ENVIRONMENTAL COMPLIANCE FACESHEET FOR THEPROGRAMMATIC INITIAL ENVIRONMENTAL EXAMINATION (PIEE)

File Number/Document Control Number (DCN): [as assigned by BEO]

Sampriti: Strengthening Communities Impacted by the Rohingya Crisis

Special Objective: Strengthening Communities Impacted by the Rohingya Crisis

Program Areas:

Program Elements: ,

Solicitation #:[As assigned by contracting office]

Contract/Award Number (if known): N/A

Geographic Location : Bangladesh/Asia; 388

Originating Bureau/Office: Asia Bureau

Supplemental IEE: NOAmendment: NOProgrammatic IEE: YES

DCN and date of Original document:

DCN and ECD link(s) of Amendment(s):

Funding Amount: US$127,765,000 (combined)

Life of Project Amount:

US$127,765,000 (combined)

Implementation Start/End: FY 2019 – September 30, 2024

Prepared By: Jason Gilpin Date Prepared: May 24, 2019

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Expiration Date (if any): September 30, 2024 Reporting due dates (if any):

Environmental Media and/or Human Health Potentially Impacted (check all that apply):None Air Water Land Biodiversity Human Health Other

Recommended Threshold Determination: Negative Determination with conditions X Categorical Exclusion X Positive Determination

Deferral ExemptionAny pesticide(s) procurement or use, or both shall be in compliance with Asia 16-003: Bangladesh Programmatic Pesticide Evaluation Report and Safe Use Action Plan (PPERSUAP/20151) as amended with PPERSUAP Implementation Manual2

Climate Change:GCC/Adaption GCC/Mitigation X Climate Risk Screening [(to be completed for individual activities by an implementing partner(s)]Adaptation/Mitigation Measures: Mission has launched Climate Risk Analysis for the Bangladesh CDCS, Second Wave and Climate Change Annex to the CDCS is being drafted.

USAID recently supported numerous assessments of climate risks, e.g. 2016 CRM for the current CDCS, which found the scope and nature of proposed interventions in the area of influence to be of high risk, particularly when construction, rehabilitation or renovation of multipurpose cyclone shelters is involved.3

1 See at: https://ecd.usaid.gov/repository/pdf/45501.pdf2 See at: https://ecd.usaid.gov/repository/pdf/50669.pdf3 FRAGILITY AND CLIMATE RISKS IN BANGLADESH at: https://pdf.usaid.gov/pdf_docs/PA00TBFJ.pdf, USAID/BANGLADESH COMPREHENSIVE RISK AND RESILIENCE ASSESSMENT at: https://www.usaid.gov/sites/default/files/documents/1861/BNG_resilience_assessment_report_4Apr2017_final.pdf, CLIMATE RISK PROFILE BANGLADESH at: https://www.climatelinks.org/sites/default/files/asset/document/2018-02-Mar_CadmusCISF_Climate-Risk-Profile-Bangladesh.pdf,Climate Change Information Fact Sheet BANGLADESH at: https://www.climatelinks.org/sites/default/files/asset/document/Bangladesh%20Climate%20Info%20Fact%20Sheet_FINAL.pdf, FAA 118/119 at: https://www.usaid.gov/sites/default/files/documents/1865/Bangladesh-Tropical-Forests-and-Biodiversity-Assessment-2016.pdf, Climate Change and Education at: https://www.unisdr.org/files/16355_climatechangeedbangladesh.pdf, CLIMATE CHANGE AND COASTAL ZONES AN ANNEX TO THE USAID CLIMATE-RESILIENT DEVELOPMENT FRAMEWORK at: http://www.adaptationlearning.net/sites/default/files/resource-files/Coastal-Marine-Annex.pdf, http://sdwebx.worldbank.org/climateportal/countryprofile/doc/GFDRRCountryProfiles/wb_gfdrr_climate_change_country_profile_for_BGD.pdf , https://www.climatelinks.org/countries/bangladesh#climate-info; South Asia Hot-spots. The Impact of Temperature and Precipitation Changes on Living Standards: https://openknowledge.worldbank.org/bitstream/handle/10986/28723/9781464811555.pdf?sequence=5&isAllowed=y Climate Displacement in Bangladesh:

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Further climate risk screening shall be conducted by the implementing partner(s) at activity level for those activities under the approved Negative Determination with Conditions and Positive Threshold Decision and for those rate “moderate” to “high” risk in the updated Climate Change Annex to the Bangladesh 2nd

Wave CDCS, which has been drafted and is under review in the Mission.

1. Background and Context4 (see maps in Annex 5)

The Rohingya people have faced decades of systematic discrimination, statelessness and targeted violence in Rakhine State, Myanmar. Such persecution has forced Rohingya women, girls, boys and men into Bangladesh for many years, with significant spikes following violent attacks in 1978, 1991-1992, and again in 2016. Yet it was August 2017 that triggered by far the largest and fastest refugee influx into Bangladesh. More than 740,000 Rohingya have fled violence in Burma’s Rakhine State since August 2017, bringing the total Rohingya refugee population in Bangladesh to well over 900,000 people as of January 2019.5 The international is supporting GOB and these Rohingya refugees, the majority of whom are women and children who reside in refugee settlements and host communities.

Despite chronic development deficits and lagging indicators, Cox’s Bazar and Bandarban Districts were not geographic areas of emphasis for USAID prior to the crisis due to comparatively low population densities, access difficulties, and lack of political will. USAID had historically prioritized other, more population-dense areas in Bangladesh to maximize impact and reach the greatest number of people. Pre-existing programming across the two districts included five USAID-supported health clinics, a counter trafficking in persons (C/TIP) shelter, access to information digital centers, two environmental management and resilience activities, and two education activities. As the consequences of the refugee influx on Bangladeshi communities became evident, the Mission adapted existing development activities to help meet emergent needs and reduce tensions. This included defining the Resilience Focus Area, which includes all of Bandarban and Cox’s Bazar, as a component of the (Area) Zone of Influence (ZOI,) a requirement for Feed the Future programming. In Washington, Bureaus mobilized additional resources to support the expansion of development activities in host and impacted communities. The Mission, with support from Washington, conducted a Rapid Education and Risk Analysis; a health, nutrition, and market systems assessment; and a shelter assessment in host and impacted communities to better understand the extent of needs and inform programming. In addition, USAID leveraged humanitarian funding through Food for Peace and the Office of Foreign Disaster Assistance to address immediate food assistance needs in camps and acute vulnerabilities related to natural disasters in host communities to complement these

https://unfccc.int/files/adaptation/groups_committees/loss_and_damage_executive_committee/application/pdf/ds_bangladesh_report.pdf4 2019 JOINT RESPONSE PLAN FOR ROHINGYA HUMANITARIAN CRISIS, https://reliefweb.int/sites/reliefweb.int/files/resources/2019%20JRP%20for%20Rohingya%20Humanitarian%20Crisis%20%28February%202019%29.compressed_0.pdf https://migrationdataportal.org/themes/environmental_migrationhttps://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=23324&LangID=Ehttp://ec.europa.eu/echo/files/funding/decisions/2013/HIPs/bangladesh.pdf5 UNHCR. “Refugee Response in Bangladesh” Operational Portal. Accessed 11 Feb 2019. https://data2.unhcr.org/en/situations/myanmar_refugees

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shifts in USAID's development programs. USAID has closely coordinated response efforts with the State Department’s Bureau for Population, Refugees, and Migration (State/PRM), the U.S. Centers for Disease Control and Prevention, and other interagency actors, as well as with the broader donor and non-governmental organization community, including through the Inter-Sector Coordination Group.

The speed and scale of the refugee flows since August 2017 has resulted in a critical emergency and is a strain on already stretched resources in the region. The displacement has resulted in serious concerns regarding social cohesion between the refugees and the host communities. The presence of over one million Rohingya refugees has had a dramatic effect on the host communities surrounding the camps, especially in the upazilas (sub-districts) of Ukhiya and Teknaf, which are bearing the brunt of the burden of the crisis. While host communities in Ukhiya and Teknaf are acutely affected, other upazilas in Cox’s Bazar and Bandarban districts are also severely impacted by the displacement of the refugees. Accounts from the field describe a deterioration of the situation, such as increases in crime and security-related threats, loss of livelihoods, increase in child marriage, increased risk of drug and human trafficking, inflated prices for basic goods and services, increased resentment and insecurity in the area, community concerns about overcrowding, the rapid deforestation in the area, and impact of closing the Naf River fishery. The magnitude of the aid reaching the Rohingya camps causes a sense of deprivation and disparity to boil among the local population, who are also disadvantaged and struggling. As a direct result of atrocities committed by the Burmese Army and the ensuing Rohingya displacement, there are risks cascading across various sectors in Cox’s Bazar and Bandarban districts, with nearly all of the issues causing or exacerbating issues in other sectors.

Almost all the DRP are hosted in some of the world’s most congested areas, including in the Kutupalong “mega-camp”, which has fast become the largest displaced population camp in the world. The DRP account for about one-third of the total population in Cox’s Bazaar, a district that was already facing severe development challenges. They are sheltered in makeshift shelters and extremely congested settlements, in areas that have minimal access to basic infrastructure and services and are prone to natural disasters, especially cyclones and floods. Setting up of camps has led to rapid deforestation, further increasing vulnerability of the DRP to disasters and monsoon rains. Relocation of households most at-risk from landslides and flooding is underway, but there is insufficient suitable land available to accommodate even the highest-risk category.

The influx is straining existing infrastructure and degrading an already resource-constrained social service delivery system and the environment in Cox’s Bazar district. Stress on existing water points has increased over 20 fold with the new influx, rendering many of them dysfunctional while disposal and treatment of fecal sludge have become a challenge. Over 70 percent of water stored in households is contaminated, and there have been outbreaks of diseases like diphtheria, measles, and diarrhea. The influx has increased strain on referral and inpatient services provided by the district hospital and the two upazila Health Complexes.

Bandarban6

6 http://documents.worldbank.org/curated/pt/874871468198578021/pdf/E26060V30P118710Mar0disclosable0ver.pdfState of the Environment in the Chittagong Hill Tracks, ISRIS, The Netherlands, 2007; http://www.fao.org/3/a-az429e.pdf

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The Chittagong Hill Tracts (CHT) comprises of three hill districts, Bandarban, Khagrachari and Rangamati. The formal administrative structure of the hill district is headed by the Deputy Commissioner. Moreover apart from the formal system of governance, CHT is divided into three circles: a) Chakma Circle, b) Mong Circle and c) Bhomong Circle. Each circle is headed by a Circle Chief known as Raja. The Circle Chiefs are entrusted with responsibility of collecting taxes and are empowered to bestow justice in accordance with customary laws of tribal/ethnic people living in their jurisdiction. The CHT Regulation 1900 gives the authority of the general administration of Chittagong to the District Commissioner (DC) of GOB. The DC by law has to act with the Chiefs in matters affecting administration of the CHT. Since the 1997 Peace Accord a Hill Regional Council has been set up for overall coordination of administrative and development affairs in the region.

In CHT there are about 12 ethnicities (11 indigenous and Bangalees). Essentially there are 11 ethnic multi-lingual minorities in CHT they are: Bawn/Bawm, Chak, Chakma, Khyang, Khumi, Lushei/Lushai, Marma (Maghs), Mrus/Mro (Moorangs), Pangkhua/Pankhua, Tangchangya, and Tipperas (Tipras)7.

1.1 Purpose and Scope of IEE:

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22 CFR 216 and specified conditions become mandatory obligations of implementation. This PIEE also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal) and seeks to ensure compliance with Agency Construction Risk policy (ADS 201maw.)

This PIEE 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 mitigation and monitoring plans (EMMPs) and/or Environmental Assessments (EAs.)

Summary of Findings:

To align with the Special Objective “Strengthening Communities Impacted by the Rohingya Crisis” in the USAID/Bangladesh 2nd Wave Country Development Cooperation Strategy (under preparation,) this PIEE (PAD-level) folds-in and covers all USAID current and planned activities in the host and impacted communities of the Resilience Focus Area, which includes Cox’s Bazar and Bandarban (all upazillas.)

This PIEE provides reference to all current activities (defined as under implementation, awarded or under procurement) folded into the SO and their respective approved IEEs. 7 https://www.ifad.org/documents/38714170/40224860/bangladesh_ctn.pdf/ea8bae36-7450-447a-b0e9-4c010ba315bf

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All conditions, limitations and stipulation for revisions in the approved IEEs remain in force for the individual folded-in projects for the combined LOP funding levels and LOP duration, where the end date will the date approved in this IEE.

For other new activities under design or solicited under the Agency-wide New Partnership Initiative Annual Program Statement, they will be covered under this PIEE as written so long as the scope and nature of the activities and their associated environmental and social impacts remain as described herein.

For proposed new activities, the PIEE established addition conditions, which can be refined at a later date through an amendment to the PIEE or through the memo to the file as warranted.

For the NPI APS 22 CFR 216 Deferral, approved by BEO/DCHA on May 14, 2019, the deferral shall be cleared by issuance of BEO/Asia-approved Categorical Exclusion or Initial Environmental Examination prior to disbursement of funding or solicitation of awards.

2. Baseline socio-economic, environmental and climate information8

2.1 Socio-economic situation 9

Bangladesh is one of the world’s most populous country with estimated over 165 million people in a geographical area of about 144,415 sq.km and per capita income of US$1670, in 2018, well above the lower middle-income country category threshold which it crossed in FY14. During recent years, economic conditions improved in the country. However, headline inflation increased to 5.8 percent in FY18, from 5.4 percent in FY17, reflecting increases in food prices due to supply shocks. Fiscal deficit was contained at around 4.5 percent of Gross Domestic Product (GDP) in FY18. The GDP grew well above the average for developing countries in recent years, averaging 6.5 percent since 2010, with an officially estimated growth of 7.86 percent in FY18, driven by manufacturing and construction. Progress on reducing extreme poverty and boosting shared prosperity through human development and employment generation has continued with the poverty incidence based on the international $1.90 per capita per day poverty line (measured on the basis of the Purchasing Power Parity exchange rate) declining from 44.2 percent in 1991 to a 14.8 percent in 2016. In the World Bank’s Human Capital Index 2018, Bangladesh performed better than the South Asian average as well as the Lower Middle-Income average in all criteria except for Stunting. Bangladesh witnessed a profound social transformation with an influx of girls into the education system and women into the labor force. The Government of Bangladesh has also emphasized on ‘accelerating growth’ and ‘empowering citizens’ through more job creation, inequality reduction, access to education and employment, transportation and power sector improvement, social protection coverage and building resilience against natural disasters.

8 https://www.heritage.org/index/country/bangladesh http://worldpopulationreview.com/countries/bangladesh-population/9 http://documents.worldbank.org/curated/en/190391468190764030/pdf/100113-WP-PUBLIC-Box393225B-Bangladesh-Country-Snapshot.pdf; https://www.adb.org/sites/default/files/publication/419891/basic-statistics-2018.pdf

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2.2 ENVIRONMENTAL SITUATION AND RISKS 10

Bangladesh’s physical and cultural characteristics and the livelihoods of the people are defined by the Ganges-Brahmaputra-Meghna delta—the world’s largest, most densely populated delta, and one of the richest in aquatic resources. The societal vulnerability to extreme weather events is clearly illustrated in the case of Bangladesh, considered one of the most disaster-prone and climate vulnerable countries in the world. Bangladesh faces considerable development challenges posed by its low and flat topography and vulnerability to floods, torrential rains, erosion, storms and tidal surges due to severe cyclones and landslides. Its vulnerability is exacerbated by climate change induced increase in frequency and intensity of extreme weather events, sea level rise and uncertainty. Bangladesh is ranked the 6th most climate vulnerable country among 181 countries. Damages and losses associated with a single extreme event impose substantial costs on the national economy and repeated exposure to hydro-meteorological hazards such as cyclones and floods often pushes the poor, particularly rural poor, into chronic poverty.

CLIMATE RISK11

Bangladesh is prone to climate change risks in multiple ways. Climate change induced rises in sea levels, increase soil and water salinity and further threatens the country’s agriculture sector as 30% of the country’s arable land is in coastal areas. Per the Global Climate Risk Index, Bangladesh is one of the most climate change vulnerable country in the world. The World Bank projects that nearly 5.3 million poor will be vulnerable to the effects of climate change in 2050. Agriculture, the most important sector, is extremely vulnerable to climate change as increasing temperatures, rainfall variability, and humidity impact crop yield, livestock and fish production. It is estimated that the country is likely to be negatively affected by sea level rise and saltwater intrusion, mean temperature increases (1.7o C by 2050), rainfall variability, and an increase in the frequency and intensity of extreme weather events. Increased soil and water salinity is projected to result in a 15.6% yield reduction in high-yielding rice varieties before 2050, and overall production of rice – a staple to decline in all the three rice growing seasons by 8%–17% by 2050. While early monsoon arrival can cause flood damage when rice seedlings are

10Bangladesh is ranked 179 of 181 countries on Environmental Performance Index: https://epi.envirocenter.yale.edu/sites/default/files/2018-bgd.pdfBangladesh is projected to face over 2.0% loss of annual GDP by 2050 due to climate change - https://www.adb.org/sites/default/files/publication/42811/assessing-costs-climate-change-and-adaptation-south-asia.pdf .http://documents.worldbank.org/curated/en/585301536851966118/pdf/129915-CEA-P161076-PUBLIC-Disclosed-9-16-2018.pdf;http://www.indiaenvironmentportal.org.in/files/file/bangladesh%20environment%20and%20climate%20change%20outlook12.pdf; http://documents.worldbank.org/curated/en/239271500275879803/pdf/117480-PUB-Date-6-29-2017-PUBLIC.pdf11 https://epi.envirocenter.yale.edu/epi-country-report/BGDGlobal Climate Risk Index 2019 https://germanwatch.org/sites/germanwatch.org/files/Global%20Climate%20Risk%20Index%202019_2.pdf http://www3.weforum.org/docs/WEF_Global_Risks_Report_2019.pdf

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submerged in early growth stages, especially when farmers are not using submergence-tolerant varieties, on the other hand, late monsoon arrival can lead to water stress. With climate change impacts increasing in coming years, several studies conclude that extreme weather conditions (floods and cyclones) are expected to increase in frequency and intensity in Bangladesh.12

In the last 30 years, Bangladesh has experienced nearly 200 climate-related disasters including droughts, extreme temperatures, floods, and storms. These events have had significant impacts, including loss of life, and the destruction of homes and livelihoods and costs estimated at $16 billion in damages. Women are among the most vulnerable people to these impacts due to unequal access to natural and financial resources, and education and social restrictions. Climate projections suggest an increase in the frequency of extreme events is likely for Bangladesh.

USAID recently supported numerous analysis of climate risks, e.g. at the current CDCS, including in health sector, which found that interventions of moderate and to high risk when construction, rehabilitation or renovation of facilities is involved.13

The climate of this region is tropical and characterized by a change of four, monsoon-related seasons: pre-monsoon (March to May); monsoon (June to September); post-monsoon (October to November); and the dry season (December to February). The influx area is highly susceptible to tropical cyclones and tidal surges. Cyclone storms develop in the Bay, generally in the periods from April to May and October to November, occasionally making landfall and causing severe damage to human settlements and vegetation. Climate change will exacerbate many of the current problems and natural hazards the country faces and the predicted higher wind speeds and storm surges will lead to more damage in the coastal region. Predictions include: increasingly frequent and severe tropical cyclones; heavier/lighter and more erratic rainfall; higher river flows; river bank and coastal erosion; increased sedimentation; melting of the Himalayan glaciers; and sea level rises.

NATURAL DISASTERS

12 http://documents.worldbank.org/curated/en/538711501682842969/pdf/ITM00184-P161534-08-02-2017-1501682838772.pdf13 FRAGILITY AND CLIMATE RISKS IN BANGLADESH at: https://pdf.usaid.gov/pdf_docs/PA00TBFJ.pdf, USAID/BANGLADESH COMPREHENSIVE RISK AND RESILIENCE ASSESSMENT at: https://www.usaid.gov/sites/default/files/documents/1861/BNG_resilience_assessment_report_4Apr2017_final.pdf, CLIMATE RISK PROFILE BANGLADESH at: https://www.climatelinks.org/sites/default/files/asset/document/2018-02-Mar_CadmusCISF_Climate-Risk-Profile-Bangladesh.pdf,Climate Change Information Fact Sheet BANGLADESH at: https://www.climatelinks.org/sites/default/files/asset/document/Bangladesh%20Climate%20Info%20Fact%20Sheet_FINAL.pdf, FAA 118/119 at: https://www.usaid.gov/sites/default/files/documents/1865/Bangladesh-Tropical-Forests-and-Biodiversity-Assessment-2016.pdf, Climate Change and Education at: https://www.unisdr.org/files/16355_climatechangeedbangladesh.pdf, CLIMATE CHANGE AND COASTAL ZONES AN ANNEX TO THE USAID CLIMATE-RESILIENT DEVELOPMENT FRAMEWORK at: http://www.adaptationlearning.net/sites/default/files/resource-files/Coastal-Marine-Annex.pdf, http://sdwebx.worldbank.org/climateportal/countryprofile/doc/GFDRRCountryProfiles/wb_gfdrr_climate_change_country_profile_for_BGD.pdf , https://www.climatelinks.org/countries/bangladesh#climate-info

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Bangladesh is vulnerable to floods, flash floods, salinity, storm surges, landslides and earthquakes. Flooding, mainly in the period from May to October, occurs almost annually and affects most of the country with the exception of Barind Tract and hilly areas. The southern coastal part of Bangladesh is prone to storm surges and soil salinity while the hilly areas of Chittagong Hill Tracts, Cox’s Bazar and Teknaf are vulnerable to landslides. The area of the Rohingya influx has a history of occurrence of landslides, earthquakes, flash floods and tidal surges. Although the main area of the Rohingya camps is located outside of the flood zone, the camps are vulnerable to extreme weather events such as cyclones and have to withstand major precipitation and strong winds. The steep slopes without trees and vegetation become unstable in the monsoon seasons and cause landslides, shelter damage and other destruction. In general, neither the structures in the Rohingya camps nor those in the makeshift settlements are able to withstand cyclones or floods; nearly 70% of shelters in settlements were damaged by Cyclone Mora in May 2017.

AIR QUALITY

Baseline data on air quality is currently not available. However, the area of influx is hilly and close to the sea, and this geographical location, coupled with the limited amount of industry in the area, means that air quality remains within acceptable limits. Pollution from cars may be a factor in the future; there is relatively heavy tourist traffic from Cox’s Bazar to Teknaf.

SURFACE AND GROUND WATER

Surface water. The Moheshkhali Channel, Baak Khali and Naf rivers and Bay of Bengal are the main waterways of the region. The Moheshkhali Channel flows into the Bay of Bengal near Cox’s Bazar and passes the north western boundary of the area of influence. The Bakkhali River originates from the Chittagong Hill Tracts and flows into the Bay near Cox’s Bazar. Five other canals run through the hilly hinterland. During winter, the canals become almost dry. Because of the scarcity of fresh water, the region is dependent on ground water sources for its crops and horticulture.

Ground water systems. From available ground water zoning maps, it can be seen that the ground water level in and around the influx area is shallow. Ground water storage reservoirs are composed of three aquifers in Bangladesh. They are: the upper aquifer or composite aquifer, the main aquifer (at a depth of 6 m to 100 m) and the deep aquifer. With the increased trend of urbanization and irregular rainfall patterns, surface run-off has increased in recent times and this is likely to further reduce ground water recharge in all aquifers in the influx area. It was noted that the main aquifer is deteriorating towards the south and the east. In the areas near the coast the water table is descending due to over exploitation.

SOILS AND TERRAIN

Soils. The major soil types are red, alluvial, muddy and sandy soil. The soils range from clay to clayey loam on level ground and from sandy loam to coarse sand on hilly land. In the forest areas, the clayey and sandy loams are fertile, and the sandy soil is often infused with iron, resulting in a red or yellowish tinge. The hilly soils developed from un-consolidated rocks are

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moderately well to excessively well drained, generally deep, and probably the oldest soils in this region, while those occurring on hills from consolidated rocks tend to be formed in weathered sandstones, shales, and siltstones. The soils developing from the weathered sandstones tend to be sandy loams to clay loams, and those in shales silty clay loams.

Geomorphology. Most of the area of Bangladesh is a vast low lying alluvial plain, sloping gently to the south and southeast. According to the Ecological Zoning Map of Bangladesh, the influx area falls under the Chittagong Coastal Plain and in terms of physiological formation, the area has lower hill ranges. The influx area is situated on a combination of small hills and plains extending into the Chittagong Hill Tracts bordering Myanmar. This region has a complicated and relatively recent tectonic history.

VEGETATION AND WILDLIFE

The forest land in the Ukhia and Teknaf upazilas is covered by tropical evergreen and semi-evergreen forests occurring in deep valleys and shaded slopes. Human activities have denuded most parts of the hills which have been re-occupied by sun grass, herbs and shrubs. Still, the area houses rich biodiversity, especially within the protected areas (PA). In the last two decades, the forest areas in Ukhia and Teknaf have been significantly degraded or have been cleared. Between 1989 and 2009, the forest coverage of TWS was reduced by 46% from 3,304 ha to 1,794 ha. The shrub type of forests increased by 25% from 6,263 ha to 7,824 ha.

Apart from the degradation, this forest area still houses rich biodiversity including megafauna like the Asian elephant (Elephas maximus) and many different bird species. It has been confirmed that more than 50% of the country’s wildlife species are living in the forests of Ukhia, Teknaf, Inani and Himchari within the Cox’s Bazar South Forest Division.

Teknaf Wildlife Sanctuary.

The Teknaf Wildlife Sanctuary (TWS) is the most important forest ecosystem in Bangladesh. The sanctuary is home to the Teknaf Game Reserve which was established to focus on the conservation of the Asian Elephant, more than one hundred of which have been observed in the sanctuary. In many places, the elephant corridors have been blocked by host communities and infrastructure and some of these corridors are being hampered by the Rohingya. Over the last 50 years the vegetation in the AoI has been degraded by both human and natural factors. In the period 1920 to 1990, natural forests were cleared to make way for wood lots. The Rohingya influx in 1991 and several other influxes reduced the forests of Ukhia and Teknaf substantially. Three major cyclones, in 1991, 1994 and 1997 severely affected the forest areas. Conversion of many foothills and low-lying areas into paddy fields and settlements through the process of forest land encroachment has shrunk the forests severely. Inside the TWS boundary, the settlements and homestead forests were increased over 50%. In 2012, the natural forests under the TWS covered only 10% of the area and the rest was covered by shrubs with a few scattered trees. They are eight habitats in the TWS which support rich biodiversity: high forests; plantations; grasslands and bamboo; wetlands; tidal mudflats and mangrove vegetation along the Naf River to the east; sandy beaches along the Bay of Bengal to the west; cliffs and steep slopes; and cultivated fields and settlements. Some of these habitats have been highly degraded due to

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anthropogenic causes. Biodiversity in the TWS covers many endangered species in Bangladesh and the habitat has been declared critical. In the 1990s the TWS housed more than half of the mammalian species of the country. Since then, during the last three decades, this area has lost several faunal species due to anthropogenic pressure.

Himchari National Park.

Himchari National Park, declared in 1980, is another important protected areas in Bangladesh. It lies within the Cox’s Bazar South Forest Division covering an area of 1729 ha. The park is home to 56 species of reptiles, 13 species of amphibians, 286 species of birds, and more than 100 species of trees, shrubs, grasses, canes, palms, ferns and herbs. The biodiversity of the park is threatened by many anthropogenic factors which have been exacerbated by the Rohingya influx as merchants illegally collect bamboo and fuelwoods from this forest and sell them to the Rohingya community.

Inani National Park .

The Inani National Park, within the Cox’s Bazar South Forest Division, covers an area of 7,700 ha of reserve forest falling under an evergreen and semi evergreen tropical forest zone. It includes both the Inani and the Ukhia forest range. Although the Inani forest area was historically rich in biodiversity, the current vegetation consists mainly of herbs, sun grass, shrubs and bushes. The high forest has shrunk from 70% to less than 30% in the last three decades. Bushes, sun grass and bamboo dominate the landscape. There are 443 plant species from 93 families in the Inani National Park and is also home to 29 species of amphibians under six families. Among the amphibians, 12 are rare, 9 are common and 8 are very common. Although the current Rohingya influx does not have any direct influence on the Inani protected area, there are still some assumptions that bamboo and fuelwood are being extracted from the Inani protected areas and sold to the Rohingya community.

Marine and Fresh Water Environment

The surface hydrology in the forest areas is regulated by rainfall and runoff from adjacent uplands and the relief pattern of the plains. The area is interspersed by valleys and gullies and crossed by 149 streams which at the eastern side flow to the Naf river and at the western side flow to the Bay of Bengal. There are a few shallow depressions in the area providing wetlands to migratory birds, and fish for local livelihoods. They also house habitats for other wildlife. A survey of the fisheries fauna of the Naaf river estuary in the 1990s recorded 123 fish species, 20 species of shrimp and prawns, 3 species of crabs and 2 species of lobster. The dominant group was represented by a few small sized fishes. Given the close proximity to the sea and the presence of backwaters, the people in the region are habituated in pisciculture and prawn culture. The people also practice salt farming.

Current State of Environment After Rohingya Influx

In most parts of Ukhia, especially in the areas of Kutupalong and Balukhali, land use has completely changed within a short period of time. Some of the hills have been completely

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denuded and deforested and the area is now filled with shelters. Other hills will likely face a similar fate. There are over a million Rohingya who have so far been sheltered within a few square kilometers of the influx area combining old and new makeshift camps. The most alarming impacts of the influx are: forest degradation and habitat loss; the fragmentation of territory for wildlife; human-wildlife conflicts, including interference with elephant corridors; hill cutting, soil erosion and stream congestion; ground water source depletion; and pollution watershed degradation and water scarcity. Soil pollution and compaction, lighting, noise and air pollution are other areas of concern.

Forest Degradation and Habitat Loss

The Rohingya gather whatever materials they are able to in order to build their shelters. This has resulted in indiscriminate cleaning of the vegetation cover from hills and forests. Fuelwood for daily cooking is also being collected from forests, and this is causing serious forest degradation and habitat destruction. A new access road to the Rohingya camps on the Cox’s Bazar – Teknaf highway is under construction and this will facilitate access not only to the camps, but also to the forests and their resources.

Fragmentation of Wildlife’s Territory and Corridor

The area from TWS to the Himchari National Park is almost a continuous hill belt covered with degraded forest vegetation. This allows wildlife, especially the Asian elephant, to move freely from one side to the other in search of food. The elephant’s habitat and corridors have become fragmented as a result of Rohingya settlement inside the forest.

Human-Wildlife Conflicts

The Teknaf-Ukhia forest area is a habitat comparatively rich in wildlife, where wild elephants, deer, wild boar, monkeys, birds, squirrels, red jungle fowl and different types of snakes still exist. The construction of Rohingya shelters inside this territory means that people and wildlife are now cohabiting. During the movement of both wildlife and humans, there is high possibility of incidents of human-wildlife conflict; wildlife is at risk of being hunted and killed, and people are also at risk. There are reportedly incidents of deer hunting by Rohingya for meat, and some Rohingya have been killed by wild elephants. In addition, local poachers may seek to exploit the situation.

Hill Cutting, Soil Erosion and Stream Congestion

To accommodate large numbers of Rohingya people, a number of hills have been cleaned and steps have been cut into the slope to facilitate access to the shelters. Hill cutting loosens the soil resulting in soil erosion, sedimentation and siltation - a washing out of the valuable fertile top soil that will make the hills unsuitable for supporting any valuable vegetation cover. The eroded soil will also cause stream congestion, which might hinder stream flow, which in turn will result in habitat loss, water pollution and water scarcity further downstream, standing waters which are breeding grounds for mosquitoes. Hill cutting and the clearing of vegetation cover also increases the risk of hill and land slide at the time of monsoon rains. Denuded hills become dry and usually

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generate cracks, and in the rainy season there is more chance that water will enter into the denuded hills through the cracks. As a result, there is a high risk of local landslides which could cause the destruction of the shelters and potential causalities.

Watershed Degradation and Water Scarcity

Around 3,000 to 4,000 acres (1,200 – 1,600 ha) of hilly land in the Teknaf-Ukhia-Himchari watershed area have been cleared by removing vegetation cover to erect shelters for the Rohingya people. The watershed absorbs large quantities of rainwater, and holds water with the help of the vegetation cover existing on it; removing the vegetation cover of hills reduces their water retaining capacities. This capacity is already much reduced by the felling of large trees. The watershed acts as a major source of essential fresh water in the form of a stream for local residents; it is used for drinking and other domestic purposes year-round. Fresh water scarcity is now a common phenomenon in the Teknaf Ukhia areas, as most of the area is hilly, and its subsoil is rocky and impermeable, restricting boring for ground water.

Waste pollution

Polythene sheets, synthetic ropes and nails are currently being used to make shelters for the Rohingya, and these are a source of soil pollution. Other sources of pollution are: plastic bags used for packaging relief items; polythene bags used for the distribution of cooked food for children and newcomers; plastic bottles, and used torch batteries. A proper system of waste disposal needs to be in place for these materials. Drainage systems blocked by polythene bags have been identified as a major cause of flooding in Bangladesh during the monsoon season.

Lighting and Noise Pollution

Lighting in shelters at night, and cooking inside the forest is hampering the nesting, roosting, breeding, and feeding grounds of wildlife. Noise, originating from communication among the Rohingya people, service providers, relief distributors, and from a sharp increase in vehicular movement is also disturbing wildlife.

Air and Water Pollution

Smoke and dust generated from stoves and from traffic is a source of air pollution. A lack of solid waste management in the Rohingya camps is causing water pollution in nearby streams; unmanaged human waste is being channeled to hilly streams and contaminating water, which might cause the spread of waterborne and contagious diseases among nearby localities and host communities.

2.3 Regulatory and Organizational Framework

Bangladesh’s policy and legal framework governing environmental performance has been gradually improving.14 The 1992 National Environment Policy was Bangladesh’s first

14 Bangladesh was ranked 52 of 70 countries on Environmental Democracy Index: https://environmentaldemocracyindex.org/rank-countries#all

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environmental law, which was revised in 2013 and is currently being updated15. Since then, over 25 different acts, policies, guidelines, and regulations have been instituted. The available benchmark data suggests that Bangladesh’s regime for environmental protection is not as strict as in some other countries in Asia.16 When Bangladesh was compared with select Asian countries based on both the stringency of environmental regulations and their enforcement, it ranked lower than several lower-middle-income countries, such as the Philippines, Indonesia, and Cambodia. Although the surveyed group ranked Bangladesh higher than Vietnam in terms of stringency, Bangladesh was perceived as weaker on enforcement.

Key legal and policy documents include:

The Constitution of the Peoples’ Republic of Bangladesh, 197217

National Sustainable Development Strategy (2010-2020) Bangladesh Climate Change Strategy and Action Plan (BCCSAP, 2009) National Biodiversity Assessment and Programme of Action 2020 National Biodiversity Strategy and Action Plan (2004, updated in 2016) National Environment Policy (1992) National Environment Management Action Plan (1995) Energy Efficiency and Conservation Master Plan (2015) National Aquaculture Development Strategy and Action Plan 2013–2020 National Forest Policy (1994) and draft Forest Policy (2015) Bangladesh Climate Change and Gender Action Plan (2013) National Wetland Policy (1998) National Water Policy (1999) National Land Use Policy (2001)

National Environment Policy, 1992. The National Environment Policy of 1992 sets out the basic framework for environmental action, together with a set of broad sector action guidelines. The Policy provides the broader framework of sustainable development in the country. It also

15 From: https://green.edu.bd/wp-content/uploads/2019/01/Greening-Justice-in-Bangladesh_A-Road-to-Successful-Environmental-Court.pdf - “During the ancient Bengal, the protection of the environment was accepted as of duty. In view of Muslim rulers, the protection, conservation and development of the environment and natural resources are a mandatory religious duty. Mint Towns and administrative headquarters were located on riverbanks in consideration of sound environment. Sher-Shah (1540-45) for the first time considered environment as essential issue for the welfare of the state. During the Moghul period, many royal orders (farmans) were circulated by the Muslim rulers to protect and conserve environment.”16 http://documents.worldbank.org/curated/en/585301536851966118/pdf/129915-CEA-P161076-PUBLIC-Disclosed-9-16-2018.pdf17 Article 18A, (15Th Amendment, 2011/12): The state shall endeavor to protect andimprove the environment and preserve and safeguard the natural resources,biodiversity, wetlands, forest and wildlife for the present and future citizens.

Article 31: Right to Life has been extended to include right to safe environmentwhen the importation of radiated milk was challenged through a writ petition,WP No. 92/1996. (ref: in two cases [XLVIII DLR, 1996, p.438 and XVII Bangladesh Legal Digest (BLD), 1996 (AD), pg. 1] the Supreme Court has resolved that the "right to life" enshrined as a fundamental right includes the "right to a healthy environment". )

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stated all major undertakings, which will have a bearing on the environment; (including setting up of an industrial establishment) must undertake an IEE and EIA before initiation of the project.

Key elements of the policy are: maintaining ecological balance and ensuring sustainable development of the country through protection and conservation of the environment; protecting the country from natural disasters; identifying and regulating all activities that pollute and destroy the environment; ensuring environment-friendly development in all sectors; ensuring sustainable and environmentally sound management of the natural resources; maintaining active association, as far as possible, with all international initiatives related to environment.

Bangladesh Environmental Conservation Act (1995) and Amendments. The Bangladesh Environment Conservation Act of 1995 is the key legislation in relation to environment protection in Bangladesh. This Act is promulgated for environment conservation, standards, development, pollution control, and abatement. It has repealed the Environment Pollution Control Ordinance of 1977. The Act has been amended in 2000, 2002, 2007 and 2010.

The main objectives of the Act are: conservation and improvement of the environment, and control and mitigation of pollution of the environment. The main strategies of the Act can be summarized as: providing appropriate organizational structure and regulatory powers to the Department of Environment to monitor environmental issues, and enforce control measures where appropriate; declaration of ecologically critical areas and restriction on the operations and processes, which can or cannot be carried out / initiated within these; promulgation of standards for quality of air, water, noise and soil for various applications; Regulation of allowable vehicle emissions; regulatory responsibility for the environmental clearance process for new and existing project and developments; regulation of discharge limits and discharge permits for industries and other developments; promulgation of a standard limit for discharging and emitting waste; and formulation and declaration of environmental guidelines for key issues.

The Department of Environment (DoE) executes the Act under the leadership of the Director General (DG). As stipulated under the ECA, the Project proponent must obtain Environmental Clearance from the DG of DoE before any new project can be approved. An appeal procedure exists for those proponents who fail to obtain clearance, however failure to comply with any part of this Act may result in punishment equivalent to a maximum of five years imprisonment, or a maximum fine of Tk. 500,000, or both.

The Environmental Conservation Act (Amendment 2000) The Bangladesh Environment Conservation Act (Amendment 2000) focuses on ascertaining responsibility for compensation in cases of damage to ecosystems. It allows for increased provision of punitive measures both for fines and imprisonment, and the authority for nominated officials to record the details of alleged offences and to prosecute the offenders. The 2002 Amendment of the ECA elaborates on the following parts of the Act: restrictions on automobile emissions; restrictions on the sale and production of environmentally harmful items like polyethen bags; assistance from law enforcement agencies for environmental actions; authority to try environmental cases in court (also supported by the Environmental Court Act, 2000).

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The Environmental Conservation Act, 2010, is the amendment of ECA’95. Some changes and inclusions has been made in different clauses particularly in defining the Ecological Critical Area, farming certain rules and conditions in cutting and/or razing hills, handling disposal of hazardous wastes, managing ship braking industries & wetlands, fixing responsibilities of environmental and safety management, obligations of obtaining and issuance of environmental clearance certificates and imposing penalties for violations including but not limited to filing cases for compensations, fixing fees and framing different rules under this Act.

Environment Conservation Rules (1997) and Amendments The ECR is a set of rules, promulgated under the Environmental Conservation Act, which specifies environmental approvals processes for various project types and provides allowable limits for environmental disturbance or pollutative discharge / emissions. The Environment Conservation Rules (1997) (ECR) provides categorization of industries and projects and identifies types of environmental assessments required against respective categories of industries or projects. The rules set: National Environmental Quality Standards for ambient air, various types of water, industrial effluent, emission, noise, vehicular exhaust etc.; requirements for and procedures to obtain, Environmental Clearance; and requirement for IEE / EIAs according to categories of industrial and other development interventions.

Tourism Destination Management Plan for the Bandarban Hill District, Bangladesh (2017 – 2027)18

Occupational health and safety related law and rules include: Bangladesh Labor Act 2006, Water Supply and Sewerage Authority Act 1996, Labor Relations under Labor Laws, 1996 (Revisions to scattered Acts and Ordinances to formulate a unified code,) Public Health Emergency Provisions Ordinance, 1994, The Employees State Insurance Act, 1948, The Employer's Liability Act, 1938, Maternity Benefit Act, 1950.

Organization Framework19 (see Rohingya Response Coordination Mechanism in Annex 5)

Overall, environment, forestry and climate change issues fall within the jurisdiction of several ministries and divisions/departments, and also involve CSOs, NGOs and the private sector. Such a range of stakeholders poses a significant challenge for coordination.

The Ministry of Environment and Forests (MoEF) and its agencies are the central apex body of the Government of Bangladesh responsible for the policy, planning and administration of all forestry and environment-related issues and development programs. They are the custodian of country’s environment and ensures its protection and development through the development and implementation of appropriate laws and regulations. The MoEF will be the lead ministry for the implementation of the CIP. Key agencies under MoEF are the Department of Environment, Forest Department, Bangladesh Forest Research Institute, Bangladesh Forest Industries Development Corporation, Bangladesh National Herbarium and Bangladesh Climate Change Trust.

18 http://lib.icimod.org/record/32764/files/icimodTourismBangladesh017.pdf19 https://reliefweb.int/sites/reliefweb.int/files/resources/2019%20JRP%20for%20Rohingya%20Humanitarian%20Crisis%20%28February%202019%29.compressed_0.pdf

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Even a robust legal and regulatory framework, which is not the case in Bangladesh, is only as effective as its implementation. The institutions charged with implementing and upholding the laws and regulations are therefore the second critical pillar of environmental governance. Bangladesh’s DoE has the mandate to implement Bangladesh’s legal and regulatory framework for environmental protection, but lacks the technical and financial resources to effectively do so. The DoE is the only institution in Bangladesh with a mandate for environmental protection, and has been given wide powers under the 1995 ECA. However, as the reality on the ground shows, the DoE is under equipped to effectively address the country’s diverse and mounting environmental and climate challenges. The volume of tasks undertaken by the DoE has increased manifold over the last two decades due to the scale of environmental issues and regulatory demand, and changing economic, population, and environmental conditions. However, its manpower at federal, divisional and district levels has not increased nearly enough to accommodate this increase.

Other key government institutions with a stake in the EFCC sectors include: the Finance Division and the Economic Relations Division of the Ministry of Finance (the latter being the National Designated Authority for the Green Climate Fund); the General Economic Division of the Planning Commission; the Ministry of Agriculture; the Ministry of Fisheries and Livestock; the Ministry of Water Resources; the Ministry of Disaster Management and Relief; the Ministry of Chittagong Hill Tracts Affairs; and the Ministry of Women and Children Affairs. For specific programmes, additional Ministries may include the Ministry of Food, the Ministry of Science and Technology, the Ministry of Public Administration, the Ministry of Power, and the Ministry for Local Government and Rural Development & Cooperatives. .

Of the more prominent NGOs, CSOs and academic institutions it is worth citing the following: International Union of Conservation of Nature (IUCN); International Centre for Climate Change and Development (ICCCAD); Centre for Climate Change and Environmental Research, BRAC University (BRACU); Centre for Policy Dialogue (CPD); Bangladesh Centre for Advanced Studies (BCAS); Institute for Forestry and Environmental Sciences (IFES) at Chittagong University; Bangladesh Institute for Development Studies (BIDS); Water Aid; Grameen Shakti; Arannayk Foundation; Palli Karma Sahayak Foundation (PKSF); Action Aid Bangladesh; Waste Concern, Oxfam GB; Technical Assistance for Rural Development (TARA); Christian Commission for Development in Bangladesh (CCDB); Centre for Natural Resources Studies (CNRS) Society for Environment and Human Development (SEHD).

The Rohingya humanitarian response is led and coordinated by the Government of Bangladesh, which established a “National Strategy on Myanmar Refugees and Undocumented Myanmar Nationals” in 2013. That strategy established the National Task Force (NTF), chaired by the Ministry of Foreign Affairs, and including 29 Ministries and entities, which provides oversight and strategic guidance to the response.

Following the influx, the Refugee Relief and Repatriation Commissioner (RRRC), under the Ministry of Disaster Management and Relief, were mandated to provide operational coordination for all refugees / Forcibly Displaced Myanmar Nationals. The District Commissioner also

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continues to play the critical role, and has the primary responsibility for operational coordination of the response for Bangladeshi host communities including Disaster Risk Reduction.

For the humanitarian agencies, strategic guidance and national level government engagement is provided by the Strategic Executive Group (SEG) in Dhaka, co-chaired by the Resident Coordinator, IOM and UNHCR. At the District level, the Senior Coordinator leads the Inter-Sector Coordination Group, composed of thematic Sector and Working Group Coordinators who represent the humanitarian community, ensuring coordination with the RRRC and the DC (including with the Upazila Nirbahi Officers (UNO) at the Upazila, sub-District level: this includes regular coordination meetings at the Upazila level co-chaired by UNOs and ISCG).

The Senior Coordinator has direct reporting lines to the three SEG Co-Chairs based in Dhaka and coordinates the response at the level of Cox's Bazar. The Senior Coordinator chairs the Heads of SubOice Group (HoSOG) which brings together the heads of all UN Agencies and Representatives of the international NGO and national NGO community, as well as donor representatives based in Cox’s Bazar. The Senior Coordinator also chairs and leads the Inter-Sector Coordination Group (ISCG), and guides the response, with the support of a Secretariat. In 2019, in addition to the humanitarian response efforts in the camps, under the leadership of the Government, a coordination mechanism will also be established to promote peaceful coexistence between and within communities as well as address host community needs. This platform will be led by the Deputy Commissioner with support from the Senior Coordinator and the ISCG to ensure a cohesive response, also with the aim of strengthening representation and involvement by national civil society partners. The Deputy Commissioner also leads disaster risk reduction planning for the whole district.

The Government provides overall leadership and coordination for the humanitarian response. In regards to operational coordination, the RRRC co-chairs Sector Coordinators meetings in Cox’s Bazar on a regular basis.

At the sector level, relevant line Ministries and Departments guide the response, with the sectors supporting the mainstreaming of service delivery, as appropriate, by basing coordination teams in the relevant government offices.

At the camp level, coordination is led by the Camp-in-Charge officials under the RRRC’s office, who are mandated by the Government of Bangladesh to assume camp management responsibilities. During the course of 2018, additional camps were formally demarcated, and boundaries drawn, enabling camp management oversight of the vast majority of the Rohingya settlements within a total of 34 formally designated camps at the end of the year. Under the auspices of the Site Management Sector, Site Management Support (SMS) Agencies have been deployed in all camps to support the CiC in managing the camps. CiCs chair regular camp level coordination meetings, attended by camp level Sector Focal Points. These focal points are operational staff of agencies delivering in the camps who oversee and coordinate service delivery in their specific technical areas within the boundaries of the camps, which is often delivered by multiple agencies. The CiCs liaise closely with all actors and monitor service delivery overall in the camps, ensuring gaps and duplications are identified and addressed.

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The Camp Management function also entails community outreach and participation, which is done in coordination with the Site Management and Protection sectors. As part of the 2019 efforts by the Protection and Site Management partners, a new community representation model within the camps should progressively be implemented that includes grassroots community organizations and religious leaders. In addition, several community groups have been established by CiC, SMS agencies and other actors at the camp level to support service delivery and maintenance, and represent groups of the population.

3. Program, project and activity description

The Sampriti Project is a Special Objective/SO “Communities Impacted by the Rohingya Displacement” under the Mission’s 2019-2024 CDCS with ultimate goal to protect the lives of, and foster peace, dignity, health, opportunity and prosperity for, the people who have been affected by the Rohingya crisis in Bangladesh.

The geographic focus (ZOI) of the SO is limited to host and impacted communities of the Resilience Focus Area, which includes Cox’s Bazar and Bandarban (all upazillas). However, USAID will continue to engage at the national and sub-national levels to respond to the Rohingya crisis.

Table 1 covers all current and proposed activities folded into this SO as follows:

No

Start Date - End Date

Project & Activity 22 CFR 216 Documentationand Threshold Decisions

LOP $ level

1 3/2019- 3/2022

Multi-purpose Cyclone Shelter Refurbishmentand Repair in Cox’s Bazar and Bandarban(R&R)

https://ecd.usaid.gov/repository/pdf/50277.pdf

https://ecd.usaid.gov/repository/pdf/51791.pdf

2 9/2019- 9/2024

Multi-purpose Cyclone Shelter Constructionin Cox’s Bazar and Bandarban(BUILD)

https://ecd.usaid.gov/repository/pdf/51754.pdf

https://ecd.usaid.gov/repository/pdf/38047.pdf

https://ecd.usaid.gov/repository/pdf/38926.pdf

https://ecd.usaid.gov/repository/pdf/42736.pdf

3 9/2019 - 9/2022

Conflict Mitigation, Resilience andStabilization

https://ecd.usaid.gov/repository/pdf/51825.pdf

4 9/2018 – 10/2020

Advancing Access to ReliableInformation

https://ecd.usaid.gov/repository/pdf/42916.pdf

https://ecd.usaid.gov/

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repository/pdf/50976.pdf

5 6/2019– 5/2022

Local Works Bangladesh https://ecd.usaid.gov/document.php?doc_id=51825

https://ecd.usaid.gov/repository/pdf/51825.pdf

6 1/2020– m12/2024

Esho Shikhi (“Come and Learn”), Education in Crisis Activity

https://ecd.usaid.gov/repository/pdf/52012.pdf

7 10/2020– 9/2024

Local Development Activities for Cox’s Bazar and Bandarban - Multiple Activities, Multisector (Livelihoods, Localization, Capacity Development, WASH, Health, DRG, Public Awareness, Media )

Threshold Decisions, conditions, limitations and stipulation for revisions approved in this IEE

8 4/22/2019–TBD

New Partnership Initiative: Conflict Prevention and Recovery Program (NPI: CPRP)

Global 22 CFR 216 document: Deferral of Threshold Decision approved by BEO/DCHA - https://sites.google.com/a/usaid.gov/dcha-environmental-compliance-management/sub-offices/ppm/npi?pli=1

Local Development Activities in Cox’s Bazar and Bandarban will seek to support selected host communities small-scale and pilot activities in water and sanitation, agricultural productivity, health and nutrition as well as capacity and gender focused technical assistance.

4. Environmental Determination

4.1 Recommended Action

All conditions, limitations and stipulation for revisions in the approved IEE for projects listed in Table 1 above, remain in force for their LOP funding levels and LOP duration.

The below are recommended determinations for the planned activities referred to in Section 7 and 8, Table 1 above:

a) Recommended Action: Categorical Exclusion (about 70% of funding, or $ 89 million ) Pursuant to 22 CFR 216.2(c)(2)(i), the originator of the activities has determined that all of the activities consist of types of interventions entirely within the categories listed in paragraph (c)(2), “Categorical Exclusions,” of Section 216.2, “Applicability of Procedures,” of Title 22 CFR Part 216, “AID Environmental Procedures”, and therefore are categorically excluded from further environmental review requirements (see Face sheet Table 3). The proposed activities are fully within the following classes of actions:

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a. Education, technical assistance, or training activities except to the extent such activity includes activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(i)];

b. Analyses, studies, academic or research workshops and meetings. [22 CFR 216.2(c)(2)(iii)];

c. Document and information transfers. [22 CFR 216.2(c)(2)(v)]; andd. Studies, projects or activities intended to develop the capability of recipient countries to

engage in development planning, except to the extent designed to result in activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(xiv)].

b) Recommended Action: Pursuant to 22 CFR216.3(a)(2)(iii), a Negative Determination with Conditions (about 30% of funding, or $ 38 million) is recommended for any activities that have the potential for adverse impact on the environment in the following categories:

a. Small-scale construction/rehabilitation, renovation and improvement of facilities; b. Small-scale WATSAN, water and water quality assurance activities;c. Improved health, nutrition and feedingd. Afforestation e. Other small-scale livelihoods supporting activities.

For each of these activities an implementer partner will conduct an Environmental Due Diligence (EDD) analysis and climate risk screening as part of the Environmental Review and Assessment Checklist (Annex 1) and climate risk screening to document existing environmental and social concerns and foreseeable environmental effects resulting from the activity. Climate risk screening will be done for activities of high and medium risk, in particular.

In consultation with relevant A/COR and MEO/CIL, an IP can review and update relevant Mission-approved Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP,) developed earlier, when applicable and commensurate with the scope and nature of the activities.

The updated EM, which outlines screening, selection and eligibility criteria, due diligence and EA processes, provided record keeping forms and FEMMP, shall be reviewed and approved by cognizant Team Leader/A/COR and MEO/CIL in consultation with the Regional Environmental Advisor (REA) for Central and South Asia and OAPA.

After its approval, individual projects and activities then shall use EM, which cover activities of similar scope and nature. The Standard Conditions List in Annex 3 may be used as a guide in updating an EM, FEMMP along with other references listed in the Implementer’s Procedures section below.

c) Recommended Action for New Partnership Initiative: Conflict Prevention and Recovery Program (NPI: CPRP) Annual Program Statement: Deferral – in accordance with 22CFR216.3(a)(7)(iv) the deferral shall be cleared by issuance of BEO/Asia-approved Categorical Exclusion or Initial Environmental Examination prior to disbursement of funding or solicitation of awards.

Individual country IEEs and EMMPs will be prepared by the responsible Mission for the specific addenda issued by them and awards completed by them under this unfunded APS.

USAID/Bangladesh-specific RCE/IEE shall be concurred to by BEO/Asia.

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BEO/DCHA SPECIFIED CONDITIONS OF APPROVAL (Tracking No: DCHA-PPM_NPI_IEE- Deferral_2019-24, https://sites.google.com/a/usaid.gov/dcha-environmental-compliance-management/ sub-offices/ppm/npi?pli=1 )

Environmental Budgeting. Sufficient budget should be allocated for staffing and implementation of environment and climate safeguarding measures within the project and/or activity. However, the budget for environmental compliance must not exceed the Total Estimated Cost (TEC) of the activity. The budgeting for environmental compliance is to be reviewed in the beginning of the activity, and annually with work plans. Refer to the USAID Environmental Budgeting Toolkit for step-by-step guidance for both budget developers and USAID budget reviewers. While the BEO can provide guidance on budgeting for environmental compliance, only the C/AOR can authorize budget commitments.

4.2 Implementer and USAID Procedures:

Implementing partner(s) shall comply with the following procedures for all relevant activities with Negative Determination with Conditions and will demonstrate their compliance in their quarterly and annual performance reports, or as appropriate and approved by the relevant A/COR. As part of its initial Work Plan, and all Annual Work Plans thereafter, the IP, in collaboration with the USAID A/COR and MEO/CIL, shall review all ongoing and planned activities under the award to determine if they are within the scope and nature of activities in the approved PIEE and the EM.

● The Mission should amend current PERSUAP to include any additional pesticides required for implementation of activities. BEO/Asia shall review and approve SOW for such amendment, and ultimately review and approve the amended PERSUAP. The PIEE Amendment shall be prepared to reflect on the list of pesticides approved for same and similar unrestricted uses and on the findings and recommendations (“SUAP”) of the PERSUAP. IPs shall comply with PERSUAP requirements.

● The IPs shall have sufficient technical and financial resources to implement all approved conditions.

● All activities should seek to raise environmental awareness, promote regional and national environmentally and socially sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of environmental compliance and governance, public participation in decision-making.

● The IPs shall include environment compliance considerations into all aspects of project and activity implementation and should promote and train local counterparts on environmental requirements and standards across all of the activities. Such proposed activities shall be included into annual work plans, and results should be reported in annual performance reports (reporting will include photographic documentation and site visit reports which fully record that all proposed mitigation procedures were followed throughout implementation of the subject work).

● Prior to the launch of each activity that received NDC determination in this PIEE the IPs should recruit a qualified Environmental Impact Professional (EIP) concurred to by the relevant A/COR and MEO/CIL, who should ensure implementation of an EM, when warranted, conduct an EDD review described below and develop other required environmental compliance documentation, recommend environmental actions to be taken by the activity, train personnel (including sub-grantees and sub-contractors), coordinate implementation of mitigation measures, monitoring, and reporting. Should the EIP lack special technical knowledge to identify any special environmental impact, the

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implementer will consult with a specialist in the relevant area. (See Annex 4 for sample TOR for the EIP)

● Prior to the launch of each activity that received NDC determination in this IEE, including sub-grants and sub-contracts, the IPs’ EIP shall implement the EM. If implementation of the process established in the EM results in a finding of potential significant adverse environmental and social impacts, a SOW for Scoping and EA shall be reviewed and approved by BEO/Asia, and resulting Scoping Statement (SS), SS and EA shall be done by the implementer prior to start of activities. The detailed EA process will be established on a case-by-case basis in accordance with 22 CFR 216.

● All “moderate to high risk” activities, including all construction activities, identified through implementation of the EM shall be accompanied by a climate risk screening conducted by using tools available at: https://www.climatelinks.org/tools and ADS 201mal

● Host country laws and regulations for environmental, health, safety, labor and fire safety protection and management shall be followed in implementing the activities unless otherwise directed in writing by USAID. In the case of a conflict between the host country regulations and USAID regulations, the latter shall govern. For activities categorized as “potential risks”' or “definite risks” of adverse environmental impact, the implementing partner will be required to obtain a letter from the local or regional office for environmental protection stating that the office: a) has been contacted by the implementing partner concerning the activities; b) will maintain contact with the activity; and c) will be aware of the potential environmental impacts of the activity to help ensure that no detrimental impact will result from this activity.

● If the during implementation of the EM, an IP determines that small scale construction, rehabilitation, renovation and improvement activities can follow best practices and standard conditions and that no further environmental assessment is required, each small scale construction activity shall be conducted in a manner consistent with good design and implementation practices described in: a) USAID Environmental Guidelines for Small-Scale Activities at: http://www.usaidgems.org/; b) IFC Environmental, Health and Safety Guidelines as provided at: http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines; c) World Health Organization guidelines as provided at http://www.who.int/publications/guidelines/environmental_health/en/index.html; https://www.who.int/management/quality/Waste/en/

● In accordance with USAID Construction Policy and ADS 201maw all small scale construction, rehabilitation, renovation and implement activities shall be reviewed and concurred by USAID Engineer and shall be subject to climate risk screening at an activity level documented in EDD/RC.

● For activities categorized as “potential risks”' or “definite risks” of adverse environmental impact prior to their implementation, the implementer should conduct public consultations and will seek concurrence from the national duly authorized environmental agency on EMMPs (Ministry of Environment and Forest, or other depending on the scope of the activity).

● Sub-contracts or grants from the IPs to other organizations must incorporate contract/agreement provisions stipulating compliance with 22 CFR 216, ADS 204 and the PIEE.

● The implementer’s performance reports to USAID shall contain a section specific to environmental compliance and include activity summaries along with environmental impacts, success or failure of

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mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the activity, mitigation measures or monitoring procedures. If the activities implemented do not impact the environment, this should be documented as well. The implementer’s annual report will include an annex containing a table indicating the title, date of award, description and threshold determination of each sub-contract and/or sub-grant activity.

● As part of its initial Work Plan, and all Annual Work Plans thereafter, the implementer, in collaboration with the USAID A/COR and MEO shall review all ongoing and planned activities under this award to determine if they are within the scope of the approved PIEE; and classify them in accordance with Face sheet Table 3.

Resource Allocation, Training and Reporting requirements:

● The SO AOR/CORs and activity managers will work with the USAID contracting office to include budgets and environmental compliance requirements specified in this PIEE into RFA/RFPs to ensure that applicants and bidders budget for appropriate resources, staff, mitigation and monitoring, and reporting procedures, and/or amend current awards and contracts as warranted The IEE Amendment 2 shall be included in the RFA/RFP package for new programs, projects and activities.

● The agreement/contract with the IP shall include relevant environmental compliance and reporting language per the PIEE.

● A/CORs together with MEO/CIL or his designee, i.e. Deputy MEO and CIL, shall explain all environmental conditions, limitations and stipulation for the revisions to the IPs at the post-award conference.

● The A/COR of each activity, in consultation with the MEO/CIL or REA/SCA & OAPA and corresponding implementing partner(s), will actively oversee and evaluate whether environmental consequences not foreseen by this PIEE arise during implementation, and will modify or halt activities as appropriate. If additional components or sub activities are added to an activity but are not described in this PIEE, an amended PIEE must be prepared.

● It is A/COR responsibility to ensure that IPs follow the environmental compliance requirements specified in this PIEE.

4.3 Programs and projects linked to Sampriti. For information purpose only, the following Table 2 outlines the specific interventions throughout USAID which are directly linked to responding to the Rohingya crisis, but are not encapsulated under this Project, either 1) because the activity is humanitarian assistance, or 2) because the activity dedicates the majority of its resources to areas not impacted by the Rohingya refugee crisis.

Table 2 Linked Activities (under other PADs with and individually approved IEEs) – For Information Purpose ONLY

Start/End Date

Activity & Description(Implementer)

PAD

Op Unit/Link to approved 22CFR216 documentation

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8/2017-8/2020

Obirodh - Road to Tolerance(Management Systems International)

DO1 Mission/ DRG

10/2014-11/2020

Bangladesh Counter Trafficking in Persons (BC/TIP)(Winrock International)

DO1 Mission /DRG

6/2018-6/2021

Rights for Gender Diverse Populations(Bandu Social Welfare Society)

DO1 Mission /DRG

10/2018-9/2021

Promoting Peace and Justice(Democracy International)

DO1 Mission /DRG

10/2018 - 10/2020

Partnership for Inclusive Tolerant Bangladesh(UNDP)

DO1 Mission/ DRG

9/2012-12/2019

Access to Information (A2i)(UNDP)

DO1/DO2

Mission/DRG

8/2013- 8/2020

Chittagong Hill Tracts Watershed Co-Management(UNDP)

DO4/DO1

Mission/EG

3/2019-2/2024

Community Partnerships to Strengthen Sustainable Development(US Forest Service)

DO4 Mission /EG

2/2018-9/2023

Bangladesh Aquaculture and Nutrition Activity (BANA)(World Fish Center)

DO2 Mission/ EG

3/2018-9/2019

Enhanced Coastal Fisheries in Bangladesh (ECOFISH)(World Fish Center)

DO4 Mission /EG

9/2018-9/2023

Bangladesh Nutrition Activity(Abt Associates)

DO2 Mission /EG

6/2015-6/2020

Bangladesh Livestock Production for Improved Nutrition Activity(ACDI-VOCA)

DO2 Mission /EG

5/2019-5/2024

CSISA - Mechanization and Irrigation Activity - Phase II(CIMMYT)

DO2 Mission /EG

10/2017- 9/2022

Advancing Universal Health Coverage (AUHC)(Chemmonics)

DO3 Mission/ PHNE

3/2017-3/2022

Social and Behavior Change Communication (SBCC) - Ujjiban (Johns Hopkins University)

DO3 Mission /PHNE

10/2016- 10/2021

Marketing Innovations for Sustainable Health Development(Social Marketing Company)

DO3 Mission/PHNE

1/2020 - 12/2024

Inclusive Education for Children with Disabilities Activity

DO3 Mission/PHNE

8/2017- USAID Food Assistance20 N/A FFP

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8/2022 (WFP, UNICEF & CARE)

9/2019- 9/2022

EG/BFS Resilience Focus Area Activity DO2 BFS

9/2019- 9/2022

Food for Peace Transitional Funding N/A FFP

8/2017-Present

OFDA Programming N/A OFDA

5. Limitations of the PIEE:

5.1 All chemicals, registered by the U.S. EPA, as pesticides shall be procured, used or recommended for use only in accordance with BEO- PERSUAPs for Bangladesh and PERSUAP Environmental Manual. If any additional chemicals are proposed, the PERSUAP shall be amended and approved by the BEO/Asia. This PIEE shall be amended to reflect on the list of pesticides approved for same and similar unrestricted uses and on findings and recommendations of the PERSUAP, and approved by the BEO/Asia.

5.2 No procurement or use of Asbestos, Lead and Mercury Containing Materials (ALMCM) (i.e. piping, roofing, batteries, etc.), Polychlorinated Biphenyls (PCBs) or other toxic/hazardous materials prohibited by US EPA as provided at: http://www.epa.gov/asbestos and/or under international environmental agreements and conventions, e.g. Stockholm Convention on Persistent Organic Pollutants as provided at: http://chm.pops.int.

5.3 GDA and DCA – note ADS 204 requirement for GDA and ADS 249 for DCA.5.4 Assistance, procurement and/or use of genetically engineered organisms (GEOs) which require

preparation of biosafety assessment (review) in accordance with ADS 211 in an amendment to the IEE approved by BFS Biosafety Adviser and Asia BEO.

Any of these actions would require an amendment to the IEE duly approved by Asia BEO.

6. Revisions

Pursuant to 22CFR216.3(a)(9), if new information becomes available which indicates that activities to be funded by the project might be “major” and the project’s effect “significant,” any Negative Determination with Conditions will be reviewed and revised by the originator of the activity and submitted to the BEO for approval and, if appropriate, an environmental assessment or other relevant documentation will be prepared. It is the responsibility of the USAID COR/AOR to keep the MEO/CIL USAID/Bangladesh, and the BEO/Asia informed of any new information or changes in the scope and/or nature of the activity that might require revision of the IEE.

20 https://www.feedthefuture.gov/wp-content/uploads/2018/11/Bangladesh_GFSS_Country_Plan_Public_CLEARED_7.11.18_508_Compliant.pdf

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USAID APPROVAL OF ENVIRONMENTAL ACTION(S) RECOMMENDED:

Clearance:

Mission Environmental OfficerClimate Integration Lead (A): _________________ Date: _____________

Regional Environmental Adviser: ________________ Date: _____________ (SCA & OAPA) Andrei Barannik

Director/Program Office: _________________ Date: _____________Todd Andrews

Director/DRG Office: __________________ Date: _____________Randall Olson

Director/PHNE Office: __________________ Date: _____________Ariella Camera

Director/FDHA Office: __________________ Date: _____________Paul Mason

Director/EG Office: __________________ Date: _____________Thomas Pope

Regional Legal Officer _______________ Date:____________

Deputy Mission Director: ________________ Date: _____________Beverly Busa

Mission Director: ________________ Date: _____________Thomas Pope

Concurrence:

Asia Bureau Environmental Officer __________________ Date: _____________Will Gibson

Approved: ____________________ Disapproved: ________________

Note to BEO/Asia:

This IEE is Procurement Sensitive, do not post until cleared by Bangladesh/OAAPOC: Contracting Officer _________________, email______________

This IEE may be posted upon written clearance from USAID/Bangladesh.

DISTRIBUTION: MEO, COR/AOR, OAA, RLO, BEO/DCHA

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ANNEX : 1

General Conditions for Small-Scale Construction (May be used as one of the guidance documents to develop site specific Mitigation and Monitoring Plan,

i.e., M&M Plan)

Small-scale construction activities occur in association with a wide variety of development activities financed by USAID. Construction activities include demolition; site clearing; soil grading, leveling and compaction; excavation; pipe and equipment installation; and the erection of physical structures. These activities have the potential to result in significant adverse environmental impacts, but most of those impacts can be mitigated down to acceptable levels through the use of good construction management practices.

These standard conditions have been developed by USAID to ensure that small-scale construction activities do not result in significant adverse environmental impact. When adherence to these conditions is a condition of small-scale construction contracts, no significant adverse environmental impact is presumed to result from activity implementation.

Contract/Agreement Officers, Agreement/Contract Officer Representatives (A/CORs), Activity mangers, Program Officers, MEOs, and implementing organizations must be aware that these standard conditions are generic in nature, and that additional potentially significant adverse environmental impacts may be associated with small-scale construction activities. It is the responsibility of the individual USAID missions, and/or their implementing contractors and grantees, to monitor construction and to ensure that significant adverse environmental impacts do not result from these activities.

For the purposes of this general guidance, “small-scale” construction activities are defined here as those that cost less than $100,000 per construction activity. Because of the exceptionally diverse physical conditions under which Bureau construction activities take place, and the very broad kinds of construction that take place, the following conditions are to be followed “as practicable and appropriate.”

General Conditions for Small-Scale Construction Activities

Establish and adhere to construction timetables that minimize disruption to the normal activities of the construction area.

Coordinate truck and other construction activity to minimize noise, traffic disruption and dust. Develop and implement appropriate human health and worker safety measures during

construction. Post construction timetables and traffic diversion schedules at the activity site. Where significant environmental impacts may occur, document and photograph pre-construction

and post-construction conditions. Avoid subsidence and building stabilization problems through proper foundation excavation, fill

placement and borrow pit management. Fill should avoid pockets of segregated materials, it should use well-graded materials, and it

should be compacted to recognized standards.

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Backfill and/or restore borrow areas and quarries before abandonment unless alternative uses for those sites are planned.

Control runoff into borrow pits. Provide temporary sanitation at the construction site. Recover and replant topsoil and plants as practicable. Set protocols for vehicle maintenance to control contamination by grease, oil and fuels. Install temporary erosion control and sediment retention measures when permanent ones either

are not feasible or are delayed. Avoid pollution of waterways with stockpiled construction materials. Cover stockpiled construction materials, as practicable. Place solvents, lubricants, oils, and other semi-hazardous and hazardous liquids over a lined area

with appropriate secondary containment in order to contain spillage. Test the integrity of bulk storage tanks and drums, and secure valves on oil and fuel supplies.

Build appropriate containment structures around bulk storage tanks and materials stores to prevent spillage entering watercourses.

Handle, store, use and process branded materials in accordance with manufacturer’s instructions and recommendations.

Take waste materials to appropriate, designated local disposal areas. Avoid the use of cement; paper; board; sealant and glazing formulations; piping; roofing material;

or other materials containing asbestos. Do not use PCBs in electric transformers. Avoid sealant and glazing formulations that use lead as a drying agent. Use lead-free paint, primers, varnishes and stains.. Minimize the use of solvent-based paints, or replace with water-based materials. Minimize burning of waste materials. Employ techniques to minimize dust and vapor emissions as practicable (e.g., road speed limits,

air extraction equipment, scaffolding covers, road spray). Recycle wastewater to the extent practicable. Build tanks or other separators for silt-laden material prior to allowing significant outflow into

watercourses. Build collection channels leading to oil and/or silt traps, particularly around areas used for vehicle

washing or fueling. Seal or remove abandoned drains to minimize water contamination. Segregate waste which can be salvaged, re-used or recycled. Introduce measures to control and minimize the volume of waste on site. Employ sensitive strategies with regard to trees, watercourses, plant or animal species or habitats,

and important historical and archaeological features. As practicable, landscape construction sites in a way that is appropriate to local conditions. Minimize the disturbance of, and reduce the spread of, ground contaminants. Do not build structures in sensitive areas such as wetlands. If waste will be buried on site, avoid siting burial pits up-gradient from drinking water sources

such as wells. Pits should be lined with impermeable material (e.g., clay or polyethylene). If waste will be buried on site, avoid siting waste pits where water tables are high or underlying

geology makes contamination of groundwater likely. If no alternative site is available, ensure that pits are lined with impermeable material.

Provide for the safe disposal of gray water from bathing and washing.

STANDARD CONSTRUCTION CONDITIONS

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Establish and adhere to construction timetables that minimize exposed land surface and disruption to the normal activities of the construction area.

Post construction timetables and traffic diversion schedules at the activity site. Coordinate truck and other construction activity to minimize noise, traffic disruption and dust. Where environmental impacts may occur, document and photograph pre-construction and post-

construction conditions. Earth fill material should avoid pockets of segregated materials, it should consist of well-graded

earthen materials, and it should be compacted to USG or international standards Install temporary erosion control and sediment retention measures until permanent ones can be

constructed. Use proper bedding materials for pipes, and backfill appropriately for the pipeline Use vegetative soil cover and appropriately selected geotextile materials to prevent erosion of

drainage structures and at the outfall according to established best practice standards. If no other measure is available, riprap (cobbled stone), gravel, or concrete can be used to augment erosion and sediment control measures.

Do not allow people or animals to drink directly from water sources. In coastal areas, maintain water withdrawals within safe yield limits to avoid salt water intrusion

and well contamination. Ensure that spilled water and rainwater drain to a soak way or equivalent structure. Re-vegetate areas damaged during construction. Do not remove erosion control measures until

construction and re-vegetation activities are completed. As practicable, landscape construction sites in a way that is appropriate to local conditions.

EXCAVATION AND BORROW PITS

Use material from the required excavations first, since it produces a fairly durable aggregate for both surface stabilization and erosion control and is very cost effective.

Place fences around borrow pit excavations, as necessary. Ensure excavation is accompanied by well-engineered drainage to control runoff into the pit. Develop specific procedures for storing topsoil, and for phased closure and reshaping and

restoration of the pit when extraction has been completed. Include plans for segregating gravel and quarry materials by quality and grade for possible future uses. Where appropriate, include reseeding or re-vegetation to reduce soil erosion, prevent gullying and minimize visual impacts.

Discuss with local communities the option of retaining quarry pits as water collection ponds to water cattle, irrigate crops or for similar uses. Issues of disease transmission, and prohibiting the use of pit water for human consumption, bathing, and clothes washing, should be highlighted.

Decommission/restore areas so that they are suitable for sustainable use after extraction is completed.

Backfill and/or restore borrow areas and quarries before abandonment if alternative uses for those sites are not planned.

MATERIAL STORAGE AND HANDLING

Identify sites for temporary/permanent storage of excavated material and construction materials. Avoid pollution of waterways with stockpiled construction materials. Set protocols for vehicle maintenance to control contamination by grease, oil and fuels. Build collection channels leading to oil and/or silt traps, particularly around areas used for vehicle

washing or fueling.

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Build appropriate containment structures around bulk storage tanks and materials stores to prevent spillage entering watercourses.

Build tanks or other separators for silt-laden material prior to allowing significant outflow into watercourses.

Cover stockpiled construction materials, as practicable. Minimize the disturbance of, and reduce the spread of, ground contaminants. Handle, store, use and process branded materials in accordance with manufacturer’s instructions

and recommendations. Segregate construction waste that can be salvaged, re-used or recycled. Take construction waste materials to appropriate, designated local disposal areas. Minimize burning of waste materials. If construction waste will be buried on site, avoid siting burial pits up-gradient from drinking

water sources such as wells. Pits should be lined with impermeable material (e.g., clay or polyethylene).

If construction waste will be buried on site, avoid siting waste pits where water tables are high or underlying geology makes contamination of groundwater likely. If no alternative site is available, ensure that pits are lined with impermeable material.

HUMAN HEALTH AND WORKER SAFETY DURING CONSTRUCTION

Provide workers with appropriate safety equipment. Protect workers from injury by flying or falling rock, slope failures and avalanche. Explore off-site accommodation for crew. Keep camp sizes to a minimum. Provide temporary sanitation facilities on construction sites. Maintain good first aid capabilities on site.

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Annex : 2General Conditions for Small-Scale

Water and Wastewater Activities

USAID finances, directly or indirectly, a large number of water and wastewater activities. These occur in both rural and urban areas, and in association with residential, commercial, industrial and medical facilities. Water and wastewater activities have the potential to result in significant adverse environmental impacts, but most of those impacts can be mitigated down to acceptable levels through the use of good siting, design, construction, operations and maintenance practices.

These general conditions for small-scale water and wastewater activities have been developed by USAID to ensure that water and wastewater activities financed by the Agency do not result in significant adverse environmental impact. When adherence to general conditions such as these, as practical and appropriate, is a condition of water and wastewater contracts, no significant adverse environmental impact is presumed to result from activity implementation.

Contract/Agreement Officers, Agreement/Contract Officer Representatives (A/CORs), Activity mangers, Program Officers, MEOs, and implementing organizations must be aware that these standard conditions are generic in nature, and that additional potentially significant adverse environmental impacts may be associated with water and wastewater activities. It is the responsibility of the individual USAID missions, and/or their implementing contractors and grantees, to monitor water and wastewater activities and to ensure that significant adverse environmental impacts do not result.

For the purposes of this guidance, “small-scale” water and wastewater activities are defined as those that cost less than $200,000 per individual construction activity. Because of the exceptionally diverse physical, biological and social environments under which USAID water and wastewater activities take place, and the broad kinds of water and wastewater activities that are financed, these standard conditions are to be followed “as practicable and appropriate.”

Standard Conditions for Water and Wastewater Activities

Standard Siting Conditions Site water supply facilities in a way that minimizes the potential for contamination, taking into

account existing and likely future land use patterns in the water supply—i.e., wellhead protection, or upper watershed—area.

Site wastewater facilities in a way that minimizes their potential for contaminating water supply sources, or for exposing human populations to water-borne contaminants.

Avoid siting water supply and wastewater facilities in flood-prone areas. Do not site water and wastewater facilities on active faults or other areas where ground stability

problems such as soil creep occur. Locate wastewater facilities downwind of local population. Build latrines and similar sanitation facilities down gradient of water supply wells. As necessary,

evaluate depth to water table including seasonal fluctuations. Pit latrines should not be installed where the water table is shallow or the composition of the overlying deposits make groundwater vulnerable to contamination.

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Employ sensitive siting strategies that take into appropriate consideration impact on trees, wetlands and watercourses, important plant and animal habitat, and significant historical and archaeological resources. Avoid or mitigate adverse impacts to these resources.

Standard Design Conditions In general, design water supply facilities to protect water quality, minimize the potential for

contamination, and minimize operation and maintenance costs. In general, design wastewater facilities to avoid contamination of water supplies and human

exposure, and minimize operation and maintenance costs. In general, do not construct new wastewater pipelines unless treatment is provided at the outfall. Where latrines are installed, use improved ventilated pit designs that reduce insect vectors.

Standard Construction Conditions Establish and adhere to construction timetables that minimize disruption to the normal activities

of the construction area. Post construction timetables and traffic diversion schedules at the activity site. Coordinate truck and other construction activity to minimize noise, traffic disruption and dust. Develop and implement appropriate human health and worker safety measures during

construction as well as during operation and maintenance phases. Where significant environmental impacts may occur, document and photograph pre-construction

and post-construction conditions. Avoid subsidence and building stabilization problems through proper foundation excavation, fill

placement and borrow pit management. Fill should avoid pockets of segregated materials, it should use well-graded materials, and it

should be compacted to recognized standards. Backfill and/or restore borrow areas and quarries before abandonment unless alternative uses for

those sites are planned. Control runoff into borrow pits. Install temporary erosion control and sediment retention measures when permanent ones either

are not feasible or are delayed. Provide temporary sanitation at the construction site. Set protocols for vehicle maintenance to control contamination by grease, oil and fuels. Build collection channels leading to oil and/or silt traps, particularly around areas used for vehicle

washing or fueling. Build appropriate containment structures around bulk storage tanks and materials stores to

prevent spillage entering watercourses. Build tanks or other separators for silt-laden material prior to allowing significant outflow into

watercourses. Avoid pollution of waterways with stockpiled construction materials. Cover stockpiled construction materials, as practicable. Minimize the disturbance of, and reduce the spread of, ground contaminants. Handle, store, use and process branded materials in accordance with manufacturer’s instructions

and recommendations. Use lead-free paint, primers, varnishes and stains. Minimize the use of solvent-based paints. Introduce measures to control and minimize the volume of waste on site. Segregate waste that can be salvaged, re-used or recycled. Take waste materials to appropriate, designated local disposal areas. Minimize burning of waste materials.

33

If waste will be buried on site, avoid siting burial pits up-gradient from drinking water sources such as wells. Pits should be lined with impermeable material (e.g., clay or polyethylene).

If waste will be buried on site, avoid siting waste pits where water tables are high or underlying geology makes contamination of groundwater likely. If no alternative site is available, ensure that pits are lined with impermeable material.

Provide for the safe disposal of gray water from bathing and washing. Recycle wastewater to the extent practicable. Seal or remove abandoned drains to minimize water contamination. Use proper bedding materials for pipes, and backfill appropriately for the pipeline. Use riprap (cobbled stone), gravel, or concrete as needed to prevent erosion of drainage structures

at the outfall of sanitation activities according to established standards. Monitor and repair leaks from cracked containment structures, broken pipes, faulty valves and

similar structures. Do not use piping containing asbestos. Replace lead pipes and joints in drinking water delivery system. Provide proper wellhead protection against contaminant sources. Keep livestock from grazing immediately up-gradient of water supplies. Do not allow animals to drink directly from water sources, unless those sources are subsequently

treated. In coastal areas, maintain withdrawals within safe yield limits to avoid salt water intrusion and

well contamination. Ensure that spilled water and rainwater drain to a soak way or equivalent structure. Monitor drains and soak ways and keep clear of debris. Collect and dispose of sludge from wastewater treatment facilities at appropriate frequencies. Dispose of sludge in areas designated by local authorities. Test sludge for metals, pathogens and other appropriate constituents prior to use as fertilizer. Recover and replant topsoil and plants as practicable. Re-vegetate areas damaged during construction. Do not remove erosion control measures until re-

vegetation is completed. As practicable, landscape construction sites in a way that is appropriate to local conditions.

Standard Operations and Maintenance Conditions

As a rule, financing for water and wastewater infrastructure improvements should not be provided unless appropriate operations and maintenance (O&M) provisions are in place.

On larger activities, an O&M Manual should be prepared before water or wastewater system operations begin.

Address financial and system power issues in O&M plans.

Additional Standard Conditions for Health Clinics and Medical Facilities

Do not dispose of hazardous and chemical wastes to sewer systems. Collect and segregate waste from patients treated with cytotoxic drugs. Separate and disinfect stools from cholera patients prior to discharge. Disinfect blood before discharge to sewers unless there is an adequate wastewater treatment

facility. Water-soluble, relatively mild pharmaceutical mixtures, such as vitamin solutions, cough syrups,

intravenous solutions, eye drops, etc.—but not antibiotics—may be diluted with large amounts of water and then discharged to sewer systems that can handle them.

Avoid burial of chemical wastes where there is potential for groundwater contamination.

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35

ANNEX 3

EMMP Template with Monitoring Log and Budgeting Information(To use, complete areas with the green highlight. Delete explanatory comments in yellow highlight and then complete with activity specific information as appropriate. )

EMMP for Activity XXX

Person Responsible for Overseeing completion of and compliance with the EMMP: [name, title, contact information]

Activity 1: [name of activity][briefly describe activity & summarize potential adverse environmental impacts—from IEE]IEE/EA Condition

Specific Mitigation Measures

How monitored

Timing & Responsible Parties

Estimated Costs

Monitoring LogDate Result Follow

-up(reproduced from the IEE or EA)

Specific action to be taken to comply with the condition.(if an IEE or EA condition is already specific to the project/ activity and implementation actions self-evident, this “translation step” can be omitted)

How will the activity verify that the mitigation action is being implemented and is both effective and sufficient?

Who is responsible for mitigation, monitoring, reporting?Timing/frequency of these actions

Estimated costs of mitigation and monitoring, or budget notes that allow such an estimate to be made. Pass on to the activity budgeting team.

1

2

3

4

A single IEE/EA condition may require multiple mitigation actions to implement—add rows as necessary

123

123

[add rows as needed for additional conditions][repeat table as needed for additional activities]

36

ANNEX 4

TERMS OF REFERENCE / JOB DESCRIPTION

POSITION TITLE: Environmental Impact Specialist, [INSERT ACTIVITY NAME]

LOCATION: Dhaka, Bangladesh

REPORTS TO: [INSERT THE POSITION, CHIEF OF PARTY or OTHER]

PERFORMANCE PERIOD: [INSERT PERIOD, SPECIFY WHETHER IT IS A FULL OR PART TIME POSITION]

ELIGIBILITY: [US or LOCAL HIRE]

ACTIVITY SUMMARY:

[INSERT ACTIVITY SUMMARY]

POSITION SUMMARY:

USAID policy requires implementing organizations to ensure their activities do not have a negative impact on the environment. This is done primarily through detailed analyses of activities to identify potential impacts, and the development and implementation of mitigation and monitoring measures to minimize and monitor these risks.

[ACTIVITY X] is required to follow environmental determinations specified in the USAID approved IEE [INSERT IEE DCN NUMBER], which outlines the activities with the potential for negative environmental impacts, and specifies actions to minimize the risk of these activities. The Environmental Impact Specialist will be responsible to ensure that the IEE requirements are implemented by the activity team, including sub-contractors and grantees if applicable, and that all environmental impact analyses are completed as required by the IEE.

ESSENTIAL RESPONSIBILITIES [THIS IS AN ILLUSTRATIVE LIST, IT SHOULD BE COMPLETED BASED ON THE REQUIREMENTS OF THE IEE]:

● Work with activity staff to implement the measures outlined in the [ACTIVITY X] IEE [INCLUDE ALL APPLICABLE], that includes develop, implement, monitor, report on, and update, as appropriate, the:

o Environmental Due Diligence report (EDD)o Environmental Monitoring and Mitigation Plan (EMMP) and Environmental Manual

(EM)o Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP)o Scoping Statement (SS) and Environmental Assessment (EA)

● Ensure that all activities consider potential environmental impact and address any environmental concerns;

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● Conduct evaluation of potential environmental impacts in …[e.g. construction], and ensure detailed engineering studies are completed for structures address environmental concerns;

● Coordinate as necessary with the GOB to process all documents required to obtain required environmental clearances and ensure compliance with relevant GOB environmental protection regulations;

● Work with the [ACTIVITY X] grant and contracts team to incorporate required environmental mitigation measures into grant and sub-contract documentation and activity implementation;

● Assist [ACTIVITY X] staff in monitoring the implementation of [INSERT EMMP, PERSUAP or EA] during operation of the activity, including regular visits to …[hazardous waste management, rehabilitation and/or construction sites];

● Report on the implementation of [EMMP, PERSUAP, EA] as part of activity quarterly reports, and as otherwise appropriate;

● Ensure timely completion of all EMMP related deliverables and periodic reporting required by the EMMP;

● Develop training materials and provide training to and build the capacity of local implementing partners (including sub-contractors, grantees, community based organizations, activity staff, and GOB counterparts, as necessary) on the requirements of the [EMMP, PERSUAP, EA] and national environmental regulations and how to comply with mitigation measures specified;

● Lead the inclusion of environmental compliance tasks, e.g. training, monitoring, reporting, updates, etc., in the annual implementation plan; and,

● Carry out other tasks as designated by COP.

QUALIFICATIONS AND REQUIREMENTS:

Education: Bachelor’s degree in Environmental Science and/or Management or Environmental Engineering or related field. Master’s degree preferred.

Experience:

● At least 5 years of experience working as environmental specialist, with a focus on regulatory compliance, environmental monitoring methods, impact analysis and assessment;

● Experience in conducting trainings;

● Experience in writing Environmental Impact Assessment(s) (EIA);

● Experience working in ….[e.g. parks or protected area infrastructure; conducting environmental assessments in the health sector; and/or natural resource management];

● Knowledge of biological, water sciences, and/or the earth-sciences ;

● Knowledge of Bangladesh environmental regulations required;

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● Previous experience with donor funded activities preferred;

● Familiarity with USAID environmental guidelines is preferred

Skills:

● Proficiency with Microsoft Office;

● Should have strong analytical skills, be gender sensitive, and possess a proven track record of working successfully in a variety of cultural contexts;

● Excellent interpersonal and community consultation skills;

● Excellent writing skills;

● Fluent Bangla and English language skills [speak, read, write]

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Annex : 5From: https://reliefweb.int/sites/reliefweb.int/files/resources/2019%20JRP%20for%20Rohingya%20Humanitarian%20Crisis%20%28February%202019%29.compressed_0.pdf

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From: https://reliefweb.int/sites/reliefweb.int/files/resources/2019%20JRP%20for%20Rohingya%20Humanitarian%20Crisis%20%28February%202019%29.compressed_0.pdf

41

http://documents.worldbank.org/curated/en/668321551867075566/pdf/EMCRP-ESMF-Final-Disclosure.pdf http://documents.worldbank.org/curated/en/668321551867075566/pdf/EMCRP-

ESMF-Final-Disclosure.pdf

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