Every USAID-funded programme is required to comply with the U.S. Government’s (USG’s) environmental regulations (often referred to as “Reg. 216”). Reg. 216 outlines the Environmental Impact Assessment (EIA)process that USAID has designed to identify potential effects —positive or negative— that a project or activity may have on the environment. The process is intended to prevent activities that are likely to cause significant environmental harm and to ensure that projects monitor and mitigate any negative effects on the environment. (For more information, see Title 22 of the Code of Federal Regulations and the administrative guidelines in Chapter 204 of USAID’s Automated Directives System.)
As the initial and foundational step of the environmental compliance process, USAID issues a pre-award analysis of potential activities that will be supported by the project to determine what environmental impacts a project’s activities may have in the course of implementation. This pre-award analysis is called an Initial Environmental Examination (IEE) and serves as the source document for development of the Environmental Review Form (ERF), which in turn serves to inform the development of the Environmental Mitigation and Monitoring Plan (EMMP). An adequately developed EMMP enables the programme to comply with all USAID Environmental Compliance requirements to minimise environmental hazards.
All USAID implementing partners, are required to review their planned activities to identify activities which may pose an environmental risk. This is performed using the Environmental Review Form or ERF, which is completed prior to the implementation of activities and submitted to USAID for approval. As part of the ERF, each activity is measured as part of the Screening result as “Very Low Risk”, “High-Risk” or “Moderate or unknown risk”.
The Environmental Mitigation and Monitoring Plan or EMMP identifies the activities requiring mitigation, describes the environmental threats posed by the programme activities as well as the mitigation measures planned to combat the threats and indicates the plan for monitoring of these mitigation measures. The plan includes indicators, frequency and responsibility for monitoring of the mitigation measures, and is submitted to USAID for approval.
SustainAbility Solutions specializes in working with organizations that are executing programmes funded by the US Government and other donors. As part of our Environmental Compliance service offering, we provide guidance to prime recipients of USAID funding and their sub-recipients on how to meet the USAID Environmental Compliance requirements.
As part of our environmental compliance service offering, we perform the following:
(a) Considering all requirements of Federal Regulations Part 216 (Environmental Procedures), we can assist organisations to review their planned activities against a pre-defined list of programme activities which may pose an environmental risk.
(b) Using the outcomes of step (a), we can help will develop the Environmental Mitigation and Monitoring Plan to identify the activities requiring mitigation, describe the environmental threats posed by the programme activities, the mitigation measures that will be implemented to manage the identified threats and the monitoring and reporting of mitigation measures.
(c) We can assist management to create an Environmental Policy to: