1
Environmental Compliance and Mitigation Measures – Guidelines for Applicant Organizations
Every USAID-funded program is required to comply with the U.S. Government’s (USG’s) environmental regulations process and procedures that are
defined in Chapter 22, Part 216 of the US Code of Federal Regulations (22 CFR 216 ) often referred to as “Reg. 216”. These regulations outline the
Environmental Impact Assessment (EIA) that USAID has designed to identify potential effects —positive or negative— that a project or activity may have on
the environment. The prime objective of these procedures is to prevent activities that are likely to cause significant environmental harm and to ensure that
all project teams monitor and mitigate any negative effects on the environment.
As per Reg. 216, USAID requires that all projects funded through Small Grants and Ambassador’s Fund Program (SGAFP) shall be screened and reviewed
following these procedures. All organizations applying for funding are thus required to meet the environmental obligations set out in these regulations. The
role of SGAFP ensures that environmental consequences of USAID financed activities are identified and considered prior to a final decision of proceeding
with the financing. Pursuant to this, a screening procedure is conducted at SGAFP starting from the application stage and the findings are incorporated into
the final documents. The role of applicant however, is to confirm that application submitted is in line with procedures set out in reg. 216.
While USAID and SGAFP usually conduct significant portions of the screening process, an organization is typically responsible for assessing its project’s
compliance with the regulations and submitting verification for USAID approval. SGAFP has set out some simple procedures that applicants and grantees
are required to follow. For additional information or clarity, applicants are encouraged to contact SGAFP through email or telephone. The following table
sums up the stages that applicants are required to follow:
S. No.
Step(s)
Pre Award
1
Submission
EDF forms
Description
of The environmental consequences of any proposed intervention (if any) need to
be identified, mapped and addressed at the planning & design stage. Considering
this an applicant’s first responsibility is to complete & submit the Environmental
Documentation Form (EDF) attached with this document. (Please see
attachment 1 to understand the terms used in “Section B” of EDF
particularly for activities that may fall under “Categorical Exclusion”
and “Negative Determination with Condition”)
Forms to be filled
Responsibility
EDF Form
Applicant
Organizations
2
S. No.
Pre Award
Step(s)
Description
Forms to be filled
Responsibility
IA Form
SGAFP
Note: Incomplete applications are not entertained at SGAFP.
2
3
Cross Checking
of EDF
Summary
Processing
4
Grant
Agreements
Preparation
5
Compliance
Monitoring
6
Verification
SGAFP’s field teams cross check the completed EDF form along with other
information provided by the applicant during the institutional assessment.
While preparing summary, SGAFP will make sure that items associated with all
environmental concerns are taken into account. Also, mitigation measures and
compliance having cost implications are reflected in the project budget under
USAID’s share.
A grantee specific Environmental Mitigation and Monitoring Plan (EMMP) will be
prepared based on the activities mentioned in EDF. This is a work plan item thus
Mitigation Measures and Compliance procedures will be entered into the project
work plan particularly the milestones on basis of this EMMP and hence
incorporated in the Grant Agreement by SGAFP.
& Grantee’s responsibility to comply with USAID’s environmental regulations does
not end when their program begins. Monthly reporting against that formats
prescribed in grant agreement is obligatory for the Grantee. On monthly basis
Grantee’s are expected to provide records of environmental compliance,
indicating how they monitored and complied with their mitigation plan. For this
purpose the EMMP will serve as a “checklist” clearly defining the timeline and
respected Means of Verification (MOVs) for each mitigation measures outlined.
Updating of these checklists is mandatory for Grantee and these are required to
be annexed with the Monthly Progress Reports (MPRs) of each month.
The annexed EMMP is then verified by SGAFP staff during their routinely
monitoring field visits. In case of non-compliance the installment of the following
month is not released until the non-compliance issue is resolved, through
dedicated visits by engineers for this purpose.
SGAFP
SGAFP
Updated EMMP
Form & MPRs
Grantees
NFRs
SGAFP
3
Attachment 1: Please refer to the following “Summary Table” to understand “Section B” of EDF form.
Activities
Categorical Exclusion
 Project/ Program Management
 Developing sound monitoring and evaluation techniques that report
on impact and not just outcomes
 Ensuring the sustainability of funded initiatives
 Miscellaneous durable goods –stove or refrigerator for a school or
hospital; washing machine for a clinic.
 Technical assistance, education, training programs except to the
extent such programs include activities directly affecting the
environment
 Financial, accounting, management and other capacity building
 Community mobilization/ organization efforts
 Funding watch-dog organizations to monitor activities
 Training for preparing grant proposals
 Analysis, studies, workshops and meetings





Effects
on Determination and Regulations 216 action required
natural
or
physical
environment
No adverse effect Categorical Exclusion per 22 CFR 216.2 (c) (1) (i)
on the natural or
physical
environment
No adverse effect Categorical Exclusion per 22 CFR 216.2 (c) (2)(i)
on the natural or
physical
environment
No adverse effect Categorical Exclusion per 22 CFR 216.2(c) (2)(iii)
on the natural or
physical
environment
No adverse effect Categorical Exclusion per 22 CFR 216.2 (c) (2)(v)
Document and information transfer
Public outreach campaigns, including development of print or other on the natural or
physical
media
environment
Discussion panel (s) organized to discussion television/radio
Public service announcement (PSAs) for television and radio distinctive
produced
Activities that will develop the capability of recipient countries to No adverse effect Categorical Exclusion per CFR 216.2(c) (2) (xiv)
on the natural or
engage in developing planning
physical
environment
4
Activities
Effects
on Determination and Regulations 216 action required
natural
or
physical
environment
Negative Determination with Condition
 Upgrade the capabilities of existing training, education and health Minor to moderate
facilities through physical site upgrade, provision of equipment, etc. adverse effects on
the natural or
physical
environment

Provision of school equipment and supplies, desks, chairs,
laboratory equipment and library items.

Provision of income generating equipment weaving looms, tools for
furniture making, rice-milling machine. Communal Construction
equipment such as brickmaking machine. Provision of computers, IT
Negative Determination with Conditions per 22 CFR
216.3 (a) (2)(iii)
Conditions are that these systems have a site specific
EDF with an EMMP to be reviewed and approved by
the COR/AOR
The recipient (grantee) will properly manage and dispose
equipment (computers, electric power generation &
distribution equipment, laboratory equipment, etc.) when its
useful life ends. All such equipment will be disposed in an
environmentally safe manner by a certified company in
accordance with Pakistani laws, and in their absence, in
accordance with international best practices acceptable to
USAID (alternatively, when procuring equipment from a
licensed provider/dealer an agreement may be reached that
such equipment will be returned to the dealer for its
environmentally safe disposal). For procuring of electronic
and miscellaneous equipment and furniture, the implementers
will adhere to USAID’s general policies on commodity
eligibility
provided
at
http://www.usaid.gov/policy/ads/300/31251m.pdf and will not
finance unsafe or ineffective products, such as certain
pesticides, food products, or pharmaceuticals and other
commodities not eligible for financing under this policy.
Minor to moderate Same as above.
adverse effects on
the natural or
physical
environment
Minor to moderate Same as above
adverse effects on Conditions are that these systems have a site specific EDF
the natural or with an EMMP to be reviewed and approved by the
5
Activities
Effects
on Determination and Regulations 216 action required
natural
or
physical
environment
equipment, multimedia equipment, generators or other electro- physical
COR/AOR.
mechanical or electronic equipment etc.
environment
 Small-Scale rehabilitation/improvement and operationalization of
existing infrastructure/buildings
 Small-Scale construction projects (Less than 10,000 sq. ft) school
rooms, community centers, health facilities, foot bridges, housing
for a government or community paid nurse or teachers,
workshops, community abattoir, grain storage, rural airstrip for a
hospital, and school dormitory for distant students
 Water related projects, wells, latrines, pumps, bore holes, shower
stalls and wash basin, fish ponds
not assisted under SGAFP
 Grants that use or fund pesticides
 Grants That generate medical waste for human or animal treatment Minor to moderate Negative Determination with Conditions per 22 CFR
 Grants that fund activities that produce or dispose of solid or liquid adverse effects on 216.3 (a) (2)(iii)
the natural or Conditions are that these systems have a site specific
waste
physical
EDF with an EMMP to be reviewed and approved by
 Grants that fund agriculture projects/activities.
environment
the COR/AOR and the MEO/DMEO
 Any grants that the COR/AOR desires the MEO/DMEO to review.
For all other NDC activities that are not falling under below categories:
Minor to moderate Negative Determination with Conditions per 22 CFR
 Grants that generate medical waste for human or animal treatment adverse effects on 216.3 (a) (2)(iii)
the natural or Conditions are that these systems have a site specific
 Agriculture project grants
physical
EDF with an EMMP to be reviewed and approved by
environment
the COR/AOR and the MEO/DMEO
USAID Disclaimer: This application guideline for the Ambassador’s Fund Program is made possible with support from the American people delivered through the United States Agency for International Development (USAID).
The contents are the sole responsibility of National Rural Support Programme (NRSP) and do not necessarily reflect the views of USAID or the United States Government.