Amendment to Request for Categorical Exclusionlac-IEE-17-10

LAC-IEE-17-19

ENVIRONMENTAL THRESHOLD DECISION

Amendment to Request for Categorical ExclusionLAC-IEE-17-10

Activity Location:Haiti

Activity Title:Post-Return Humanitarian Assistance to Deportees Program

Activity Number:AID-521-IO-1700001

Life-of-Activity Funding:$1 Million

Life-of-Activity:November 1, 2016– May 31, 2017

IEE Prepared by:Gerard Fontain, Senior Rule of Law Advisor, USAID/Haiti

Reference Env. Threshold Decisions:LAC-IEE-17-10

Recommended Threshold Decision:Categorical Exclusion

Bureau Threshold Decision:Concur

PURPOSE AND SCOPE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions, for the activities detailed below. The Threshold Decisions based on this document, are formal Agency decisions on whether the proposed actions are major actions significantly affecting the environment, and therefore, provides a brief statement of the factual basis as to whether an Environmental Assessment or an Environmental Impact Statement is required for the activities managed under the scope of this document.

This is an amendment to LAC-IEE-17-10 Request for Categorical Exclusion of November 30, 2016. This amendment includes the required Climate Risk Management documentation. In addition, this document now reflects that the implementer, International Office of Migration (IOM), is a Public International Organization, and as such, the procedures of ADS 308 apply. Lastly, to meet needs of the Haitian migrants, two activities have been added: provision of tents and/or containers and portable toilets and psychosocial and counselling services. Details of this amendment appear below and in the attached Amendment to Request for Categorical Exclusion.

ACTIVITY DESCRIPTION

a)Support ONM’s operational capacities through provision of tents and/or containers as well as portable toilets at the Port-au-Prince airport (subject to Government of Haiti approvals and authorization) in which the registration process could be carried out and where staff and returnees would be protected from the elements (rain etc.) as well as to have restroom facilities to relieve themselves as necessary (not to include construction activities);

b)Transportation assistance from the point of entry into Haiti to ONM’s Reception Center (if required);

c)Food, water, and basic over-the-counter medicine to beneficiaries upon arrival and during their stay at ONM’s Reception Center;

d)Psychosocial and counselling services to beneficiaries upon arrival;

e)Temporary accommodation in ONM’s Reception Center (if required);

f)Arrival kits for beneficiaries (including hygiene kits);

g)Onward transportation assistance stipend ($100) to each returnee to relocate to their communities of origin or other regions in Haiti.

USAID assistance will enable IOM to provide humanitarian assistance to Haitian deportees while building the technical capacities of ONM throughout the upcoming six months. No construction will be undertaken. Proposed activities will be limited to the installation of prefabricated units to support the ONM.

JUSTIFICATION FOR CATEGORICAL EXCLUSION REQUEST

A Categorical Exclusion is issued to USAID/Haiti’s Post-Return Humanitarian Assistance to Deportees Program pursuant to 22 CFR PART 216, 216.2 (c)(2):

(v) Document and information transfers;
(viii) Programs involving nutrition, health care or population and family planning services except to the extent designed to include activities directly affecting the environment (such as construction of facilities, water supply systems, waste water treatment, etc.)

Further, in accordance with ADS Chapter 308 on Awards to Public International Organizations, under 308.3.11 Application of USAID Policies and Procedures:

c. Application of USAID Environmental Regulations. For the reasons outlined in section 308.3.11.b and because of the nature of the awards, program contributions not for the purpose of carrying out a specifically identifiable project or projects, as well as all general contributions, will normally be categorically excluded from environmental analysis under 22 CFR 216.2(c)(2)(vi). In awarding cost-type grants to PIOs with their own environmental policies, for activities that are not exempt or categorically excluded from environmental analysis under 22 CFR 216, USAID should strive to rely upon the PIO’s application of its own environmental policies to the activity proposed and include appropriate language in the PIO agreement. Any environmental conditions proposed to ensure adequate environmental review of the activity proposed should have due regard to both the independence and sovereignty of the PIO and the purpose and intent of the environmental impact assessment requirements of USAID. (See ADS 204, Environmental Procedures and 22 CFR 216)

However, the USAID AOR/COR needs to ensure that due diligence has been conducted by IOM to demonstrate that environmental concerns are adequately addressed for any small scale construction activities, in the project planning and implementation while applying IOM internal environmental procedures. The AOR/COR must request documentation of an appropriate Mitigation Plan that will be applied to ensure environmental compliance during the period of performance.

CLIMATE RISK SCREENING

Executive Order 13677 requires federal agencies to incorporate climate resilience into international development activities. The resulting Climate Risk Management processes ( requires USAID’s operating units to identified climate risks, rate these risk ratings, and identify how these risks will be addressed; including new opportunities and any further analysis that may needed in association with all planned activities. According to the guidance, this assessment must be documented in Project Appraisal Documents (PADs) and environmental compliance analyses (typically found in an Initial Environmental Examination (IEE)). In the case of this IEE, the methodology used to conduct the Climate Risk Screening was a combination of USAID’s Climate Risk Screening and Management Tools and existing Climate Change Vulnerability and Risk Analysis. Climate risk assessment must be conducted at the activity level if 1) a project- and strategy-level assessment was not completed, which includes cases where the activity does not fall under a project.

The results of this analysis are presented below. The conclusion of the Climate Risk Screening has determined that the majority of activities subject to this IEE are considered to be low risk and no further action is warranted. Climate change is unlikely to materially impact achievement or sustainability of activity outcomes.

Defined or Anticipated Project Elements / Climate Risks / Risk Rating / How Risks are Addressed at Project Level / Further Analysis and Actions for Activity Design/ Implementation / Opportunities to Strengthen Climate Resilience
I. Strengthen ONM Operational Capacities
Support ONM’s operational capacities by providing support for three (3) additional staff / N/A / Low / N/A / N/A / N/A
Provision of tents and/or containers as well as portable toilets at the Port-au-Prince airport in which the registration process could be carried out / N/A / Medium / Ensure compliance with GoH requirements / Verify plans for proper maintenance, cleaning and disposal of chemically treated sewage for port-a-potties. Can lead toenvironmental degradation / N/A
Refurbish, equip and expand ONM’s Reception Center / ONM’s reception center, if not properly refurbished, could be vulnerable to the effects of severe weather (e.g., heavy rainfall, flooding, high winds) if not built to international standards / Medium / Ensure that USAID engineering advice is made available to the grantee to advise on design and implementation standards / N/A / N/A
Work closely with the ONM to formalize a referral process for those returnees requiring documentation, / N/A / Low / N/A / N/A / N/A
II. Support the Reception and Reintegration of Returnees from the US
Provide transportation assistance from the point of entry to ONM’s Reception Center and onward transportation for returnees who wish to relocate outside of PAP / Transportation from point of entry and to onward destination could be potentially disrupted by severe weather / Low / Build flexibility into the timing and approach(es) to accommodate any disruptions or delays due to extreme weather events / N/A / N/A
Provision of food, water, medicine, and arrival kits to beneficiaries upon arrival and during stay at the ONM’s Reception Center / Procurement and delivery of food, water, medicine, and arrival kits could be delayed in the event of severe weather / Low / Ensure that there are adequate stocks in-house to accommodate new groups in the event of a severe weather situation / N/A / N/A
Provision of temporary accommodation in ONM’s Reception Center / Transportation from point of entry and to onward destination could be potentially disrupted by severe weather (e.g. floods, extreme storms) / Low / Ensure that the number of beneficiaries requiring accommodations and sent to the center does not exceed the capacity of the facility. Consider other institutions and social networks that exist and their capacity to provide alternate accommodations. / N/A / N/A

CONDITIONS AND REQUIREMENTS

If during implementation, project activities are considered outside of those described in this document, an amendment shall be submitted. Pursuant to 22CFR216.3(a)(9), if new activities are added and/or information becomes available which indicates that activities to be funded by the project might be “major” and the project’s effect “significant,” this determination will be reviewed and revised by the Contract/Agreement Officer’s Representative of the project, and submitted to the Mission Environmental Officer, Regional Environmental Advisor, and Bureau Environmental Officer for approval and, if appropriate, an environmental assessment will be prepared.

Signed

______Date ______

Diana Shannon

Bureau Environmental Officer

Bureau for Latin America & the Caribbean

Copy to:JeneC. ThomasMission Director

Veena Reddy, DMD

Jennifer Graetz, PCPS

Abdel Abellard, Dep MEO

Copy to:Robert Clausen, Regional Environmental Advisor, USAID/DR

Copy to:Belinda Bernard, Gene George, LAC/CAR

Todd Anderson, LAC/SPO

Copy to:IEE File

Amendment to Request for Categorical Exclusion

Activity Location:Haiti

Activity Title:Post-Return Humanitarian Assistance to Deportees Program

Activity Number:AID-521-IO-17-00001

Life-of-Activity Funding:$1 Million

Life-of-Activity:November 1, 2016– May 31, 2017

Reference Threshold Decision:LAC-IEE-17-10

IEE Prepared by:Gerard Fontain, Senior Rule of Law Advisor, USAID/Haiti

Date Prepared:December 19, 2016

Recommended Threshold Decision:Categorical Exclusion

BACKGROUND AND ACTIVITY DESCRIPTION

All USAID activities and activity extensions or amendments must have an environmental review prior to the irreversible obligation of funds per USAID’s Environmental Procedures as codified in 22 CFR 216.

Following the recent increase of illegal Haitian migrants to several Latin American countries and to the United States, the U.S. Immigration and Customs Enforcement (ICE) announced in September 2016 the reinstatement of Haitian deportations, which had been temporarily suspended after the 2010 earthquake. Subsequent to this announcement, the Department of Homeland Security (DHS) initiated the first series of deportations of Haitian migrants to Haiti on November 3. As of November 29, 2016, there have been seven flights of returnees from the U.S. to Haiti, with the first flights between 22 to 30 repatriated migrants coming mostly from Alexandria, Louisiana, and the flights November 25 and November 29 each transporting 60 deportees, an increase from the previous flights. According to ICE, this repatriation process will continue throughout a six-month period and over 3,240 deportees (135 per week) will be repatriated to Haiti during that period. The next flight of 60 passengers was scheduled to arrive on December 1 and flights of up to 135 deportees each are expected to begin during the week of December 5, 2016.

The Government of Haiti (GoH)’s National Office for Migration (ONM) is the primary agency responsible for providing reception and reintegration assistance to Haitian migrants. However given ONM’s limited financial and operational capacities to handle migrant repatriation without assistance, and the particular vulnerabilities of the repatriated migrants, International Office of Migration (IOM) has started to assist ONM in welcoming the migrants repatriated from the US in November 2016 by providing a) Support for ONM’s operational capacities through provision of tents and/or containers as well as portable toilets at the Port-au-Prince airport (subject to Government of Haiti approvals and authorization) in which the registration process could be carried out and where staff and returnees would be protected from the elements (rain etc.) as well as to have restroom facilities to relieve themselves as necessary; b) Transportation assistance from the point of entry into Haiti to ONM’s Reception Center (if required); c) Food, water, and basic over-the-counter medicine to beneficiaries upon arrival and during their stay at ONM’s Reception Center; d) Psychosocial and counselling services to beneficiaries upon arrival; e) Temporary accommodation in ONM’s Reception Center (if required); f) Arrival kits for beneficiaries (including hygiene kits); g) Onward transportation assistance stipend ($100) to each returnee to relocate to their communities of origin or other regions in Haiti.

2.JUSTIFICATION FOR CATEGORICAL EXCLUSION REQUEST

IOM will be assisting with the registration process by ONM, providing information to these migrants and counseling services, as well as providing basic over-the-counter medicine, and welcome hygiene kits containing personal care products to the returnees upon their arrival, and during their very short stay at ONM’s Reception Center if required. These services are considered Document and information transfers, and nutrition and health care-related services, as such the IO activities met the categorical exclusion of 22 CFR 216.2(c)(2)(viii). Such personal care items and over-the-counter medicines will not have an effect on the natural or physical environment. Moreover, USAID does not have control over the personal care items to be provided to the returnees and how they will be used once the returnees will be relocated into their community of origin.

In accordance with ADS Chapter 308 on Awards to Public International Organizations, under 308.3.11 Application of USAID Policies and Procedures:

However, the USAID AOR/COR needs to ensure that due diligence has been conducted by IOM to demonstrate that environmental concerns are adequately addressed for any small scale construction activities, in the project planning and implementation while applying IOM internal environmental procedures. The AOR/CORs must request documentation of an appropriate Mitigation Plan that will be applied to ensure environmental compliance during the period of performance.

CLIMATE RISK SCREENING

Defined or Anticipated Project Elements / Climate Risks / Risk Rating / How Risks are Addressed at Project Level / Further Analysis and Actions for Activity Design/ Implementation / Opportunities to Strengthen Climate Resilience
I. Strengthen ONM Operational Capacities
Support ONM’s operational capacities by providing support for three (3) additional staff / N/A / Low / N/A / N/A / N/A
Provision of tents and/or containers as well as portable toilets at the Port-au-Prince airport in which the registration process could be carried out / N/A / Medium / Ensure compliance with GoHrequirements / Verify plans for proper maintenance, cleaning and disposal of chemically treated sewage for port-a-potties. Can lead toenvironmental degradation / N/A
Refurbish, equip and expand ONM’s Reception Center / ONM’s reception center, if not properly refurbished, could be vulnerable to the effects of severe weather (e.g., heavy rainfall, flooding, high winds) if not built to international standards / Medium / Ensure that USAID engineering advice is made available to the grantee to advise on design and implementation standards / N/A / N/A
Work closely with the ONM to formalize a referral process for those returnees requiring documentation, / N/A / Low / N/A / N/A / N/A
II. Support the Reception and Reintegration of Returnees from the US
Provide transportation assistance from the point of entry to ONM’s Reception Center and onward transportation for returnees who wish to relocate outside of PAP / Transportation from point of entry and to onward destination could be potentially disrupted by severe weather / Low / Build flexibility into the timing and approach(es) to accommodate any disruptions or delays due to extreme weather events / N/A / N/A
Provision of food, water, medicine, and arrival kits to beneficiaries upon arrival and during stay at the ONM’s Reception Center / Procurement and delivery of food, water, medicine, and arrival kits could be delayed in the event of severe weather / Low / Ensure that there are adequate stocks in-house to accommodate new groups in the event of a severe weather situation / N/A / N/A
Provision of temporary accommodation in ONM’s Reception Center / Transportation from point of entry and to onward destination could be potentially disrupted by severe weather (e.g. floods, extreme storms) / Low / Ensure that the number of beneficiaries requiring accommodations and sent to the center does not exceed the capacity of the facility. Consider other institutions and social networks that exist and their capacity to provide alternate accommodations. / N/A / N/A

Approved: