What If I Must Go Beyond a Preliminary Assessment? (the example of a USAID EA under Reg. 216)...
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Transcript of What If I Must Go Beyond a Preliminary Assessment? (the example of a USAID EA under Reg. 216)...
What If I Must Go Beyond a Preliminary Assessment?
(the example of a USAID EA under Reg. 216)
[DATE][SPEAKERS NAMES]
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 2
Our focus thus far
To this point, we have focused on Phase I of the EIA process. . .
• Understand proposed activities
• Screen• Conduct preliminary
assessment (if needed)
• Scope• Evaluate baseline situation• Identify & choose alternatives• Identify and characterize
potential impacts of proposed activity and each alternative
• Develop mitigation and monitoring
• Communicate and document
Phase I:Initial inquiries
Phase II:Full EIA (if needed)
Our focus!
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 3
Now, we focus on the full EIA
The “full EIA” is Phase II of the EIA process:
• Scope• Evaluate baseline situation• Identify & choose alternatives• Identify and characterize
potential impacts of proposed activity and each alternative
• Develop mitigation and monitoring
• Communicate and document
Phase II:Full EIA (if needed)
New focus!
When is a full EIA needed?
When screening indicates an activity is high risk*
When a preliminary assessment indicates that significant adverse impacts are possible
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*But we still recommend doing a preliminary assessment!
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 4
Review: Phase 1
Screen the activity
Based on the nature of the activity what
level of environmental
review is indicated?
Conduct a Preliminary Assessment
A rapid, simplified EIA study using simple tools
(e.g. the USAID IEE)
ACTIVITY IS OF MODERATEOR UNKNOWNRISK
SIGNIFICANT ADVERSE IMPACTS
POSSIBLE
SIGNIFICANT ADVERSE IMPACTS
VERY UNLIKELY
ACTIVITY IS LOW RISK (Based on its nature, very unlikely to have significant adverse impacts)
ACTIVITY IS HIGH RISK (Based on its nature, likely to have significant adverse impacts)
Phase IIPhase IUnderstand proposed activity
Why is the activity being proposed?
What is being proposed?
BEGIN FULL EIA
STUDY
STOP EIA
process
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 5
Review: the IEE
Remember, the IEE is USAID’s “Preliminary Assessment” A positive determination triggers an full EIA
Recommendation Reg. 216 terminology
Implications(if IEE is approved)
No significant adverse environmental impacts
NEGATIVEDETERMINATION
Activity passes environmental review
With specified mitigation and monitoring, no significant environmental impacts
NEGATIVEDETERMINATIONWITH CONDITIONS
The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented
Significant adverse environmental impacts are possible
POSITIVEDETERMINATION
Do full EAor redesign activity
Not enough information to evaluate impacts DEFERRAL
You cannot implement the activity until the IEE is finalized
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 6
USAID: 2 types of full EIA study
Reg. 216 specifies 2 types of full EIAs:
Used to assess the environmental effects of a specific project or action, e.g.
An EA to assess a single dam or irrigation project
An EA to assess impacts of a gas or oil pipeline
The Environmental Assessment (EA)
Programmatic Environmental Assessment
(PEA)*Used to assess the environmental effects of a class of similar actions, e.g.,
dams, irrigation projects and related water resource development,
sustainable forest management plans
*The term in Reg. 216 is “Program Assessment”
Reg 216 discusses only the content of the EA in detail.
However, the regulation states: “To the extent practicable,the form and content of the PEA will be the same as for EAs.”
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 7
How is an EA different than an IEE?
Analysis of environmental impacts is much more detailed
Alternatives must be formally defined. The impacts of each alternative must be analysed, and the results compared. (216.6(c))
USAID must consult with the host country government during preparation and regarding the results (216.6(e))!
!
!
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 8
First steps in preparing an EA
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PrepareScopingStatement
PrepareTORs
Assemble Team
2 BEO review
The purpose of scoping is to determine the the significant issues the EA will address.
The deliverable for the scoping process is the scoping statement.
The statement includes:
Scope and significance of issues to be analyzed
Issues that do not need to be addressed
Schedule and format of EA, expertise needed
Public consultation is not required by Reg. 216. However, good EIA practice requires public consultation during scoping.!
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 9
First steps in preparing an EA
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3
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PrepareScopingStatement
PrepareTORs
Assemble Team
2 BEO review
The scoping statement must be submitted to and approved by the Bureau Environmental Officer (BEO).
STRONGLY RECOMMENDED:Consult with the BEO before beginning the Scoping process.
Terms of Reference for the EIA team are based on the types of issues and analysis required by the scoping statement
Assemble a team based on the TORs.Frequently requires contracting with one or more experts, or an EIA consulting firm.
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 10
The EA outline
Reg. 216 specifies that an EA will contain the following elements:
1. Summary
2. Purpose
3. Comparison of alternatives*
4. Affected Environment
5. Environmental Consequences
6. List of Preparers and appendices
Appendices (as indicated)
*Reg. 216 uses the term: “Alternatives Including the Proposed Action”
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 11
Contents of the EA sections
Summary
Purpose
Comparison of alternatives
Affected Environment
EnvironmentalConsequences
List of Preparers
Major conclusions
Areas of controversy
Issues still to be resolved.
Describes the development need or objective that the proposed actions (and its alternatives) are intended to address
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 12
Contents of the EA sections
Summary
Purpose
Comparison of alternatives
Affected Environment
EnvironmentalConsequences
List of Preparers
Includes the no action alternative
Explain why certain alternatives were not considered
Present the alternatives considered
NOTE: This is a summary of the analysis presented in “Environmental Consequences”
Include mitigation actions
Compare the environmental impacts of these
alternatives.
Identify the preferred alternative
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 13
Contents of the EA sections
Summary
Purpose
Comparison of alternatives
Affected Environment
EnvironmentalConsequences
List of Preparers
“Succinctly” describe the environment of the area(s) to be affected
Note that different alternatives may affect different geographic areas or aspects of the environment. The description here must cover all alternatives
Descriptions shall be “no longer than is necessary to understand the effects of
the alternatives”
!
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 14
Contents of the EA sections
Summary
Purpose
Comparison of alternatives
Affected Environment
EnvironmentalConsequences
List of Preparers
Includes the proposed action and the no action alternative
Impacts of alternatives are not compared.
Should include*
• Any adverse effects and their significance (including those that cannot be avoided)
• Relationship between short-term uses of the environment and maintenance/ enhancement of long-term productivity
• Conflicts with other policies, plans or controls for the areas under consideration
• Recommended mitigation measures
Presents the environmental impacts of each alternative
*See 216.6.(c)(5) for full list
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 15
NOTE: WHEN ASSESSING IMPACTS,TOO MUCH INFORMATION IS AS BAD AS NOT ENOUGH
Provide the most detailed analysis for the more significant impacts.
.
Summarize or reference for lesser impacts
!
*See 216.6.(c)(4)
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 16
Contents of the EA sections
Summary
Purpose
Comparison of alternatives
Affected Environment
EnvironmentalConsequences
List of Preparers
Names and qualifications of the EA Team
Annexes can be useful in organizing the EA so that only the most critical information for decision-making is in the body of the EA
ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 17
Coordination with host country procedures
What are the implications? USAID projects must satisfy BOTH Reg. 216 AND host
country procedures One EIA document should be created to satisfy both
procedures Will require discussions in the scoping process with host
country EIA regulatory agency.
The large majority of host countries now have EIA policies and procedures
Most projects that require an EA under Reg. 216 will also require a full EIA under host country procedures
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ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 18
Gaps in the Reg. 216 EA requirements
Reg. 216 does not have language that emphasizes the importance of a detailed mitigation and monitoring plan
However, Mitigation and Monitoring Plans are essential to making the EA effective
Remember, Mitigation and Monitoring plans assign responsibilities and establish schedules/time lines and reporting requirements.