Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project...

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USAID BEO DECISION MEMO FOR THE ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) and ENVIRONMENTAL STATUS REPORT (ESR) PREP FY17 Awardee: Helen Keller Institute (HKI) DCHA Office: Food for Peace Program Title: Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience, and Gender Equity (SAPLING) Award Number: AID-FFP-A-15-00010 Country/Region: Bangladesh/Asia Life of Grant: September, 2015-September 2020 LOP Funding: $28,777,000 IEE Link: http://gemini.info.usaid.gov/egat/envcomp/document.php?doc_id=49021 ENVIRONMENTAL ACTION RECOMMENDED: Categorical Exclusion: X Negative Determination w/ Conditions: X Positive Determination: Deferral: Bureau Environmental Threshold Decision (ETD): Approval w/ Conditions USAID Bureau Environmental Officer Approval: This USAID BEO Decision Memo is to inform HKI that both the Environmental Mitigation and Monitoring Plan (EMMP)* and Environmental Status Report (ESR) PREP FY17 have been approved by the DCHA Bureau Environmental Officer (BEO) on April 19, 2017 with project-specific conditions that will be ensured by the AOR. Summary of Compliance: The DCHA BEO would like to commend HKI for a well done set of assessments, meeting a high degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena Bishop. In particular, the EMMP update reflects a thoughtful analysis, for example through agroforestry and intercropping provided for the 1

Transcript of Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project...

Page 1: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

USAID BEO DECISION MEMO FOR THE ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) and

ENVIRONMENTAL STATUS REPORT (ESR) PREP FY17 Awardee: Helen Keller Institute (HKI) DCHA Office: Food for Peace Program Title: Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience, and Gender Equity (SAPLING) Award Number: AID-FFP-A-15-00010 Country/Region: Bangladesh/Asia Life of Grant: September, 2015-September 2020 LOP Funding: $28,777,000 IEE Link: http://gemini.info.usaid.gov/egat/envcomp/document.php?doc_id=49021

ENVIRONMENTAL ACTION RECOMMENDED:

Categorical Exclusion: X Negative Determination w/ Conditions: X

Positive Determination: Deferral:

Bureau Environmental Threshold Decision (ETD): Approval w/ Conditions

USAID Bureau Environmental Officer Approval: This USAID BEO Decision Memo is to inform HKI that both the Environmental Mitigation and Monitoring Plan (EMMP)* and Environmental Status Report (ESR) PREP FY17 have been approved by the DCHA Bureau Environmental Officer (BEO) on April 19, 2017 with project-specific conditions that will be ensured by the AOR. Summary of Compliance: The DCHA BEO would like to commend HKI for a well done set of assessments, meeting a high degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena Bishop. In particular, the EMMP update reflects a thoughtful analysis, for example through agroforestry and intercropping provided for the

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activities in Promote Homestead Food Production (HFP). In addition, from an award management perspective, a good level of detail is provided regarding funds for mitigation (p. EMMP, 6), and staffing in Table 3: Staffing and Expertise over LOA (p. EMMP, 35, 36). Kindly note that there appear to be a version control issue (?), as mentioned below in Conditions 2 and 3, but otherwise HKI’s EMMP update is excellent. *Note: An updated EMMP was provided to the DCHA BEO after the original IEE/EMMP approval in order to address the BEO conditions in the IEE. Conditions (3): Condition 1: HKI must provide the DCHA BEO with greater information regarding the scale of Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture in the next two weeks, maximum 30 days, if delays in the field are justified to the AOR. At that time, HKI must also provide justification for not doing an Environmental Assessment for the activity. Condition 2: HKI must incorporate their WQAP into their EMMP and provide an in the next FY18 PREP Environmental Status Report. Condition 3: HKI must incorporate their energy saving cooking best practices from their ESR FY17 PREP into their EMMP and provide an update in the next FY18 PREP Environmental Status Report. ______________________________________________________________________________ Issue 1: Scale of Irrigation Activities Discussion: The DCHA BEO appreciate that HKI has provided new mitigation measures and detail regarding Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture (Capturing rainwater or diverting other surface water to create temporary water reservoirs or ponds). However, neither EMMP and narrative nor ESR mention details regarding the scale of the irrigation activities. Given the potential for environmental consequences with an irrigation project, HKI must provide greater detail regarding the scale, for example, how many existing canals or ponds will be renovated? What is the size or kilometer measurements? The BEO is considering that an Environmental Assessment (EA) might be needed. Please provide information about scale of the irrigation activities. Irrigation projects often trigger EAs

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in other FFP projects. The BEO is going to assume that EAs are needed for activities until HKI provides justification to the contrary. Condition 1: HKI must provide the DCHA BEO with greater information regarding the scale of Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture in the next two weeks, maximum 30 days, if delays in the field are justified to the AOR. At that time, HKI must also provide justification for not doing an Environmental Assessment for the activity. ______________________________________________________________________________ Issue 2: Water Quality Assurance Plan (WQAP) Discussion: HKI mentions water quality testing throughout the EMMP but does not mention the WQAP. In the ESR, HKI also mentioned doing a WQAP. However, there is no mention of the WQAP in this EMMP. HKI must integrate the WQAP into the EMMP plan. Condition 2: HKI incorporate their WQAP into their EMMP and provide an the next FY18 PREP Environmental Status Report. ______________________________________________________________________________ Issue 3: Cooking Practices. Discussion: In their response to the DCHA BEO IEE Conditions, HKI mentioned that it would incorporate energy saving cooking practices into all cooking demonstration activities. However, the mitigation measure mentioned in ESR was not incorporated into the EMMP table or the 1

narrative. Further, there was no mention of stoves or fuelwood in the EMMP Table either. The ESR narrative does address best environmental practices for cookstove. Condition 3: HKI must incorporate their energy saving cooking best practices from their ESR FY17 PREP into their EMMP and provide an update in the next FY18 PREP Environmental Status Report. ______________________________________________________________________________

1 Incorporate energy saving cooking practices into all cooking demonstration activities.

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Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience and Gender Equity (SAPLING)

Environmental Mitigation and Monitoring Plan (EMMP)

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Contact Information:

Treena Bishop- Chief of Party, SAPLING Helen Keller International House 10E, Road 82, Gulshan 2, Dhaka 1212 Tel: (088) 02-882-3055 E-mail: [email protected]

Activity/Project Title: Sustainable Agriculture and Production Linked to Improve Nutrition Status, Resilience and Gender Equity (SAPLING)

Contract/Award Name(s) & Number(s) (if known): AID-FFP-A1500010 Geographic Location (Country(ies))/ Region/Global: Bangladesh/Asia Operating Unit(s): DCHA Food for Peace

IEE approval date: 20/09/2016 IEE Number: 49021

Amount of Commodity: $ Life of Award (LOA): $28,777,000 Project Start and End Dates: September, 2015 to September 2020

EMMP Prepared By: Md. Kamrul Hasan Bhuiyan; Environment Specialist- SAPLING Project

Date Prepared: February 23, 2017

Implementing Partner(s): Helen Keller International

Reporting due dates (if any): Recommended Threshold Determination:

× Categorical Exclusion Positive Determination

× Negative Determination With Conditions Deferral

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Table of Contents ACRONYMS ................................................................................................................................................... 3

1 EXECUTIVE SUMMARY.......................................................................................................................... 5

APPROVAL of EMMP: .................................................................................................................. 6

2 INTRODUCTION ..................................................................................................................................... 7

2.1 Purpose and Guiding Principals .................................................................................................... 7

2.2 Background ................................................................................................................................... 7

3 REGULATORY FRAMEWORK ................................................................................................................. 8

3.1 Relevant Laws and Strategies of Bangladesh ............................................................................... 8

3.2 Relevant policies - Laws and Strategies of United States ............................................................. 8

3.3 USAID Environmental Regulations and Requirements ................................................................ 9

3.3.1 Initial Environmental Evaluation ........................................................................................ 9

3.3.2 Environmental Due Diligence ........................................................................................... 10

3.3.3 EMMP ................................................................................................................................ 10

4 ENVIRONMENTAL SCREENING ACTIVITIES ......................................................................................... 10

4.1 Potential Environmental Impacts ................................................................................................ 10

4.2 Environmental Effects Mitigation Measures .............................................................................. 23

4.2.1 Activities Determined to have Potential Environmental Effects ...................................... 23

4.2.2 Mitigation Measures ......................................................................................................... 24

5 MONITORING SYSTEM ......................................................................................................................... 32

5.1 Performance Monitoring Measurement ...................................................................................... 32

5.1.1 Stand-alone Environmental Indicator ............................................................................... 32

5.1.2 Integrated Environmental Indicators ................................................................................. 33

5.2 Monitoring Plan .......................................................................................................................... 34

5.2.1 Staffing.............................................................................................................................. 34

5.2.2 Schedule ............................................................................................................................ 35

5.2.3 Budget ............................................................................................................................... 38

6 CORRECTIVE ACTION PLAN ................................................................................................................ 40

7 REPORTING .......................................................................................................................................... 40

7.1 Site Visit Reports ........................................................................................................................ 40

7.2 Reporting Schedule ..................................................................................................................... 40

ANNEX 1: RECOMMENDED IEE DETERMINATIONS, MITIGATION, MONITORING AND EVALUATION FROM IEE ...................................................................................................................................................... 41

ANNEX 2: ENVIRONMENTAL AWARENESS/SCREENING CHECKLISTS ......................................................... 55

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Acronyms ADS Automated Directives System BCC Behavior Change Communication BEO Bureau Environment Officer CFR U.S. Code of Federal Regulations CFW Cash for Work CHSW Community Health Service Workers CHT Chittagong Hill Tracts CRA Community Risk Assessment DMC Disaster Management Committee DPHE Department of Public Health Engineering DRR Disaster Risk Reduction ECA Ecologically Critical Area EMMP Environmental Mitigation and Monitoring Plan ENA-EHA Essential Nutrition Actions-Essential Hygiene Actions ENCAP Environmental Compliance and Management Support Program ESR Environmental Status Report GAP Good Aquaculture Practices GOB Government of Bangladesh HFP Homestead Food Production HH Households HKI Helen Keller International IEE Initial Environmental Examination IPM Integrated Pest Management IPTT Indicator Performance Tracking Table LF Lead Farmer M2W2 Making Markets Work for Women MEO Mission Environment Officer MoHFW Ministry of Health and Family Welfare NDw/C Negative Determination with Conditions NEPA National Environmental Policy Act NIE Nutrition in Emergencies NOC No Objection Certificate PDMC Para Disaster Management Committee PERSUAP Pesticide Evaluation Report and Safe Use Action Plan PHI Pre-Harvest Interval

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PIRS Performance Indicator Reference Sheet PPE Personnel Protective Equipment RiA Required if Applicable RRAP Risk Reduction Action Plans SAPLING Sustainable Agriculture and Production Linked to Improved Nutrition Status

Resilience, and Gender Equity SILC Savings and Internal Lending Communities SRDI Soil Research and Development Institute SUAP Safer Use Action Plan UDMC Union Disaster Management Committee USAID United States Agency for International Development USG United States Government UzDMC Upazila Disaster Management Committee WASH Water, Sanitation and Hygiene WHO World Health Organization WUC Water User Committees

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1 Executive Summary This document serves as an expanded description of the mtigation measures and monitoring methods recommended in the Environmental Mitigation and Monitoring Plan (EMMP) (Annex 1). The recommended mitigation measures and monitoring methods have been developed to meet the environmental conditions established in the Initial Environmental Examination (IEE). Adherence to the IEE positions the implementing agencies, Helen Keller International (HKI), Catholic Relief Services, and Caritas/Bangladesh, to carry out the Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience, and Gender Equity (SAPLING) project in accordance with U.S. federal regulation 22 Code of Federal Regulations (CFR) 216 and national Bangladeshi law.

Of the twenty-five activities implemented in the SAPLING project, eight were determined to have a potential negative effect on the environment. For these eight activities, IEE conditions were established. This narrative discusses the mitigation measures perceived to be needed to meet IEE conditions. Annexed to this document are monitoring tools and site visit forms created to monitor mitigation measures and report on the progress and adequacy of the mitigation measure indicators in meeting IEE conditions.

Environmental mitigation actions represent 7% of the total SAPLING budget. The Environmental Specialist will oversee the implementation of recommended mitigation measures. SAPLING activity coordinators, technical staff, field facilitators, and monitoring and evaluation staff will all support the implementation of recommended mitigation measures and the collection of data needed to report on mitigation measure effectiveness. Key SAPLING staff will meet to review the EMMP and modify it according to observations on the ground. Mitigation measures will be reported to the United States Agency for International Development (USAID) on an annual basis in the Environmental Status Report (ESR).

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USAID APPROVAL for HKl-SAPLING EMMP :

Food for Peace, Mission (or Regional Office, as appropriate*):

Food for Peace Officer* Date:

Mission Environmental Officer* --~-=-------L---=------Date: _ 6_1_/_o __ 3/_:?_Ci_:1_'f-

Food for Peace, Washington:

Agreement Officer's Representative ~ ' Va Date: Cf J J I / {7 I I

OCHA Bureau Environmental Officer Date: ------------ ------~

Regional Environmental Officer** _____________ Date: ______ _

* FFP/M/R environmental officer clearance is mandatory; clearance by the FFPIMIR FFP officer is optional. **REO clearance is optional.

Erika J. Clesceri
4/19/2017
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2 Introduction

2.1 Purpose and Guiding Principals The EMMP has three main purposes. First, the EMMP translates the conditions outlined in the SAPLING IEE (approved by DCHA BEO on 20 September 2016) into mitigation measures. Second, it establishes indicators and the criteria to measure those indicators to monitor the implementation of and effectiveness of the mitigation measures. Thirdly, it establishes the indicator data collection schedule and the person ultimately responsible for reporting on specific indicators. The EMMP seeks to follow the four guiding principles below: Realistic – Mitigation measures must be achievable within time, resources and capabilities. Well-targeted – Mitigation measures must respond to the IEE conditions which in turn should correspond to the identified environmental threats and stressors for the area of implementation. Prevention-focused – Prevention of negative environmental effects is usually cheaper than remediation. Funded – There must be sufficient budget to cover the implementation of the mitigation measures and their monitoring otherwise the actions cannot be achieved. 2.2 Background HKI, Catholic Relief Services, and Caritas/Bangladesh will work in partnership with individuals, communities and the Government of Bangladesh (GOB), to implement the SAPLING project, a multi-sectoral, integrated approach to reduce food insecurity and malnutrition in all unions of the upazilas of Thanchi, Ruma, Lama, Rowangchari, and Bandarban Sadar, within the Bandarban District of the Chittagong Hill Tracts (CHT). These areas have a high proportion of people living in extreme poverty, combined with high rates of stunting, undernutrition, food insecurity, and fertility. The overall goal of the SAPLING project is improved gender equitable food security, nutrition and resilience of vulnerable people in selected upazilas of the CHT in Bangladesh. This goal will be achieved by separating activities into three main purposes:

x Purpose 1: Increased equitable access to income and nutritious foods for both males and females x Purpose 2: Improved nutritional status of children under five years of age, pregnant and lactating

women and adolescent girls x Purpose 3: Strengthened gender equitable ability of people, households, communities, and

systems to mitigate, adapt to and recover from man-made and natural shocks and stresses

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3 Regulatory Framework

3.1 Relevant Laws and Strategies of Bangladesh Recent Bangladesh environmental law is based on the guiding principles stated in the Bangladesh Environmental Policy, 1992. The legal framework of this policy proposed:

1) To amend all law to meet present day needs; 2) Frame new laws to control pollution and degradation; 3) Ensure implementation and raise public awareness; and 4) Ratify all concerned international laws/conventions and policies and bring national laws into line

with such. The Environmental Conservation Act, 1995, was developed in accordance with these principles, and serves as the main legislative framework relating to environmental protection. Three amendments have followed in 2000, 2002, and 2010. While the Act focuses primarily on the control of industrial pollution, it also allows for the establishment of Ecologically Critical Areas (ECA) and defines the type of activities that can and cannot be carried out in these ECAs. In order to implement the Environmental Conservation Act, 1995, the Environmental Conservation Rules, 1997 were formed. These rules classify initiatives by potential environmental impact and assigns different assessment and management requirements. The following classification descriptions are taken directly from the background paper for the seventh Five-Year Plan.i

x Green List projects are those with positive environmental impacts or negligible negative impacts such as plantation and nursery. Clearance for these is obtained based on the project description, initial screening and No Objection Certificate (NOC) by the local authority.

x Orange A projects are those with minor and mostly temporary environmental impacts for which there are standard mitigation measures, such as the installation of tube wells, pond sand filter (PSF), tank/reservoir, sanitary latrines, etc. Application for Department of Environment (DOE) environmental clearance requires general information, a feasibility report, a process flow diagram and schematic diagrams of facilities, environmental screening form, and NOC from the local authority.

x Orange B projects are those with moderately significant environmental impacts for which mitigation measures are easily identified.

x Red List projects are those which may cause ‘significant adverse’ environmental impacts.

Refer to Section 2.2 of the SAPLING IEEii for additional national environmental policies and procedures.

3.2 Relevant policies - Laws and Strategies of United States The Foreign Assistance Act of 1961 established USAID and separated, for the first time, military and humanitarian foreign assistance, acknowledging "that a principal objective of the foreign policy of the

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United States is the encouragement and sustained support of the people of developing countries." Sections 117, 118 and 119 each outline environmental-oriented mandates related to operations in foreign countries. The U.S. National Environmental Policy Act (NEPA) 1970 calls for federal agencies like USAID to act as responsible stewards of natural resources. The Act requires federal agencies to prepare detailed statements assessing the environmental impact of and alternatives to major federal actions significantly affecting the environment. These statements are commonly referred to as Environmental Impact Statements and Environmental Assessments. The Act also established the President’s Council on Environmental Quality to oversee the implementation of NEPA. The Protection and Enhancement of Environmental Quality order established on March 5, 1970 and amended by U.S. Executive Order 12441 (May 24, 1977) extended the reach of NEPA by requiring that US government agencies (including USAID) undertaking activities/projects in foreign countries develop procedures to, in effect, comply with the spirit of NEPA. 3.3 USAID Environmental Regulations and Requirements 22 CFR 216 (“Reg. 216”) is the US federal regulation defining USAID’s pre-implementation environmental impact assessment process. The output of this process is Reg. 216 documentation – Requests for Categorical Exclusion, IEEs, and Environmental Assessments. Related mandatory provisions of USAID’s Automated Directives System (ADS)—especially, but not only, ADS 201.3.12.2.b and 204. 3.3.1 Initial Environmental Evaluation

3.3.1.1 Background and purpose As defined in Reg. 216 the IEE is “the first review of the reasonably foreseeable effects of a proposed action on the environment. Its function is to provide a brief statement of the factual basis for a Threshold Decision as to whether an Environmental Assessment or an Environmental Impact Statement will be required”. 3.3.1.2 Requirements Reg. 216 requires that any project funded by USAID provide documentation indicating if there are potential adverse effects to the environment from funded activities. If so, the recipient of the grant must propose mitigation measures to prevent this potential harm to the environment. There are two exceptions:

x Activities carried out in an emergency or that have exceptional foreign policy sensitivities are exempt.

x Activities that, by their nature, are unlikely to have a negative impact on the environment qualify for a Categorical Exclusion. (A program with only categorically excluded activities will not have to carry-out an IEE but will have to submit a Categorical Exclusion Factsheet with the relevant Reg 216 sections cited.)

All other programs must prepare an IEE and request the relevant category/categories or “Threshold Decision(s)” along with justification in a narrative report. USAID has determined four possible categories (Threshold Decisions) resulting from the IEE:

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x Negative Determination: No anticipated adverse impact on the environment. x Negative Determination with Conditions: Possible adverse impact but measures will be taken

to guard against it. x Positive Determination: Likely adverse impact. x Deferral: Not enough is known about the project(s) to make a determination of environmental

impact. 3.3.2 Environmental Due Diligence

Environmental Due Diligence forms are not specifically required by Reg. 216 or the ADS. However, as part of the pre-implementation environmental impact review process, using a Leopold matrix or environmental checklists can help predict the impact of a project on the environment. 3.3.3 EMMP

EMMPs are not specifically required by Reg. 216 or the ADS for IEEs. Reg. 216 does require monitoring of the environment for programs that have prepared Environmental Impact Statements or Environmental Assessments. However, for the SAPLING project, the EMMP is implicitly required by the IEE and reference to the plan is made throughout the IEE document.

4 Environmental Screening Activities 4.1 Potential Environmental Impacts In general, it is anticipated that the proposed SAPLING activities will not present any significant adverse environmental effects provided that the mitigation and monitoring activities recommended in Section 4.0 of this IEE are carried out. A discussion of potential environmental impacts for each activity is presented below. This entire section is copied from Section 3 of the SAPLING IEE. Activities are grouped by Purpose. For the numbering of activities below, the first number corresponds to the Purpose number, the second number corresponds to the Sub-Purpose number, and the third number corresponds to the Activity number. Purpose 1: Increased equitable access to income and nutritious foods for both males and females Activity 1.1.1: Microenterprise development for poor and extreme poor households (HH): Sustainable agriculture practice promotion: Crop yields and income-generating capacities of project participants will be improved by using better agricultural production techniques. Training on techniques such as contour farming, raised-bed technology, use of vegetative strips as water buffers, companion planting, intercropping, trough irrigation, integrated pest management (IPM), and use of organic fertilizers will be offered to project participants to increase yields and incomes while at the same time protect the environment. There are no adverse effects on the environment from classroom training on sustainable agricultural techniques. It is anticipated that the training will result in the uptake of more environmentally friendly agricultural practices by the participants and thus have a positive impact.

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Contour farming (Image 1) is a method of cultivating sloping land in which crops are planted in strips along the contour lines using soil erosion control measures, such as contour hedgerows. In 2011, HKI conducted an assessment of contour farms under construction by participant farmer groups in the Making Markets Work for Women (M2W2) project in Laxmichari Upazila in Khagrachari District of the CHT. The study looked at the appropriate steepness of slope and intercropping, mulching, and erosion control measures. The assessment identified multiple cropping, close planting, strip cropping, mulching, cover cropping, tillage, partial weeding etc.; cropping patterns in the CHT that can retain soil fertility and increase productivity.1 Crop cultivation can pose a threat to the environment in numerous ways including degradation of marginal and fragile lands, deforestation, loss of biodiversity, introduction of exotic species, soil erosion, nutrient depletion, loss of wildlife habitat, displacement of more appropriate land uses and reduction in water quality due to farm runoff. However, when properly managed, crop production can enhance agrobiodiversity, erosion control, soil fertility and economic well-being. Proposed sustainable agriculture practices of contour farming, hedgerows, terracing, bunds, raised-bed technology, vegetative strips as water buffers, companion planting, intercropping, trough irrigation, and IPM can reduce soil erosion, moisture losses, and pest infestations. Application of agroforestry methods can improve wildlife habitats, biodiversity, water retention capacity, soil permeability and provide a source of renewable energy. Adoption of these practices is a positive step toward climate change adaptation. Projected increased temperatures signal greater evaporation rates. Practices that retain moisture (e.g. vegetative strips, trough irrigation) efficiently utilize available water. Agroforestry creates a vegetative upper story that provides shade and reduces soil and air temperatures in close proximity. Trees are also essential consumers of the greenhouse gas carbon dioxide. The proposed sustainable agriculture practices are therefore expected to benefit the environment. Soil Fertility and Erosion Control: Injudicious application of chemical or organic fertilizers to improve soil nutrients can constitute an environmental threat, as fertilizers can cause pollution when they are applied more heavily than crops can absorb or when they are washed or blown off the soil surface before absorption by crops. Excess nitrogen and phosphates can leach into groundwater or run off into waterways, negatively affect lakes, streams, reservoirs and ponds, and lead to an explosion of algae which suppresses other aquatic plants and animals. While organic fertilizers are absorbed more easily into the environment with fewer side effects, excessive application and runoff of nutrient-rich water may also negatively affect watersheds.

1 Helen Keller International (HKI). 2012. Resilience to health shocks through improved agricultural production and market access for Making Markets Works for Women.

Image 1: (source: Sudibbo Kranti Khisha)

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Based on recommendations from the M2W2 assessment and experience of other projects working in hilly areas around the world, SAPLING will address erosion and soil fertility issues by intercropping and planting hedgerows respectively. For soil erosion control, the assessment report recommended two varieties of grass: Vetiviera zizanoides (vetiver grass) and Thysanolaena maxima (broom grass). Although they are not nitrogen fixing plants, there are many additional benefits of using these grasses, from crop protection to income generation. Therefore, the hedgerows will be planted using a mixture of nitrogen-fixing and erosion-controlling plant species. Depending on the location, suitable locally available nitrogen-fixing hedgerow species will be chosen such as Bogamedula (Tephorosia candida), and a local variety of pigeon pea (Cajanus cajan) to control soil erosion. Pineapple and banana rows will be planted with annual root cash crops, like turmeric, ginger, and taro, to help control erosion. Additionally, short-term fruit trees, such as papaya, will also be planted between rows for certain crops like turmeric, ginger, and taro. Finally, SAPLING will utilize a number of other simple technologies for sustainable land management, including basket and trench composting, bio-fencing, contour trenching, mulching, and deep planting to prevent soil erosion. The promotion of these natural soil erosion control and fertility improvement techniques is expected to minimize damaging HH practices and thus have a positive impact on the environment. Pest management: Pesticides pose a risk to the environment and human health if improperly used, including contamination of soil and water, harm to non-target organisms, destruction of natural pest control systems, and pest resurgence and resistance. SAPLING will promote the crop-based IPM approach, which encourages farmers to use natural pest control methods but allows the use of chemical or organic pesticides as a last resort to save their crops. The project will not directly promote any chemical pesticides. However, recognizing that it is common for farmers to use pesticides on their crops for disease and pest control, the project will train participants in the safe and judicious use of pesticides in accordance with the mission-wide Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP). Small animal husbandry: SAPLING will promote poultry, goat, and pig production to increase availability and accessibility of animal food sources, and nutritional messaging to encourage utilization. The project will aim for HH level production of 6 to 12 chickens and one pig/goat. It will also assist participants to build poultry sheds and adopt improved feeding practices. A one-day participatory training on poultry-rearing techniques will cover supplemental feeding, how to separate chicks from hens during the first 10 to 15 days, how to select appropriate breeds, and how, when, and why to vaccinate. Refresher trainings will stress application of skills and knowledge. Awareness events will be held with participant HHs, headmen/Karbaris, Upazila Livestock Officers, veterinarians and other local elites, to educate the broader community on livestock rearing practices and the need for proper vaccination to build herd immunity. Deworming will also be promoted. Community-based vaccinators (male and female youth) will be chosen in each upazila, trained to provide vaccinations, and linked to the Department of Livestock Services. HHs will also receive technical assistance from the project’s technical team.

Image 2: Hedgerows (source: Sudibbo Kranti Khisha)

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There can be significant negative effects on the environment if livestock and poultry are not properly managed because livestock can be affected by many different types of diseases (e.g., viral, bacterial, ecto-parasites and endo-parasites, etc.) and create waste. Viral and bacterial diseases can be easily transmitted from infected to non-infected poultry and livestock. Inappropriate use of veterinary drugs and improper disposal of related medical waste can pollute the surrounding environment. Improper management and burial of poultry and livestock that die as a result can cause air and water pollution. Certain zoonotic diseases (e.g., anthrax, brocelosis etc.) can even be transmitted to humans. Animal waste can also be a health hazard and contribute to environmental problems, as farmyard manure is often allowed to deteriorate on the ground or contaminate water systems. SAPLING will incorporate training on appropriate disease and waste management to avoid loss of animal assets by HHs, as well as potential health hazards to the HH members and surrounding neighbors. While inappropriate use of veterinary drugs and improper disposal of related medical waste could have potential negative effects on the environment, due to the small-scale nature of these activities and awareness raising by the project, no significant adverse effects are expected. Aquaculture: There are numerous environmental concerns regarding aquaculture. These concerns are discussed in USAID’s Sectoral Environmental Guidelines for Fisheries and Aquacultures.2 Large-scale aquaculture is generally not considered feasible for the CHT due to its mountainous nature, but small-scale aquaculture is feasible and has good potential as an Income Generating Activity (IGA) that will improve both HH nutrition and income. Through working with WorldFish as a technical partner, SAPLING will provide training in good aquaculture practices (GAP) to all its field facilitators and promote aquaculture where/when feasible and sustainable. SAPLING will work with participants to identify ponds and creeks in Bandarban district and train them in GAP. Primarily, the project will adapt the WorldFish developed “polyculture model”, which combines fast growing native and exotic carp species and short cycle self-recruit fishes like tilapia and ‘mola’, which is also a highly micronutrient rich small fish. However, final selection of fish species will be done with the producers and will be culturally appropriate. The polyculture system focuses on raising several fish species together that will not harm or compete with each other for food and space. Additionally, cuchia (Monopterus cuchia), a type of eel fish consumed by ethnic people, is found throughout Bangladesh, including hilly areas. SAPLING will adapt cuchia culture technology developed by WorldFish in other areas of Bangladesh to the CHT context. SAPLING will also establish a need-based community “fish nursery” in selected paras/villages to raise and supply larger size fish fingerlings to the surrounding communities in a timely manner.3 Rice-fish farming is a proven technology that benefits rice farmers by providing fish as an additional crop to increase HH consumption and income. It increases rice production by 5-10%, reduces rice pest and disease infestation and weeds due to fish activity in the rice fields and leads to reduced use of harmful chemicals. Rice-fish farming has been successful in the hilly areas of Indonesia and China.4 SAPLING will carry out adaptive research on rice-fish farming in a limited scale and then scale up through dissemination of the refined technology in wider areas. There could be minimal adverse and/or positive effects on the environment from small-scale aquaculture, such as resource optimization with the complementary utilization of land and water. If not properly managed, potential negative environmental impacts include loss of native species; pollution of water due 2 USAID’s Sector Environmental Guidelines for Fisheries and Aquacultures can be found at http://www.usaidgems.org/Sectors/fisheries.htm 3 Haque, M.A.B.M and Mokarrom, H. (2016). Report on Scoping study on fisheries potential in Bandarban for poor people. 13 – 16 February, 2016. WorldFish, Bangladesh. 4 Halwart M and Gupta MV (eds.) 2004. Culture of fish in rice fields. FAO and The WorldFish Center

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to overuse of fertilizers; and the killing of predator fish by chemicals like rotenone, which can also have a negative impact on environment and human health. Business management skills training: No harmful effects to the environment are foreseen from actions related to training project participants in business management skills. Post-harvest management training: Appropriate post-harvest handling can significantly reduce post-harvest waste, thereby fully utilizing water and nutrients provided by nature and providing a benefit to the environment. Classroom training on post-harvest management of crops has no negative effects on the environment, but may have indirect positive effects on the environment by improving post-harvest practices. Expanded off-farm production: SAPLING will conduct an assessment of off-farm production opportunities. It is anticipated that these opportunities will include handicrafts and hand-weaving (Image 35). Traditional handicraft production is an important marker of identity and culture for the indigenous communities in Bandarban district, and as such it is vital for local communities to preserve and develop these skills. Providing assistance to producers in off-farm production includes skills training in production techniques and business. Participants will be selected based on an assessment of social vulnerability, interest and current productive activities.Although traditional handicraft and hand-weaving can have negative effects on the environment due to wastewater produced by using chemicals and surface water for bleaching and dyeing, SAPLING will promote natural dyes and train producers in wastewater management to mitigate effects which may have an overall positive effect due to improved practices adopted by both target and non-target populations. In the case of SAPLING, the activities supported in this arena will be very small-scale and are not anticipated to have any significant adverse effects. Activity 1.2.1: Promote Homestead Food Production (HFP) Under the HFP model, producer groups, Village Model Farms and Lead Farmers (LF) will be identified and organized. Trainings will incorporate topics on sustainable agriculture practices, soil fertility, soil erosion control, pest management, small animal husbandry, aquaculture, post-harvest management and small business management. Threats and benefits of these actions to the environment are discussed under Activity 1.1.1. Additional key actions promoted under the HFP model are establishment of demonstration plots, gender and nutrition training for the HH, establishment of a system to promote access to quality inputs and market negotiation skills, technical training for LFs and regular HH visits to provide extension services.

5 Photos from: http/:https://www.iisd.org/pdf/2008/rtea_lao_silk.pdf/traditionalhandicrafts; http://www.wipo.int/ipadvantage/en/details.jsp?id=2892/promoting traditional handicraft; http: google.com/handicraft photo of CHT

Image 3: Handicrafts products of CHT

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There are no anticipated direct effects to the environment from the gender and nutrition trainings, the establishment of a system or technical training to the LFs to become local service providers. Demonstration plots: The establishment of demonstration plots/ponds will normally be on LF property though some exceptions could occur based on different ethnic group practices. Previously undeveloped land or marginal land will not be sought for the establishment of demonstration plots for HFP. Demonstration plots/ponds will promote actions that are in alignment with national and other climate change adaptation initiatives. Practices promoted on demonstration plots/ponds are discussed under Activity 1.1.1 and are expected to have a direct and indirect effect on the environment through adoption and dissemination of these practices. During implementation, participating farmers may apply pesticides to the demonstration plots as part of practicing and demonstrating improved pest management practices that they are learning. Farmers will be responsible for procuring any pesticides used on the demonstration plots as their own cost share contribution. SAPLING will not procure pesticides for this activity. However, training on use and application of pesticides will be provided in accordance with the PERSUAP. There is a risk to human health and the environment if farmers apply pesticides used on demonstration plots in excess or contrary to manufacturer’s recommendations, and/or does not use proper personal protective equipment. Seed and sapling providers: LFs will be supported to become local service providers of seed and saplings. Nurseries will not promote exotic or invasive plant species. On the contrary, seed producers will follow the Mari Seed Model that focuses on preserving indigenous vegetable seeds. These activities will provide a benefit to the environment by preserving agro-biodiversity and possibly promote climate change adaptation by expanding availability to local varieties with natural drought tolerance and pest resistance. Small plastic sheathes are typically used to transport seedlings and saplings. Arbitrary disposal of these plastic bags could potentially have a negative effect on the environment. SAPLING will work with LFs, nurseries and participant producers to develop a waste reduction reuse and disposal plan to minimize plastic bags littering the environment. Activity 1.2.2: Link microenterprise producers to markets and create a demand for products coming out of the CHT Actions under this activity focus on enabling project participants to become market actors. Potential environmental effects of some actions under this activity (such as post-harvest production for “new market” penetration and value addition) have been discussed under other activities. Aggregation of produce is one method for obtaining entrance to formal markets. Although collection point management systems will be promoted, no construction of collection centers is contemplated under this activity. It is anticipated that actions under Activity 1.2.2 will have no significant negative effect on the environment. Activity 1.2.3: Introduce Savings and Internal Lending Communities (SILC) The establishment of SILC may have an indirect positive effect on the environment. As designed, this approach invites Agriculture Extension agents to SILC meetings to speak about improved production practices that SILC participants could fund. SILC groups are self-selecting and open to all community residents, i.e., participation is not limited to other project specific eligibility criteria such as those criteria applied to HFP. In that sense, through SILC, SAPLING may reach a greater audience in its promotion of sustainable agricultural practices. Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture Potential negative effects on the environment may occur if proper mitigation measures are not taken with regards to the capture and retention of water. To be considered are loss to the aquatic ecosystem by

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creating stagnant water in previously flowing channels, loss to biodiversity, risk of increased cases of cholera, dysentery, malaria and typhoid, or disturbance in local ecology as well as impact on downstream users who may be deprived of water or subject to pollution. Furthermore, loss of top soil and water pollution due to sedimentation and run-off may be negative results of irrigation schemes if mitigation measures are not taken. Purpose 2: Improved nutritional status of children under five years of age, pregnant and lactating women and adolescent girls Activity 2.1.1: Train government and non-government health service providers including traditional birth attendants and the traditional healthcare practitioners and agriculture extension workers on Essential Nutrition Actions-Essential Hygiene Actions (ENA-EHA) framework As mentioned above in Section 1.2, SAPLING will use the ENA-EHA framework as its core technical approach to improve the nutritional status of women and children, including adolescent nutrition, in target communities. The ENA-EHA framework will be integrated, through training, into existing delivery platforms, including health service providers in the Community Clinics, Upazila Health Complexes, district hospital, and the Community Health Service Workers (CHSW). SAPLING (HKI staff) will directly provide the ENA-EHA Training of Trainers to the Civil Surgeons Office, the health implementation arm of the Hill District Councils, and CHSWs. All pregnant and lactating women and mothers of children under two years of age will receive the ENA-EHA training from the CHSWs. Training of agriculture, fisheries, and livestock extension agents provides another point of delivery for key nutrition messages as participants interact with these individuals. Finally, traditional health service providers, including village doctors and healers and Community Skilled Birth Attendants will receive ENA-EHA training, including adolescent nutrition. While the EHA-EHA messages do encourage the consumption of micronutrient-rich foods such as those grown through HFP, use of improved sanitation technologies, and use of healthcare services, all of which might have indirect negative effects if related activities are not implemented using appropriate mitigation measures, the training itself is expected to have no negative effects on the environment. Activity 2.1.2: Introduce the Nurturing Connections© gender transformative/sensitive approach across program elements The project will use a gender transformative approach developed and tested in Bangladesh called Nurturing Connections© to address gender inequality issues that affect women’s position and decision-making power in the HH. This approach engages men and women, separately and together, in a series of exercises that build their communication skills to address various HH and community dynamics such as roles and behaviors, power relations, and decision making patterns. Participatory and non-formal learning methods (e.g., role play, story-telling, drawing pictures, and games) are used to challenge intra-HH inequalities that contribute to food insecurity and malnutrition. There are no anticipated direct effects to the environment from implementation of this activity. Activity 2.1.3: Promote Essential Nutrition Actions (ENA), Essential Hygiene Actions (EHA) and Adolescent Nutrition at the community level Following the “1000 Days” approach to prevent malnutrition, which includes the period from conception through two years of age, all HHs in a community with pregnant and lactating women and women with children under two, will be invited to participate in courtyard sessions facilitated by CHSWs to learn about nutrition and hygiene. No adverse impact to the environment from this activity is anticipated.

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Activity 2.1.4: Organize nutrition fairs and cooking demonstrations The project will organize and implement different types of fairs at the community level as an opportunity for food and poultry producers to demonstrate techniques and sell their products. Booths will be set up for cooking demonstrations, farming demonstrations, nutrition information and disaster risk reduction (DRR) strategies. Local influential people will be invited, along with health service providers. The project participants will be invited to talk about their successes and challenges. There will also be theater and games for children. Nutrition, handwashing, and other Water, Sanitation and Hygiene (WASH) strategies will be promoted to reinforce messages received via other mechanisms. As part of the overall nutrition training strategy, implementing partners will organize and facilitate small-scale participatory cooking demonstrations based outdoors to highlight cooking methods that preserve the nutrient value of food. There are no adverse impacts to the environment anticipated for this activity. Activity 2.1.5: Provide Nutrition in Emergencies (NIE) training for Ministry of Health and Family Welfare (MoHFW) staff at supervisory positions and Disaster Management Committees (DMCs) In the context of environmental emergencies and conflicts, maintaining good nutrition practices is critical to helping people recover physically, for example, encouraging and enabling mothers to continue exclusive breast feeding. NIE supports nutrition and hygiene practices in emergency settings when community structures and resources may be weakened. Union DMC (UDMC) members will be trained to disseminate messaging on ENA and EHA post emergency, but will support Purpose 2 generally through improved knowledge and practice of nutrition-related behaviors. Other disaster risk management strategies will be addressed in activities under Purpose 3. This activity will convene UDMC, upazila DMCs (UzDMC) and MoHFW supervisory staff to discuss and learn about nutrition concerns, good practices, where to get information during and after an emergency, and being mindful of the needs of men and women, children, persons with disabilities and the elderly. All UDMCs and MoHFW supervisors from the SAPLING target areas will receive NIE training. NIE trainings will benefit those affected by disasters as staff will be prepared to provide guidance and will be aware of risk factors to look for in affected populations, such as creating gender sensitive disaster shelters or spaces. No adverse impact to the environment from this activity is anticipated. Activity 2.2.1: Design and implement Behavior Change Communication (BCC) around Nutrition and WASH Nutrition: The BCC intervention will aim to positively impact the first 1,000 days of life, changing the knowledge, attitudes and practices of pregnant and mothers on proper Infant and Young Child Feeding, including early initiation of breastfeeding and exclusive breastfeeding for the first six months, with complementary feeding from six months onwards. Previously designed and tested BCC materials will be introduced to families, such as the 12-month pregnancy and postpartum calendar that begins in the fourth

Image 4: Nutritious food cooking demonstration

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month of pregnancy and supports optimal behaviors and nutrition (including family support) for each month. Participants learn about food groups by color coding and playing games. Other tools include crop calendars showing what to plant seasonally and food plate posters with ideal food plates, both of which are also visual and color coded. BCC activities will engage entire HHs whenever possible, highlighting women’s role in ensuring the family’s nutritional health. No adverse effects on the environment are anticipated as a result of the design, training and implementation of the nutrition BCC strategy. Hygiene and sanitation practices: The project will develop a strategy to introduce and encourage uptake of safe WASH behaviors. A modified Community-Led Total Sanitation approach based on community champions, regular consultations and community monitoring of WASH projects and practices will be applied. Key individuals, such as youth and community leaders who have the ability to influence sanitation practices, will be identified. Messages will focus on the link between sanitation and health, cultural beliefs preventing adoption of good hygiene, and existing positive practices, and will be bolstered through the use of dramas, songs and other traditional media. When possible, the project will leverage existing materials by WASH actors including other USAID projects and United Nations Children’s Fund (UNICEF). The project will support exchange visits to model villages for influential Para Development Committee members, so positive practices can be observed and carried back to their communities. All field staff will be trained to understand, monitor and highlight safe hygiene and sanitation practices in addition to implementation of WASH behavior change activities using the USAID “Designing Behavior Change: Water, Sanitation and Hygiene” curriculum to which HKI contributed. There are no direct effects to the environment anticipated as a result of promoting the WASH BCC strategy. However, there are potential indirect positive effects on the environment including improved management of sanitation facilities and defecation practices which may prevent contamination of water supplies, improved water treatment and storage. Activity 2.2.2: Promote the use of improved sanitation technologies and systems SAPLING will present HHs with a range of simple appropriate technologies that can be purchased from the local market or made at home by poor HHs, as well as slightly more advanced options for others. Examples include Tippy Taps, standard pits with water seals, or off-set water seal toilets. Sanitation activities can have negative impacts on the environment including the contamination of water sources and surrounding environment, as well as the occurrence of fecal and waterborne diseases, if facilities are poorly maintained. The improper disposal of refuse can have a significant effect on the health of communities, and can lead to pollution of surface water, as rain washes refuse into rivers and streams. There may also be a significant risk of groundwater contamination. Refuse disposed of in storm drains may cause blockages and encourage fly and mosquito breeding. Alternately, proper construction, use and maintenance of sanitation technologies, in conjunction with the BCC messages mentioned in Activity 2.2.1, will have positive impacts on the environment. Activity 2.2.3: Increase access to safe water supply technologies and infrastructure SAPLING will promote safe water supply technologies in communities based on assessments of geographical and hydro-geological conditions. Options include protected shallow wells (to be raised in flood-prone areas), tube wells, ring wells, rain water harvesting tanks and cisterns, or possibly more elaborate systems, such as piped gravity-fed water systems drawing from nearby springs, infiltration galleries or deep set pumps. In terms of installation, although SAPLING will not fund any major construction activities, it may fund minor works related to improvement/installation related to provision of water including those commonly undertaken under cash for work (CFW), or small-scale professional

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service contracts that require some level of skilled labor. However, primarily it will promote installation or improvement of safe water supply infrastructure which will be funded by others. SAPLING will also work with the Department of Public Health Engineering (DPHE) to identify appropriate standard designs. These efforts will be linked with hygiene promotion around water treatment (e.g., boiling water, aqua tabs). Negative effects on the environment and human health can result due to poor construction practices or if the standards and design are not followed, including contamination of ground water, soil erosion and consumption of unsafe water. Adverse impacts on the environment and people’s health may be elevated if the water points are not properly operated or maintained. Alternately, with proper design, construction, operation and maintenance of safe water points, in conjunction with the promotion of water treatment, this activity may have positive effects on the environment. Purpose 3: Strengthened gender equitable ability of people, households, communities, and systems to mitigate, adapt to and recover from man-made and natural shocks and stresses Activity 3.1.1: Assist vulnerable HHs in developing preparedness strategies and action plans for shocks The project will work with men and women (together and separately) to promote HH preparedness plans. HHs will also participate in Community Risk Assessments (CRA), and prioritize actions that will benefit those experiencing high levels of food insecurity, nutritional stunting, and exposure to natural and man-made shocks as determined by the community in PRA exercises used to identify the most vulnerable. This would have indirect benefits to the environment as participants will be more capable to develop preparedness strategies for shocks to reduce environmental vulnerability, such as the elevation of latrines to prevent contamination of water sources or the surrounding environment. Many of these strategies will be linked to activities under Purpose 1 and 2. Activity 3.1.2: Assist HHs to develop a variety of strategies to protect productive assets As part of the CRA, SAPLING will help HHs inventory their assets and adopt strategies to protect them against man-made and natural shocks. Project field facilitators will link community representatives with local authorities such as Agriculture and Livestock officers to understand services available to protect livelihood assets. Individuals will be trained to administer livestock vaccines to protect them from flood-related diseases. HHs that are heavily dependent on agriculture or rearing small livestock for their livelihoods are particularly vulnerable to seasonal shocks. The project will assist them to diversify their livelihoods under Purpose 1. There are no adverse effects to the environment anticipated under this activity. Activity 3.1.3: Assist vulnerable HHs to access social safety nets to recover from stresses Government safety net programs are currently functioning in some Unions to support HHs after a natural disaster or other shock. The project field facilitators will train highly vulnerable HHs on how to access existing government safety net programs to support HHs after natural disasters or other shocks, involving Union Parishads and UDMCs. Examples include voluntary group feeding, voluntary group development and 40-day work creation programs for men and women, as well as ongoing safety net programs to support widows, and maternity allowances for women. Together with the Union administration, the project will develop and strengthen community structures and systems at the para (village) level. These structures and systems will draw upon existing human and natural resources from within the community to improve community capacity to mitigate and respond to shocks, with additional resource inputs coming from the government and the project in the form of CFW. All design processes promoted/facilitated by the project will incorporate men, women, elderly, people with disabilities and youth to ensure plans reflect diverse needs. No adverse effects on the environment are anticipated under this activity.

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Activity 3.2.1: Form and support Para - level DMCs to lead DRR activities The project will help create Para DMCs (PDMC) in villages, consisting of five to seven members, with a minimum of three female members, to be selected by the community based on demonstrated leadership ability and interest in disaster management. Field facilitators, the DRR Manager and UDMC will train PDMC members on the skills required to fulfill their functions, including training community members in disaster preparedness, early warning dissemination, evacuation coordination and assistance, performing emergency assessments, and acting as the key link between the community and UDMC. This activity is expected to have no major effects on the environment. Activity 3.2.2: Assist PDMC to develop community Risk Reduction Action Plans (RRAP) The project FFs will work with UDMC members to facilitate inclusive DRR planning, starting with a CRA to prioritize local DRR challenges. CRA is a participatory process for assessing hazards, vulnerabilities, risks, ability to cope, and preparing coping strategies. It uses secondary data, observation, and participatory discourses to identify, analyze and evaluate the risk environment of a particular community. The CRA addresses the comprehensive resilience of a community regarding food security and nutrition issues, in addition to human-made and natural shocks. It focuses not only on the direct loss of lives and property as a result of a disaster but also long-term effects such as loss of livelihoods and HHs’ ability to provide for their families. Community members will devise actions to address these challenges, and develop a RRAP, including both HH-level (HH savings, secondary livelihoods) and community-level actions (road improvements, embankment repair, sanitation, food storage). No direct impact on the environment is anticipated for the development of RRAPs by PDMC, although an indirect positive effect on the environment can be expected with the implementation of mitigation and recovery actions identified in the RRAPs. Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geo-spatial mapping and awareness raising The project will work to increase awareness of alternatives to traditional or adapted jhum cultivation, such as discouraging burning, planting crops that enrich rather than deplete soil, reforesting and forest management approaches, watershed management practices, and use of non-chemical farm inputs, linking to activities under Purpose 1. Dialogs will be held to facilitate community leaders to pose their own solutions while also learning about alternative natural resource management practices that have worked within the South Asia region, such as planting of pineapple or coffee as cash crops, crop and land rotation, and selective trimming of forests as an approach to forest management (linking to agriculture activities under Purpose 1). Demonstration plots will be promoted to test new practices, led by key community agriculture champions. The spatial maps will be provided to the UDMC and UzDMCs for future analysis and development of strategies to improve environmental safeguards. The geo-spatial mapping and awareness raising activities themselves are not anticipated to have any direct impact on the environment; there may be indirect positive effects on the environment through implementation of promoted changes in agricultural practices and watershed management. Activity 3.2.4: Facilitate establishment of capable gender-equitable community task forces to prepare for and respond to disasters To increase resilience of HHs against shocks, SAPLING will work with PDMCs to form village or Ward-level task forces (depending on the distance between villages). Task force membership will represent a cross section of the population, including women and youth and the most vulnerable, and will be trained to carry out critical functions before, during and following a shock (e.g., early warning dissemination,

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shelter management, search and rescue, first aid, water and sanitation, and livelihoods). SAPLING will facilitate participatory sessions aimed at understanding how roles and needs of all HH members change in the event of a disaster. SAPLING will also determine how women and men have different mobility and access to resources in the event of a disaster. Task force members will help train other community members and engage in regular but informal monitoring to ensure that all inputs reach intended HHs and reflect the needs of the broader community. Members will also assist FFs in conducting HH visits to discuss preparedness and gather input during the DRR process. No direct impact on the environment is expected from the establishment and training of these community task forces. Activity 3.2.5: Increase community knowledge on approaches to mitigate man-made stresses To improve environmental management, SAPLING will also help communities mitigate potential violence. Field assessments have identified land disputes between indigenous and Bengali communities to be among the shocks experienced in CHT, as well as domestic violence. SAPLING will integrate sessions on peacebuilding into DRR planning and prevention processes in an effort to rebuild or strengthen inter-personal relationships, within the home and between communities. Trainings will be held with youth and community leaders in every union who are well placed to advance a culture of peace within the CHT, promoting non-violent methods to address conflict. Additionally, peacebuilding will be raised by project facilitators during the CRA process and integrated into RRAP development workshops and Nurturing Connections© sessions. There are no direct effects on the environment anticipated under this activity but there may be indirect positive effects by helping reduce man-made stresses on the environment through conflict resolution. Activity 3.2.6: Facilitate funding of government approved mitigation projects from community DRR plans, using project, community and government contribution A lack of adequate infrastructure in the CHT, such as connector roads to allow evacuation, contributes significantly to the vulnerability of the population to natural disasters. Water resource management projects are needed to increase the availability of water during the dry season, creek and valley projects have the potential to support aquaculture as a secondary livelihood, and construction of market stalls may improve market functions. Project staff will consult with the UDMC and PDMC to identify small-scale infrastructure improvements from the RRAP that can be supported through CFW during the project period. Recruitment for CFW will have clear eligibility criteria and an emphasis will be placed on recruitment of women. Community RRAPs might include community sporting and cultural events or inter-communal construction projects to upgrade existing community centers, which could help reduce inter-ethnic tensions. While SAPLING will implement a few of the schemes prioritized within the RRAP through its CFW program, typically the types of schemes identified require skilled labor and larger budgets. In this regard, the RRAP is a tool that allows local governments and communities to seek donors to meet documented needs. SAPLING will not support any large-scale RRAP projects; these activities will be carried out with the support of the GOB. SAPLING will primarily be involved in facilitating the CRAs and the GOB’s incorporation of identified priorities in RRAPs. CFW projects, which involve relatively simple improvements/construction that can be achieved with supervised unskilled labor will be implemented between November and May to avoid the monsoon season. For example, to protect lives and properties in the CHT from landslides during monsoon season, the government has supported initiatives by the Soil Research and Development Institute (SRDI) to construct guide walls on the downsides of hill valleys (Image 5). This type of infrastructure has proven successful and is well accepted by the CHT community. SAPLING will identify locations where guide walls must be constructed or repaired, and will coordinate with SRDI for these activities. The

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Image 5: SRDI guide-wall in Bandarban (source: SRDI)

construction/rehabilitation of guide walls can lead to changes in land use and farming practices, affect water quality, and ultimately contribute to socio-cultural changes. Guide walls can lead to increased sedimentation, potential changes in vegetation cover, and increased water pollution. Drainage systems, while essential on poorly drained fields, may negatively affect associated ecosystems due to chemical and nutrient effluent discharge. The constructions of these guide walls have potential negative effects on the environment, but activities supported by SAPLING are small-scale in nature and are therefore not anticipated to have significant adverse effects on the environment if the appropriate mitigation measures are taken. Activity 3.3.1: Form and train UDMC to develop DMPs, with support from Regional and Upazila DMCs SAPLING will help establish UDMCs where they did not previously exist, and strengthen their capacity to fulfill their functions by conducting training, sponsoring monthly meetings, and providing assistance to members as they initiate new roles at the community level. No direct effects anticipated to the environment under this activity. Activity 3.3.2: Link communities to District, Upazila and Union DMC structures and to national Climate Early Warning System Disciplined coordination between community-based, local and national early warning system is critical for timely and appropriate responses by all relevant stakeholders in the event of a potential natural or human-made emergency. SAPLING will strengthen these systems using a community-led approach in developing RRAPs with local government and the existing efforts and information at higher levels so that the different nexuses in the system effectively support one another to prepare for and respond to the range of climactic and human-made shocks that affect CHT. SAPLING will arrange for annual mock drills in advance of rainy season to test the system and track the speed and accuracy of information passing from one leg of the system to the next. Following each drill, the SAPLING DRR Manager will work with communities and the various government DMCs to review the process and improve the response capacity of the system as a whole. There are no direct negative effects on the environment anticipated under this activity. Activity 3.3.3: Establish a community-based Conflict Early Warning System There is no system in the CHT to monitor conflict and its potential to escalate into violence. SAPLING will recommend a community-based system that links to the UDMCs. It will present the system to the UDMC and UzDMC, securing permission from the Chairman to set up the system. Once accepted by the UDMC and UzDMC, SAPLING will promote the system to local civil society organizations, private companies, and relevant government authorities. A community-based conflict Early Warning System will be piloted to systematically analyze potential conflict trends and link this analysis to local and national efforts charged with improving relationships within the CHT to help inform decisions related to governance and resource allocation by providing objective input around potential flags such as land or water disputes or youth bulges. No direct impact on the environment is anticipated under this activity but it may have indirect positive effects on the environment by resolving conflicts through negotiation.

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4.2 Environmental Effects Mitigation Measures 4.2.1 Activities Determined to have Potential Environmental Effects Of the twenty-five activities described in section 4.1, six were recommended in the SAPLING IEE for a Negative Determination with Conditions (NDw/C) but two other activities (Activity 1.2.3: Introduce Savings and Internal Lending Committees (SILC) and Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geo-spatial mapping and awareness raising) suggested by DCHA BEO for considering as NDw/C during the approval of SAPLING IEE.

Table 1: Environmental Threshold Decision for SAPLING (per approved IEE by DCHA BEO) Purpose 1 Sub-purposes

Increased equitable access to income and nutritious foods for both males and females

1.1: Increased sales and profitability from IGAs/markets 1.2: Increased homestead agriculture production of nutritious foods

Activities Threshold Determination (1.1.1) Microenterprise development for poor and extreme poor households (HH)

Negative Determination with Conditions as per 22 CFR 216.3(a)(2)(iii)

(1.2.1) Promote Homestead Food Production (HFP) Negative Determination with Conditions as per 22 CFR 216.3(a)(2)(iii)

(1.2.3) Introduce Savings and Internal Lending Committees (SILC)

Negative Determination with Conditions as per 22 CFR 216.3(a)(2)(iii)

(1.2.4) Improve access to water for irrigation, livestock and aquaculture

Negative Determination with Conditions as per 22 CFR 216.3(a)(2)(iii)

Purpose 2 Sub-purposes

Improved nutritional status of children under five years of age, pregnant and lactating women and adolescent girls

2.1: Adequate and equitable distribution and consumption of safe and diverse nutritious foods in households 2.2: Improved health of household members, especially pregnant and lactating women, adolescent girls and children under five

Activities Threshold Determination (2.2.2) Promote the use of improved sanitation technologies and systems

Negative Determination with Conditions as per 22 CFR 16.3(a)(2)(iii)

(2.2.3) Increase access to safe water through appropriate water supply technologies and infrastructure

Negative Determination with Conditions as per 22 CFR 216.3(a)(2)(iii)

Purpose 3 Sub-purposes

Strengthened gender equitable ability of people, households, communities, and systems to mitigate, adapt to and recover from man-made and natural shocks and stresses

3.1: Gender equitable resilience strategies are increased for target people and households to protect their lives and livelihoods from man-made and natural shocks and stresses 3.2: Communities are strengthened to mitigate and recover from man-made and natural shocks and stresses 3.3: Local Government DRR and disaster recovery systems are strengthened

Activities Threshold Determination (3.2.3) Promote community strategies to address/mitigate the hazards of environmental degradation through geo-spatial mapping and awareness raising

Negative Determination with Conditions as per 22 CFR 16.3(a)(2)(iii)

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(3.2.6) Facilitate funding of government approved mitigation projects from community DRR plans, using project, community and government contribution

Negative Determination with Conditions as per 22 CFR 16.3(a)(2)(iii)

4.2.2 Mitigation Measures

This section will expand upon the mitigation measures for each of the NDw/C activities. Mitigation measures discussed in this section are the actions currently perceived to be necessary to meet IEE conditions. Short of an IEE amendment, mitigation measures may be modified to meet the realities on the ground. Activity 1.1.1: Microenterprise development for poor and extreme poor households Mitigation Measure 1: Promote strategies to transition away from jhum cultivation By improving the productivity of cultivated land, producers will be able to fallow old jhum plots for longer periods of time and extend the productive life of a plot under cultivation reducing the need to “slash and burn” forested plots. Under Activity 1.1.1 a menu of sustainable agriculture practices will be selected based in in-situ factors such as soil composition, plot size, water availability, slope, and traditional cultural practices. These strategies will be reported on under the categories of:

x Aquaculture x Cultural Practices x Livestock Management x Pest Management x Disease Management x Soil fertility and conservation (soil erosion management) x Irrigation x Climate-mitigation and adaptation

Monitoring methods and tools for this mitigation measure are the same as those developed for Indicator Performance Tracking Table-2[Environmental Indicators aligned with M&E framework] indicators #3, Number of farmers and others who have applied improved technologies or management practices as a result of United States Government (USG) assistance, and #5, Number of hectares under improved technologies or management practices as a result of USG assistance. Under the PIRS description for #3 and #5, it is expected that the improved technologies and management practices will include hedgerows, intercropping, and non-GMO varieties. Mitigation Measure 2: Incorporate proper handling, storage, use and application of fertilizers into soil fertility training Fertilizers are not covered by the Mission-wide PERSUAP, and therefore it is important that the SAPLING program develop sound fertilizer use and handling messages. Fertilizer application points to consider:

x More is not better. Applying the appropriate quantity of fertilizer will go far in protecting soil and water resources. Follow quantity instructions as per soil recommendation via online of Soil Research and Development Institute (SRDI)iii.

x Fertilizers should not be applied too close to seeds and young roots and stems of plants.

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x Fertilizers should not be applied to plant leaves when they are young and wet. x Manures and fertilizers should be mixed thoroughly with the soil. x Urea should not be applied to soil with standing water. x Manure should be applied 7-10 days before sowing or planting of a crop.

Fertilizer handling points to consider:

x How far is the fertilizer mixing site from a water source? (>100 ft. from water source and downhill if possible)

x Is the mixing site on concrete or permeable soil? (On impermeable surface with run-off to a vegetated site)

x If the fertilizer is a liquid, is it hand-poured? What protective measures can be taken? (Closed system or latex gloves)

x How is fertilizer application equipment cleaned? Directly in a water source? (Sprayer washed out in field with reinstate used for the next fertilizer application on target crop)

Mitigation Measure 3: Develop SAPLING specific Safer Use Action Plan (SUAP). SAPLING SUAP template has been adapted from the PERSUAP. SAPLING SUAP already approved by MEO and DCHA BEO on 13 February 2017. Mitigation Measure 4: Train participants in waste management Training manual topics should include but are not limited to:

x Slurry preparation x Composting x Cleaning of goat shed, pig hut or chicken coop x Animal feces disposal x Odor and insect, particularly mosquito, control

A review of the training manual and observation of topics included serves to meet this mitigation measure. Mitigation Measure 5: Train participants in disease control management Training manual should incorporate topics in-line with Department of Livestock Services. Topics should include but are not limited to:

x Common disease identification and treatment procedure x Linkages with agro-vets x Storage and disposal of medicines x Bio-safety methods

A review of the training manual and observation of topics included serves to meet this mitigation measure. Mitigation Measure 6: Coordinate with health and hygiene BCC activities to encourage increased hygiene and homestead environmental health standards.

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BCC interventions should link human health risks associated with close animal contact. Topics should include but are not limited to:

x Washing hands (with soap, if possible) at all appropriate times for children and caregivers. x Corralling animals away from sleeping quarters. x Safe animal waste disposal procedures

Health coordinator should report to the Environmental Specialist estimated number of individuals reached through BCC interventions related to small animal husbandry hygiene. Mitigation Measure 7: Monitor grazing land ecological conditions In an area that receives as much rain as the CHT, the main concern for small ruminant livestock is that grazing patterns are may allow low-utility plants to gain dominance in composition. This happens when preferred plants are consumed by livestock allowing unpalatable plants to become the dominant plant species. This shift in plant composition degrades the utility of the grazing area in terms of nutritional value for the livestock and may have effects on wildlife food availability as well. The goal of monitoring plant composition is to ensure that palatable forage plants make up the majority of plant composition and are in a stable or increasing trend. This mitigation measure need only be reported on every other year after a community has joined SAPLING small animal husbandry activities. In general, if a community were to begin the first year of the project, the monitoring plot would be reported on during the first, third and fifth years. More frequent monitoring may likely be observing changes in weather rather than the effects of grazing. Monitoring should take place before the rainy season. Mitigation Measure 8: Train participants in environmentally sound production practices This mitigation measure will be monitored according to the Monitoring & Evaluation plan for Indicator Performance Tracking Table-2 [Environmental Indicators aligned with M&E framework ] indicator 4 (Number of private enterprises, producer organizations, water user associations, women's groups, trade and business associations and community-based organizations that applied improved technologies or management practices as a result of USG assistance) Improved technologies and management practices include but are not limited to:

x Waste water reuse x Use of natural dyes x Water use efficiency

Mitigation Measure 9: Raise awareness on GAPiv in target communities (Annex-3 Good Aquaculture Practices) Awareness raising strategies and topics will be carried out by SAPLING partner WorldFish. This mitigation measure seeks to align itself with WorldFish’s EMMP mitigation measures. Awareness raising events held and number of aquaculture producers demonstrating awareness of GAP will be monitored. See Annex 2 – Site visit forms for the GAP site visit form.

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Awareness raising should include topics on environmentally conscious pond design, hazard conscious site selection, disease and waste management, practicing positive traditional techniques, and establishing healthy input routines. Environmentally conscious pond design focuses on preventing contaminants and cultured fish from entering natural bodies of water. In most cases for SAPLING, ponds will be far from natural water bodies. Hazard conscious site selection takes into consideration up-gradient latrines that may introduce harmful pathogens into the pond through subsurface flow. Site selection in sloped terrain should also consider HH dwellings directly below the pond. In the case that an earthen wall fails, the outflow of water should not jeopardize houses directly below it. Awareness raising should also promote practices that minimize the risk of introducing an infectious disease and spreading it throughout the fish population and also the risk that diseased fish or infectious agents will leave the pond and spread to other sites and to other susceptible species. Good water quality, nutrition, and handling will go far towards preventing disease. Also, preventive medical practices such as quarantining, conducting routine observation, vaccination, and the use of immunostimulants, probiotics, and being able to diagnose common disease are important. If the project decides to provide training in use of aquaculture pesticides, it must be done in accordance with the Mission-wide PERSUAP. Conducting a risk analysis is a good first step in identifying common diseases and mechanisms of disease introduction. The management of disease and pathogens must be done under international (if fish is to be exported) and national law. The World Organization for Animal Health maintains the international Aquatic Animal Health Code.6 SAPLING should consult with the Bangladesh Fisheries Research Institute (BFRI) on accepted disposal practices for solid and liquid animal wastes, particularly when harboring disease pathogens. Mitigation Measure 10: Train hatchery owners on improved hatch stock management in alignment with government standards Hatchery owners should not only implement GAP but also be held to government standards for stock management. SAPLING should consult with Bangladesh Fisheries Research Institute to ensure that government standards for hatcheries are promoted. Improved stock management includes but is not limited to:

x Preventative steps for crossbreeding x Harmful environmental corollary effects of over-application of drugs and chemicals

The training manual should include the topics above. Review of the manual and observation of the included topics is sufficient to meet this mitigation measure. Activity 1.2.1: Promote Homestead Food Production (HFP) Mitigation Measure 1: Verify environmentally sound site selection and design. This mitigation measure ensures that SAPLING sets an exemplary model for the community in its use of land and does cause an environmental harm. Prudent selection of the demo plot site will help avoid negative environmental effect. Checklists for crop demo plots and aquaculture demo plots will be used to analyze potential environmental effect of demonstration plots. These checklists will review proximity to 6 http://www.oie.int/fileadmin/Home/eng/Health_standards/aahc/2010/en_index.htm

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ecologically sensitive areas, potential to contaminate surface water or groundwater and potential to be contaminated by adjacent contamination sources such as latrines. If the demonstration plot will be used for training in pesticide application, the checklist will verify that the site is located beyond 30 m from surface drinking water, shallow wells used for drinking, human habitation, and livestock habitation. The demonstration plot site selection need only be check upon establishment. Mitigation Measure 2: Develop nursery and greenhouse waste reduction plan. Options for reducing nursery and greenhouse waste should be considered, especially alternatives to the use of disposable plastic bags. Some research highlights that plants grown in bio-degradable bags suffer less transplant shock and establish roots better than plants grown in plastic tubingv. Financial incentive programs to encourage seedling buyers to return plastic sheathes may reduce waste entering the environment but these mechanisms tend to have low success rates. Improvements on the use of biodegradable jute root bags could be done in coordination with the alternative income generating activities to make these bags available and affordable to nursery owners. Options for the reduction of waste, particularly plastic seedling bag waste should be incorporated into a nursery and greenhouse waste reduction plan. This plan may be revised upon success or failure of waste reduction options. Activity 1.2.3: Introduce Savings and Internal Lending Committees (SILC) A mitigation measure for Activity 1.2.3 will be added and will read as follows: Mitigation Measure 1: The training manual for SILC groups will cover environmentally friendly ways to utilize funds, including: x Discourage the use of funds for any type of environmentally unfriendly and/or unsustainable

agricultural practices, including tobacco cultivation. x If funds will be used for purchasing chemical fertilizers/pesticides, then messages regarding the

safe and judicial use of chemicals will be included, covering appropriate chemicals, doses, timing and method before commencing application.

x Discourage the use of funds for purchasing pesticides, including rotenone which is often used for killing natural fish species as part of aquaculture practices. Participants will be trained instead on using drying or netting instead of rotenone to kill predator fish species.

x Encourage to use funds for IPM to get rid from pest infestation in the crop lands Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture Mitigation Measure 1: Train pond owners in linkages between pond management and mosquito-borne illnesses. The World Health Organization (WHO) has stated that without mitigation – climate change will result in an increase in the malaria burden in several regions of the world that are endemic for the disease7, particularly in densely-populated tropical countries such as Bangladesh. Research agrees that ponds and irrigation systems can increase incidence of malaria.vi vii Also abandonment of ponds can lead to higher malaria-vector abundance than when ponds are in operation.viii With this understanding, SAPLING will train water capture pond owners in methods and procedures to keep mosquito populations at a minimum.

7 World Health Organization (2015) Global technical strategy for malaria 2016-2030. Accessed June 22, 20016 at http://apps.who.int/iris/bitstream/10665/176712/1/9789241564991_eng.pdf?ua=1

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Topics may include: crop irrigation regimes that reduce larval development of malaria-vectors based on flooding timing, leaving some fish in ponds when selling fish harvest to keep mosquito populations down, keeping pond clear of vegetation, drying pond, decommissioning pond when no longer interested in fish farming. Mitigation Measure 2: Link with health and hygiene training to prioritize water sources for specific uses throughout the year, including proper use of water in capture ponds Any easy access source of water can be an attractive place to wash cloths, to take a bath, and even to collect drinking water. Introduction of soaps, food scraps and oils can contaminate water capture ponds. Also, depending on the inputs used in the water capture pond, withdrawing the water for use elsewhere may be harmful to human health. WASH activities should include water capture ponds in its discussion on how to prioritize available water sources and on where and how to obtain safe water for domestic needs. Mitigation Measure 3: Train producers to make water withdraw at times which reduce downstream effects. Rights to water are vested in the State. Minimum surface waters rights require that sufficient stream-flow be left in-stream for maintaining the conveyance channel. During periods of water shortages, priority for water allocation is first for domestic and municipal uses, followed by non-consumptive uses such as sustenance of the river regime, irrigation, industry, environment, salinity management, and recreation. If water diversion from a perennial stream is part of the design for water capture, pond operators should make in-stream withdraws during peak stream flows. This would be after a rainfall event. If the sources river is large enough that withdraws for the water capture pond will not be noted by downstream users this mitigation measure can be assumed to be met. Activity 2.2.2: Promote the use of improved sanitation technologies and systems To be considered “improved”, site selection of sanitation facilities must be environmentally conscious and will be monitored using the Environmental Compliance and Management Support Program (ENCAP) Visual Field Guide for Latrines. Mitigation Measure 1: Site location will take into consideration the following:

x Depth to water table (min. 1.5 m between pit and water table) x Water sources are at low risk of harmful pathogen contamination

High population densities require close attention to site selection and latrine design. The movement of fecal bacteria both laterally and horizontally in the soil subsurface depends greatly on hydrogeological conditions. A review by the Development Resource Center identified, “…recommendations published by the GOB DPHE, to install pit latrines or ring slab latrines 30 feet from shallow hand tube wells (depth 240 feet). For the deep hand tube wells (depth 900 to 1100 feet), no separation is required. This is the informal recommendation for rural areas.” ix While these recommendations do simplify site selection for latrines, they do not guarantee that soil and groundwater properties will slow pathogen transport sufficiently to keep water sources safe. For potential latrine sites, a Latrine Decision Tree has been created to walk through the steps necessary to ensure that harmful pathogens are not entering human or animal water sources. If parameters to calculate “# of pathogen transport days” cannot be obtained, SAPLING should abide by the GOB DPHE informal recommendations.

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Mitigation Measure 2: Train users in proper construction, maintenance, and decommissioning of the latrine. Training topics should include but are not limited to:

x Material production (e.g. concrete sanitation slab) x Installation method x Repair methods, and where to find replacement parts x Use of lime or ash to kill bacteria and reduce odor x How to clean the facility and surrounding area, and where to find cleaning products x When and how to decommission a latrine

Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure Mitigation Measure 1: Carry out water resources sustainability assessments A water resource sustainability assessment should be carried out before site selection and installation of any water infrastructure. Attention should specifically be devoted to environmental water requirements and sustainability of water use in the face of climate variability and change at the basin level. Consideration of downgradient or downstream users should be considered. Mitigation Measure 2: Define land ownership and user rights and validate with government and local authorities The process for defining land ownership and user rights will be the following:

x Meeting held with land owner & local community x Community leaders act as witnesses of the meeting x The signature of the Upazila chairman or Ward member, will serve as validation of the land

ownership and user rights. A photo taken of the agreement, kept on file, will serve to document that this mitigation measure has been met. Mitigation Measure 3: Up-gradient source protection measures incorporated into overall water point design and agreed to by the community before project initiation Source protection measures should be tailored to the location and type of water delivery system. Natural Springs Apply a checklist with the following criteria:

x Designated perimeter above source of no cutting, no grazing, no latrine construction x A portion of water left in-stream to maintain downstream ecological health x Protected from surface flow contamination (e.g. filter on stream diversion intake pipe)

Water sources meeting specific criteria above will be considered to have met the mitigation measure. Wells Apply ENCAP Visual Field Guide for Water Supply (Annex-2) to constructed wells. All answers to the Field Guide should be "no" for the indicator to be met.

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Mitigation Measure 4: Train Water User Committees (WUC) in water point maintenance and water quality monitoring A WUC will be considered to be fully trained when all members have completed water point training. Training topics should include but are certainly not limited to: hand-over of water quality monitoring, safe disposal of arsenic test strips, to whom to report water quality test results, and response protocol if water quality test results do not meet with adopted standards, maintenance procedures, where to obtain parts. Mitigation Measure 5: Monitor water quality HKI is responsible for initial water quality testing if all water points constructed with US government funds. This should be done in coordination with the DPHE arsenic testing program. At minimum, fecal coliform and arsenic must be tested prior to use and thereafter for four quarters (5 times) for all water points. Arsenic testing must conform to the requirements enumerated in Guidance Cable State 98 108651 that arsenic concentration be <0.01mg/L. DPHE arsenic standards are <0.05 mg/L and therefore less stringent. SAPLING should adhere to the more stringent arsenic concentration of <0.01mg/L. WHO and DPHE fecal coliform standard is that none are detected in a 100mL sample. Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geo-spatial mapping and awareness raising A mitigation measure specific to Activity 3.2.3 will be added to the EMMP as follows: Mitigation Measure 1: Train DMC members on sound NRM practices and alternatives for jhum cultivation. Activity 3.2.6: Facilitate funding of government approved mitigation projects from community DRR plans, using project, community and government contributions Mitigation Measure 1: Fund mitigation proposals that meet environmental criteria Since the list of activities presented in each RRAP will be broad, proposals for CFW funded projects should be reviewed with general requirement that funded activities be carried out in a manner that will not cause harm to environment. A requirement of funded CFW proposals should be that activities effecting the environment should be accompanied with appropriate mitigation measures.

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5 Monitoring System 5.1 Performance Monitoring Measurement Performance Indicator Reference Sheets (PIRS) have been created for IPTT indicators that also cross-over to the EMMP as environmental monitoring indicators. PIRs for EMMP indicators that are not reported on in the IPTT may be developed later. SAPLING will incorporate all approved environmental indicators into their detailed implementation plan. Below are presented both Stand-alone Environmental Indicators and Integrated Environmental Indicators. Outcome- and Output-level indicators are represented here. 5.1.1 Stand-alone Environmental Indicator

Output and outcome-level Indicators x # of participants trained on safe use x # and % of farmer use judicial use of chemicals (pesticides, fertilizer and chemical dyes)

[Judicial use of chemical means: identifying appropriate chemicals, applying right doses, maintained appropriate Time for spraying or using and Using Personnel Protective Equipment (full shelves shirt, full pant, boots, eye protector glass, gloves and cap)]

x # of retailers/ HHs/ Local service provider trained and applying safe use of chemicals x # of trained participant reduce of cost using chemicals pesticide x % of farmers who use basket and trench composting x % of farmers who apply bio-fencing, contour trenching, mulching, and deep planting for HFP x % of farmers who uses organic fertilizers/compost x % of farmers who knows the process for fertilizer testing x % of farmers who apply PHI (Pre-Harvest Interval) before harvesting x % of farmers who clean poultry and goat/pig rearing hut and shed regularly x % of farmers who dumping of disposal of poultry and pig/goat fecal properly x % of farmers who dumping of disposal of solid infectious waste properly x # of HHs buried dead animals/livestock if dies under earth x # of HHs applying vaccine following best practices x # of producers trained in GAP x % of producers trained on applying GAP x % of producers using traditional practices such as netting and drying of pond x # of participants trained on re-using wastewater, natural dye etc. x % of participants who are re-using wastewater, natural dye etc. x # of participants trained on solid wastes management x # of water structures will comply with environmental compliance x % of reservoirs protected x % of HHs who use lined pits x % of HHs who use lime or ash for killing fecal bacteria x % of HHs who applied training knowledge on production of materials (e.g., sanitation slabs) out

of total trained x % of communities that adopt water protection practices such as fencing, covering etc. x # of participants trained on NRM x % of improvement /construction sites applying appropriate mitigation measures x % of sites practicing required health and safety per type of site

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5.1.2 Integrated Environmental Indicators Outcome –level Indicators Table-2 describes how environmental and climate change consideration have been integrated into the M&E Plan.

Table 2: Environmental Indicators aligned with M&E framework (IPTT)

Sl

Environmental Indicator Indicator Type Activities covered

M&E framework-

Indicator Performance

Tracking Table

1 Number of farmers and others who have applied improved technologies or management practices as a result of USG assistance (Required if Applicable [RiA])

Outcome (FFP-9) Cultural Practices; Livestock Management; Aquaculture Management; Pest Management; Disease Management; Soil-related Fertility and Conservation; Irrigation- water diversification; Water Management - non-irrigation-based; Climate Mitigation or Adaptation; Post-harvest -Handling & Storage and Other: e.g. improved mechanical and physical land preparation

EMMP review-annually

2 Number of hectares under improved technologies or management practices as a result of USG assistance (RiA)

Outcome (FFP-15) Cultural Practices; Livestock Management; Aquaculture Management; Pest Management; Disease Management; Soil-related Fertility and Conservation; Irrigation- water diversification; Water Management - non-irrigation-based; Climate Mitigation or Adaptation; Post-harvest -Handling & Storage and Other: e.g. improved mechanical and physical land preparation

EMMP review-annually

3 Number of private enterprises, producer organizations, water user associations, women’s groups, trade and business associations and community-based organizations (CBOs) that applied improved technologies or management practices as a result of USG assistance (RiA)

Outcome (FFP-10) Promoting improved technologies or management practices collectively as an organization, enterprise, group or association

EMMP review-annually

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5 Percent of physically improved sanitation facilities with feces visibly present on the floor, wall, or area immediately surrounding the facility (RiA)

Outcome (FFP-46) Promoting safe sanitation behaviors EMMP review-annually

6 Number of people gaining access to an improved drinking water source (RiA)

Outcome (FFP-47) Promoting infrastructure-related wash interventions – upon completion of construction or rehabilitation of an improved water source

EMMP review-annually

5.2 Monitoring Plan

5.2.1 Staffing

The Environmental Specialist will oversee the implementation of recommended mitigation measures. There is budget for this position and the individual is on-staff. Implementation of the mitigation measures is expected to be carried out by budgeted staff positions.

Table 3: Staffing and Expertize over LOA

Sl. No Experts Roles and Responsibility No. of Staff

1 Environment Specialist x Ensure USAID environmental compliance 22 CFR 216 x Compile and report on mitigation measure indicator data

approved in the EMMP. x Conduct screening/environmental assessment x Facilitate trainings on USAID PERSUAP and IPM x Attend group meeting; workshop; x Coordinate with other FFP projects, the BEO, and USAID

Bangladesh mission x Organize Farmer Field Days at demonstration plots x Conduct courtyard sessions, workshops, field visits, etc.

as required by the project

1

2 Technical Officers (Horticulture & livestock)

x Assist with conducting environmental screenings (e.g. agricultural plots, aquaculture plots, small scale livestock activities, small scale water supply activities)

x Assist with collecting water samples for testing coliform, arsenic, pH etc.

x Assist with conducting training sessions on the safe use of pesticides and IPM per the USAID PERSUAP.

08

3 Field Facilitators x Assist with conducting environmental screening x Conduct site visits for monitoring x Assist with conducting courtyard sessions at the

community level

30

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4 Environmental Interns x Conduct site visits for monitoring x Assist with conducting environmental screenings x Assist with organizing Farmer Field Days at project

supported demonstration sites and courtyard sessions on safe use of pesticides, IPM based pest/weed management, health waste and solid waste management for raising awareness

10

5 Union Supervisor x Supervision of courtyard sessions conducted x Supervision of environmental assessment and site visits

for monitoring

10

5.2.2 Schedule

Monitoring schedule for each indicator can be found in Annex 1 - EMMP.

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5.2.3 Budget Table 4: Environmental Budget- Life of Project

Funding source for Life of Project (LOP)

Detailed Line Items Agriculture Sector Capacity

Object Class Category Section 202e Funds

Program element sub-total

Unit

Unit Amount (US$)

No. of Units Amount US ($)

1. Salary 1.1.2 Local staff Environment Specialist Months 2000 60 120000 120000 2. Fringe Benefit Environment Specialist 600 10 6000 6000 4. Travel and Transport 4.5 In-Country Air travel Days 185 10 1850 1850 4.6 In-Country Ground Travel Days 28 60 1680 1680 4.7 In-Country Per-diem Local Staff Days 28 60 1680 1680 6. Program Supplies Seeds/saplings Item 1.1 2184 2084 2084 7. Other Direct Costs Training/workshop Training on IPM pest/weed management Batch 2100 25 52500 52500 Water Quality Testing Samples 200 7 1400 1400 Environmental Training on Safe Use of Pesticides Batch 1100 25 27500 27500 Assessment/Reviews Environmental Screening for demonstration plots Study 200 50 10000 10000 Environmental Assessment for water structures and WASH activities

Study 500 48 24000 24000

Environmental Review Study 100 24 2400 2400 Natural Resource and Biodiversity Conservation - 270,114 - - 270114 Water Supply and Sanitation Items 299,896 - - 299896 8.0 Staff Training 8.3 Local staff training

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Environmental Interns Months 150 36 5400 5400 Environmental Specialist and Environmental interns Training 4608 2 9216 9216 9. USAID Branding and Marketing IEC materials (Flipcharts/flyer) Items 29400 - - 29400 11. Total Sub-contracts 11 A. Contractual/Sub-Awards Included in Indirect Cost Base IEE/other consultants Person/firm 3500 - - 3500 Total PROGRAMME $8,68,620

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6 Corrective Action Plan The project coordinators, the Environmental Specialist, and appropriate finance staff will meet once a year prior to the submission of the ESR to, 1) discuss the effectiveness of the mitigation measures to protect against environmental harm, 2) review feasibility of data collection, 3) address budget realignments for EMMP actions, and 4) recommend adjustments to mitigation measures, indicators, or indicator criteria. Adjustments should be in-line with the 4(four) EMMP guiding principles:

Realistic – Achievable within time, resources and capabilities

Well-targeted – Mitigation measures must respond to the IEE conditions which in turn should correspond to the identified environmental threats and stressors for the area of implementation.

Prevention-focused – Prevention of negative environmental effects is usually cheaper than remediation.

Funded – There must be sufficient budget to cover the implementation of the mitigation measures and their monitoring otherwise the actions cannot be achieved.

7 Reporting 7.1 Site Visit Reports Site visit reports should be modified according to the needs of the project in order to gather the necessary information. Site visit reports can be seen in Annex 2 – Site Visit Forms.

7.2 Reporting Schedule

Reporting of process indicators will generally take place on a quarterly basis. Output and outcome indicators will generally be reported on an annual basis. Reporting schedule for each indicator is identified in Annex 1 - EMMP. All environmental indicators will be reported to USAID on an annual basis in the ESR.

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Annex 1: Recommended IEE Determinations, Mitigation, Monitoring and Evaluation from IEE Activities classified as NDw/C with probable environmental impacts and possible mitigation measures of SAPLING over LOA have been

described in below Table – 5 as updated EMMP version as per instruction of DCHA BEO and MEO following the IEE condition 4 (HKI must reclassify the Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising to a Negative Determination with Conditions) and 5 (HKI must reclassify Activity 1.2.3: Introduce Savings and Internal Lending Committees (SILC) to a Negative Determination with Conditions).

Table 5: Updated Environmental Mitigation and Monitoring Plan (EMMP)

Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

Activity 1.1.1: Microenterprise development for poor and extreme poor households And Activity 1.2.1: Promote Homestead Food Production (HFP)

216.3(a)(2)(iii) Sustainable agriculture practice promotion: o Surface water and soil

contamination and risks to human health due to the use of chemicals (farmers may use pesticides and chemical fertilizers)

o Training materials and pesticide-related information that is poorly communicated or is misused or misinterpreted by the trainee/recipient could have potential negative environmental impacts

o Potential risk to biological

o Introduces the USAID/Bangladesh 2015 mission-wide PERSUAP and provide training and disseminate information about proper selection, application and how to safely use pesticides consistent with the SUAP and how and when to use Personnel Protective Equipment (PPE)

O Follow relevant recommendations and apply specific mitigation measures related to training described within the SUAP in the USAID Bangladesh 2015 Programmatic PERSUAP

O Prepare SUAP and Compliance Tracker

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 Programmatic PERSUAP

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of participants trained on safe use #&% of farmer use judicial use of chemicals (pesticides, fertilizer and chemical dyes) [ Judicial use of chemical means: identifying appropriate chemicals, applying right doses, maintained appropriate Time for

Quarterly

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

environment (aquatic, terrestrial, wetland, endangered species, and beneficial plants and animals) and public health

spraying or using and Using Personnel Protective Equipment (full shelves shirt, full pant, boots, eye protector glass, gloves and cap)] # of retailers/ HHs/ Local service provider trained and applying safe use of chemicals # of trained participant reduce of cost using chemicals pesticide

Annually

Annually

Soil Fertility and Erosion Control: o Injudicious

application of chemical or organic fertilizers to improve soil nutrients can

o Apply several simple technologies for sustainable land management (SLM), including basket and trench composting, bio-fencing, contour trenching, mulching, and deep planting

o Promote the use of organic

Environment specialist Manager, Livelihoods & Food Security

% of farmers who use basket and trench composting % of farmers

Annually

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

constitute an environmental threat

o Fertilizers can cause pollution when they are applied more heavily than crops can absorb or when they are washed or blown off the soil surface before absorption by crops

o Excess nitrogen and phosphates can pose potential risk to biological environment (aquatic, terrestrial, wetland, endangered species, and beneficial plants and animals) and public health

fertilizers/compost manure instead of chemical fertilizers

o Prepare “Pesticide Safer Use Action Plan and Compliance Tracker”

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 Programmatic PERSUAP

o Incorporate identification of counterfeit fertilizer into soil fertility training

o Training topic will include identification of adulterated organic fertilizer

Technical Officer (Horticulture)

who apply bio-fencing, contour trenching, mulching, and deep planting for HFP % of farmers who uses organic fertilizers/ Compost % trained participant who knows and practiced the process for fertilizer testing

Annually

Annually

Pest management: o Pesticides pose a risk

to the environment and human health if improperly used

o SAPLING will promote the IPM approach

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 mission-wide PERSUAP

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of hectares under improved technologies or management practices as a result of USG assistance (Technology type: Soil-related fertility

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

Activity 1.1.1: Microenterprise development for poor and extreme poor households

and conservation, Water management) (FFP 15) % of farmers who apply PHI before harvesting

Annually

Small Animal Husbandry:

o Livestock can be affected by different types of diseases like viral, bacterial, ecto-parasites and endo-parasites etc. If any poultry and livestock are affected by viral and bacterial diseases that might be transmitted to the other poultry & livestock which are not affected, it can cause significant loss of life (to other animals). It may also cause air pollution and water pollution in the case that any livestock or poultry carcasses are not well managed

o SAPLING will organize deworming & vaccination campaigns for livestock and poultry. Focus will also be placed on training on proper shed management to reduce outbreaks of and contain diseases like viral, bacterial, ecto-parasites, endo-parasites etc.)

o SAPLING will train participants on selection and use of pesticides or formulations with lower biological persistence that can be useful for managing resistance for livestock and poultry production. Insecticides with short residual lives tend to slow the development of resistance due to reduced exposure. However, application of pesticides for the control of livestock pests is a minor use category and the side effects are not a major concern compared to uses in agronomic crop production

o SAPLING will work closely with DLS for disease control, including

Environment Specialist Technical Specialist (Animal Husbandry) Field Facilitators

% of farmers who clean poultry and goat/pig rearing hut and shed regularly % of farmers who dumping of disposal of poultry and pig/goat fecal properly

% of farmers who dumping of disposal of Solid infectious waste properly

Annually

Annually

Annually

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

(buried). Even zoonotic disease (e.g., anthrax, brocelosis etc.) can be transmitted to the human body

o Animal waste can be a health hazard and cause environmental problems, as farmyard manure is often allowed to deteriorate on the ground water systems and accumulating in inland water bodies, making the water unfit for human consumption

o Inappropriate use of veterinary drugs and improper disposal of related medical waste could have potential negative effects on the environment

o Livestock can be affected by ecto-parasites such as flies, gnats, fleas, midges, ticks and flies. Insecticides continue to be the primary means of control for ecto-parasites on

incorporating key messages into training (e.g., bio-safety, mobile technology messages and linkage with agro-vets

o Composting will be promoted o Regular cleaning of poultry and

goat/pig rearing hut and shed will be promoted

o Disposal and dumping of poultry and goat/pig fecal disposal to nearby safe dumping / collection corners will be promoted

o Controlling odor, insects and mosquito breeding around the poultry and goat/pig rearing farm will be promoted

o Composting slurry will be promoted Veterinary Medicine: SAPLING will

develop training module include veterinary and healthcare waste disposal topics within the veterinary training module:

o Solid infectious waste: Autoclave, incinerate/burn, or bury.

o Blood and other infectious bodily fluids:

x Pour treated fluids into a pit where they will be filtered by the soil, but will not contaminate drinking water.

o Sharps: x Separate from other waste.

Immediately after use, put in a plastic, metal, or cardboard

# of HHs buried dead animals/ livestock if dies under earth # of HHs applying vaccine following best practices

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

livestock but there are concerns over resistance and residue problem.

o Human health can be affected from veterinary medicine resulting from veterinary services as well as poor quality of veterinary pharmaceuticals and if handled, treated, or disposed of incorrectly healthcare can spread disease, poisoning people, livestock, wild animals, plants and whole ecosystems.

container that will keep liquid from leaking; cardboard containers should be lined with plastic bags.

x If possible, containers should be colored yellow and marked “SHARPS,” “Infectious waste,” “Dangerous,” or something similar, in all relevant languages.

x Burn or encapsulate the sharps when containers reach ¾ full. If the container is to be reused, sterilize with bleach or other disinfectant.

o Wash water and sewage: x Treat using best available

treatment system. x Pour treated liquid in a pit where it

will be filtered by the soil, but will not contaminate drinking water.

o Placenta Pit construction: x Gather necessary materials,

including slab, cover, lining, drainage channel (plastic pipe), ventilation pipe with rain cover, nylon mosquito netting, fencing materials, etc.

x Dig the pit x Reinforce the bottom of the pit

(concrete, bricks, stones or clay) x Reinforce the side of the pit

(concrete, bricks, etc.) x Place the slab over the pit x Place a plastic (not metal)

ventilation pipe in a hole in the slab.

x Make a drainage channel around

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

Activity 1.1.1: Microenterprise development for poor and extreme poor households Activity 1.1.1: Microenterprise development for poor and extreme poor households

the pit to prevent runoff water from entering and to protect the walls of the pit.

o Quality of veterinary medicine (counterfeit veterinary medicine):

x Read the product label first x Read production date and expiry

date x Check the company registration no,

batch no, trade mark etc. x Common disease identification and

treatment procedures o Storage and disposal of medicines: x Bio-safety methods

Aquaculture: o Loss of native species

from the water bodies o Pollution of water due

to overuse of fertilizers

o Killing of predator fish by chemicals like rotenone

o Promote fingerlings (puna) from hatcheries rather than from natural bodies of water to reduce the burden on the ecosystem

o Train on Good Aquaculture Practices (GAP)

o Encourage traditional practices, such as netting and drying of pond, for capturing predator fish

o SAPLING will conduct pH testing before commencing aquaculture because fish culture requires a specific level of acidity.

Technical Officer (Fisheries) Environment Specialist Technical Officer (Horticulture)

# of producers trained in GAP

% of trained producers applying GAP

% of producers using traditional practices such as netting and drying of pond

Quarterly

Annually

Annually

Expanded off-farm production- handicraft and hand weaving: o Contamination of

nearby soil and ground and/or surface water from bleaching

o Train participants to improve environmental performance such as reusing wastewater, using natural dyes, and increasing the efficiency of water use in the processing of handicrafts

Environment specialist

Manager, Livelihoods & Food Security

# of participants trained on re-using wastewater, natural dye

Quarterly

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

and/or dyeing silk and/or other fibers

Technical Officer (Horticulture)

etc.

% of participants who are re-using wastewater, natural dye etc.

Activity 1.1.1: Microenterprise development for poor and extreme poor households

Solid Wastes Management o Contamination of

nearby soil and ground water or surface water from solid wastes due to unplanned dumping

o Project participants will be trained on Community Based Management of Solid Waste. This training will serve to raise awareness of and teach proper sanitary behavior, and build awareness to reduce, reuse and recycle.

o Unwanted waste will be separated and will go to the appropriate facility:

o SAPLING will introduce transfer points where local waste is collected and separated before being transported to landfills or recycling facilities.

o Awareness raising sessions on encourage practices to minimize public health, safety, and environmental risks.

o Train participants on environmentally sound production practices.

o Improved technologies and management practices include but are not limited to:

x Waste water reuse

Environment specialist Manager, Livelihoods & Food Security

Manager (MCHN)

# of participants trained on solid wastes management Number of private enterprises, producer organizations, water user associations, women's groups, trade and business associations and community-based organizations that applied improved technologies or management

Quarterly

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

x Use of natural dyes x Water use efficiency

o Training and awareness sessions on air pollution control.

o Air pollution control measures include:

x Use of masks and ear plugs by exposed operators

x Follow special timetables (avoid community sleeping/leisure times) to reduce impact on neighbors

x Follow strict maintenance and keep equipment lubricated

o Coordinate with health and hygiene SBCC activities to encourage increased hygiene and homestead environmental health standards.

SBCC interventions should cover human health risks associated with close animal contact. Topics should include but are not limited to: o Washing hands (with soap if

possible) at all appropriate times for children and caregivers.

o Corralling animals away from sleeping quarters.

o Safe animal waste disposal procedures.

practices as a result of USG assistance. (FFP-10)

Activity 1.2.1: Promote Homestead Food Production

216.3(a)(2)(iii) Establishment of Demonstration plots: o Improper use of

chemical pesticides threatening human health and the environment (aquatic,

o Verify that site selection for demo plot will not convert natural forest or wetland nor will it be constructed in an environmentally sensitive area prior to establishment

o Follow the USAID Bangladesh 2015 Mission-wide PERSUAP that

Environment specialist Manager, Livelihoods & Food Security

# of participants trained on safe use # of hectares under

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

(HFP) terrestrial, flora, fauna and human health).

o Inappropriate adaptation of agricultural practices by farmers and farmers’ groups; for example, continuing to grow crops in monoculture or applying chemicals injudiciously

includes recommendations and specific mitigation measures related to safe use

o Use and follow Material Safety Data Sheets on safe chemical use and storage

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 mission-wide PERSUAP

o Develop and use a checklist to evaluate environmental suitability of potential demonstration plots

Technical Officer (Horticulture)

improved technologies or management practices as a result of USG assistance (Technology type: Soil-related fertility and conservation, Water management) (FFP 15) % of farmers who applied improved technologies or management practices as a result of USG assistance (Technology type: Soil-related fertility and conservation, Water management) (FFP 15)

Activity 1.2.3 216.3(a)(2)(iii) o There is no direct impact on the

The training manual for SILC groups will cover environmentally friendly

SILC manager # of participants

Quarterly

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

Introduce Savings and Internal Landing Communities (SILC)

environment but unforeseen indirect effects may occur (if there are no mitigation measures) from the misuse of funds. Likewise, there exists the possibility of the funds for tobacco cultivation, purchasing of chemical fertilizers and chemical pesticides as well as for rotenone uses in the pond fish culture

ways to utilize funds, including:

o Discourage the use of funds for any type of environmentally unfriendly and/or unsustainable agricultural practices, including tobacco cultivation.

o If funds will be used for purchasing chemical fertilizers/pesticides, then messages regarding the safe and judicial use of chemicals will be included, covering the right chemicals, right doses, right time and right method before commencing application.

o Discourage the use of funds for purchasing pesticides, including rotenone which is often used for killing predator fish species as part of aquaculture practices. Participants will be trained instead on using drying or netting instead of rotenone.

o Encourage to use funds for IPM to get rid from pest infestation in the crop lands

and Environment Specialist

trained on best management of fund

-Asses the use of fund in respect with ensure the Environmental compliances in utilization of this fund.

- #/% of Group and or Individual fund utilization plan activity (total and Environmental compliances- Yes or Not numbers)

Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture (Capturing rainwater or diverting other

216.3(a)(2)(iii) o Loss to aquatic ecosystem by creating stagnant water in flowing channels, loss to biodiversity, or implementing interventions in ecologically protected areas

o Develop and use environmental screening checklist before commencing construction

o Confirm natural over-flow of channel water

o Protect reservoir from contamination o Train communities on safe use of

water reservoir o Promote fish production such as

Food security and livelihood Manager Environment specialist

# of water structures will comply with environmental compliance % of reservoirs

Annually

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Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

surface water to create temporary water reservoirs or ponds)

o Loss of top soil and water pollution due to sedimentation and run-off from irrigation schemes

o Risk of increased cases of malaria

o Risk of increased cases of cholera, dysentery and typhoid

o Impact on downstream users who may be deprived of water or subject to pollution

Tilapia Nilotica to reduce mosquito population

o Ensure low height (not more than 1m) of barriers to allow natural over-flow of water for continued access by downstream users

protected

Activity 2.2.2: Promote the use of improved sanitation technologies and systems

216.3(a)(2)(iii) o Poor sanitation can pollute surface water, as rain washes refuse into rivers and streams

o There may also be a significant risk of groundwater contamination which can be transported to shallow Wells or nearby surface water sources. A poorly designed latrine may also serve as a breeding ground for disease-carrying vectors

o Refuse disposed of in storm drains may cause blockages and

o Encourage the use of lined pits to prevent contamination of water sources.

o Ensure construction or promotion of construction designs are area appropriate, taking into consideration the high water table, and dense population. Recommendations published by the GOB DPHE, on pit latrine installation or ring slab latrines will be followed, including ensuring that they are at least 30 feet from shallow hand tube wells (depth 240 feet).

o Promote lime or ash to kill fecal bacteria

o Raise awareness on fecal management and disposal of solids through posters, leaflet and flip chart, courtyard meeting, relevant

DRR Manager; Environment Specialist

# of participants trained % of HHs who use lined pits

% of HHs who use lime or ash for killing fecal bacteria % of HHs who applied training knowledge on production of materials (e.g., sanitation slabs) out of

Quarterly

Annually

Annually

Page 55: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

encourage fly and mosquito breeding

video documentary as well as established outlet of the toilets into the safe distances

o Reinforce the need to clean the toilets, water containers and tippy taps regularly

o Work with private companies to source WASH materials, including replacement parts, and encourage development of rural sanitation marts

o Support training for HHs on production of materials (e.g., sanitation slabs), and on installment and repair

total trained

Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure

216.3(a)(2)(iii) o Potential negative impacts include the contamination of ground water, soil erosion, and consumption of unsafe water if standards and design are not maintained properly

o Adverse impacts on the environment and people’s health may be elevated if the water points are not maintained and operated well.

o Using pesticides may cause surface water pollution due to

o Train communities to protect water sources from contamination through use of fencing and/or covering

o Test water for arsenic and other requirements before installation of water retention structures

o Explore rainwater harvesting possibilities and initiate rainwater harvesting where appropriate

o Train communities to reduce the risk of pesticide contamination of surface water following USAID/Bangladesh 2015 Programmatic PERSUAP allowed pesticides training

DRR manager

Environment Specialist

% of communities that adopt water protection practices such as fencing, covering etc.

Annually

Page 56: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

farming activities o Contamination of

water due to poor construction practices

Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising

216.3(a)(2)(iii) o The geo-spatial mappings are not anticipated to have any direct negative impact on the environment.

o Activity 1.1.1, including on-farm NRM, alternatives to jhum cultivation, and promotion of innovative risk-reduction solutions on demonstration plots which will have negative affect to the environment

o Under Activity 1.1.1, SAPLING will work with direct project participants to promote sound on-farm NRM implementation and alternatives to jhum cultivation that will serve as models for the community at large.

o All NRM and alternatives to jhum cultivation with direct project participants should follow mitigation measures under Activity 1.1.1. Any risk-reducing solution implemented on a demonstration plot should also follow mitigation measures for demonstration plots

o SAPLING will ensure the appropriate training is provided to DMC members in NRM activity implementation and on jhum cultivation alternatives.

Technical Advisor (DRR) & Environment Specialist

# of participants trained on NRM

#/% of trained participant practiced NRM technology as 1st time

Quarterly

Page 57: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Program Activities

22 CFR Citation

Potential Adverse Impacts and Risks Recommended Mitigation Measures Responsible

Parties

Monitoring Schedule

Indicators How Often

Activity 3.2.6: Facilitate funding of government approved mitigation projects from community DRR plans, using project, community and government contributions

216.3(a)(2)(iii) o Land use changes, effects on water quality, changes in farming practices and socio-cultural changes

o Increases in erosion and sedimentation, changes in vegetation cover, water pollution and water logging

o Deforestation and loss of biodiversity

o Develop and use a checklist to examine the suitability of proposed constructions with regard to physical, biological, and socio-economic considerations

o Proper positioning of construction sites and adherence to best engineering practices

o Worker health and safety concerns can be addressed through proper training, adhering to safety procedures and ensuring the use of protective clothing and equipment

DRR manager Environment Specialist

% of improvement /construction sites applying appropriate mitigation measures

% of sites practicing required health and safety per type of site

Annually

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Annex 2: Environmental Awareness/screening Checklists-Site Visit Forms

1. Good Aquaculture Practices Awareness Checklist Relevant for: Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: % of producers trained applying GAP

To be completed during site visit. Awareness of GAP can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

GAP Check ( ) Comments/Recommendations Yes No

Practicing key disease and waste management techniques?

If yes, list practices: Practicing positive traditional techniques?

If yes, list practices:

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Fertilizer amounts are correct for size of pond and number of fish?

Supplementary feeding amounts are correct for number of fish?

Water pH is tested?

Name of Evaluator: Signature:

2. Hand-weaving and handicraft awareness checklist Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: Evaluate percentage of participants who are reusing wastewater related to what they produced out of total trained participants who received training on environmental management practices like re-using wastewater To be completed during site visit. Monitor awareness sessions for environmental management practices like re-using wastewater, appropriate discharge, etc. can be demonstrated through oral dialogue or observation of practices in operation.

Page 60: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Hand-weaving and Handicraft Check ( ) Comments

/Recommendations Yes No

Practicing appropriate discharge techniques?

If yes, list practices (how the waste material disposed of):

Practicing natural dyes instead of chemicals?

If yes, list practices:

Practicing PPE (hand gloves, musk, glasses etc.) during using of chemical dyes?

Participant received training in waste water management?

If Yes, list trainings date:

Name of Evaluator: Signature:

Page 61: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

3. Soil Fertility and Erosion Control Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: # of hectares under improved technologies or management practices as a result of USG assistance

This checklist will evaluate total decimal of land attained soil erosion control through Sustainable Land Management (SLM) practices To be completed during site visit. Awareness of SLM practices can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Soil Fertility and Erosion Control

Check ( ) Comments/Recommendations Yes No

Practicing SLM techniques?

If yes, list practices:

Practicing Integrated Pest Management to get rid of pest infestation?

If yes, list practices:

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Practicing safe use of pesticides during application to crop land if use chemical pesticides in the crop field?

Participant received training in IPM practices and safe use of pesticides management?

If Yes, list trainings date:

Name of Evaluator: Signature:

4. Small Animal Husbandry Types of animals: _____________________ Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE indicators:

x % of farmers who applied knowledge after receiving training on disease control of livestock x % of farmers who clean poultry and goat/pig rearing hut and shed regularly x % of farmers who disposal of poultry and pig/goat fecal properly x % of farmers who dumping of disposal of Solid infectious waste properly

To be completed during site visit. Awareness of environmentally friendly practices can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Small Animal Husbandry Check ( ) Comments/Recommendations Yes No

Page 63: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Cleaning of poultry and goat/pig rearing hut and shed regularly?

If yes, please check the shed:

Disposal of poultry and pig/goat fecal properly?

If yes, check the disposal site:

Controlled of odors, insects and mosquito breeding grounds around the poultry and goat/pig rearing shed?

If yes, check the shed

Maintained regular vaccination?

Practices diversified feed items and initiate fodder cultivation?

If yes, make a short note

Page 64: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

Received training on cleaning of poultry/goat sheds; disposal wastes into the safe disposal sites, controlling odor, insects and mosquito breeding around the poultry and goat/pig rearing farm/shed and as well as composting manure?

If Yes, list of training with dates

Name of Evaluator: Signature:

5. Environmental Screening Checklist for Demonstration Plots Relevant for

Activity 1.2.1: Promote Homestead Food Production (HFP) IEE indicator: % of farmers who applied improved technologies or management practices as a result of USG assistance

To be completed during site selection before commencing demonstration Date of site visit: Community or GPS Coordinates:

Name of producer:

Environmental Screening Checklist Check ( ) Comments Yes No Environmentally conscious design 1.0 Topographic, Hydrologic and

Soil condition?

1.1. Is there any water sources within 30 m from the site?

1.2. Is there any livestock shed/farm or households within 30m from the site?

Page 65: Environmental Mitigation and Monitoring Plan · degree of professionalism, prepared by: the project Environment Specialist, Md. Kamrul Hasan Bhuiyan under direction of COP Treena

1.3 What types of soil texture existing in the plot?

Porous?

Dense?

1.4: Is there any Ecological Critical Area near the potential plot?

2.0 Type of demo plot? 2.1. Open field?

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2.2. Bund of aquatic resource?

Note: if 1.1; 1.2 and 1.4 answers are ‘yes’ the plot will be disallowed for demonstration; if 2.2 answer is ‘yes’ plot will be conditionally allowed for demonstration Name of Evaluator: Signature:

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6. Environmental Screening Checklist for Water Capture Ponds Relevant for:

Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture Indicator: # of checklists filled To be completed during site visit. All answers, except for those in bold text, should be answered with “no” to meet the IEE condition. If the answer is yes to any of the questions, other than those in bold text, the evaluator should write down corrective measures recommended for the water capture pond operator.

Date of site visit: Community or GPS Coordinates:

Name of producer:

Environmental Screening Checklist Check ( ) Comments Yes No Environmentally conscious design

1. Does the pond have an outlet?

1.1. If yes to question 1, does the drainage to a natural body of water?

1.2. If yes to question 1, is there evidence of erosion along the drainage outlet?

1.3 If yes to question 1, is there evidence of standing water in the drainage canal?

1.4 If yes to question 1, can culture fish escape through the outlet?

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2. Is there a pond inlet?

2.1. If yes to question 2, does the water flow directly into pond without a sediment trap?

2.2. If yes to question 2, is there evidence of contamination sources within 30 m of the pond inlet (e.g. household dump sites, livestock pen, evidence of open defecation)

3. Flood prone area?

3.1. If yes to question 3, based on historical memory of floods heights, can the fish be swept into natural bodies of water?

Mosquito mitigation Is there vegetation growing in the water?

Is the pond empty of fish?

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Is there standing water around the pond? (assuming that it has not just rained)

Hazard conscious site selection

Are there human or livestock habitations directly below the pond embankments?

Name of Evaluator: Signature:

7. Environmental Screening Checklist for small scale sanitation activities Relevant for

Activity 2.2.2: Promote the use of improved sanitation technologies and systems IEE indicator: % of participants who use lined pits To be completed during site visits before construction. Awareness of Environment friend practices can be demonstrated through oral dialogue or observation of practices in operation. If the answers ‘Yes’ latrine site will be disallowed for construction. Date of site visit: Community or GPS Coordinates:

Name of producer:

Environmental Screening Checklist

Check ( )

Comments Yes No

Environmentally conscious design

1. Is there an open‐bottom pit latrine or septic soak away within 30m of a shallow well, stream or pond

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providing drinking water?

2. Are nearby

surface waters overgrown with aquatic plants/algae?

3. Are children getting water‐borne illnesses more frequently and/or more severely than in the past?

4. Is there standing or stagnant water around latrines?

5. Has drinking water from sources nearest the latrine/toilet become off‐color or developed a bad smell or taste?

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Name of Evaluator: Signature:

8. Environmental Screening Checklist for small scale sanitation activities Relevant for

Activity 2.2.2: Promote the use of improved sanitation technologies and systems IEE indicator: % of participants who use lime or ash for killing fecal bacteria After construction. To be completed during site visits after construction. All answers, except for those in bold text, should be answered with “no” to meet the IEE condition. POTENTIAL PROBLEMS. A “YES” answer to any of the following indicates that an environmental concern MAY exist; follow‐up is required. Notify the Chief of Party or concern people (Manager-MCHN).

Date of site visit: Community or GPS Coordinates:

Name of producer:

Environmental Screening Checklist Check ( ) Comments Yes No Environmentally conscious design 1. Do latrines seem

abandoned/overgrown/unused?

2. Are human feces evident in nearby field or brush?

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3. Is there overflow or seepage around latrines or septic tanks?

4. Are insects able to freely enter and leave the pit or tank?

5. Are handwashing stations lacking? 6. Is water or soap missing at handwashing

stations?

7. Are latrine waste bins being dumped near/around the latrine?

8. Is pump‐out or other waste disposed off‐site in an uncontrolled manner?

9. Are specific groups such as women, young children, or particular ethnic or

religious minorities) refusing to use latrines?

10. Do the latrines smell notably bad? 11. Are there complaints of bad smells around

latrines?

Name of Evaluator: Signature:

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9. Safe Water Accessibility Relevant for Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure

IEE indicator: % of communities that adopt water protection practices such as fencing, covering etc To be completed during site visits. Awareness of Environment friend practices can be demonstrated through oral dialog or observation of practices in operation. PROBLEMS: A “YES” answer to any of the following indicates an environmental deficit in activity design or management. For USAID‐funded activities, corrective action will be required. Notify the Chief of Party and the Program Manager. Date of site visit: Community or GPS Coordinates:

Name of producer:

Environmental Screening Checklist Check ( ) Comments Yes No Environmentally conscious design 1. Is a tank or well supplying water for domestic use

uncovered?

2. Is there stagnant water around the water supply point?

3. Arsenic or fecal contamination tested regularly? If yes, check the results or collect copies 4. Do livestock share the water supply point?

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5. Is community practicing rain water harvesting?

If yes; how collect rain water? 6. Is there soil erosion in the vicinity of the water supply

point?

7. Is water leaking from tanks/pipes/supply points?

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8. Are wells going dry (seasonally) at the inspection site

or in the surrounding area that did not do so in the past?

9. Are children getting water‐borne illnesses more frequently and/or more severely than in the past, and are these children drinking from a USAID‐provided water source?

10. Taste the water. Does it taste bad or salty? Are users complaining of a bad taste?

11. Look at & smell the water. Is it off‐color? Is there sediment? Does it smell bad? Are users complaining of any these issues?

Selected Water Quality Standards for Human Health* WHO, Guidelines for Drinking‐Water Quality (3rd Edition), 2006

Arsenic < 0.01 mg/L (10 ppb) Lead < 0.01 mg/L Total Coliforms not detectable in any 100mL sample Copper < 2 mg/L Nitrate (as NO3) < 50 mg/L Nitrite (as NO2) < 0.2 mg/L for long‐term exposure Fluoride < 1.5 mg/l

Name of Evaluator: Signature:

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Annex-3: Good Aquaculture Practices (GAP) GAP will comply with the following best management approaches for aquaculture: x Use proper slopes and compaction to minimize erosion potential on embankments. x Design discharge structures and canals to prevent erosion due to impact of water or

scouring due to excessive water velocity. x Provide vegetative cover on embankments and above water slopes of canals to prevent

erosion. x Provide grass cover on watersheds and gravel on farm roads and tops of embankments to

prevent erosion. x Position aerators to prevent erosion of insides of embankments and pond bottoms by

aerator-induced water currents. x Do not leave the drain open in empty ponds to prevent rainfall erosion and discharge of

suspended solids. x Do not allow livestock to walk on pond embankments or to wade in ponds. x Do not remove sediment from ponds and place in spoil piles on embankments of

surrounding area; use sediment to repair pond embankments or dispose of it in a responsible manner.

Boyd (2003) also provided a list of GAP that could be adopted to minimize nutrient loads in aquaculture effluents and lessen the likelihood of eutrophication in receiving water bodies. The recommended GAPs include: x Use fertilizers only as needed to maintain phytoplankton blooms. x Select stocking and feeding rates that do not exceed the assimilation capacity of ponds. x Feeds should be of high quality, water-stable, and contain no more nitrogen and

phosphorus than necessary. x Apply feeds conservatively to avoid overfeeding and to assure that as much of the feed is

consumed as possible. x Do not use water exchange or reduce water exchange rates as much as possible. x In intensive aquaculture, apply enough mechanical aeration to prevent chronically low

dissolved oxygen concentration and to promote nitrification and other aerobic, natural water purification processes.

x Provide storage volume for heavy rainfall to minimize storm overflow. x Deep water release structures should not be installed in ponds, for they discharge lower

quality water from near pond bottoms. x Where possible, discharge pond draining effluent through a settling basin or a vegetated

ditch. x Reuse water where possible.

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References i Ministry of Planning (undated) Environment, Forestry and Biodiversity Conservation, Background Paper for the Seventh Five Year Plan.

Accessed December 2015 http://www.plancomm.gov.bd/wp-content/uploads/2015/02/11b_Environment-Forestry-and-Bioderversity-Conservation.pdf

ii http://gemini.info.usaid.gov/repository/pdf/49021.pdf; iii http://www.frs-bd.com/ iv Best Management Practices for Responsible Aquaculture; Claude E. Boyd, Chhorn Lim, Julio Queiroz, Khalid Salie, Lorens de Wet & Aaron McNevin v Muriuki, J.K., Kuria, A.W., Muthuri, C.W., Mukuralinda, A., Simons, A.J., and Jamnadass, R.H. (2014). Testing Biodegradable Seedling

Containers as an Alternative for Polythene Tubes in Tropical Small-Scale Tree Nurseries. Small-scale Forestry: Volume 13, Issue 2 (2014), Page 127-142.

vi Sogoba, N., Doumbia, S., Vounatsou, P., Bagayoko, M.M., Dolo, G., Traoré, S.F., Maïga, H.M. Touré, Y.T., and Smith, T. (2007) Malaria

transmission dynamics in Niono, Mali: The effect of the irrigation systems. Acta Tropica 101 (2007) 232–240 vii Maheu-Giroux, M., Casapí, M., Soto-Calle, V.E., Ford, L.B., Buckeridge, D.L., Coomes, O.T., and Gyorkos, T.W. (2010) Risk of malaria

transmission from fish ponds in the Peruvian Amazon. Acta Tropica 115 (2010) 112–118

viii Howard, A.F.V and Omlin, F.X. (2008). Abandoning small-scale fish farming in western Kenya leads to higher malaria vector abundance. Acta Tropica 105 (2008) 67–73 ix Parker, A, Carlier, I. (2009), National regulations on the safe distance between latrines and water points. Draft version. DEW Point.

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Attachment F: Face sheet for Food for Peace Environmental Status Report

USAID / Bangladesh

Activity/Project Title: Sustainable Agriculture and Production Linked to Improve Nutrition Status, Resilience and Gender Equity (SAPLING)

Contract/Award Name(s) & Number(s) (if known): AID-FFP-A1500010

Geographic Location (Country(ies))/ Region/Global: Bangladesh/Asia Operating Unit(s): DCHA Food for Peace

ESR Year: 2017 IEE Number: 49021

IEE Link: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/49021.pdf Amount of Dollar Funding Requested in the PREP: $ Amount of Commodity: $ Life of Award (LOA): $ $28,777,000

Project Start and End Dates: September, 2015 to September 2020

ESR Prepared By: Md. Kamrul Hasan Bhuiyan; Environment Specialist- SAPLING Project

Date Prepared: January 17, 2017

Implementing Partner(s): Reporting due dates (if any): Recommended Threshold Determination: × Categorical Exclusion

Positive Determination

× Negative Determination With Conditions Deferral

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USAID APPROVAL OF ENVIRONMENT AL ACTION(S):

Foodfor Peace, Mission (or Regional Office, as appropriate*):

FoodforPeaceOfficer* ~ Date Oprif 4t Zo!?

MissionEnvironmenta!O: ~---Date O~. i~·~i.r Food for Peace, Washington:

Agreement Officer's Representative Date:

DCHA Bureau Environmental Officer Date: _______ _ ~~~~------

Regional Environmental Officer**----------- Date: --------

* FFPIMIR environmental officer clearance is mandatory; clearance by the FFPIMIR FFP officer is optional. **REO clearance is optional.

Erika J. Clesceri
4/19/2017
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Acronyms

SAPLING Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience and Gender Equity

AIs Active Ingredients BEO Bureau Environmental Officer CBOs community-based organizations CFR Code of Federal Regulation CHT Chittagong Hill Tracts DCHA Democracy, Conflict and Humanitarian Assistance DPHE Department of Public Health Engineering EMMP Environmental Mitigation and Monitoring ESR Environmental Status Report FFD Farmers Field Day FFP Food for Peace FY Fiscal Year GAP Good Aquaculture Practices GMO Genetically Modified Organisms HHs House-Holds ICS Improved Cook Stove IEE Initial Environmental Examination IPM Integrated Pest Management LOP Life of Project MEO Mission Environmental Officer NDw/C Negative Determination with Condition NRM Natural Resource Management PERSUAP Pesticides Evaluation Report and Safer Use Action Plan PMP Pest Management Plan RUP Restricted Use of Pesticides SBCC Social Behavior Change Communication SEFA The United Nations Secretary-General Initiative, Sustainable Energy for All SUAP Safer Use Action Plan USAID United States Agency for International Development USEPA United States Environmental Protection Agency VMF Village Model Farm WASH Water Hygiene and Sanitation WQAP Water Quality Assurance Plan

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1. Introduction: The Sustainable Agriculture and Production Linked to Improved Nutrition Status, Resilience and Gender Equity (SAPLING) program Initial Environmental Examination (IEE) submitted by Helen Keller International (HKI) was approved on September 20, 2016 by the United States Agency for International Development (USAID) Democracy, Conflict and Humanitarian Assistance (DCHA) Bureau Environmental Officer (BEO) with 13 conditions and one recommendation. HKI submitted responses to the IEE conditions on October 27, 2016 to the DCHA BEO as well as the Mission Environmental Officer (MEO). In addition, SAPLING’s Environmental Mitigation and Monitoring (EMMP) plan has been accepted with the approval of IEE and FY16 Environmental Status Report (ESR). As per instructions from the DCHA MEO, the updated EMMP has been included in the FY17 ESR.

2. Environmental Compliance in the Upcoming Implementation Year

A. Staffing and Expertise: The staffing and expertise plan for the upcoming year (FY17) is presented in Table 1:

Table-1: Staffing and Expertise plan for FY17 Timeline - FY17 Sl

No

Experts Roles and Responsibility No. of

Staff Q1 Q2 Q3 Q4

1 Environment Specialist

• Ensure USAID environmental compliance 22 CFR 216

• Compile and report on mitigation measure indicator data approved in the EMMP.

• Conduct screening/environmental assessment • Facilitate trainings on USAID PERSUAP and

Integrated Pest Management • Attend group meeting; workshop; • Coordinate with other FFP projects, the BEO, and

USAID Bangladesh mission • Organize farmers field days (FFDs) at

demonstration plots • Conduct courtyard sessions, workshops, field

visits, etc. as required by the project

1

2 Technical Officers (Horticulture & livestock)

• Assist with conducting environmental screenings (e.g. agricultural plots, aquaculture plots, small scale livestock activities, small scale water supply activities)

• Assist with collecting water samples for testing coliform, arsenic, pH etc.

• Assist with conducting training sessions on the safe use of pesticides and Integrated Pest Management per the USAID PERSUAP.

08

3 Field Facilitators

• Assist with conducting environmental screening • Conduct site visits for monitoring • Assist with conducting courtyard sessions at the

30

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community level 4 Environmental

Interns • Conduct site visits for monitoring • Assist with conducting environmental screenings • Assist with organizing FFDs at project supported

demonstration sites and courtyard sessions on safe use of pesticides, IPM based pest/weed management, health waste and solid waste management for raising awareness

10

5 Union Supervisor

• Supervision of courtyard sessions conducted • Supervision of environmental assessment and site

visits for monitoring

10

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Table 2 outlines the FY17 schedule for environmental training (including courtyard sessions), assessment/analyses, and monitoring. It also includes the water testing plan for FY17.

Table-2: Environmental training, assessment/analyses, monitoring, and water testing plan for FY17

FY17 (Oct 2016- Sept 2017) Activity Description

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Three-day basic training for Environmental Interns on USAID Environmental Compliance 216 CFR 22, USAID/Bangladesh mission-wide PERSUAP, and how to complete the environmental monitoring forms for monitoring project activities.

x x

One-day training for all managerial and supervisory project staff on USAID PERSUAP under Purpose-1, Activity 1.2.4: Homestead Food Production. A total of 12 batches will be trained (20/batch).

x x x Training

One-day training for Technical Officers, Field Facilitators, Supervisors and field coordinators on IPM based Pest Management Plan (PMP) followed by USAID PERSUAP under Purpose-1, Activity 1.1.1: Microenterprise development for poor and extreme poor. A total of 12 batches will be trained (20/batch).

x x x

Environmental Assessment

Environmental assessments will be carried out for project supported contour farming demonstration plots. There will be 10 plots under Purpose-1, Activity 1.2.4: Homestead Food Production.

X x

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Environmental assessments will be conducted for on-farm and off-farm activities under Purpose-1, Activity 1.1.1: Microenterprise development for poor and extreme poor.

x x x

The environmental suitability will be assessed for SAPLING supported aquaculture ponds under Purpose-1, Activity 1.1.1: Microenterprise development for poor and extreme poor.

x x X x x x x

The small scale water supply activity will be environmentally assessed for identification of serious environmental concerns for livestock, irrigation and aquaculture under Purpose-1, Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture.

x X x x x x x

Pest management activities will be assessed in the village model farms (VMF) and contour farming under Purpose-1, Activity 1.1.1: Microenterprise development for poor and extreme poor.

x x X x x x x x

An environmental assessment will be conducted of small scale poultry and livestock activities under Purpose-1, Activity 1.1.1: Microenterprise development for poor and extreme poor.

X x x x x x

An environmental assessment will be conducted for small scale safe water supply activities under Purpose-2, Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure.

x x X x x x x x

Water Testing

Water quality tests will be conducted for safe water supply activities under Purpose-2, Activity 2.2.3: Increase access to safe water through appropriate water supply

x x x x x

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technologies and infrastructure. SAPLING will test water pH levels before starting aquaculture activities since because fish lifecycle requires specific acidity levels under Purpose-1, Activity: 1.1.1 Microenterprise development for poor and extreme poor.

x X x

Environmental Monitoring

Environmental routine monitoring will be conducted for field level activities which are considered as Negative Determination with Condition (NDw/C) in the approved IEE.

x X x x x x x x

Courtyard Sessions for awareness raising

Courtyard sessions may be prepared and facilitated at the community level regarding: • Safe use of pesticides followed by

USAID/Bangladesh mission wide PERSUAP

• IPM based pest management following USAID-PERSUAP

• Soil erosion and fertility controls by judicious use of fertilizers and identification of counterfeit fertilizers

• Management of water structures • Solid waste management

x X x x x x x x

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Budgeting:

The PREP budgets for environmental compliance resources is integrated with program activities. As such, most of the environmental assessments, including those for project supported demonstration plots, aquaculture plots, VMF, contour farming, water access points for livestock and aquaculture, pest control activities, and courtyard sessions and training for staff capacity building for monitoring environmental issues, are budgeted under Purpose-1: Increased equitable access to income and nutritious foods for both males and females. Environmental assessments for WASH and improving access to clean water, as well as the water quality assurance plan, are budgeted under Purpose-2: Improved nutritional status of children under five years of age, pregnant and lactating women, and adolescent girls. Lastly, cash for work activities, such as small scale water diversion structures, small scale connecting road renovation, etc., are budgeted under Purpose-3: Strengthened gender equitable ability of people, HHs, communities, and systems to mitigate, adapt to and recover from man-made and natural shocks and stresses. The environmental budget is primarily covered by monetization proceeds, though some will be covered by 202(e) funds proceeds. Table 3 provides the budget for FY17 environmental compliance and climate integration.

Table-3: Budget for environmental compliance and climate integration for FY17

Detailed Line Items

Object Class Category Qty Unit Unit Amt. (US$)

Total (US$)

C.4.1 Basic training on USAID Environmental Compliance 216 CFR 22; USAID PERSUAP for environmental interns 1 Day 2,959 2,959

C.4.2 Conduct environmental monitoring 50 Day 90 4,500

C.4.3. Appoint 10 Environmental Interns for 10 months 10 No. 1,282 12,820

C.4.5 Disposal of program facilitated materials 30 Day 100 3,000 D.1.2.4.2-2 days training on USAID PERSUAP and IPM at district level, 12 batches per batch 25 participants and 2 facilitators-26

12 Training 2,661 31,932

D.1.5.2.4: SAPLING will test pH level prior to fingerling introduction as aquaculture initiation because fish lifestyle requires a specific stage of acidity

50 Samples 9 450

D.2.4.2: Cooking demonstrations- introduce Improve Cook Stove (ICS) 5 No. 128 640

D.2.8.3: Water Quality Testing for safe water supply 30 Samples 9 270

Tablets for Environmental Interns for data collection 10 No. 500 5000

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3. Progress Toward Achieving Environmental Compliance:

A. Previous Conditions from IEE or ESR: Response to previous IEE and ESR conditions and recommendations were submitted to the MEO and DCHA BEO concurrently on October 27, 2016. The BEO conditions have been clarified by HKI as follows: IEE Condition 1: HKI will need to submit the SUAP for DCHA BEO and MEO approval before pesticide related activities can commence. Issue 1: The SUAP is an important piece of environmental compliance. USAID Discussion: The DCHA BEO is pleased to note HKI’s level of compliance with the Bangladesh Mission Wide PERSUAP (2015). The BEO recognizes that HKI will be filling out a Safer Use Action Plan (SUAP). The BEO would like to request a copy of the SUAP and remind HKI that, in addition to MEO approval, the SUAP will need to be approved by the BEO.

Pesticides Safer Use Action Plan (SUAP) & Compliance Trackeri

Implementing Partner: Helen Keller International

Project: Sustainable Agriculture and Production Linked to Improved Nutrition, Resilience and Gender (SAPLING)

Initial Submission

SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

SUPPORTS ONLY PESTICIDES AUTHORIZED BY THE 2015 USAID PERSUAP Immediately

Develop pesticides inventory and review for Class I chemicals; Deadline: January 31, 2017 Responsible: Environmental Specialist

Underway 1 Inventory pesticides supported and ensure NO SUPPORT for Class I chemicals.

No Class I chemicals will be used under SAPLING.

Review inventory annually (in October). Responsible: Environmental Specialist

2 Ensure that Class I fumigants, as approved in this PERSUAP, can only be used by, or under supervision of, a certified pesticide

No Class I fumigants will be used under SAPLING.

Verify annually (in October); Responsible: Environmental Specialist

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

applicator. 3 Ensure that Restricted

Use Pesticides (RUPs), as classified by United States Environmental Protection Agency (USEPA), can only be used by, or under supervision of, a certified pesticide applicator.

No RUPs will be used under SAPLING

Review of RUPs annually (in October); Responsible: Environmental Specialist

4 Ensure that veterinary use of pesticides can only be provided by trained veterinary workers

No veterinary pesticides used under SAPLING

Verify annually (in October); Responsible: Environmental Specialist

List of PERSUAP-allowed pesticides and AIs used/recommended by project will be distributed to project field staff as part of compliance training; Deadline: January 2017; Responsible: Environmental Specialist

Underway 5 Distribute copies of the list of allowed Active Ingredients (AIs) with matching commercial product names and list of cancelled products to all project field extension staff.

List will be prepared and distributed to the project field staff

Distribute updated list annually (in January) Responsible: Environmental Specialist

Underway

As soon as possible: Cross-check all informational training materials with the approved list; Deadline: January 2017; Responsible: Environment Specialist

Underway 6 Assure that USAID-funded pesticide support is limited to ONLY PESTICIDES APPROVED BY PERSUAP. Continue verification throughout the life of the project.

Training materials and content currently recommend only approved pesticides.

Verify annually (in January) Responsible: Environmental Specialist

Underway

Pesticide technical assistance and use must be governed by a set of locally adapted IPM-based pest management plans and observe enumerated use restrictions. For agricultural activities these will be crop-and-pest specific. By 2017

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

7 Using information in PERSUAP Annexes A and B, adopt/develop crop and pest-specific Integrated Pest Management (IPM)-based pest management plans (PMPs). For chemical controls, PMPs must include use restrictions specified in Annex B pesticide profiles. (E.g. no use near surface waters.)

Currently under development

Complete IPM-based PMPs; Deadline: March 2017; Responsible: Environment Specialist and Manager, Food Security and Livelihood (FS&L)

Underway

8 Translate PMPs into crop-specific field reference guides or posters for farmers to anticipate and manage pests.

Will begin after completion of PMPs

After finalization of IPM-based PMPs, develop initial set of field reference guides or posters for farmers; Deadline: June 2017; Responsible: Environment Specialist and Manager (FS&L)/ Social and Behavior Change Communication (SBCC) specialist

By 2017 First-time training to be conducted for project staff; Deadline: during Quarter 4 of FY 2016 (June to September) Responsible: Environmental Specialist and Manager (FS&L)

9 Provide first-time training to appropriate project staff, partners and participants in PMPs; Provide refresher training annually.

PMP under preparation

Annual refresher training; Deadline: February 2017; Responsible: Environmental Specialist

Underway

By 2017 10 Require and enforce

PMP implementation in situations where the project has direct control over pesticide use.

N/A – there are no situations currently where the project has direct control over pesticide use

N/A N/A

Integrate PMP approach into current training modules and extension materials; Deadline: September 2017; Responsible: Environmental Specialist and Manager (FS&L)

11 Require and enforce that field extension under direct project control be PMP based.

No action taken to date – awaiting completion of PMPs

Incorporate use of PMPs into Farmer Leader trainings and Farmer Producer Group courtyard sessions as part of training on improved agricultural practices; Deadline: September 2017; Responsible:

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

Environmental Specialist and Manager (FS&L)

Implement PMPs for all project demo plots; Deadline: Begin in third quarter of FY 2017 following training and roll-out conducted in second quarter; Responsible: Environmental Specialist assisted by Technical Officer (Horticulture & Marketing)

12 Where project control over extension or agricultural practice on the ground is less than complete, promote and support PMPs to the greatest possible extent.

No action taken to date – awaiting completion of PMPs

Promote PMPs as part of skill development training provided to project staff and Lead Farmers; Deadline: Begin in Quarter 3 of FY 2017; Responsible: Environmental Specialist, Manager (FS&L)

Ongoing over Life of Project (LOP) 13 Modify PMPs over LOP

based on ground- truthing /Field experience.

Action to be taken after introduction of PMPs

Collect feedback from field extension agents and modify PMPs accordingly; Deadline: October 2017; Responsible: Environmental Specialist, M&E manager

For all target activities, appropriate project staff and participants must be trained in safer pesticide use and pesticide first aid.

Compile product labels and MSDS for all pesticides in project pesticide inventory; Deadline: February 2017; Responsible: Environmental Specialist

Underway 14 Ensure availability of product label and Material Safety Data Sheets (MSDS). For all products in use, project personnel must obtain and review the product label and MSDS to ensure that pesticide users are aware of potential hazards and are undertaking all measures to minimize risks to human health and safety and to the environment.

Training and courtyard sessions will include content and guidance on the review of product labels

Introduce use of MSDS in trainings and courtyard sessions; continue training on how to read and interpret product labels; Deadline: Ongoing for the LOP Responsible: Environmental Specialist and Manager (FS&L)

15 Ensure that, for all projects that provide support for procurement or use, or both of seed treated with pesticides, training in handling

Training and courtyard sessions will include content and guidance on handling of dressed seeds

Ensure content on handling of dressed seed is updated and included in training materials; Deadline: February 2017 Responsible: Environmental Specialist

Underway

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

dressed seeds is provided.

Continue providing training on handling of dressed seeds as part of training and courtyard sessions; Deadline: Ongoing for the LOP Responsible: Environmental Specialist and Manager (FS&L)

16 Ensure that training is provided to relevant staff of all projects that provide support for treatment of stored commodities.

N/A- SAPLING is not involved with stored commodities

N/A N/A

Ensure content on post-harvest use of pesticides is updated and included in training materials; Deadline: February 2017 Responsible: Environmental Specialist

Underway 17 Ensure that training of trainers (TOT) is provided to relevant staff to support participants of all projects that provide support to farmers in post-harvest use of pesticides.

SAPLING will provide TOT for FFs and Technical Officers to create master trainers for supporting project participants (farmers) in post-harvest management and courtyard sessions will include content and guidance on post-harvest use of pesticides - emphasizing the use of biological pesticides like neem leaves and nishinda leaves for grain storage.

Provide training on post-harvest use of pesticides as part of training and courtyard sessions; Deadline: Ongoing for the LOP Responsible: Environmental Specialist and Manager (FS&L)

18 Ensure that TOT training is provided to relevant staff to support participants of all projects that provide support to fish farmers using pesticides.

SAPLING will provide TOT to FFs and Technical Officers to create master trainers for supporting fish farmers (project participants) on using pesticides especially use of Rotenone for removing predators

Provide training on using pesticides in fish farming as part of training and courtyard sessions likewise; ensuring the safe use of rotenone, e.g., using personnel protective equipment (PPE) during application, would be added to the training manual on Good Aquaculture Practices (GAP). Deadline: Ongoing for the LOP Responsibility: Environment Specialist and Manager (FS&L)

19 Ensure that TOT training is provided to relevant staff to support participants of all projects that provide support to health service activities that use disinfectants and

SAPLING will provide TOT training to Maternal Child Health and Nutrition (MCHN) specialists for health service activities that use disinfectants and pesticides

Provide training on using of disinfectants and pesticides in health services as part of training and courtyard sessions; Deadline: Ongoing for the LOP Responsibility: Manager (MCHN); Environment Specialist and Technical Advisor of Eye and

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

pesticides. Tropical Diseases 20 Ensure that if livestock

projects introduce veterinary pesticide use, they must inform the Environmental Officer for approval

No veterinary pesticides will be used under SAPLING

Deadline: Verify annually; Responsible: Technical Officer (animal husbandry) and Environmental Specialist

N/A- no veterinary pesticides currently used

21 Develop a Training Plan for Pesticide Safe Practices and IPM for project staff and participants, including an annual refresher training at least.

Training Plan to be developed as part of SAPLING Detailed Implementation Plan (DIP)

Deadline: Update plan on a quarterly basis; Responsible: Environmental Specialist and Manager (FS&L)

22 Develop or source curricula conforming to required training elements specified in Annex C of the 2015 USAID PERSUAP.

Project will be sourced* and developed a set of training materials on safer pesticide use *includes materials developed by Croplife Asia and adapted by the USAID Ag Extension and USAID Ag Inputs Projects

Review existing materials and ensure that they conform to required training elements specified in Annex C; Deadline: February 2017; Responsible: Environmental Specialist

Underway

Training on safer use of pesticides to be provided to selected local service providers or extension agents; Deadline: Quarters 3 and 4 of FY16; Responsible: Environmental Specialist and Manager (FS&L)

Refresher Training for all relevant project staff; Deadline: To be conducted in January 2017 and January 2018; Responsible: Environmental Specialist

Underway

23 Implement training plan, providing first time training to all relevant staff and beneficiaries within 6 months.

Initial training on safer pesticide use will be provided by fourth quarter of FY16 to relevant project staff

Provide training / share information on safer use of pesticides at Farmer Field Days, farmer courtyard sessions, and Lead Farmer trainings; Deadline: on going for the LOP Responsible: Environment Specialist

To the greatest degree possible, all projects must require use & maintenance of appropriate PPE – as well as safe pesticide purchase, handling, storage and disposal practices.

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

24 If carbamate or organophosphate-class pesticides are used extensively, follow procedures for baseline testing for cholinesterase inhibition, and establish a periodic cholinesterase monitoring schedule when necessary.

N/A – There is no extensive use of carbamate or organophosphate-class pesticides under SAPLING.

N/A

25 Implement/observe core risk mitigation measures (PPE and other precautions) identified in the summary section of each extended pesticide profile. Where control is less complete, take all practicable measures to support and promote implementation of these measures.

Beneficiaries are given information on PPE as part of training/ courtyard sessions on safe use of pesticides

Continue to provide information on PPE as part of training and courtyard sessions as per training calendar; Environmental Specialist and Manager (FS&L)

26

Whenever providing, supporting or recommending pesticides for use, assure that appropriate PPE is available and, to the greatest degree possible, require its use.

SAPLING, in coordination with the Nobo Jatra and SHOUHARDO III Projects, will confirm that appropriate PPE is available in the FFP zone; SAPLING cannot require use of PPE as actions by participant farmers are outside its control

Continue to promote farmer use of PPE, and share information on local availability, as part of beneficiary training and information sessions Environmental Specialist & Manager (FS&L)

27 Whenever directly using, procuring or supplying pesticides, ensure that quality application equipment is available and local capacity for its available and maintained.

N/A- project does not directly use, procure or supply pesticides

N/A

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

28 To the greatest degree possible, enforce good disposal and clean-up practices.

N/A – project does not have direct control over pesticide use by participants and thus cannot enforce good disposal and clean-up practices

N/A

29 For directly supported pesticide stores, assure that Food and Agriculture Organization (FAO) Best Management Practices are met. (See Annex C). For directly supported pesticide transport, ensure that minimum practices specified in Annex C are met.

N/A- currently no involvement for directly supported pesticides stores or transport to the participant level

N/A

Projects must follow safety restrictions and precautions for all target activities 30 People who are not

wearing PPE should not enter pesticide treated areas during Restricted Entry Intervals (REI) to perform tasks that involve contact with pesticide treated surfaces. Each pesticide label specifies a REI usually ranging from 12 to 72 hours.

N/A – project staff do not directly use or apply pesticides under this scenario; project does not have direct control over pesticide use by project participants

N/A N/A

31 Warning signs should be posted to warn people in advance about pesticide application and REI.

N/A – project staff do not directly use or apply pesticides as part of project activities

N/A N/A

32 Products that are suspected to have potential to cause harm to unborn child, such as Dimethoate and Mancozeb, will not be handled and applied by pregnant women. Pregnant women should not enter treated areas during application and REI.

N/A – project staff do not directly use or apply pesticides as part of project activities; project does not have direct control over pesticide use by project participants

N/A N/A

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SI Required compliance (mitigation) measure

Initial compliance status (if not known, indicate)

Actions planned to achieve & maintain compliance (with deadlines & responsible party)

Status of compliance actions

Update and expand content on PHI in project training materials; Deadline: March 2017 Responsible: Environment specialist and manager (FS&L)

Underway 33 Pre-harvest interval (PHI) is the time required between the last application of pesticides and the safe harvesting of edible crops for immediate consumption. Farmers will be trained on the importance of adhering to the PHI stated on the label to ensure no chemical residues are found on harvested crops.

Information on PHI is currently provided to farmers as part of project-sponsored training and information sessions Continue providing training to

beneficiary farmers; Deadline: Ongoing for LOP Responsible: Environment specialist and manager (FS&L)

Projects must be systematic in their pesticide related record-keeping and monitoring 34 Pesticide efficacy in

demonstration plots must be evaluated

SAPLING will develop pesticide information data sheet for pesticides efficacy and evaluation

Deadline: As per crop season; Responsible: Environment Specialist; Upazila coordinator, union supervisors & Field facilitators

35 Any evidence of pesticide resistance development must be tracked and reported

Information tracked by pesticides data sheet/ monitoring form

Deadline: As per crop season for demonstration plots; Responsible: Environment Specialist

Flow-down requirements 36 Prime contractors must

write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use.

Pending Update sub-award agreements with CRS and Caritas to include pesticide compliance requirements; Deadline: March 2017; Responsible: Environmental Specialist and Chief of Party (COP)

Underway

Pesticide registration status in Bangladesh and USEPA must be updated annually.

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IEE Condition 2: HKI must include Rotenone in their SUAP and comply with the PERSUAP for all pesticide related activities. Issue 2: The application of Rotenone. Discussion: In the IEE, HKI mentions the use of Rotenone. HKI must comply with PERSUAP and SUAP for the Rotenone for this activity. Rotenone was approved in the Bangladesh Mission Wide PERSUAP (2015). However, no mention is made of Rotenone activities complying with the PERSUAP. The PERSUAP must be applied to all activities including aquaculture. HKI must include Rotenone in their SUAP (see Condition 1) to be submitted to the DCHA BEO.

Rotenone has been added in the SUAP (see line 18 in the table above) as per IEE Condition 2. IEE Condition 3: HKI must provide greater detail on the scale of the Activity 1.2.4, especially related to the irrigation activities, to the DCHA BEO within one month of today (09/20/2016). Issue 3: Lack of detail regarding irrigation activities. Discussion: For the Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture (Capturing rainwater or diverting other surface water to create temporary water reservoirs or ponds), not enough details were provided regarding the scale of the livestock activities. Given the sensitivity of this activity, HKI must assess if the scale of the irrigation activities warrants a Positive Determination classification pursuant to 22 CFR 16.3(a) (2) (iii). Activities that receive a Positive Determination will require further environmental analysis such as a Scoping Statement and Environmental Assessment (EA).

! Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture

(Capturing rainwater or diverting other surface water to create temporary water reservoirs or ponds):

Water scarcity is common throughout all Upazilas of Bandarban District. Deforestation, siltation in local rivers, introduction of high water consumption forest species, and to some extent the traditional farming system, all contribute to water scarcity. This problem limits community farming (where irrigation is needed) and access to water for irrigation, livestock and aquaculture. However, if water reservoirs can be created at the community level through internal or external support without interrupting the existing water flow and its sounding environment, then the community can have more water availability for irrigation, livestock rearing and aquaculture. The activities will be small scale in nature since HKI will not construct any new canals or ponds, but will instead renovate existing canals or ponds using a community development approach. Livestock activities: SAPLING will promote poultry, goat, and pig production to increase availability and accessibility of animal source foods, and nutritional messaging to encourage

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utilization. The project will aim for HH level production of 6 to 12 chickens and one pig/goat through improved rearing practices, including technical assistance to promote construction and/or maintenance of healthy poultry sheds; each broiler requires one square foot of floor space, while a layer requires two square feet of floor space, thus the size of the shed depends on number of birds to be reared. SAPLING will also promote balanced supplementary feeding, scientific hatching pots, feeding and drinking pots, and vaccinations and treatment. The project will provide technical support to participants in HFP groups for improved poultry rearing practices. It is estimated that around 10,000 HHs out of a total of 55,000 HHs participating in SAPLING will receive technical support in livestock rearing from the project over LOP.

SAPLING will provide basic participatory training on poultry-rearing techniques as well as refresher trainings to be conducted with project participant annually. Training topics will cover supplemental feeding, how to separate chicks from hens during the first 10-15 days, how to select appropriate breeds, how and when to vaccinate poultry, and improved hatching practices through using hazal (improved hatching pot). Participants will also learn how to prepare nutritionally balanced feed from locally available resources. The SAPLING technical team will develop the training curriculum and will assist Implementing Partner staff to organize and conduct the poultry rearing sessions for participants. The Technical Officers will support FFs and will also provide regular technical assistance to them as well as group members. Regular follow up visits will be conducted by FFs, while spot check visits will be conducted by the technical officers, environmental specialist and M&E team as part of overall monitoring.

HHs participating in SAPLING livestock activities will be linked with government extension services to gain access to vaccinations and disease control. Since the district Department of Livestock Services (DLS) alone does not have sufficient capacity to provide intensive support to all rural HHs, the project will create a group of livestock health workers from villagers who are interested in providing vaccination services as a micro-enterprise, subsequently developing their capacity to provide vaccines within their communities, while at the same time train them to operate as a fee-for-service private business. A total of 100 community-based vaccinators (male and female youth) will be trained across 5 Upazilas (about 20 per Upazila) with the support of Upazila livestock officers from DLS. The training will cover how to identify the vaccines, role of vaccinators, cold chain maintenance during vaccine transportation, route and administration of vaccines, handling of poultry birds, precautionary measures of vaccination, and safe disposal of all medical waste. The training will be facilitated through practical demonstrations. This service will create an opportunity and incentives for additional income and will help to sustain the vaccination service in the villages. Vaccinators will also link with the DLS for a sustainable supply of vaccines as well as technical support during the training and vaccination program at the community level. The training manual will also cover waste management, disease control, and coordination with health and hygiene activities to encourage increased hygiene and homestead environmental standards. As with any livestock activity, possible negative impacts can result from animal manure being transported from fields into water bodies through rainfall, runoff or irrigation, which can pollute local drinking water sources and spread human and animal diseases. Nutrients from manure and fertilizers can also cause nutrient loading of local water bodies, resulting in degraded water

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quality, reduced wildlife, fish and mollusk populations, and toxic algal blooms. Moreover, such reductions in water quality can impact other uses of water bodies as well, such as drinking water, sanitation, fishing, aquaculture, recreation and tourism, and other farms.ii In relation to this allowing livestock direct access to surface water sources has led to a number of environmental and health problems, such as excessive nutrient loading of surface water as mentioned. In additions, direct access to surface water also results in stream bank degradation and erosion from overgrazing and hoof traffic. Maintaining riparian vegetation is important for stabilizing stream banks and reducing sediment loads entering the stream through erosion processes. Steam bank vegetation also dissipates energy of floodwater, slows overland flow, absorbs nutrients or chemicals from crops and grazing land, and lowers water temperatures. An effective technique to protect surface water quality and stream banks and also provide a safe, reliable supply of drinking water for livestock is to create small water diversions from streams to a less environmentally sensitive area. Proper water management in and around yards where animals are being raised, including proper protection (or isolation) of agricultural drainage well inlets, is essential to guarding against surface and ground water contaminationiii. The following mitigation measure is included in the EMMP to monitor grazing land ecological conditions and to adjust stocking rates (number of livestock) as needed. Mitigation Measure: Monitor grazing land ecological conditions for small animal management. In an area that receives as much rain as the Chittagong Hill Tracts (CHT), the main concern for small ruminant livestock is that grazing patterns may allow low-utility plants to gain dominance. This occurs when small animal husbandry (e.g., goats/pigs) consume preferred plants, allowing unpalatable plants to become the dominant plant species. This shift in plant composition degrades the nutritional value of grazing areas for livestock and may affect wildlife food availability as well. The goal of monitoring plant composition is to ensure that palatable forage plants make up the majority of plant composition and are in a stable or increasing trend. This mitigation measure need only be reported on every other year after a community has joined SAPLING small animal husbandry activities. In general, if a community were to begin in the first year of the project, the monitoring plot would be reported on during years 1, 3, and 5. More frequent monitoring may likely be observing changes in weather rather than the effects of grazing of the low number of small animals. Monitoring should take place before the rainy season.

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IEE Condition 4: HKI must reclassify the Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising to a Negative Determination with Conditions and provide the DCHA BEO and Mission Environmental Officer (MEO) with appropriate mitigation measures within one month of today (09/20/2016).

Issue 4: Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising was improperly classified. Discussion: Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising was classified as a Categorical Exclusion (CE) is this IEE. However due to the scope and potential for negative environmental impacts, this activity needs to be reclassified as a Negative Determination with Conditions (ND w/C). Activity 3.2.3 will require mitigation measures for its proposed activities. The activities that require particular attention in the Environmental Mitigation and Monitoring Plan (EMMP) include: Natural Resource Management (NRM) promotion, demonstrations plots, and alternatives for jhum cultivation. ! Activity 3.2.3: Promote community strategies to address/mitigate the hazards of

environmental degradation through geospatial mapping and awareness raising- Negative Determination with Condition (ND w/C)

Dialogue with community leaders is meant to encourage a two-way exchange of knowledge and promote synergistic alternatives to practices contributing to environmental degradation that increase community hazard. It is anticipated that many on-farm solutions proposed are already covered under Activity 1.1.1, including on-farm NRM, alternatives to jhum cultivation, and promotion of innovative risk-reduction solutions on demonstration plots. Spatial maps will be provided to the Union Disaster Management Committee (UMDC) and Upazila Disaster Management Committee (DMC) for future analysis and development of strategies to improve environmental safeguards. The geo-spatial mappings are not anticipated to have any direct negative impact on the environment. This is also the case for workshops with the UDMC, Ministry of Environment and Forest, and in schools to discuss environmental practices, awareness rising campaigns on alternatives to jhum cultivation, etc. How recipients of SBCC messages act upon disseminated knowledge is outside the control of the project. However, under Activity 1.1.1, SAPLING will work with direct project participants to promote sound on-farm NRM implementation and alternatives to jhum cultivation that will serve as models for the community at large. All NRM and alternatives to jhum cultivation with direct project participants should follow mitigation measures under Activity 1.1.1. Any risk-reducing solution implemented on a demonstration plot should also follow mitigation measures for demonstration plots under Activity 1.1.1. Solutions proposed on community land should be managed by the appropriate Disaster Management Committee. SAPLING will ensure the appropriate training is provided to DMC members in NRM activity implementation and on jhum cultivation alternatives.

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A mitigation measure specific to Activity 3.2.3 will be added to the EMMP as follows: Mitigation Measure: Train DMC members on sound NRM practices and alternatives for jhum cultivation. IEE Condition 5: HKI must reclassify the Activity 1.2.3: Introduce Savings and Internal Lending Communities (SILC) to a Negative Determination with Conditions and provide the DCHA BEO and MEO with appropriate mitigation measures within one month of today (09/20/2016). Issue 5: The activity related to the Savings and Internal Lending Communities was improperly classified. Discussion: The Activity 1.2.3: Introduce Savings and Internal Lending Communities (SILC) was classified as a Categorical Exclusion (CE) in this IEE. However, due to the scope and potential indirect, negative environmental impacts, this activity needs to be reclassified as a Negative Determination with Conditions (ND w/C). The project cannot control how individuals spend their savings and lent money. However, the project can incorporate environmental messaging into this activity and thus help mitigate the potential negative environmental impacts. Since the number of people that are reached in these activities is usually very high, these activities can encourage a large number of participants to be more environmentally sensitive.

! Activity 1.2.3: Introduce Savings and Internal Landing Communities (SILC) - Negative

Determination with condition (ND w/C) SILC groups are user-owned, self-managed savings and lending groups that are accessible, transparent and flexible, offering poor HHs safe and frequent opportunities to save in the convenience of their own community. SAPLING will introduce SILC as part of the larger package of livelihood activities under Purpose 1 (Increased equitable access to income and nutritious foods for both males and females), identifying those communities who have an interest in forming SILC. This is the most relevant form of financial service delivery for poor rural HHs of CHT, as they remain out of reach from any type of formal financial services including non-government organization (NGO) microfinance services. Therefore, it is believed that this may help SAPLING project participants in CHT.

The limited presence of formal financial services, limited number of NGOs with microfinance activities, and the remoteness and poverty of CHT, particularly in SAPLING working areas, severely limits access of poor HHs to formal financial services. For financial needs, such as investment for income generating activities or other purposes, vulnerable HHs in CHT usually rely on money lenders who recoup higher than usual interest rates. As a result, many people in CHT remain in debt to money lenders for many years. Sometimes poor borrowers are obliged to sell their agriculture products to these money lenders in advance for a nominal rate instead of paying back the amount with high interest. This leads to vicious cycle of poverty over generations. SILC could be a viable strategy for poor/vulnerable HHs in CHT that offers

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accessible, transparent and flexible financial services.

Men and women from low income HHs, with a special emphasis on women-headed HHs within SAPLING working areas, who have no/minimal access to formal financial institutions will be covered under the SILC approach. This will facilitate access to affordable and appropriate financial services (savings and loans) for investment in income generating activities, thus leading to increased HH income and equitable food security. As formal financial institutes remain out of reach in most SAPLING working areas, SILC will be leveraged as a delivery platform for a broader array of financial and non-financial services, such as financial education, marketing and business skills, to equip HHs with a broader range of economic strengthening strategies. Additionally, savings through SILC will contribute to a contingency fund to support families in case of any emergency. In addition to SILC, SAPLING will also focus on access to emergency funds by encouraging participants to set up a social fund. There is no direct impact on the environment but it will have indirect effects on the environment in terms of unplanned (if there are no mitigation measures) fund utilization. A mitigation measure for Activity 1.2.3 will be added and will read as follows: Mitigation Measure: The training manual for SILC groups will cover environmentally friendly ways to utilize funds, including:

• Discourage the use of funds for any type of environmentally unfriendly and/or unsustainable agricultural practices, including tobacco cultivation.

• If funds will be used for purchasing chemical fertilizers/pesticides, then messages regarding the safe and judicial use of chemicals will be included, covering the right chemicals, right doses, right time and right method before commencing application.

• Discourage the use of funds for purchasing pesticides, including rotenone which is often used for killing predator fish species as part of aquaculture practices. Participants will be trained instead on using drying or netting instead of rotenone.

• Encourage the use funds for Integrated Pest Management to get rid from pest infestation in the crop lands

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IEE Condition 6: HKI must provide greater mitigation measures for Activity 1.1.1: Microenterprise development for poor and extreme poor households, especially with respect to solid waste production and air pollution, to the MEO. Issue 6: Microenterprise activities may contribute to unmanaged solid waste production and air pollution. Discussion: Although HKI mentions some mitigation measures for Activity 1.1.1: Microenterprise development for poor and extreme poor households, microenterprise related activities must take into account solid waste production and air pollution. USAID has developed Sector Environmental Guidelines for Micro and Small Enterprises (MSEs). Is part of these guidelines, USAID has specifically designed a guide for Mechanisms for MSEs to Control Environmental Impact. These guidelines are useful for HKI’s activities and should be applied to the activities’ mitigation measures. With respect to the solid waste, USAID also produced the Sector Environmental Guidelines for Solid Waste. HKI will need to incorporate some of the best environmental practices from these guidelines into the mitigation measures. ! Activity 1.1.1: Microenterprise development for poor and extreme poor householdsiv Mitigation Measure 1: Project participants will be trained on Community Based Management of Solid Waste This training will serve to raise awareness of and teach proper sanitary behavior, and build awareness to reduce, reuse and recycle. Mitigation Measure 2: Project participants will be trained on waste management for small animal husbandry. The training manual will include but is not limited to:

• Slurry preparation • Composting • Cleaning of goat sheds, pig huts or chicken coops • Animal feces disposal • Odor and insect (particularly mosquito) control

A review of the training manual and observation of topics included in the training manual serves to meet this mitigation measure. Mitigation Measure 3: Unwanted waste will be separated and will go to the appropriate facility. SAPLING will introduce transfer points where local waste is collected and separated before being transported to landfills or recycling facilities.

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Mitigation Measure 4: Awareness raising sessions to encourage practices to minimize public health, safety, and environmental risks. The creation or use of open dumps should be avoided where possible. If open dumps are currently being used, SAPLING will encourage participants through trainings, group sessions and courtyard sessions, to implement practices to avoid open dumps to minimize impacts on public health, safety, and the surrounding environment. Mitigation Measure 5: Train participants on environmentally sound production practices. This mitigation measure will be monitored as per the SAPLING Monitoring & Evaluation plan for Indicator 4 (FFP Indicator 10) in the Indicator Performance Tracking Table (IPTT): Number of private enterprises, producer organizations, water user associations, women's groups, trade and business associations and community-based organizations that applied improved technologies or management practices as a result of USG assistance. Improved technologies and management practices include but are not limited to:

• Waste water reuse • Use of natural dyes • Water use efficiency

Mitigation Measure 6: Training and awareness sessions on air pollution control. Air pollution control measures include:

• Use of masks and ear plugs by exposed operators • Follow special timetables (avoid community sleeping/leisure times) to reduce impact on

neighbors • Follow strict maintenance and keep equipment lubricated

Mitigation Measure 7: Coordinate with health and hygiene SBCC activities to encourage increased hygiene and homestead environmental health standards. SBCC interventions should cover human health risks associated with close animal contact. Topics should include but are not limited to:

• Washing hands (with soap if possible) at all appropriate times for children and caregivers. • Corralling animals away from sleeping quarters. • Safe animal waste disposal procedures.

The health coordinator should report to the Environmental Specialist the estimated number of individuals reached through SBCC interventions related to small animal husbandry hygiene.

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IEE Condition 7: HKI must ensure the appropriate disposal of and management of healthcare waste resulting from veterinary services, monitor the quality of veterinary pharmaceuticals, and promote best environmental practices with respect to the training of health service providers. Issue 7: The IEE does not include information regarding how the veterinary and healthcare waste will be disposed of properly.

Discussion: The IEE correctly identifies with respect to the small animal husbandry activities that the “inappropriate use of veterinary drugs and improper disposal of related medical waste could have potential negative effects on the environment”. (p 67) However in the Environmental Mitigation and Monitoring Plan (EMMP) Table, no mitigation measure is listed to mitigate against this potential adverse environmental impact. If handled, treated, or disposed of incorrectly healthcare can spread disease, poisoning people, livestock, wild animals, plants and whole ecosystems.

Healthcare waste: Currently, little or no management of healthcare wastes typically occurs in small scale facilities in Asia. Training and supplies are minimal. Common practice in urban areas is to dispose of healthcare waste along with the general solid waste or, in peri-urban and rural areas, to bury waste, without treatment, in an unlined pit. Unwanted pharmaceuticals and veterinary waste may be dumped into the local sanitation outlet, be it a sewage system, septic tank or latrine.

For healthcare waste pertaining to the veterinary activities, the HKI team must work with its implementing partners and vendors to assure, to the extent possible, that the veterinary service providers involved have adequate procedures and capacities in place to properly dispose of blood, sharps, and other hazardous waste that may result from veterinary services to livestock in the project.

For more information regarding healthcare waste, the USAID Sector Environmental Guideline for Healthcare Waste also provide valuable information, including the appropriate type of incinerators to use for different types of waste (p. 9).

Placenta Waste: For Activity 2.1.1: Train government and nongovernment health service providers including traditional birth attendants and the traditional healthcare practitioners and agriculture extension workers on Essential Nutrition Actions and Essential Hygiene Actions

(ENA/EHA) framework, the IEE makes no mention of placenta disposal and placenta pits. Given the close proximity of birth attendants and healthcare practitioners to issues surrounding proper placenta handling, the DCHA BEO would like HKI to ensure that they are promoting best environmental practices with respect to placenta disposal. For more information, Health Care Without Harm produced a Technical Specifications: Placenta Pits with best practices for placenta pit construction.

Quality of Veterinary inputs (Counterfeit pharmaceuticals): In addition to concerns regarding the veterinary waste, another concern with veterinary activities, especially with those related to

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pharmacies, is the prevalence of counterfeit pharmaceuticals on the market. This problem can dramatically impact the livelihood of rural livestock owners. Proper precautions must be in place to ensure that vendors are providing quality veterinary pharmaceuticals and eliminating counterfeit ones. Mitigation Measure: Include veterinary and healthcare waste disposal topics within the veterinary training module

The veterinary and healthcare training manual will incorporate the following training modules on health care waste managementv:

1. Solid infectious waste

• Autoclaves, incinerate/burn, or bury.

2. Blood and other infectious bodily fluids • Disinfect by adding chlorine oxide powder, dehydrated lime oxide (CaO), bleach

(sodium hypochlorite) or other disinfectant. • Pour treated fluids into a pit where they will be filtered by the soil, but will not

contaminate drinking water.

3. Sharps • Separate from other waste. Immediately after use, put in a plastic, metal, or cardboard

container that will keep liquid from leaking; cardboard containers should be lined with plastic bags.

• If possible, containers should be colored yellow and marked “SHARPS,” “Infectious waste,” “Dangerous,” or something similar, in all relevant languages.

• Burn or encapsulate the sharps when containers reach ¾ full. • If the container is to be reused, sterilize with bleach or other disinfectant.

4. Wash water and sewage

• Treat using best available treatment system. • If sewage will not be treated, disinfect wash water by adding chlorine oxide powder,

dehydrated lime oxide (CaO), bleach (sodium hypochlorite) or other disinfectant. • Pour treated liquid in a pit where it will be filtered by the soil, but will not

contaminate drinking water.

5. Placenta Pit constructionvi • Gather necessary materials, including slab, cover, lining, drainage channel (plastic

pipe), ventilation pipe with rain cover, nylon mosquito netting, fencing materials, etc. • Reinforce the bottom of the pit (concrete, bricks, stones or clay) • Reinforce the side of the pit (concrete, bricks, etc.) • Place the slab over the pit • Place a plastic (not metal) ventilation pipe in a hole in the slab. • Make a drainage channel around the pit to prevent runoff water from entering and to

protect the walls of the pit.

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6. Quality of veterinary medicine (counterfeit veterinary medicine)

• Read the product label first • Read production date and expiry date • Check the company registration no, batch no, trade mark etc. • Common disease identification and treatment procedures • Storage and disposal of medicines • Bio-safety methods

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IEE Condition 8: HKI must develop and implement a Water Quality Assurance Plan to address water contamination concerns and send the DCHA BEO copies of the geographical and Hydro geological conditions assessments and promote best environmental practices in safe water supply activities. Issue 8: Water quality assurance is not consistently addressed throughout related activities in the IEE. Discussion: Water testing: The BEO commends HKI for including illustrative water quality testing throughout their project. However, the BEO notes that there is a lack of integrated Water Quality Assurance Plan (WQAP); water pollution or water quality concerns are noted under several activities. The IEE mentions that for drinking water sources, “Test water for arsenic and other requirements before installation of water retention structures.” (p.71, 72) The BEO wishes to remind HKI that water quality levels must also meet USAID and WHO standards for all activities. More information is found in the USAID Sector Environmental Guidelines for Water Supply and Sanitation. Initial water quality testing is the responsibility of HKI, but HKI should also set in place measures to provide reasonable assurance that ongoing water quality monitoring occurs. A WQAP also develops a response protocol in case contamination is detected. A simple example WQAP can be found here. The HKI WQAP must include minimum USAID and WHO requirements, but also test for other contaminants that could be in the area that are location specific. The DCHA BEO is pleased to note that HKI is doing assessments on the geographical and Hydrogeological conditions. The BEO would like to request a copy of these assessments. Safe Water Supply: In the IEE in Activity 2.2.3: Increase access to safe water supply technologies and infrastructure, HKI mentions using that they will be working in collaboration with the Department of Public Health Engineering (DPHE) to identify and introduce safe water supply options. The IEE is unclear about the level of influence that HKI will have in the decision making process if any. The DCHA BEO would like HKI to promote best environmental practices in any collaboration with DPHE. USAID has created Sector Environmental Guidelines for Water Supply and Sanitation. Mitigation Measure: Develop a Water Quality Assurance Plan (WQAP) vii The project will undertake the following activities in conjunction with the establishment of all new water access points, or the rehabilitation of existing water access points:

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1) Initial Water Quality Testing: At the time of the installation and/or rehabilitation of the water access point, SAPLING will complete the following water quality tests: • Arsenic: In compliance with Guidance Cable State 98 108651, SAPLING will test

groundwater or surface water access points for inorganic arsenic at a level not to exceed 10 ppb (10 micrograms/liter [.01 mg/l]). Following completion of the well installation/construction phase, the new or rehabilitated well will be pumped and tested, with samples taken once water that is representative of the aquifer is found (i.e., once equilibrium conditions have been established rather than stagnant water around the well, or water that has been affected by installation or drilling).

• Total Coliform: SAPLING will test all new or rehabilitated water access points (groundwater- and surface water-sourced) for no detectable fecal coliform in any 100 ml sample. Initial coliform testing will be completed using either low-cost field test kits, which SAPLING will obtain from an overseas vendor, or laboratory analysis, pending confirmation of adequate and available facilities.

2) Water Quality Monitoring: SAPLING will monitor the established or rehabilitated water

access point for the first year after installation. This includes testing water quality once before the water point is opened to the public and once every three months for the first year the water point is in operation.

3) Response Protocol: If at the initial water quality testing or at any other time the water

quality monitoring indicates that contaminant levels exceed the thresholds established in this WQAP, SAPLING will take the following actions: • If arsenic levels are exceeded: If field test results indicate inorganic arsenic levels

greater than 10 ppb (10 micrograms/liter [.01 mg/l]), and SAPLING wishes to continue use of the groundwater-sourced access point being sampled, the project will submit a sample to a qualified laboratory for analysis. The laboratory selected must be one approved by either the Regional Environmental Advisor (REA) or MEO. If the selected laboratory confirms the presence of inorganic arsenic in excess of 10 ppb, the project shall disassemble the water access point or otherwise prevent groundwater withdrawal. SAPLING may alternatively opt to bypass laboratory analysis, in which case the project will disassemble the water access point or otherwise prevent groundwater withdrawal based solely on the indicative field test results.

• If fecal coliform is detected: If test results indicate the presence of fecal coliform, and SAPLING wishes to continue use of the water access point being sampled, the project will submit a sample for (re) testing by a qualified laboratory. The laboratory selected must be one approved by either the REA or MEO. If the presence of fecal coliform is confirmed through laboratory (re) testing, SAPLING will ensure that the sampled water access point is restricted to non-potable, non-domestic uses only (i.e. for irrigation purposes only).

4) Responsibility:

• SAPLING’s Environmental Specialist has overall responsibility for ensuring that the project implements the WQAP and complies with all IEE conditions and environmental mitigation and monitoring requirements.

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• Individual project team leaders (e.g., Manager, MCHN, Disaster Risk Reduction Advisor, etc.) will have primary responsibility for ensuring that this WQAP is implemented as it relates to project activities under their direct supervision. Team leaders may delegate certain WQAP-related tasks (e.g. monitoring), but will retain responsibility for their completion.

5) Reporting and Recordkeeping: Reporting on implementation of the WQAP will be completed as part of overall project environmental compliance reporting to USAID, as specified in the project PMP. All documentation generated in support of this WQAP will be retained as part of the project record, and provided to USAID at its request. This includes technical specifications for the establishment, installation or rehabilitation of water access points, as well as monitoring logs and similar compliance records.

If HKI conducts geographic and hydrogeological assessments prior to establishment of any new water access points, or the rehabilitation of existing water access points, the assessment results will be submitted to the DCHA BEO as per instructions.

IEE Condition 9: HKI must respond to the MEO with greater details and clear mitigation measure for aquaculture activities. Issue 9: Lack of detail regarding aquaculture activities. Discussion: The IEE explains some of the items and potential adverse impacts from the aquaculture related activities under Activity 1.1.1: Microenterprise development for poor and extreme poor households. However, more details must be provided about the specifics around aquaculture activities. For example, what are “Good Aquaculture Practices (GAP)”? Greater detail must be provided around this practice in order to assess GAP. Also, is there a native fish species alternative to the Tilapia Nilotica? In the event of fish pond construction, what will be done to mitigate soil disturbance and other potential negative environmental impacts? Will water testing be done to ensure the water is not contaminated? What will be checked in the Environmental Due Diligence Review (EDDR) checklist? These types of details must be addressed in greater specificity and clear mitigation measure must be provided in order to ensure best environmental practices. The Food and Agriculture Organization (FAO) provides helpful resources for rice fish farming, including the article Rice fish benefits and problems by Josh Sollows.

! Activity 1.1.1: Microenterprise development for poor and extreme poor households- Aquaculture activities

GAPviii: GAP will comply with the following best management approaches for aquaculture: • Use proper slopes and compaction to minimize erosion potential on embankments. • Design discharge structures and canals to prevent erosion due to impact of water or

scouring due to excessive water velocity.

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• Provide vegetative cover on embankments and above water slopes of canals to prevent erosion.

• Provide grass cover on watersheds and gravel on farm roads and tops of embankments to prevent erosion.

• Position aerators to prevent erosion of insides of embankments and pond bottoms by aerator-induced water currents.

• Do not leave the drain open in empty ponds to prevent rainfall erosion and discharge of suspended solids.

• Do not allow livestock to walk on pond embankments or to wade in ponds. • Do not remove sediment from ponds and place in spoil piles on embankments of

surrounding area; use sediment to repair pond embankments or dispose of it in a responsible manner.

Boyd (2003) also provided a list of GAP that could be adopted to minimize nutrient loads in aquaculture effluents and lessen the likelihood of eutrophication in receiving water bodies. The recommended GAPs include:

• Use fertilizers only as needed to maintain phytoplankton blooms. • Select stocking and feeding rates that do not exceed the assimilation capacity of ponds. • Feeds should be of high quality, water-stable, and contain no more nitrogen and

phosphorus than necessary. • Apply feeds conservatively to avoid overfeeding and to assure that as much of the feed is

consumed as possible. • Do not use water exchange or reduce water exchange rates as much as possible. • In intensive aquaculture, apply enough mechanical aeration to prevent chronically low

dissolved oxygen concentration and to promote nitrification and other aerobic, natural water purification processes.

• Provide storage volume for heavy rainfall to minimize storm overflow. • Deep water release structures should not be installed in ponds, for they discharge lower

quality water from near pond bottoms. • Where possible, discharge pond draining effluent through a settling basin or a vegetated

ditch. • Reuse water where possible.

Native and naturalized species instead of Tilapia Nilotica: For polyculture, locally preferred and suitable fish species will be selected from a list of Indian major carp species, mainly Rui (Labeo rohita), Catla (Catla catla), Mrigal (Cirrhinus mrigala), kalibaush (Labeo calbasu), and Chinese carp species, mainly Silver carp (Hypophthalmichthys molitrix), Grass carp (Ctenopharyngodon idella), Common carp (Cyprinus carpio), Silver barb/Thai sarputi (Barbonymus gonionotus) and Tilapia (Oreochromis niloticus). Indian major carp are indigenous species and their existence in Sangu River flowing through Bandarban district has been reported over the years. On the other hand, listed Asian carps and tilapia were introduced long ago in Bangladesh and are well adjusted to aquaculture systems. In the hilly areas, SAPLING will also introduce Cuchia (Monopterus cuchia), a type of eel fish which is the preferred species for consumption by ethnic people and is found everywhere in

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Bangladesh, including hilly areas.

Water Testing: It is important to test the pH, the level of acidity or alkalinity, of water. The pH level of the water can provide information on potential contamination. SAPLING will conduct pH testing before commencing aquaculture because fish culture requires a specific level of acidity. If the pH level is too low or too high, fish will get sick or die. The project will:

• Introduce a pH meter to test water quality of aquaculture ponds. • Train project participants on using a pH meter, including calibration of the meter,

collecting a water sample in a clean container, adjusting the meter to match the sample temperature, putting the probe into the sample and reading the pH measurements of the sample.

• Train participants to understand the pH scale.

Mitigation Measure 1: Raise awareness on GAP in target communities. Awareness raising strategies and topics will be implemented by SAPLING’s envisioned technical partner, World Fish Center (WFC) though this sub-grant award has yet to be approved. This mitigation measure seeks to align itself with WFC’s EMMP mitigation measures. Awareness raising events held and the number of aquaculture producers demonstrating awareness of GAP will be monitored. Awareness raising should include topics on environmentally conscious pond designs, hazard conscious site selection, disease and waste management, practicing positive traditional techniques, and establishing healthy input routines. Environmentally conscious pond design focuses on preventing contaminants and cultured fish from entering natural bodies of water. In most cases for SAPLING, ponds will be far from natural water bodies. Hazard conscious site selection takes into consideration up-gradient latrines that may introduce harmful pathogens into the pond through subsurface flow. Site selection in sloped terrain should also consider HH dwellings directly below the pond. In the case that an earthen wall fails, the outflow of water should not jeopardize houses directly below it. Awareness raising should also promote practices that minimize the risk of introducing an infectious disease and spreading it throughout the fish population, as well as the risk that diseased fish or infectious agents will leave the pond and spread to other sites and to other susceptible species. Good water quality, nutrition, and handling will go far towards preventing disease. Additionally, preventive medical practices such as quarantining, conducting routine observation, vaccination, the use of immunostimulants and probiotics, and being able to diagnose common disease are important. If the project decides to provide training in the use of aquaculture pesticides, it must be done in accordance with the Mission-wide PERSUAP. Conducting a risk analysis is a good first step in identifying common diseases and mechanisms of disease introduction. The management of disease and pathogens must be done under international (if fish is to be exported) and national law. The World Organization for Animal Health maintains the international Aquatic Animal Health Code. SAPLING should consult with the Bangladesh Fisheries Research Institute on accepted disposal practices for solid and liquid animal wastes, particularly when harboring disease pathogens.

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Mitigation Measure 2: Train hatchery owners on improved hatch stock management in alignment with government standards. Hatchery owners should not only implement GAP but also be held to government standards for stock management. SAPLING will consult with Bangladesh Fisheries Research Institute to ensure that government standards for hatcheries are promoted. The training manual for improved stock management will include but is not limited to:

• Preventative steps for crossbreeding • Harmful environmental corollary effects of over-application of drugs and chemicals

Review of the manual and ensure the content is included in the training, verifying the training takes place, and observation of the trainees actually adopt the practices will help to meet this mitigation measure. EDDR Checklist: SAPLING will follow the developed EDDR checklist to determine the suitability of aquaculture at the pre-selection stage. The EDDR checklist can be found in Annex 2 in the ESR –FY17. IEE Condition 10: HKI should recommend energy saving cooking practices, when appropriate, at the cooking demonstrations. Issue 10: Cooking demonstration and activities. Discussion: For the Activity 2.1.4: Organize nutrition fairs and cooking demonstrations, the DCHA BEO notes that HKI will be promoting a wide variety of activities at these cooking demonstrations. The BEO notes that there was no mention of related energy issues planned for these cooking demonstrations in the IEE. Given the importance of energy saving cooking practices in order to ensure best environmental practices, the DCHA BEO recommends that Energy related issues and energy saving options be presented at these cooking demonstrations. USAID developed a toolkit for stove programs entitled Fuel Efficient Stove Programs in Humanitarian Settings: An Implementer’s Toolkit. Although the BEO recognizes that HKI is not doing a Stove Program, this toolkit is an excellent resource regarding energy saving cooking practices.

Mitigation Measure: Incorporate energy saving cooking practices into all cooking demonstration activities. The United Nations Secretary-General initiative, Sustainable Energy for All (SEFA), has designated Bangladesh as a priority country for promoting sustainable energy access. SAPLING will promote this during the cooking demonstrations by using more energy efficient, ICS, such as insulated cookers and/or solar cookers or mud stoves.ix The program will encourage the adoption of ICS that are affordable and easy to use, reducing the number of risky trips for firewood and reducing deforestation. Furthermore, burning smaller quantities of timber fuel means less smoke

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will engulf the houses and enter the lungs of users. ICS have high sides, which assists with heat transferx. The Bangladesh Country Action Plan for Clean Cook Stoves, formulated in November 2013 by the Ministry of Power, Energy, and Mineral Resources, lays out a plan for increasing use of ICSs by 2018 through learning about clean cook stoves, growing fuel wood sources, using pruned wood for fuel, and other more energy-efficient and environmentally-friendly ways to contribute to community sustainability. SAPLING will contribute to this action plan by promoting this appropriate technology. Regarding the promotion of safe and effective use of fuelwood or energy sources used by the project participants to prepare food and other commodities, activities using fuel-efficient cook stoves will be designed based on the USAID fuel efficient stove program guide. SAPLING will conduct cross visits with other USAID programs to learn about the technologies being promoted and see how they are being implemented (what works/what does not) and request copies of manuals, guidelines and/or other materials that have been helpful in promoting the successful and environmentally appropriate introduction of this technology.

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IEE Condition 11: HKI must provide more detail regarding any environmental issues, best environmental practices, and/or lessons learned from the implementation of these fertilizer activities, including education of counterfeit fertilizers. Issue 11: Fertilizer activities. Discussion: The DCHA BEO appreciates HKI mentioning their fertilizer activities and their promotion of organic fertilizers. The IEE notes that the promotion of organic over chemical fertilizers and that HKI will “Evaluate (the) percentage of producers properly using organic and chemical fertilizers quarterly.” Concerning the range of risks associated with fertilizers, the DCHA BEO is concerned about the limited information provided in the IEE regarding the fertilizers. As with any technology, it is recommended that fertilizers be thoughtfully employed according to best practice, promoting integrated soil fertility management, within the context of the prevailing biophysical and socioeconomic conditions, as well as the desired outcomes. This USAID AFR Fertilizer fact sheet was developed to assist in that regard. “Dodgy” Fertilizers: As noted in this The Guardian article, the sale of counterfeit, diluted, or adulterated fertilizers is a concern. The ESR must make mention of how the project will address the issue of counterfeit fertilizers and educate the community on this issue. While very challenging, the risk should be made known to the beneficiaries, especially so that those using fertilizers will be conscious of this problem after the program has ended. The DCHA BEO would like to request that additional information is provided by HKI regarding any environmental issues, best environmental practices, and/or lessons learned from the implementation of these fertilizer activities within the context of prevailing biophysical and socioeconomic conditions. The DCHA BEO is also interested in learning how HKI might address the issue of counterfeit fertilizers within SAPLING.

The EMMP currently includes a mitigation measure for Activity 1.1.1 specifying that the training manual for soil fertility include proper handling, storage, use and application of fertilizers. In fertilizer application the following principals should be taken into account:

• Fertilizers should not be applied too close to seeds and young roots and stems of plants. • Fertilizers should not be applied to plant leaves when they are young and wet. • Manures and fertilizers should be mixed thoroughly with the soil. • Urea should not be applied to soil with standing water. • Manure should be applied 7-10 days before sowing or planting of a crop.

An additional mitigation measure will be added for the identification of counterfeit fertilizer and will read as follows:

Mitigation Measure: Incorporate identification of counterfeit fertilizer into soil fertility trainingxi.

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SAPLING will develop a training manual related to the identification of counterfeit fertilizers. This will be added to the EMMP as part of the mitigation measure for Activity 1.1.1. The training manual will include the following topics: Identification of adulterated Urea

• Adulteration of urea is very rare. In a few cases, this is due to misbranding i.e. packaging of other fertilizers in bag of urea. Urea fertilizer never exists in crystalline form.

• For quality testing, pour one teaspoon of urea into two teaspoons (10ml) of water and stir them. Urea will dissolve quickly and a clear solution will develop. The solution will feel cool as urea is hygroscopic. If other materials, like lime, are mixed with urea, it will produce a pungent odor of ammonia gas when dissolved in water.

Identification of adulterated Triple Super Phosphate (TSP)

• TSP is widely used phosphatic fertilizer in Bangladesh. It is granular, grey to dark grey in color, and contains 20% of total P and 1.4% water soluble P with acidic taste. A good quality TSP has a strong acidic taste with a pungent smell, while adulterated TSP has no acidic taste and pungent smell.

• Good quality TSP is little hard and cannot be broken by pressing with two thumb nails. Adulterated TSP can be broken easily by pressing between the thumb nails. The color of good quality TSP is homogeneous when broken into pieces, while the color of adulterated TSP is not homogenous when broken.

• For quality testing, pour one teaspoon of TSP in 100ml of water in a beaker or glass and stir them for few minutes. All granules of TSP will dissolve and a clear solution like green coconut water will develop. On the other hand, a hazy/turbid/muddy solution is developed when adulterated TSP is dissolved in water.

Identification of adulterated Diammonium Phosphate (DAP)

• DAP contains 18%N, 20% total P and 17.8% water soluble P. • DAP is highly soluble in water, has a pungent smell and is acidic in taste. It is granular

and dark grey to white in color. • A good quality DAP contains 18%N, which absorbs moisture from the atmosphere and

therefore DAP becomes wet when exposed to air. • Place 1 or 2 teaspoons of DAP fertilizer on a dry paper and keep it out for 1 or 2 hours. If

it becomes wet, the fertilizer is of good quality; if it remains dry, the DAP is adulterated. • For quality testing, pour one teaspoon of DAP fertilizer into 100ml of water in a beaker

or glass. Good quality DAP will dissolve quickly. However, adulterated DAP will produce a turbid/muddy/hazy precipitate in the solution due to presence of Sulphur.

Identification of adulterated potassium chloride (Muriate of Potash)

• Muriate of Potash (MoP) is one of the most widely used potash fertilizers in Bangladesh. MoP is light to deep red in color, crystalline in nature and contains 50%K. MoP does not have pungent smell or taste.

• For quality testing, pour a half teaspoon of MoP fertilizer into 100ml of water in a beaker or glass and stir for few minutes. Good quality MoP will completely dissolve and an

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almost clear solution will be produced. But if MoP contains sand, powder of broken glasses, brick chips, etc. these materials will not be dissolved and will settle at the bottom of the container, indicating the fertilizer is adulterated. If the MoP is mixed with synthetic dye (red or other color), there will be a layer of color on the surface of the solution when dissolved in water.

Identification of adulterated potassium phosphate (Sulphate of Potash)

• Sulphate of Potash (SoP) is of large crystalline or powder form and white in color. It contains 50%K and 17%S. It is less hygroscopic compared to other fertilizers and absorbs less water, which is why it has very good shelf life. SoP is typically adulterated by mixing with lime, starch or gypsum.

• For quality testing, pour two teaspoons of SoP into a small beaker or glass container and add a few drops of 10% HCI. Adulterated SoP may produce CO2 if it contains lime, but good quality SoP will not produce any gas.

• Pure SoP is heavier in weight compared to adulterated SoP

Identification of adulterated NPKS (mixed fertilizers) • NPKS is a mixed fertilizer containing Nitrogen, Phosphorous, Potassium and Sulpher. It

is manufactured locally through physical mixing of different fertilizers like MoP, DAP, SoP, TSP, Gypsum, etc. Adulteration is noticed in respect to the proportion of different nutrients and mixing of undesirable materials like soil, dolomite, synthetic dyes, etc.

• Good quality NPKS fertilizers are heavier than adulterated NPKS fertilizers. • If adulteration is done by mixing with soil or gypsum along with black coating, the

materials will be broken down into powder by little pressing between two fingers. The color of outside and inside the granules will not be same or uniform in case of adulterated fertilizers.

Identification of adulterated gypsum

• Gypsum is an amorphous/powder, grey to white in color, and contains 16%S and 20%Ca. It contains relatively high moisture, which is why it cannot be preserved for long in the air. Gypsum fertilizer is soft and glitters when exposed to sun light. It is rare for gypsum to be adulterated due to its low price.

• For quality testing, pour one teaspoon of gypsum into a small beaker or glass container and add 10-15 drops of dilute HCI. If CO2 is produced, then the gypsum is adulterated. Good quality gypsum will not produce effervescence or gas.

• Good quality gypsum is heavier then adulterated gypsum. Identification of adulterated Zinc Sulphate, heptahydrate (ZnSO4.7H2O)

• Zinc Sulphat, heptahydrate is crystalline like sugar. It contains 23% Zn and 11% S and is friable.

• For quality testing, pour one teaspoon of Zinc Sulphate, heptahydrate in 100ml water in a glass container or a beaker and stir. The good quality Zinc Sulphate will be totally dissolved and no sediment will be found at the bottom of the container. In the case of adulterated Zinc Sulphate, heptahydrate there will be sediment at the bottom of the container.

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• Zinc sulphate, heptahydrate is lighter than zinc sulphate, monohydrate in weight. Identification of Zinc Sulphate, monohydrate (ZnSO4. H2O)

• Zinc Sulphate, monohydrate is granular and contains 36%Zn and 18%S. Good quality Zinc Sulphate, monohydrate is pale white in color, while adulterated Zinc Sulphate may be milk white in color.

• For quality testing, pour 1 to 2 teaspoons of Zinc Sulphate, monohydrate into 100ml cold water in a glass or beaker and stir. Good quality fertilizer will not dissolve fully and will produce turbidity.

Identification of adulterated Boron fertilizer

• Boric acid and Solubor are used as boron fertilizer. • Boric acid is white, of fine crystalline form, contains 17%B, and dissolves fully in cold

water and leaves no sediment in solution at the bottom. • Solubor is white, of fine powder form, a light weight, contains 20%B, and dissolves fully

in cold water and leaves no sediment in solution at the bottom. • For quality testing, pour 1 teaspoon of Boric acid or Solubor in a glass or a beaker

containing 100ml cold water and stir. Both the fertilizers will dissolve quickly and will produce a clear solution with no precipitation. Add a small amount (2g) of barium chloride into the solution, and if the fertilizers are adulterated with sodium sulphate (usually used), a white turbid or sediment like milk will be produced.

Identification of adulterated organic fertilizer The government of Bangladesh has approved the standard specification of organic fertilizer with certain physical and chemical properties through a Gazette Notification by the Ministry of Agriculture (MoA) on 02 April 2008. As per the notification the organic fertilizer should be:

• Non-granular in form; • Dark grey to black in color; • Odorless; • No bad smell; and • A good quality organic fertilizer does not feel cold when pressed in hand.

IEE Condition 12: HKI must ensure that sufficient funds are allocated in order to ensure environmental compliance and provide updates on their environmental budgeting during annual reporting.

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Environmental Budget- Life of Project

Funding source for LOP

Detailed Line Items

Agriculture Sector Capacity

Section 202e funds

Object class category Unit Unit Amount (US$) No of Units Amount US

($)

Program element sub-total

1. Salary 1.1.2 Local staff

Environment Specialist Months $2,000 60 $120,000 $120,000 2. Fringe Benefit Environment Specialist 30% 10 $3,600.0 $3,600 4. Travel and Transport 4.5 In-Country Air travel Days $185 10 $1,850 $1,850 4.6 In-Country Ground Travel Days $28 60 $1,680 $1,680 4.7 In-Country Per-diem Local Staff Days $28 60 $1,680 $1,680 6. Program Supplies Seeds/sapling Items $192 64 $12,288 $12,288 7. Other Direct Costs Training/workshop Training on IPM pest/weed management Training $404 36 $14,544 $14,544 Water Quality Testing Unit $10 80 $800 $800 Environmental Training on Safe Use of Pesticides Training $385 60 $23,100 $23,100 Assessment/Reviews Environmental Screening for demonstration plots

Study $200 50 $10,000 $10,000

Environmental Assessment for water structures and WASH activities Study $500 48 $24,000 $24,000 Environmental Review Study $100 24 $2,400 $2,400 Natural Resource and Biodiversity Conservation $270,114 $270,114 Water Supply and Sanitation Items $299,896 $299,896 8.0 Staff Training 8.3 Local staff training Environmental Interns Months $30 96 $2,880 $11,520 Environmental Specialist and Environmental interns Training $4,608 2 $9,216 $36,864 9. USAID Branding and Marketing IEC materials (Flipcharts/flyer) Items $29,400 $29,400 11. Total Sub-contracts 11 A. Contractual/Sub-Awards Included in Indirect Cost Base IEE/other consultants persons/firm $3500 1 $3500 Total PROGRAMME $688,181 $867,236

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IEE Condition 13: Follow the updated guidance on annual environmental reporting through the ESR, as described in the FY16 FFP RFA IEE. Issue 13: ESR approval

Discussion: The DCHA BEO recognizes that the ESR was submitted before the IEE received final approval and appreciates the note in the ESR to this end. Please refer to updated information on annual environmental reporting as described in the FY16 RFA IEE. The Annex 3 in the new RFA IEE provides the newest ESR template for future reference.

The newest ESR template has been used for this ESR-FY17 and will be used for future ESRs as per instruction of IEE Condition 13. Challenges in meeting IEE conditions: SAPLING field activities have not yet started with the exception of the formation of beneficiary community groups through the household census. It is expected that many field activities at community level will be in progress during FY17, after which it will be possible to identify challenges to meeting IEE conditions during implementation. Progress has been made to meet these IEE conditions:

• HKI has submitted the SUAP compliance tracker for DCHA BEO and MEO approval and included Rotenone in the SUAP tracker and complied with the PERSUAP for all pesticides related activities as per DCHA BEO instructions.

• HKI has submitted more details on the scale of Activity 1.2.4, especially related to irrigation activities, to the DCHA BEO and reclassified Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising and Activity 1.2.3: Introduce Savings and Internal Lending Committees (SILC) to a Negative Determination with Conditions and provided the DCHA BEO and MEO with appropriate mitigation measures.

• HKI has developed a Solid Waste Management plan and air pollution mitigation measures for Activity 1.1.1: Microenterprise development for poor and extreme poor households and shared with MEO as per instruction of the DCHA BEO.

• HKI has developed a plan of the appropriate disposal of and management of healthcare waste resulting from veterinary services, planned for monitoring the quality of veterinary pharmaceuticals, and promotes best environmental practices with respect to the training of health service providers and developed of WQAP to ensure safe water supply at the community level.

• HKI has developed a manual of GAP regarding the aquaculture activities as per instruction of DCHA BEO.

• HKI has planned for introducing ICS during the cooking demonstrations as per instruction of DCHA BEO.

• HKI has developed training materials for the identification of counterfeit fertilizer at the community level following instruction of DCHA BEO and allocated sufficient funds for

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environmental compliance in the LOP, as per suggestion of DCHA BEO.

Current status of the activities addressed by these conditions: HKI has developed strategies to address IEE conditions for field level activities and is waiting to implement the instructions of the DCHA BEO and MEO included in the IEE conditions for better environmental management at the beneficiary community level.

B. EMMP Reporting:

Table 1 of the EMMP (Activity/Impact/Mitigation) is attached as Annexure – I. This table includes the re-classification of Activities 1.2.3. & 3.2.3 as NDw/C. Table 2 of the EMMP (Environmental Monitoring and Evaluation Report) has not been included for the simple fact that at this point in the project there are no indicator results or recommended adjustments to report.

Initial Environmental Examination (IEE): SAPLING’s IEE was submitted to USAID on January 17, 2016, and based on feedback, the draft was revised and resubmitted first on April 7, 2016, and once again on May 25, 2016 for approval. The IEE was approved by USAID on September 20, 2016 and HKI received the approved IEE on September 27, 2016. Develop and facilitate training on USAID Environmental Compliance 22 CFR part 216: Two batches of training were conducted on USAID/Bangladesh mission-wide PERSUAP in May and August in FY16. Approximately 49 staff were trained, including union supervisors, Upazila coordinators, field facilitators, technical officers, MCHN specialists, and managers and deputy managers. In addition, three batches of half-day orientations on USAID Environmental Compliance were conducted in April for 75 recently recruited extension staff. Environmental Checklists: Environmental checklists (attached as Annexure-2) have been developed for conducting environmental assessments/screening of program activities that are considered as Negative Determination with Condition (NDw/C) in the IEE:

• GAP Awareness Checklist • Hand-weaving and Handicraft Awareness checklist • Soil Fertility and Erosion Control checklist • Small Animal Husbandry Awareness Checklist • Environmental Screening Checklist for Demonstration Plots • Environmental Screening Checklist for Water Capture Ponds • Environmental Screening Checklist for small scale sanitation activities before

construction • Environmental Screening Checklist for small scale sanitation activities after construction • Environmental Screening Checklist for Safe Water Accessibility • Transect Plant Composition Monitoring Checklist

Moreover, SAPLING has also developed a SUAP for compliance tracking following USAID/Bangladesh 2015 mission-wide PERSUAP for monitoring the project supported agricultural activities

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Develop Environmental Mitigation and Monitoring Plan (EMMP): An EMMP has been developed to mitigate any ecological and environmental hazards and to monitor program activities. The EMMP was approved by USAID at the same time as the IEE and FY16 ESR. Awareness raising and capacity building activities IEC and SBCC materials will be developed for distribution at courtyard sessions facilitated at the community level regarding:

• Safe use of pesticides followed by USAID/Bangladesh mission wide PERSUAP • IPM based pest managements following USAID-PERSUAP e.g., intercropping, contour

farming, mulching, village model farm, biological controls of pests such as mulching, sex pheromone, parching, organic fertilizer such as composting and vermi-composting, and mechanical controls for weeding e.g., hand weeding, deep ploughing, etc.

• Soil erosion and fertility controls by judicious use of fertilizers and identification of counterfeit fertilizers

• Management of water structures • Solid waste management and • Health waste management from livestock • Promotion of using netting or drying ponds before aquaculture practice to protect natural

predators as well as decreasing dependency on rotenone • Promotion of healthy sanitary behavior for sanitation activities

Moreover, SAPLING will establish high-value nutrition-oriented contour farming agricultural demonstration plots in VMFs where beneficiaries will be involved in applying soil erosion control technologies as well as sustainable agricultural practices like intercropping/multi-cropping, mulching, and terracing; mechanical controls for weed management; and biological control for pest management etc.

FFDs will be organized at demonstration plot sites with active participation of beneficiaries to share or exchange improve agricultural technologies for crop land including:

• Safe use of pesticides as a last resort; • Introduction of integrated pest management application in crop fields; • Promotion of maintaining PHI after spraying chemical pesticides and • Post-harvest management of crops etc.

SAPLING will develop aquaculture demonstration plots at the community level to introduce improved technologies for fish culture, including:

• Use of native fingerlings • Use of nets to block predators • Discouraging the use of rotenone to kill predator fish species. • Use of homemade fish feed e.g., rice burm, wheat burm, mustard oil cake, etc. • Use of fertilizers only as needed to prevent phytoplankton blooms • Selecting stocking and feeding rates that do not exceed the assimilation capacity of ponds • Use of feeds that are of high quality, water-stable, and contain no more nitrogen and

phosphorus than necessary

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• Applying feeds conservatively to avoid overfeeding and to assure that as much of the feed is consumed as possible

• Avoiding or reducing water exchange rates as much as possible • Soil fertility management, which includes:

o Judicial use of chemical fertilizers and chemical pesticides in the crop land o Promotion of mechanical and biological controls for pest and weed management o Promotion of organic fertilizers on crop land o Introducing composting and vermi-compost production technology o Manure management practices to block the livestock nutrients from entering water

sources and to enhance crop land soil.

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C. Integration into Performance M&E:

Table 4 describes how environmental and climate change consideration have been integrated into the M&E Plan.

Table-4: Environmental Indicators aligned with M&E framework (IPTT) Sl

Environmental Indicator Indicator Type Activities covered

M&E framework-

Indicator Performance

Tracking Table 1 Number of farmers and others

who have applied improved technologies or management practices as a result of USG assistance (RiA)

Outcome (FFP-9)

Cultural Practices; Livestock Management; Aquaculture Management; Pest Management; Disease Management; Soil-related Fertility and Conservation; Irrigation- water diversification; Water Management - non-irrigation-based; Climate Mitigation or Adaptation; Post-harvest -Handling & Storage and Other: e.g. improved mechanical and physical land preparation

EMMP review-annually

2 Number of hectares under improved technologies or management practices as a result of USG assistance (RiA)

Outcome (FFP-15)

Cultural Practices; Livestock Management; Aquaculture Management; Pest Management; Disease Management; Soil-related Fertility and Conservation; Irrigation- water diversification; Water Management - non-irrigation-based; Climate Mitigation or Adaptation; Post-harvest -Handling & Storage and Other: e.g. improved mechanical and physical land preparation

EMMP review-annually

3 Number of private enterprises, producer organizations, water users associations, women’s groups, trade and business associations and community-based organizations (CBOs) that applied improved technologies or management practices as a result of USG assistance (RiA)

Outcome (FFP-10)

Promoting improved technologies or management practices collectively as an organization, enterprise, group or association

EMMP review-annually

4 Number of people gaining access to an improved sanitation facility (RiA)

Outcome (FFP-48)

Promoting infrastructure-related wash interventions

EMMP review-annually

5 Percent of physically improved sanitation facilities with feces visibly present on the floor, wall, or area immediately surrounding the facility (RiA)

Outcome (FFP-46)

Promoting safe sanitation behaviors EMMP review-annually

6 Number of people gaining access to an improved drinking water source (RiA)

Outcome (FFP-47)

Promoting infrastructure-related wash interventions - upon completion of construction or rehabilitation of an improved water source

EMMP review-annually

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D. Executive Order 13677:

Healthy ecosystems provide a buffer against climate conditions outside of the historical record. SAPLING activities were designed and are now honed (through the IEE process) to safeguard healthy ecosystems throughout all its objectives. Good agricultural practices allow for sustainable use of natural resources—soil and water—needed for crop production. Lacking access to productive technologies, information on weather and climate conditions, agricultural inputs, undermine NRM activities that can play a role in fortifying farming systems’ sustainability. Soil and water conservation—watershed management—can build local farming systems’ resilience to climatic variability and climate change and add incrementally to their agricultural productivity through sophisticated use of soil, water, and vegetation. SAPLING has developed environmental and climate sustainability checklists for assessing the program activities defined as NDw/C in the approved IEE to ensure:

• Soil fertility and erosion control through introducing judicious use of fertilizer and identifying counterfeit fertilizer;

• Decreased dependency on chemical pesticides by introducing Integrated Pest Management technology;

• Introduction of sanitary behavior for project supported small scale poultry and livestock rearing practices;

• Ensure good quality seeds for project participants (avoid exotic or GMO seeds varieties); • Promote safe water access for irrigation, livestock and aquaculture; • Introduce environmentally friendly ICS project supported cooking demonstration

sessions; • Reduced dependency rotenone for killing predators and as well as promote local native

fish species for aquaculture practice; • Introduce Good Agriculture Practices such as intercropping, mulching, parching, sex

pheromone, hand weeding, etc. into the project established demonstration plots for high value crops; and

• Introduce GAP at project supported aquaculture demonstration plots to ensure climate resilient development.

E. Fumigation PEA: Not applicable

F. Lessons Learned/Innovation:

No field activities were implemented at the community level in FY16, but in FY17 there will be opportunities to introduce climate smart and environmental resilience innovations into project activities by applying climate smart farming practices that follow USAID Agriculture Sectoral Guidelines to protect natural environment, as well as promoting sustainable agriculture or livelihood activities that allow for testing innovations at the community level.

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Annexure-I: Updated EMMP Recommended IEE Determinations, Mitigation, Monitoring and Evaluation from IEE Activities under negative determination with conditions with probable environmental impacts and possible mitigation measures of

SAPLING over LOA have been described in below Table – 5 as updated EMMP version as per instruction of DCHA BEO and MEO following the IEE conditions-4 (HKI must reclassify the Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising to a Negative Determination with Conditions) and 5 ( HKI must reclassify Activity 1.2.3: Introduce Savings and Internal Lending Committees (SILC) to a Negative Determination with Conditions).

Table-5: Updated Environmental Mitigation and Monitoring Plan (EMMP)

Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

Activity 1.1.1: Microenterprise development for poor and extreme poor households

216.3(a)(2)(iii)

Sustainable agriculture practice promotion: o Surface water and soil

contamination and risks to human health due to the use of chemicals (farmers may use pesticides and chemical fertilizers)

o Training materials and pesticide-related information that is poorly communicated or is misused or misinterpreted by the trainee/recipient could have potential negative environmental impacts

o Potential risk to biological environment (aquatic, terrestrial, wetland, endangered species, and

o Introduce the USAID/Bangladesh 2015 mission-wide PERSUAP and provide training and disseminate information about proper selection, application and how to safely use pesticides consistent with the Safer Use Action Plan (SUAP) and how and when to use Personnel Protective Equipment (PPE)

O Follow relevant recommendations and apply specific mitigation measures related to training described within the SUAP in the USAID Bangladesh 2015 Programmatic PERSUAP

O Prepare SUAP and Compliance Tracker o Adapt training materials on safe use and

handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 Programmatic PERSUAP

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of participants trained on safe use % of participants using chemicals % of participants trained properly applying safe use Tracker filled out and maintained

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

beneficial plants and animals) and public health

Soil Fertility and Erosion Control: o Injudicious application of

chemical or organic fertilizers to improve soil nutrients can constitute an environmental threat

o Fertilizers can cause pollution when they are applied more heavily than crops can absorb or when they are washed or blown off the soil surface before absorption by crops

o Excess nitrogen and phosphates can pose potential risk to biological environment (aquatic, terrestrial, wetland, endangered species, and beneficial plants and animals) and public health

o Apply several simple technologies for sustainable land management (SLM), including basket and trench composting, bio-fencing, contour trenching, mulching, and deep planting

o Promote the use of organic fertilizers/compost manure instead of chemical fertilizers

o Prepare “Pesticide Safer Use Action Plan and Compliance Tracker”

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 Programmatic PERSUAP

o Incorporate identification of counterfeit fertilizer into soil fertility training

o Training topic will include identification of adulterated organic fertilizer

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

% of farmers who use basket and trench composting % of farmers who apply bio-fencing, contour trenching, mulching, and deep planting for HFP % of farmers who uses organic fertilizers/ compost

Tracker filled out and maintained # of participants trained on safe use

Quarterly

Pest management: o Pesticides pose a risk to the

environment and human health if improperly used

o SAPLING will promote the Integrated Pest Management (IPM) approach

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 mission-wide PERSUAP

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of hectares under improved technologies or management practices as a result of USG assistance (Technology type: Soil-related fertility and

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

conservation, Water management) (FFP 15)

Small Animal Husbandry: o Livestock can be affected

by different types of diseases like viral, bacterial, ecto-parasites and endo-parasites etc. If any poultry and livestock are affected by viral and bacterial diseases that might be transmitted to the other poultry & livestock which are not affected, it can cause significant loss of life (to other animals). It may also cause air pollution and water pollution in the case that any livestock or poultry carcasses are not well managed (buried). Even zoonotic disease (e.g., anthrax, brocelosis etc.) can be transmitted to the human body

o Animal waste can be a health hazard and cause environmental problems, as farmyard manure is often allowed to deteriorate on the ground water systems and accumulating in inland

o SAPLING will organize deworming & vaccination campaigns for livestock and poultry. Focus will also be placed on training on proper shed management to reduce outbreaks of and contain diseases like viral, bacterial, ecto-parasites, endo-parasites etc.)

o SAPLING will train participants on selection and use of pesticides or formulations with lower biological persistence that can be useful for managing resistance for livestock and poultry production. Insecticides with short residual lives tend to slow the development of resistance due to reduced exposure. However, application of pesticides for the control of livestock pests is a minor use category and the side effects are not a major concern compared to uses in agronomic crop production

o SAPLING will work closely with DLS for disease control, including incorporating key messages into training (e.g., bio-safety, mobile technology messages and linkage with agro-vets

o Composting will be promoted o Regular cleaning of poultry and goat/pig

rearing hut and shed will be promoted o Disposal and dumping of poultry and

goat/pig fecal disposal to nearby safe

Environment Specialist Technical Specialist (Animal Husbandry) Field Facilitators

% of farmers who use small scale compost pit

# of trainings conducted on disease control of livestock % of farmers who applied knowledge after receiving training on disease control of livestock % of farmer who compost slurry % of farmers who clean poultry and goat/pig rearing hut and shed regularly % of farmers who dumping of disposal of poultry and pig/goat fecal

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

water bodies, making the water unfit for human consumption

o Inappropriate use of veterinary drugs and improper disposal of related medical waste could have potential negative effects on the environment

o Livestock can be affected by ecto-parasites such as flies, gnats, fleas, midges, ticks and flies. Insecticides continue to be the primary means of control for ecto-parasites on livestock but there are concerns over resistance and residue problem.

o Human health can be affected from veterinary medicine resulting from veterinary services as well as poor quality of veterinary pharmaceuticals and if handled, treated, or disposed of incorrectly healthcare can spread disease, poisoning people, livestock, wild animals, plants and whole ecosystems.

dumping / collection corners will be promoted

o Controlling odor, insects and mosquito breeding around the poultry and goat/pig rearing farm will be promoted

o Composting slurry will be promoted Veterinary Medicine: SAPLING will develop

training module include veterinary and healthcare waste disposal topics within the veterinary training module:

o Solid infectious waste: Autoclave, incinerate/burn, or bury.

o Blood and other infectious bodily fluids: • Pour treated fluids into a pit where they

will be filtered by the soil, but will not contaminate drinking water.

o Sharps: • Separate from other waste. Immediately

after use, put in a plastic, metal, or cardboard container that will keep liquid from leaking; cardboard containers should be lined with plastic bags.

• If possible, containers should be colored yellow and marked “SHARPS,” “Infectious waste,” “Dangerous,” or something similar, in all relevant languages.

• Burn or encapsulate the sharps when containers reach ¾ full. If the container is to be reused, sterilize with bleach or other disinfectant.

o Wash water and sewage: • Treat using best available treatment

properly

% of farmers who dumping of disposal of Solid infectious waste properly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

system. • Pour treated liquid in a pit where it will be

filtered by the soil, but will not contaminate drinking water.

o Placenta Pit construction: • Gather necessary materials, including

slab, cover, lining, drainage channel (plastic pipe), ventilation pipe with rain cover, nylon mosquito netting, fencing materials, etc.

• Dig the pit • Reinforce the bottom of the pit (concrete,

bricks, stones or clay) • Reinforce the side of the pit (concrete,

bricks, etc.) • Place the slab over the pit • Place a plastic (not metal) ventilation pipe

in a hole in the slab. • Make a drainage channel around the pit to

prevent runoff water from entering and to protect the walls of the pit.

o Quality of veterinary medicine (counterfeit veterinary medicine):

• Read the product label first • Read production date and expiry date • Check the company registration no, batch

no, trade mark etc. • Common disease identification and

treatment procedures o Storage and disposal of medicines: • Bio-safety methods

Aquaculture: o Loss of native species from

the water bodies

o Promote fingerlings (puna) from hatcheries rather than from natural bodies of water to reduce the burden on the ecosystem

Technical Officer (Fisheries)

# of producers trained in GAP

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

o Pollution of water due to overuse of fertilizers

o Killing of predator fish by chemicals like rotenone

o Train on Good Aquaculture Practices (GAP)

o Encourage traditional practices, such as netting and drying of pond, for capturing predator fish

o SAPLING will conduct pH testing before commencing aquaculture because fish culture requires a specific level of acidity.

Environment Specialist Technical Officer (Horticulture)

% of producers using hatcheries fingerlings

% of producers trained applying GAP

% of producers using traditional practices such as netting and drying of pond

Expanded off-farm production- handicraft and hand weaving: o Contamination of nearby

soil and ground and/or surface water from bleaching and/or dyeing silk and/or other fibers

o Train participants to improve environmental performance such as reusing wastewater, using natural dyes, and increasing the efficiency of water use in the processing of handicrafts

Environment specialist

Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of documented trainings and awareness sessions on environmental management

% of participants who are re-using wastewater, natural dye etc.

Quarterly

Solid Wastes Management o Contamination of nearby

soil and ground water or surface water from solid wastes due to unplanned dumping

o Project participants will be trained on Community Based Management of Solid Waste. This training will serve to raise awareness of and teach proper sanitary behavior, and build awareness to reduce, reuse and recycle.

o Unwanted waste will be separated and will

Environment specialist Manager, Livelihoods & Food Security

# of documented trainings and awareness sessions on environmental management

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

go to the appropriate facility: o SAPLING will introduce transfer points

where local waste is collected and separated before being transported to landfills or recycling facilities.

o Awareness raising sessions on encourage practices to minimize public health, safety, and environmental risks.

o Train participants on environmentally sound production practices.

o Improved technologies and management practices include but are not limited to:

• Waste water reuse • Use of natural dyes • Water use efficiency

o Training and awareness sessions on air pollution control.

o Air pollution control measures include: • Use of masks and ear plugs by exposed

operators • Follow special timetables (avoid

community sleeping/leisure times) to reduce impact on neighbors

• Follow strict maintenance and keep equipment lubricated

o Coordinate with health and hygiene SBCC activities to encourage increased hygiene and homestead environmental health standards.

SBCC interventions should cover human health risks associated with close animal contact. Topics should include but are not limited to: o Washing hands (with soap if possible) at all

Manager (MCHN)

Number of private enterprises, producer organizations, water user associations, women's groups, trade and business associations and community-based organizations that applied improved technologies or management practices as a result of USG assistance. (FFP-10)

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

appropriate times for children and caregivers.

o Corralling animals away from sleeping quarters.

o Safe animal waste disposal procedures.

Activity 1.2.1: Promote Homestead Food Production (HFP)

216.3(a)(2)(iii)

Establishment of Demonstration plots: o Improper use of chemical

pesticides threatening human health and the environment (aquatic, terrestrial, flora, fauna and human health).

o Inappropriate adaptation of agricultural practices by farmers and farmers’ groups; for example, continuing to grow crops in monoculture or applying chemicals injudiciously

o Verify that site selection for demo plot will not convert natural forest or wetland nor will it be constructed in an environmentally sensitive area prior to establishment

o Follow the USAID Bangladesh 2015 Mission-wide PERSUAP that includes recommendations and specific mitigation measures related to safe use

o Use and follow Material Safety Data Sheets on safe chemical use and storage

o Adapt training materials on safe use and handling of pesticides that have been reviewed and approved for use in the USAID/Bangladesh 2015 mission-wide PERSUAP

o Develop and use a checklist to evaluate environmental suitability of potential demonstration plots

Environment specialist Manager, Livelihoods & Food Security Technical Officer (Horticulture)

# of documented trainings and learning sessions on safe use Tracker filled out and maintained # of hectares under improved technologies or management practices as a result of USG assistance (Technology type: Soil-related fertility and conservation, Water management) (FFP 15) % of farmers who applied improved technologies or management practices as a

Annually

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

result of USG assistance (Technology type: Soil-related fertility and conservation, Water management) (FFP 15)

Activity 1.2.3

Introduce Savings and Internal Landing Communities (SILC)

216.3(a)(2)(iii)

o There is no direct impact on the environment but unforeseen indirect effects may occur (if there are no mitigation measures) from the misuse of funds. Likewise, there exists the possibility of the funds for tobacco cultivation, purchasing of chemical fertilizers and chemical pesticides as well as for rotenone uses in the pond fish culture

The training manual for SILC groups will cover environmentally friendly ways to utilize funds, including:

o Discourage the use of funds for any type of environmentally unfriendly and/or unsustainable agricultural practices, including tobacco cultivation.

o If funds will be used for purchasing chemical fertilizers/pesticides, then messages regarding the safe and judicial use of chemicals will be included, covering the right chemicals, right doses, right time and right method before commencing application.

o Discourage the use of funds for purchasing pesticides, including rotenone which is often used for killing predator fish species as part of aquaculture practices. Participants will be trained instead on using drying or netting instead of rotenone.

o Encourage to use funds for Integrated Pest Management to get rid from pest infestation in the crop lands

SILC manager and Environment Specialist

# of documented trainings and awareness sessions on environmental friend fund management

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture (Capturing rainwater or diverting other surface water to create temporary water reservoirs or ponds)

216.3(a)(2)(iii)

o Loss to aquatic ecosystem by creating stagnant water in flowing channels, loss to biodiversity, or implementing interventions in ecologically protected areas

o Loss of top soil and water pollution due to sedimentation and run-off from irrigation schemes

o Risk of increased cases of malaria

o Risk of increased cases of cholera, dysentery and typhoid

o Impact on downstream users who may be deprived of water or subject to pollution

o Develop and use environmental screening checklist before commencing construction

o Confirm natural over-flow of channel water o Protect reservoir from contamination o Train communities on safe use of water

reservoir o Promote fish production such as Tilapia

Nilotica to reduce mosquito population o Ensure low height (not more than 1m) of

barriers to allow natural over-flow of water for continued access by downstream users

Food security and livelihood Manager Environment specialist

# of checklists filled # of structures built % of reservoirs protected

Quarterly

Activity 2.2.2: Promote the use of improved sanitation technologies and systems

216.3(a)(2)(iii)

o Poor sanitation can pollute surface water, as rain washes refuse into rivers and streams

o There may also be a significant risk of groundwater contamination which can be transported to shallow Wells or nearby surface water sources. A poorly designed latrine may also serve as a breeding ground for disease-carrying

o Encourage the use of lined pits to prevent contamination of water sources.

o Ensure construction or promotion of construction designs are area appropriate, taking into consideration the high water table, and dense population. Recommendations published by the GOB Department of Public Health Engineering, on pit latrine installation or ring slab latrines will be followed, including ensuring that they are at least 30 feet from shallow hand tube wells (depth 240 fee).

o Promote lime or ash to kill fecal bacteria

DRR Manager; Environment Specialist

% of participants who use lined pits

% of participants who use lime or ash for killing fecal bacteria % of participants who applied training knowledge on production of

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

vectors o Refuse disposed of in storm

drains may cause blockages and encourage fly and mosquito breeding

o Raise awareness on fecal management and disposal of solids through posters, leaflet and flip chart, courtyard meeting, relevant video documentary as well as established outlet of the toilets into the safe distances

o Reinforce the need to clean the toilets, water containers and tippy taps regularly

o Work with private companies to source WASH materials, including replacement parts, and encourage development of rural sanitation marts

o Support training for HHs on production of materials (e.g., sanitation slabs), and on installment and repair

materials (e.g., sanitation slabs) out of total trained

Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure

216.3(a)(2)(iii)

o Potential negative impacts include the contamination of ground water, soil erosion, and consumption of unsafe water if standards and design are not maintained properly

o Adverse impacts on the environment and people’s health may be elevated if the water points are not maintained and operated well.

o Using pesticides may cause surface water pollution due to farming activities

o Contamination of water due to poor construction practices

o Train communities to protect water sources from contamination through use of fencing and/or covering

o Test water for arsenic and other requirements before installation of water retention structures

o Explore rainwater harvesting possibilities and initiate rainwater harvesting where appropriate

o Train communities to reduce the risk of pesticide contamination of surface water following USAID/Bangladesh 2015 Programmatic PERSUAP allowed pesticides training

DRR manager

Environment Specialist

% of participants who applied improved and environmentally sustainable use of insecticides and pesticides out of total trained

% of communities that adopt water protection practices such as fencing, covering etc.

Quarterly

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Monitoring Schedule Program Activities

22CFR Citation Potential Adverse Impacts

and Risks Recommended Mitigation Measures Responsible Parties Indicators How Often

Activity 3.2.3: Promote community strategies to address/mitigate the hazards of environmental degradation through geospatial mapping and awareness raising

216.3(a)(2)(iii)

o The geo-spatial mappings are not anticipated to have any direct negative impact on the environment.

o Activity 1.1.1, including on-farm NRM, alternatives to jhum cultivation, and promotion of innovative risk-reduction solutions on demonstration plots which will have negative affect to the environment

o Under Activity 1.1.1, SAPLING will work with direct project participants to promote sound on-farm NRM implementation and alternatives to jhum cultivation that will serve as models for the community at large.

o All NRM and alternatives to jhum cultivation with direct project participants should follow mitigation measures under Activity 1.1.1. Any risk-reducing solution implemented on a demonstration plot should also follow mitigation measures for demonstration plots

o SAPLING will ensure the appropriate training is provided to DMC members in NRM activity implementation and on jhum cultivation alternatives.

Technical Advisor (DRR) & Environment Specialist

# of documented trainings and awareness sessions

Quarterly

Activity 3.2.6: Facilitate funding of government approved mitigation projects from community DRR plans, using project, community and government contributions

216.3(a)(2)(iii)

o Land use changes, effects on water quality, changes in farming practices and socio-cultural changes

o Increases in erosion and sedimentation, changes in vegetation cover, water pollution and water logging

o Deforestation and loss of biodiversity

o Develop and use a checklist to examine the suitability of proposed constructions with regard to physical, biological, and socio-economic considerations

o Proper positioning of construction sites and adherence to best engineering practices

o Worker health and safety concerns can be addressed through proper training, adhering to safety procedures and ensuring the use of protective clothing and equipment

DRR manager Environment Specialist

% of improvement /construction sites applying appropriate mitigation measures

% of sites practicing required health and safety per type of site

Quarterly (with weekly monitoring per CFW or other scheme funded by SAPLING)

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Annexure-2: Environmental Awareness/screening Checklists Site Visit Forms

1. Good Aquaculture Practices Awareness Checklist Relevant for: Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: % of producers trained applying GAP

To be completed during site visit. Awareness of GAP can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Check ( ) GAP Yes No Comments/Recommendations

Practicing key disease and waste management techniques?

If yes, list practices: Practicing positive traditional techniques?

If yes, list practices:

Fertilizer amounts are correct for size of pond and number of fish?

Supplementary feeding amounts are correct for number of fish?

Water pH is tested?

Name of Evaluator: Signature:

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2. Hand-weaving and handicraft awareness checklist

Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: Evaluate percentage of participants who are reusing wastewater related to what they produced out of total trained participants who received training on environmental management practices like re-using wastewater To be completed during site visit. Monitor awareness sessions for environmental management practices like re-using wastewater, appropriate discharge, etc. can be demonstrated through oral dialogue or observation of practices in operation. Date of site visit:

Community or GPS Coordinates:

Name of producer:

Check ( ) Hand-weaving and Handicraft Yes No Comments/Recommendations

Practicing appropriate discharge techniques?

If yes, list practices (how the waste material disposed of):

Practicing natural dyes instead of chemicals?

If yes, list practices:

Practicing PPE (hand gloves, musk, glasses etc.) during using of chemical dyes?

Participant received training in waste water management?

If Yes, list trainings date:

Name of Evaluator: Signature:

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3. Soil Fertility and Erosion Control Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE Indicator: # of hectares under improved technologies or management practices as a result of USG assistance

This checklist will evaluate total decimal of land attained soil erosion control through Sustainable Land Management (SLM) practices To be completed during site visit. Awareness of SLM practices can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Check ( ) Soil Fertility and Erosion Control Yes No Comments/Recommendations

Practicing SLM techniques? If yes, list practices:

Practicing Integrated Pest Management to get rid of pest infestation?

If yes, list practices:

Practicing safe use of pesticides during application to crop land if use chemical pesticides in the crop field?

Participant received training in IPM practices and safe use of pesticides management?

If Yes, list trainings date:

Name of Evaluator: Signature:

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4. Small Animal Husbandry Types of animals: _____________________ Relevant for Activity 1.1.1: Microenterprise development for poor and extreme poor households IEE indicators:

• % of farmers who applied knowledge after receiving training on disease control of livestock • % of farmers who clean poultry and goat/pig rearing hut and shed regularly • % of farmers who disposal of poultry and pig/goat fecal properly • % of farmers who dumping of disposal of Solid infectious waste properly

To be completed during site visit. Awareness of environmentally friendly practices can be demonstrated through oral dialogue or observation of practices in operation.

Date of site visit:

Community or GPS Coordinates:

Name of producer:

Check ( ) Small Animal Husbandry Yes No Comments/Recommendations

Cleaning of poultry and goat/pig rearing hut and shed regularly?

If yes, please check the shed:

Disposal of poultry and pig/goat fecal properly?

If yes, check the disposal site:

Controlled of odors, insects and mosquito breeding grounds around the poultry and goat/pig rearing shed?

If yes, check the shed

Maintained regular vaccination? Practices diversified feed items and initiate fodder cultivation?

If yes, make a short note Received training on cleaning of poultry/goat sheds; disposal wastes into the safe disposal sites, controlling odor, insects and mosquito breeding around the poultry and goat/pig rearing farm/shed and as well as

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composting manure? If Yes, list of training with dates

Name of Evaluator: Signature:

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5. Environmental Screening Checklist for Demonstration Plots Relevant for

Activity 1.2.1: Promote Homestead Food Production (HFP)

IEE indicator: % of farmers who applied improved technologies or management practices as a result of USG assistance

To be completed during site selection before commencing demonstration

Date of site visit: Community or GPS Coordinates:

Name of producer:

Check ( ) Environmental Screening Checklist Yes No

Comments

Environmentally conscious design 1.0 Topographic, Hydrologic and Soil condition? 1.1. Is there any water sources within 30 m from the site?

1.2. Is there any livestock shed/farm or households within 30m from the site?

1.3 What types of soil texture existing in the plot? Porous? Dense? 1.4: Is there any Ecological Critical Area near the potential plot?

2.0 Type of demo plot? 2.1. Open field? 2.2. Bund of aquatic resource? Note: if 1.1; 1.2 and 1.4 answers are ‘yes’ the plot will be disallowed for demonstration; if 2.2 answer is ‘yes’ plot will be conditionally allowed for demonstration Name of Evaluator: Signature:

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6. Environmental Screening Checklist for Water Capture Ponds Relevant for:

Activity 1.2.4: Improve access to water for irrigation, livestock and aquaculture

Indicator: # of checklists filled To be completed during site visit. All answers, except for those in bold text, should be answered with “no” to meet the IEE condition. If the answer is yes to any of the questions, other than those in bold text, the evaluator should write down corrective measures recommended for the water capture pond operator.

Date of site visit: Community or GPS Coordinates:

Name of producer:

Check ( ) Environmental Screening Checklist Yes No

Comments

Environmentally conscious design 1. Does the pond have an outlet?

1.1. If yes to question 1, does the drainage to a natural body of water?

1.2. If yes to question 1, is there evidence of erosion along the drainage outlet?

1.3 If yes to question 1, is there evidence of standing water in the drainage canal?

1.4 If yes to question 1, can culture fish escape through the outlet?

2. Is there a pond inlet? 2.1. If yes to question 2, does the water flow directly into pond without a sediment trap?

2.2. If yes to question 2, is there evidence of contamination sources within 30 m of the pond inlet (e.g. household dump sites, livestock pen, evidence of open defecation)

3. Flood prone area? 3.1. If yes to question 3, based on historical memory of floods heights, can the fish be swept into natural bodies of water?

Mosquito mitigation Is there vegetation growing in the water? Is the pond empty of fish? Is there standing water around the pond? (assuming that it has not just rained)

Hazard conscious site selection Are there human or livestock habitations directly below the pond embankments?

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Name of Evaluator: Signature:

7. Environmental Screening Checklist for small scale sanitation activities Relevant for

Activity 2.2.2: Promote the use of improved sanitation technologies and systems IEE indicator: % of participants who use lined pits To be completed during site visits before construction. Awareness of Environment friend practices can be demonstrated through oral dialogue or observation of practices in operation. If the answers ‘Yes’ latrine site will be disallowed for construction. Date of site visit: Community or GPS Coordinates:

Name of producer:

Check ( ) Environmental Screening Checklist Yes No

Comments

Environmentally conscious design 1. Is there an open‐bottom pit latrine or septic soak

away within 30m of a shallow well, stream or pond providing drinking water?

2. Are nearby surface waters overgrown with aquatic plants/algae?

3. Are children getting water‐borne illnesses more frequently and/or more severely than in the past?

4. Is there standing or stagnant water around latrines?

5. Has drinking water from sources nearest the latrine/toilet become off‐color or developed a bad smell or taste?

Name of Evaluator: Signature:

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8. Environmental Screening Checklist for small scale sanitation activities Relevant for

Activity 2.2.2: Promote the use of improved sanitation technologies and systems IEE indicator: % of participants who use lime or ash for killing fecal bacteria After construction. To be completed during site visits after construction. All answers, except for those in bold text, should be answered with “no” to meet the IEE condition. POTENTIAL PROBLEMS. A “YES” answer to any of the following indicates that an environmental concern MAY exist; follow‐up is required. Notify the Chief of Party or concern people (Manager-MCHN).

Date of site visit: Community or GPS Coordinates:

Name of producer:

Check ( ) Environmental Screening Checklist Yes No

Comments

Environmentally conscious design 1. Do latrines seem abandoned/overgrown/unused? 2. Are human feces evident in nearby field or brush? 3. Is there overflow or seepage around latrines or

septic tanks?

4. Are insects able to freely enter and leave the pit or tank?

5. Are handwashing stations lacking? 6. Is water or soap missing at handwashing stations? 7. Are latrine waste bins being dumped near/around

the latrine?

8. Is pump‐out or other waste disposed off‐site in an uncontrolled manner?

9. Are specific groups such as women, young children, or particular ethnic or religious minorities) refusing to use latrines?

10. Do the latrines smell notably bad? 11. Are there complaints of bad smells around latrines? Name of Evaluator: Signature:

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9. Safe Water Accessibility

Relevant for

Activity 2.2.3: Increase access to safe water through appropriate water supply technologies and infrastructure IEE indicator: % of communities that adopt water protection practices such as fencing, covering etc To be completed during site visits. Awareness of Environment friend practices can be demonstrated through oral dialog or observation of practices in operation. PROBLEMS: A “YES” answer to any of the following indicates an environmental deficit in activity design or management. For USAID‐funded activities, corrective action will be required. Notify the Chief of Party and the Program Manager. Date of site visit: Community or GPS Coordinates:

Name of producer:

Check ( ) Environmental Screening Checklist Yes No

Comments

Environmentally conscious design 1. Is a tank or well supplying water for domestic use

uncovered?

2. Is there stagnant water around the water supply point?

3. Arsenic or fecal contamination tested regularly? If yes, check the results or collect copies 4. Do livestock share the water supply point? 5. Is community practicing rain water harvesting? If yes; how collect rain water? 6. Is there soil erosion in the vicinity of the water

supply point?

7. Is water leaking from tanks/pipes/supply points? 8. Are wells going dry (seasonally) at the inspection

site or in the surrounding area that did not do so in the past?

9. Are children getting water‐borne illnesses more frequently and/or more severely than in the past, and are these children drinking from a USAID‐provided water source?

10. Taste the water. Does it taste bad or salty? Are users complaining of a bad taste?

11. Look at & smell the water. Is it off‐color? Is there sediment? Does it smell bad? Are users

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complaining of any these issues? Selected Water Quality Standards for Human Health* WHO, Guidelines for Drinking‐Water Quality (3rd Edition), 2006 � Arsenic < 0.01 mg/L (10 ppb) � Lead < 0.01 mg/L � Total Coliforms not detectable in any 100mL sample � Copper < 2 mg/L � Nitrate (as NO3) < 50 mg/L � Nitrite (as NO2) < 0.2 mg/L for long‐term exposure � Fluoride < 1.5 mg/l Name of Evaluator: Signature:

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Plant Composition Monitoring Transect

Purpose: In an area that receives as much rain as the CHT, the main concern that grazing pressures facilitate low-utility plants in gaining territory dominance. This happens when preferred plants are consumed by the animals allowing unpalatable plants to grow and become the dominant plant species. This shift in plant composition degrades the utility of the grazing plot in terms of nutritional value for the livestock.

Monitoring Goal: Palatable forage plants are in the majority of plant composition and are in a stable or increasing trend

Method: A linear transect will be used to monitor plant composition trend. One hundred (100) points along the monitoring transect will be recorded. The easiest way to choose these 100 points is by using a mark on the end of your boot, taking 100 steps along the transect and recording the plant closest to the mark on your boot. The transect can be a minimum of 100 steps in length or it can be longer. For example, you could take 4 steps and record the plant closest to the mark on your boot, take another 4 steps and record the plant closest to the mark on your boot, repeating this pattern until you have recorded 100 points. In this example your transect line would be 400 steps long. This pattern and transect length should remain the same throughout the life of the activity.

Transect site selection: 1. Choose a transect location that appears to represent the grazing area in terms of total plant species

composition and abundance. 2. GPS coordinates for the beginning and end of the transect point should be recorded, if the technology

is available. 3. A site description should be written to also help relocate the transect in the future. 4. Known plot characteristics should be included in the description to understand vegetation

composition better (e.g. soil type, slope, % canopy cover, depth to water table) 5. Documentation for each plot should have:

- A unique identifier. This can be a number (e.g. Transect #1) or a name, such as that of the community, if there are only a few plots.

- Monitoring date - Name of person monitoring

Recording Plant Composition: 1. Make a mark on the end of your boot. 2. Identify step pattern used along transect (this should remain the same for each transect) 3. Using Table A – 100 point transect, record the closest plant stem to the mark on your boot at each

point (if you don’t know the actual name of the plant find out at minimum if it is a palatable or unpalatable plant species). Record plant growth form (i.e. woody, forb, grass) and if it is a palatable or unpalatable plant species.

Determining percentage and trend

Over the life of the project, record results in Table B – Transect plant composition status

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1. Group like-plants together. Determine the percentage of each group of plants out of the total 100 plant points. If Bahia grass was the closest stem to the mark on your boot in 10 points then Bahia grass composes 10% of the total 100 plant points.

2. Count the number of plants in each grown form (i.e. woody, forb, grass) and determine percentage of the three growth forms. For example, you may have a transect where woody plants are 25%, forbs are 25% and grasses are 50%.

3. Count the number of plants that are palatable. Determine percentage of palatable plants versus unpalatable plants.

4. Identify, based on historical monitoring, if palatable plants are stable, increasing or decreasing. This final calculation can only be done at the end of the project. In truth, a decline in palatable plant composition may not be caught until the end of the project. This however, should not discourage SAPLING from monitoring the effects of small-animal husbandry activities. On the contrary, follow-on funding will be able to incorporate community grazing land management into activities if a decline in palatable plants in noted. On the other hand, if no change is noted then follow-on projects promoting small animal husbandry will have documentation showing that monitoring is unnecessary.

Table A – 100-Point Transect

Transect: _____________________________________

Date: ________________________________________

Name of person monitoring: __________________________________________________________

Point Plant Name

Plant growth form

W = woody F = forb

G = grass

Preferable forage (X)

Stable or Increasing (yes/no)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

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18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64

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65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100

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Table B – Transect palatable plant status

Transect: _____________________________________

Date: ________________________________________

Name of person monitoring: __________________________________________________________

Percentage Trend Baseline Midterm Final Increasing/Decreasing Dominant plant species:

1. 2. 3. Growth form Woody Forb Grass Desirability Palatable Unpalatable

Recommendations:

i Completion of the Pesticides Safer Use Action Plan & Compliance Tracker is required under the 2015 USAID Bangladesh mission-wide Programmatic PERSUAP for all implementing partners who use or recommend pesticides as part of project activities ii SECTOR ENVIRONMENTAL GUIDELINES AGRICULTURE Partial Update 2014 | Last Full Update: Prior to 2003 iii http://www.deq.state.or.us/wQ/dwp/docs/EPA/EPASWPPracticesBulletin_AnimalWaste.pdf iv Sector Environmental Management Guideline-Solid Waste Management GENERATION, HANDLING, TREATMENT, AND DISPOSAL Partial Update 2014 | Last Full Update: Prior to 2003 v SECTOR ENVIRONMENTAL GUIDELINES HEALTHCARE WASTE Partial Update 2015 | Last Full Update: Prior to 200 vi https://noharm-uscanada.org/search?search_text=Safe%20Management%20of%20Medical%20Waste vii http://www.usaidgems.org/Workshops/Malawi2013Materials/SWQAP.pdf viii Best Management Practices for Responsible Aquaculture; Claude E. Boyd, Chhorn Lim, Julio Queiroz, Khalid Salie, Lorens de Wet & Aaron McNevin ix Country Action Plan for Clean Cookstoves, November 2013, Power Division, Ministry of Power, Energy, and Mineral Resources, Government of the People’s Republic of Bangladesh. http://www.sreda.gov.bd/index.php/acts-policies-rules/24-4-cap-final/file, Accessed August 10, 2015. x http://practicalaction.org/improved-cooking-stoves xi Fertilizer recommendation Guide 2012; Ministry of Agriculture (MOA)