mitigation should be addressed in planning and engineering design. The contract for the engineering design services shall require that engineering analysis preceding design activities includes consideration of climate change and its potential impacts on the location (siting), functionality and sustainability of resulting infrastructure and infrastructure services. Such analysis must include identification of relevant data sets and gaps, review of local building standards and codes for adequacy; and determination of safety factors or other measures of uncertainty that will be carried through design. The results of this analysis, including risks identified and how they are addressed, shall be documented.
BEO SPECIFIED CONDITIONS OF APPROVALThe negative determinations recommended in this IEE are contingent on full implementation of specified conditions and a set of general monitoring and implementation requirements specified in Section 5 of the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
IMPLEMENTATIONAll details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
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USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATIONPROJECT/ACTIVITY NAME: Health Systems Strengthening Project Amendment #1Bureau Tracking ID: ______________________
Approval: _____Cleared______________________________________Patricia Rader, Ag. Mission Director
_9/20/19________Date
Clearance: ___Cleared_______________________________________Timothy Stein, Director Program Office
__9/12/2019_____Date
Clearance: _____Cleared____________________________________Rick Somarriba, Ag. Deputy Mission Director
___09/11/2019___Date
Clearance: _____ Cleared __________________________________Linda Percy, Controller Office of Financial Management
_____9/11/2019Date
Clearance: ___ Cleared ____________________________________Heather Smith-Taylor Director, Health and HIV/AIDS Office
__9/11/2019_____Date
Clearance: ____ Cleared ___________________________________Jessica Okui, Mission Environmental Officer
___9/9/2019____Date
Clearance: ____ Cleared ___________________________________David Kinyua, Regional Environmental Advisor
___9/5/2019___Date
Clearance: ___Cleared by Email________________________________Colin Quin, AFR Climate Change Advisor
__9/07/2019_____Date
Clearance: ________ Cleared _________________________________Shawna Hirsch, Climate Integration Lead
__9/10/2019_____
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Date
Concurrence:
_______ Cleared __________________________________Brian Hirsch, Africa Bureau Environmental Officer
_10/10/2019_____Date
INITIAL ENVIRONMENTAL EXAMINATIONCONTENTS1.0 PROJECT/ACTIVITY DESCRIPTION …………………………………………………………..
1.2 PROJECT/ACTIVITY SUMMARY …………………………………………………………….31.3 PROJECT/ACTIVITY DESCRIPTION …………………………………………………………8
2.0 BASELINE ENVIRONMENTAL INFORMATION......................................................................2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL, Threatened and ENDANGERED species ………………..102.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS ………………………………………………………………..10
3.0 ANALLYIS OF POTENTIAL ENVIEONMENTAL RISK ………………………………………104.0 ENVIRONMENTAL DETERMINATIONS..............................................................................11
4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 114.2 CLIMATE RISK MANAGEMENT 12
5.0 CONDITIONS AND MITIGATION MEASURES....................................................................125.1 CONDITIONS 135.2 AGENCY CONDITIONS 145.3 MITIGATION MEASURES 15
6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION............................177.0 REVISIONS......................................................................................................................18ATTACHMENTS:........................................................................................................................18
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1.0 PROJECT/ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEE The purpose of this amendment # 1 to the Initial Environmental Examination (IEE) File No. Uganda_ Health Systems Strengthening _Project _IEE_082318, approved 08/22/2018 for USAID/Uganda’s Health Systems Strengthening Project Management Team (HSS-PMT), is to provide a preliminary review of the reasonably unforeseeable effects on the environment of the following USAID interventions; expand scope, increase funding levels, and provide threshold determination for the Uganda Health Supply Chain (UHSC) Program, Waste Management Activity, Social Behavior Change for Transformation (SBC4T)activity, and Accountability and Risk Management Support Services (ARMSS) in accordance with the requirements to Title 22 of the Code of Federal Regulations (CFR) Part 216, as below. Upon approval, these respective determinations become affirmed per 22 CFR 216, and specified conditions become mandatory obligations of implementation. This analysis also documents the results of the activity-level Climate Risk Management process (UHSC and Uganda Waste Management activity), in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal_042817.
This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts should be addressed through formal Environmental Monitoring and Mitigation Plans (EMMPs) and/or Environmental Assessments (EAs), if needed.
Implementing partners are responsible for monitoring the environmental mitigation measures for their activities per the conditions of the IEE. The EMMP describes the impacts identified in the IEE and the mitigation measures planned to minimize or eliminate the environmental impacts of project activities (ADS 204 Supplement Section 5).
1.2 PROJECT/ACTIVITY OVERVIEW The UHSC MOH office project covers a 8 months implementation period (May 2019- December 2019), at a TEC of $500; Uganda Waste Management activity at a TEC of 5 million with a potential of increasing funding (TBD, 2019 –December 31, 2021); SBC4T at a TEC increase of $10 million (TBD, 2019). These activities shall be implemented through Cooperative Agreements, and Fixed Award Amount.
1.3 PROJECT/ACTIVITY DESCRIPTION
TABLE 2: DEFINED OR ILLUSTRATIVE ACTIVITIES
Activity DescriptionUHSC Expansion-MOH Brief Description: The objective of this activity is to
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office block construction
address the problem of lack of conference facilities and office space at the MOH. This project once completed will improve efficiency by creating office, meeting and research space for the MOH, as well as allow MOH to put aside secure space for US Government embeds in the current headquarters office facility. The construction of a 3-level storied office block will accommodate a conference hall, board room and offices. The total disturbed area resulting from this construction is approximated at 225 sq. meters; and shall be located at the Vector Control center along Buganda road, in Kampala. The site is free from any encumbrances and is 400 meters from the MOH headquarters. Additionally, the USG also provides technical assistance (TA) through direct staff secondments through its implementing partners, and direct USG employees supporting TA needs for governance, accountability and transparency who will be hosted out of the US Mission at this facility at the MOH.
Key outcomes or performance targets to be achieved: Procurement of A &E services, and construction of eight offices, a conference room for 80 people, a board room for 30 people and washroom/ kitchen facilities
Type of Action: Cooperative Agreement
Budget Estimate: $500,000 (from funds budget for Fleet Management activity in the original IEE)
Implementing Partner (IP): Management Sciences for Health
Waste Management Activity
Brief Description: The purpose of this activity to is to remediate health care waste generated by USAID-funded health activities. USAID Uganda is obligated under regulation 22 CFR 216 to properly collect, store, transport and dispose of waste generated by USAID activities. USAID supports Voluntary Medical Male Circumcision (VMMC) as an HIV/AIDS prevention measure throughout Uganda. VMMC interventions generate hazardous medical waste. This activity will ensure that this waste from VMMC and other health interventions is segregated, transported, treated, and disposed according to the World Health Organization, US Government, and Uganda National Environment Management Authority (NEMA) waste management standards.
Key outcomes or performance targets to be
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achieved: Illustrative targets include removal of VMMC waste from 365 health facilities across Uganda.
Type of Action: Fixed Amount Award
Budget Estimate: $ 10 million
IP: TBD
ARMSS
Brief Description: The purpose of this activity is to provide overall audit and risk management support to local PEPFAR partners, including assessment and management of risk of Antiretroviral (ARV) commodities.
Type of Action: IDIQ
Budget Estimate: $ 19.9 million
IP: TBD
SBC4T
NOTE: All details of the above sections remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
Budget Estimate: $10 million.
2.0 BASELINE ENVIRONMENTAL INFORMATIONSUMMARY OF GENERAL CONDITIONS IN UGANDA
All details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT These three activities shall take place in different locations in the country and a variety of environmental conditions shall be encountered as follow: UHSC expansion shall take place at the Vector Control Center along Buganda Road in Kampala; Uganda Waste Management activity shall take place in a total of 365 USG supported health facilities, that carry out Voluntary Medical Male Circumcision (VMMC) across the country; SBS4T shall be implemented in locations as described in the original IEE.
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The country’s environmental baseline is summarized the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project_ IEE_082318, and is cross referenced in this amendment
2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS All details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment.
3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK
TITLE: UGANDA HEALTH SYATEMS STRENGTHNING PROJECT AMEND #1
PROJECT/ACTIVITY 1: TABLE 3A. POTENTIAL IMPACTSProject/Activity Potential environmental and social impactsProject/Activity 1: UHSCSub -activity 1.1: Demolition of existing old building at site.(The old building covers an approximate area of 120 sq. meters; walls of brick, sand, cement and paint; roofed with old galvanized iron sheets)
Noise and air pollution during demolition of old building;Disposal of debris in environmentally sensitive ecosystems e. g wetlands, rivers, forests etc.; andhealth and safety risks for workers.
Sub-activity 1.2: Architectural and Engineering designs; and supervision of works.
Inappropriate designs carry inherent risks to the users and the community in terms including ease of use and disposal of waste and effluents.
Sub-activity 1.3: Actual construction works of new office block.
Health and safety risks for the workers involved in construction.Noise and air pollution during construction works;Disposal of debris in environmentally sensitive ecosystems e. g wetlands, rivers , forests, etc.;
PROJECT/ACTIVITY 2:
TABLE 3B. POTENTIAL IMPACTS – PROJECT/ACTIVITY 2Project/Activity Potential environmental and social impactsProject/Activity 2: Waste Management. Sub-activity 2.1: Collection and transportation of Health Care Waste from 375 select Health facilities country wide.
Risk of contamination and infections resulting from poor temporal storage facilities; Risk of spillage and contamination of environment with healthcare waste during transportation; and Risk of infections (e.g. HIV, Hepatitis, tetanus etc.) of personnel handling the healthcare waste.
Sub-activity 2.2: Disposal of health care waste; at selected sites.Ash from incineration facilities, shall
Risk of infections (e.g. HIV, Hepatitis, tetanus etc.) of personnel handling the healthcare waste;Incineration at lower temperatures; resulting in release of toxic
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be transported to Nakasongola constructed land fill for disposal.
emissions; and Bad odors for communities neighboring incinerators.
PROJECT/ACTIVITY 3:
Project /Activity 3: ARMSSSub-activity3.1: Providing audit and risk management support to local PEPFAR partners.
No potential environmental and social impacts.
4.0 ENVIRONMENTAL DETERMINATIONS 4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONSThe following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216. Specified conditions, detailed in Section 5, become mandatory obligations of implementation, per ADS 204.
TABLE 4: ENVIRONMENTAL DETERMINATIONSProjects/Activities Categorical Exclusion
Citation (if applicable)Negative Determination with Conditions
Positive Determination2
Deferral3
Project/Activity 1: UHSCSub-activity 1.1:Demolition of existing old building at site.
X X
Sub-activity 1.2:Architectural and Engineering designs; and supervision of works.
X X
Sub-activity 1.3 Actual construction works of new office block.
X X
Project/Activity 2: Waste managementSub- activity 2.1Collection and transportation of Health Care Waste from 375 select Health facilities country wide.
X X
Sub-activity 2.2 Disposal of health care waste; at selected sites.
X
2 Positive Determinations require preparation of a Scoping Statement and Environmental Assessment.3 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities.
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Project/Activity 3: ARMSSSub-activity 3.1Providing audit and risk management support to local PEPFAR partners.
X
4.2 CLIMATE RISK MANAGEMENT CLIMATE RISKS AND MITIGATION All details in this section remain as described in the original IEE, (File Name: Uganda_ Health_ Systems Strengthening_ Project IEE_082318 and is cross referenced in this amendment. This additional analysis documents the results of the activity-level Climate Risk Management process for UHSC MoH office block expansion, Uganda Waste Management and SBS4T activities, in accordance with ADS 201.
The analysis established that climate risks are high for construction of the office block and moderate for the waste management activity, and low for the rest.
In the original IEE and during climate risk screening for the Health Systems Strengthening PAD, climate risks were found to be low for health communication project elements, including SBS4T activities. Per ADS 201, no further climate risk analysis or action is required for the SBC4T activity.
However, for the health care waste management activity, extreme weather events like heavy rains and floods could cut off access roads to and from some health facilities in hard-to-reach areas. This could delay transportation and disposal of VMMC wastes. Climate-proofing of the transportation and disposal systems is therefore required. The activity will ensure that transportation and disposal plans are based on weather forecasts. This climate risk mitigation measure will be integrated into activity solicitation and implementation plans.
In addition, for construction of the office block, extreme weather events could likely impact the location (siting), functionality, and sustainability of resulting infrastructure and infrastructure services. Detailed risk analysis and risk mitigation should be addressed in planning and engineering design. The contract for the engineering design services shall require that engineering analysis preceding design activities includes consideration of climate change and its potential impacts on the location (siting), functionality and sustainability of resulting infrastructure and infrastructure services. Such analysis must include identification of relevant data sets and gaps, review of local building standards and codes for adequacy; and determination of safety factors or other measures of uncertainty that will be carried through design. The results of this analysis, including risks identified and how they are addressed, shall be documented.
5.0 CONDITIONS AND MITIGATION MEASURES
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5.1 CONDITIONSThe environmental determinations in this IEE are contingent upon full implementation of the following general implementation and monitoring requirements, as well as ADS 204 and other relevant requirements.
5.1.1 During Pre-Award:
5.1.1.1 Pre-Award Briefings: As feasible, the design team and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide a pre-award briefing for potential offerors on environmental compliance expectations/responsibilities at bidders’ conferences.
5.1.1.2 Solicitations: The design team, in coordination with the A/CO, will ensure solicitations include environmental compliance requirements and evaluation criteria. A/CO will ensure technical and cost proposal requirements include approach, staffing, and budget sufficient for complying with the terms of this IEE.
5.1.1.3 Awards: The A/COR, in coordination with the A/CO, will ensure all awards and sub-awards, include environmental compliance requirements.
5.1.2 During Post-Award:
5.1.2.1 Post-Award Briefings: The A/COR and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide post-award briefings for the IP on environmental compliance responsibilities.
5.1.2.3 Workplans and Budgeting: The A/COR will ensure the IP integrates environmental compliance requirements in work plans and budgets to comply with requirements, including EMMP implementation and monitoring.
5.1.2.4 Staffing: The A/COR, in coordination with the IP, will ensure all awards have staffing capacity to implement environmental compliance requirements.
5.1.2.5 Records Management: The A/COR will maintain environmental compliance documents in the official project/activity file and upload records to the designated USAID environmental compliance database system.
5.1.2.6 Host Country Environmental Compliance: The A/COR will ensure the IP complies with applicable and appropriate host country environmental requirements unless otherwise directed in writing by USAID. However, in the case of a conflict between the host country and USAID requirements, the more stringent shall govern.
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5.1.2.7 Work Plan Review: The A/COR will ensure the IP verifies, at least annually or when activities are added or modified, that activities remain with the scope of the IEE. Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.
5.1.2.8 IEE Amendment: If new activities are introduced or other changes to the scope of this IEE occur, an IEE Amendment will be required.
5.1.2.14 USAID Monitoring Oversight: The A/COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).
5.1.2.16 Environmental Compliance Mitigation and Monitoring Plan: The A/COR will ensure the IP develops, obtains approval for, and implements Environmental Mitigation and Monitoring Plans (EMMPs) that are responsive to the stipulated environmental compliance requirements.
5.1.2.17 Environmental Compliance Reporting: The A/COR will ensure the IP includes environmental compliance in regular project/activity reports, using indicators as appropriate; develops and submits the Environmental Mitigation and Monitoring Reports (EMMRs); and completes and submits a Record of Compliance (RoC) describing their implementation of EMMP requirements in conjunction with the final EMMR or at the close of sub activities (as applicable). And where required by Bureaus or Missions, ensure the IP prepares a closeout plan consistent with contract documentation for A/COR review and approval that outlines responsibilities for end-of-project operation, the transition of other operational responsibilities, and final EMMR with lessons learned.
5.1.2.18 Corrective Action: When noncompliance or unforeseen impacts are identified, IPs notify the A/COR, place a hold on activities, take corrective action, and report on the effectiveness of corrective actions. The A/COR initiates the corrective action process and ensures the IP completes and documents their activities. Where required by Bureaus or Missions, ensure Record of Compliance is completed.
5.2 AGENCY CONDITIONS5.2.1 Sub-award Screening: The A/COR will ensure the IP uses an adequate
environmental screening tool to screen any sub-award applications and to aid in the development of EMMPs.
5.2.2 Programmatic IEEs (PIEE): PIEEs stipulate requirements for additional environmental examination of new or country specific projects/activities. The A/COR of any project/activity being implemented under a PIEE will ensure appropriate reviews are
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conducted, typically through a Supplemental IEE, and approved by the cognizant BEO.
5.2.3 Supplemental IEEs (SIEEs): An SIEE will be prepared for any new project/activity being planned which fall under a PIEE. The SIEE will provide more thorough analysis of the planned activities, additional geographic context and baseline conditions as well as specific mitigation and monitoring requirements.
5.2.4 Other Supplemental Analyses: The A/COR will ensure supplemental environmental analyses that are called for in the IEE are completed and documented.
5.2.5 Resolution of Deferrals: If a deferral of the environmental threshold determination was issued, the A/COR will ensure that the appropriate 22CFR216 environmental analysis and documentation is completed and approved by the BEO before the subject activities are implemented.
5.2.6 Positive Determination: If a Positive Determination threshold determination was made, the A/COR will ensure a Scoping Statement, and if required an Environmental Assessment (EA), is completed and approved by the BEO before the subject activities are implemented.
5.2.7 Compliance with human subject research requirements: The AM, A/COR shall assure that the IP and sub-awardees, -grantees, and -contractors demonstrate completion of all requirements for ethics review and adequate medical monitoring of human subjects who participate in research trials carried out through this IEE and ensure appropriate records are maintained. All documentation demonstrating completion of required review and approval of human subject trials must be in place prior to initiating any trials and cover the period of performance of the trial as described in the research protocol.
5.3 MITIGATION MEASURESThe mitigation measures presented in this section constitute the minimum required based on available information at the time of this IEE and the environmental analysis in Section 4. These measures shall provide general direction for completing the project/activity Environmental Mitigation and Monitoring Plan (EMMP) and/or the EA and PERSUAP, if required.
PROJECT/ACTIVITY 1:
TABLE 5A. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 1Project/Activity Mitigation Measure(s)Project/Activity 1: UHSC
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Sub-activity 1.1: Demolition of existing old building at site(The old building covers an approximate area of 120 sq. meters; walls of brick, sand, cement and paint; roofed with old galvanized iron sheets)
Implement the following mitigation measures:
To minimize noise pollution: Ensure demolition works in done during the day; notify neighbors when demolition shall take place; ensure workers on site during demolition have adequate PPE including ear plugs, helmets, heavy duty gloves, gum boots, overalls etc.
Hording of demolition area with material to reduce on spread of particulate matter e.g. netting, iron sheets; sprinkling water on demolition area.
Additionally, the site should have a well-equipped First AID Box and firefighting equipment.
All waste resulting from the demolition; shall be transported to designated solid waste disposal area - as per Kampala Capital City Authority.
Sub-activity 1.2: Architectural and Engineering designs; and supervision of works.
Architectural and Engineering designs shall incorporate – Green Designs Principles; e.g. energy conservation/ use of renewable energy; maximum use of natural light; low water use/ water recycling; appropriate ventilation for increasing temperatures; proper wastewater collection and disposal; proper sanitation; proper solid waste collection and disposal etc.
Adequate protective gear (PPE) shall be provided and worn by personnel when conducting supervision work.
Sub -activity 1.3: Actual construction works of new office block.
Construction works shall be conducted following the principles for environmentally sound construction as provided in the USAID Environmental Guidelines for Small Scale Activities in Africa, Chapter 3:Constuction, which can be found at: http://www.usaidgems.org/Sectors/construction.htmhttp://www.usaidgems.org/Sectors/housing.htm;
An Environmental Monitoring and Mitigation Plan (EMMP) shall be prepared, and implemented. Additionally, host country environmental regulations shall be adhered to and all approvals from local authorities shall be obtained, including approval conditions from the National Environment Management Authority (NEMA), and Kampala City Council Authority.
PROJECT/ACTIVITY 2 :
TABLE 5B. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 2Project/Activity Mitigation Measure(s)Project/Activity 2: Waste managementSub-activity 2.1: Collection and transportation of Mitigation measures shall include the below:
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Health Care Waste from 375 select Health facilities country wide that shall be performing Voluntary Medical Male Circumcision (VMMC).
Waste management activity team will work with other implementing partner to assure that the medical facilities and operations involved have adequate procedures and capacities in place to properly handle, label, treat, store, transport and properly dispose of blood, sharps and other medical waste.
USAID’s Sector Environmental Guidelines for Health Care Waste: http://www.usaidgems.org/Documents/SectorGuidelines/Healthcare contains guidance which should inform the waste management activity to promote proper handling and disposal of medical waste, particularly in the section entitled, “Minimum elements of a complete waste management program,” and support GOU and other stakeholders to strengthen health care waste (HCW) systems.
Additionally, the waste management activity team will make reference to the Environmental Procedures Best Practices Report (2017) recommendations on health care waste management, (Attachment: F), when developing its EMMP.
The Waste Management activity shall ensure that enough resources are allocated to activities that generate VMMC in order to appropriately manage HCW at source i.e ensuring proper segregation and storage prior to collection.
The Waste Management activity shall provide facilities for proper collection, segregation, storage, and disposal of VMMC;
Waste Management activity shall apply to the National Environment Management Authority (NEMA) for a license to collect, transport and dispose HCW/Harzadous waste;
Thw wasye management activity shall ensure that all
VMMC waste is transported, incinerated and disposed in designated facilities with appropriate infrastructure for VMMC waste incineration and disposal, and are registered by NEMA
Waste management activity shall take measures to ensure that the waste management methods do not cause adverse effects to human health or the environment through emissions, effluent discharge or other contamination;
Waste management activity shall ensure that employees are equipped with skills and are regularly trained and instructed on how to handle emergency situations, while transporting or disposing HCW.
Waste management activity shall store the HCW in designated storage areas approved by the NEMA;
Waste management activity shall ensure that the collection and transportation of the waste is conducted in a manner that does not cause leakage, spillage,
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scattering or littering of the waste or the emitting of noxious smells or harmful odors;
Waste management activity shall ensure that the vessels used for transportation of HCW is not used for any other purposes;
Waste management activity shall develop shall journey management plans, and adhered to them for proper hazardous waste tracking; and shall keep records of HCW collected from each VMMC site;
Sub-activity 2.2: Disposal of health care waste; at selected sites.
Waste management activity shall treat or dispose waste in accordance with the treatment or disposal methods and environmental standards approved by the NEMA and shall use best available technologies and best environmental practices. Where there are no environmental standards, the waste management activity may, with the approval of the NEMA, use internationally recognized standards;
Waste Management Activity shall have quality control and quality assurance protocols, to ensure that the treatment and disposal of waste is in compliance with the National Environment Management Act (1995), National Environment Waste Management Regulations (2018), environmental standards, conditions in the NEMA -License, and any other applicable laws.
All private companies involved in transportation of VMMC waste are licensed and registered by the NEMA and adhere to NEMA and USAID regulations; and
All VMMC waste is transported, incinerated and disposed in designated facilities with appropriate infrastructure for VMMC waste incineration and disposal, and are registered by NEMA.
PROJECT/ACTIVITY3:
TABLE 5C. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 3Project/Activity Mitigation Measure(s)Project/Activity 3: ARMSSub-activity 3.1: Providing audit and risk management support to local PEPFAR partners
No required Environmental management conditions.
6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION
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The determinations recommended in this document apply only to projects/activities and sub-activities described herein. Other projects/activities that may arise must be documented in either a separate IEE, an IEE amendment if the activities are within the same project/activity, or other type of environmental compliance document and shall be subject to an environmental analysis within the appropriate documents listed above.
Other than projects/activities determined to have a Positive Threshold Determination, it is confirmed that the projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).
In addition, other than projects/activities determined to have a Positive Threshold Determination and/or a pesticide management plan (PERSUAP), it is confirmed that the projects/activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:
Support project preparation, project feasibility studies, or engineering design for activities listed in §216.2(d)(1);
Affect endangered and threatened species or their critical habitats per §216.5, FAA 118, FAA 119;
Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;
Promote timber harvesting per FAA 117 and 118; Lead to new construction, reconstruction, rehabilitation, or renovation work
per §216.2(b)(1); Support agro-processing or industrial enterprises per §216.1(b)(4); Provide support for regulatory permitting per §216.1(b)(2); Lead to privatization of industrial facilities or infrastructure with heavily
polluted property per §216.1(b)(4); Research, testing, or use of genetically engineered organisms per §216.1(b)
(1), ADS 211 Assist the procurement (including payment in kind, donations, guarantees of
credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).
7.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be
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amended to cover the changes. Per ADS 204, it is the responsibility of the USAID A/COR to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.
ATTACHMENTS : Annex 1: Climate Risk Management Summary Table for Activities. Annex 2: Output Matrix
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ANNEX 1: CLIMATE RISK MANAGEMENT
PROJECT CLIMATE RISK MANAGEMENT SUMMARY TABLE (Detailed table in Annex 2)Defined or Anticipated Project Elements/ Intervention Category
Climate Risks Risk Rating
How Risks are Addressed at Project Level
Further Analysis and Actions for Activity Design/ Implementation
Opportunities to Strengthen Climate Resilience
Construction of the UHSC-MOH office block
Extreme weather events could likely impacts the location (siting), functionality, and sustainability of resulting infrastructure and infrastructure services.
High Detailed risk analysis and risk mitigation should be addressed in planning and engineering design. Engineering analysis should include consideration of climate change and its potential impacts on the location (siting), functionality, and sustainability of resulting infrastructure and infrastructure services.
Climate resilience could be strengthened during planning and engineering design.
Waste Management Activity
Extreme weather events like heavy rains and floods could cut off access roads to and from some health facilities in hard-to-reach areas. This could
Moderate The activity will ensure that transportation and disposal plans are based on weather forecasts. This
None None
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Defined or Anticipated Project Elements/ Intervention Category
Climate Risks Risk Rating
How Risks are Addressed at Project Level
Further Analysis and Actions for Activity Design/ Implementation
Opportunities to Strengthen Climate Resilience
delay transportation and disposal of wastes.
climate risk mitigation measure will be integrated into activity solicitation and implementation plans.
SBC4T Limited/none. This activity only involves communication through various mass media
Low None The activity presents opportunity to include awareness raising on climate risk mainstreaming and management in planned health communication activities
ARMSS None. The activity only seeks to provide overall audit and risk management support to local PEPFAR partners.
Low None
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Annex 2: Climate Risk Screening and Management Tool for Health Systems Strengthening Project DesignOUTPUT MATRIX: CLIMATE RISKS, OPPORTUNITIES, AND ACTIONS for HSS PAD * = A required element, according to the Mandatory Reference # Project elements may include Purpose / Sub-purpose, Areas of Focus, or
Activities / Mechanisms, etc.
1.1. (a) Project Element
1.1. (b) Activities
1.2: Time frame
1.3: Geo-
graphy2: Climate
Risks*
3: Adaptive Capacity
4: Climate
Risk Rating*
5: Opportunities
6.1: Climate Risk
Management Options
6.2: How Climate
Risks Are Addressed
in the Project*
7: Next Steps for Activity Design*
8: Accepted Climate Risks*
Construction of UHSC –MOH Office block
Constructing a 3-level storied office block
20-30 years
MOH HQ in Kampala
Extreme weather events could likely impacts the location (siting), functionality, and
High Identify and address climate risks during planning and engineering design.
Detailed risk analysis and risk mitigation should be addressed in planning and engineering design. Engineering
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sustainability of resulting infrastructure and infrastructure services.
analysis should include consideration of climate change and its potential impacts on the location (siting), functionality, and sustainability of resulting infrastructure and infrastructure services.
Waste Management Activity
Properly collect, store, transport and dispose waste generated by USAID activities
5-10 years
National Extreme weather events like heavy rains and floods could cut off access roads to and from some health facilities in hard-to-reach areas. This could delay transportation and disposal of wastes.
Limited access to and use of accurate weather forecasts
Moderate
The Uganda National Meteorological Authority generates and disseminates seasonal weather forecasts.
Waste transportation and disposal plans should be based on and informed by weather forecasts
The activity will ensure that transportation and disposal plans are based on weather forecasts.
This climate risk mitigation measure will be integrated into activity solicitation and implementation plans.
None
Social Behavior
Social behavior
0-15 years
National Limited/none. This
Inadequate disseminatio
Low Presents opportunity to
N/A N/A Could consider to
None
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Change for Transformation (SBC4T)
change interventions for HIV, tuberculosis, malaria, nutrition, water sanitation and hygiene (WASH), global health security agenda (GHSA), maternal and child health and family planning.
component only involves communication through various mass media
n and use of climate information on climate risk in the health sector
include awareness raising on climate risk mainstreaming and management in planned health communication activities
include awareness raising on climate risk mainstreaming and management in planned health communication activities
ARMSS The purpose of this activity is to provide overall audit and risk management support to local PEPFAR partners
0-10 years
National None Low N/A N/A None
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