3.0 DESCRIPTION OF THE PROPOSED ACTION

AND ITS ALTERNATIVES

## INTRODUCTION

The requirements of 22 CFR 216.6 state that the section of the EA
providing a Description of the Proposed Action and its Alternatives
should:

-   *"Present the ...(the Proposed Action) and its alternatives in
    comparative form, thereby sharpening the issues and providing a
    clear basis for choice among the options by the decision-makers."*

-   *"Explore and evaluate reasonable alternatives and briefly discuss
    the reasons for eliminating those alternatives which were not
    included in the detailed study;*

-   *Devote substantial treatment for each alternative considered in
    detail including the proposed action so that the reviewers may
    evaluate their comparative merits;*

-   *Include the alternative of no action;*

-   *Identify the Agency's preferred alternative or alternatives, if
    more than one exists;*

-   *Include appropriate mitigation measures not already included in the
    proposed action or alternatives."* [^1]

Accordingly, this section of the EA presents the brief description of
the Project's geographic setting, strategic context and implementation
framework, with the remainder of the section organized to address the
issues identified by 22 CFR 216 item-by-item as follows:

-   **The Proposed Action** (Item 3.1).

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-   **Alternatives Considered** (Item 3.2). These include:

\- The "No Action" Alternative (Item 3.2.1)

-   Alternatives Eliminated From Detailed Study (Item 3.2.2);

-   Alternatives Considered in Detail (Item 3.2.3); and

-   Comparative Analysis (Item 3.2.4)

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-   **Recommended Mitigation Not Included in the Proposed Action** (Item
    3.3)

**Environmental Setting**. The Kabul-Kandahar corridor is located in
southeastern Afghanistan - a country of 647,500 square kilometers making
it slightly smaller than the state Texas and slightly larger than
France. The country is landlocked and bounded on the west by Iran, to
the south and the east by Pakistan and to the north by Turkmenistan,
Uzbekistan and Tajikistan. It also has small border with Peoples'
Republic of China in the far northeast (**Exhibit 3.0 A**). Its
geography is dominated by Hindu Kush Mountains which run northeast to
southwest through the central region dividing the northern provinces
from the remainder of the country. The southwest is occupied by desert
plateau. The lowest point in the country is at Amu Darya at 258 meters
above mean sea level (msl). The highest point is at Nowshak 7,485 meters
above msl.

The Kabul-Kandahar Road is southeastern arc of what is often described
as a ring or circular road around the base of the mountains in the
central part of the country. It traverses the relatively flat to rolling
corridor linking Kabul, Afghanistan's capital and largest city in the
east-central part of the country, and Kandahar, its second largest city
located in the south-central portion -- and (using Kabul as the zero
kilometer) several intervening small communities including Ghazni (KM
134); Mukur (KM 238); and Qalat (KM 314) (**Exhibit 3.0 B**).
Rehabilitation of the Kabul-Kandahar Road is expected to consist of the
repair and in some instances reconstruction of approximately 482
kilometers (including the repair and/or replacement of bridges and
drainage structures). The entire length of the road is in extremely poor
conditions, but field investigations indicate that the conditions of the
road can be characterized in three sections:

-   KM 0 to KM 43 - paved, but in extremely poor condition.

-   KM 43 to approximately KM 432 -- Most of the road between KM 43 KM
    482 has "*deteriorated to a very rough, potholed gravel and dirt
    road. In some cases the potholes are over a meter deep and the size
    of a car*."[^2] Portions of the pavement have survived within this
    section, however, in the populated areas (Ghazni, Mukur, Qalat and
    elsewhere).

-   KM 432 to KM 482 (Kandahar) -- paved, but in extremely poor
    condition.

Details of the administrative and strategic context and the proposed
actions are provided below. Details of the existing conditions in the
potentially affected area are provided item-by-item under the headings
of the relevant environmental criteria in Section 4.0.

**Strategic Context & Implementation Framework.** As described in the
foregoing statement of Purpose (**Section 2.0**), rehabilitation of the
Kabul-Kandahar Road is part of the larger REFS Program devised to assist
Afghanistan's economic recovery. Rehabilitation of the road will occur
in a series of construction packages which are not yet fully finalized.
It is anticipated that the construction will be in the range of 40-50
kilometers and that other international organizations may fund certain
packages. Initial assessments indicate that the road segment from KM 0
to KM 43 (i.e., the existing, paved, dual lane section south of Kabul)
will require predominantly maintenance activities and constitute a
construction package to funded with the assistance of the Japanese
Government. The first construction contract to be funded by USAID will
address the segment from KM 43 to KM 92. The remainder of the highway
will be addressed in a series of construction packages in the 40-50
kilometer range and may also involve funding by organizations in
addition to USAID. The entire segment from Kabul to Kandahar is
considered to constitute the Project for environmental assessment
purposes so that the cumulative impacts of the actions are taken into
account.

**EXHIBIT 3.0 B KABUL-KANDAHAR ROAD**

Within those portions funded by USAID, rehabilitation and the
replacement and/or repair of bridges and drainage structures will be
conducted under the supervision of a USAID General Contractor
(USAID/GC). Sub-Contractors will be responsible for various portions of
the work on a Design-Build basis within the parameters established by
the USAID/GC. It is also important to note that arrangements for the
work will use the Conditions of Contract following the model established
by FIDIC, *Federation International Des Ingenieurs Conseils*
(International Federation of Consulting Engineers). FIDIC is the most
widely adopted format for road construction projects and its
construction management system is established primarily by three major
components:

-   **FIDIC General Conditions of Contract (GCOC)**. The contents of the
    General Conditions of Contract (GCOC) are generally adopted
    verbatim.

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-   **Conditions of Particular Application (COPA).** GCOC are
    supplemented by Conditions of Particular Application (COPA) to
    render the contract specifications project-specific. COPA provisions
    have been drafted for use in the Project. The COPA environmental
    provisions are reproduced herewith as **Appendix A**.

-   **Technical Specifications**. Technical Specifications for the
    highway will be prepared by the Sub-Contractors following the
    Design-Build approach adopted for the Project. The Technical
    Specifications must consistent with the GCOC and COPA.

**3.1 THE PROPOSED ACTION**

In accordance with the requirements of 22 CFR 216, the Proposed Action
is identified as the Agency's Preferred Alternative. Key aspects of the
rehabilitation activities proposed to apply to all portions of the
highway included in the Project are anticipated as follows:

-   **Rehabilitation Activities Confined to Existing ROWs.** Recommended
    maintenance activities are expected to be limited to work within the
    existing rights-of-way (ROWs), including minor widening, removing
    deteriorated or otherwise unsatisfactory layers of road structures
    and replacing them with new materials (aggregate and new pavement),
    straightening of some tight curves and improvement of drainage
    structures (as detailed below). Rehabilitation is expected to
    consist mainly of scarifying, leveling reshaping and compacting the
    existing roadway as necessary to meet acceptable standards.

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-   **Existing Number of Lanes To Be Maintained**.

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-   **Shoulder Widths Not Yet Finalized**. A typical two-lane cross
    section will consist of a 7.5-meter carriageway plus shoulders. Two
    shoulder width options are under consideration:

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-   1.25-meter shoulders on either side; or

-   2.25-meter shoulders on either side thus providing sufficient area
    for accommodation of non-motorized traffic (NMT) as well as
    emergency pull-off area.

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-   **Replacement of Six Major Bridges**. The bridges, their locations,
    lengths and widths are as follows:

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-   KM 46.1 7 meters long 8 meters wide

-   KM 262.2 18 meters long 8 meters wide

-   KM 294.8 12 meters long 8 meters wide

-   KM 297.7 32 meters long 8 meters wide

-   KM 300.8 40 meters long 8 meters wide

-   KM 387 42 meters long 8 meters wide

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-   Repair of 43 Additional Bridges - totaling 1,357 meters (for an
    overall total of 1,513 meters) will require rehabilitation.

-   Repairs and Replacements Of Culverts -- It is estimated that 28
    large and medium box culverts will require only minor repairs to the
    parapet walls. 77 small box culverts will require replacement of
    some of their headwalls and repairs to others. A large number of
    pipe culverts (currently estimated as approximately 4,800) ranging
    in size from 46 cm to over 200 cm, many with head walls missing,
    will be rehabilitated.

-   Bus/Truck Bays and Stops To Be Provided. Sub-Contractors will be
    required to consult and coordinate with the Ministry of Public Works
    (MPW) in regard to the necessity and locations of bus bays and stops
    and truck bays and stops. Acceptable areas shall be agreed upon with
    MPW staff and the necessary design and construction undertaken to
    the same engineering standard as used for the highway.[^3]

-   Actions as Determined Necessary at the Sites of "Mexican Bridges".
    Mexican Bridges (also known as "Irish Crossings") are road sections
    intentionally depressed to allow floodwaters to overflow the road
    unimpeded. It is anticipated that 33 sections totaling 9,363 meters
    will require corrective actions.

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-   Use of Local Labor. It is anticipated that contract specifications
    will include provisions to *"maximize the use of (locally hired)
    manual labor to the extent possible... and to use Afghan
    professional staff to the greatest extent possible and to mentor
    them, and give them greater management and implementation
    responsibility...*" in accordance with stated REFS objectives.[^4]

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-   **Contract Specifications to Ensure Control of Ancillary
    Construction Activities*.*** Ancillary activities include, for
    example, the development of base camps, labor camps and asphalt
    plants necessary for the implementation of the proposed
    rehabilitation activities. The environmental portion of the
    specifications is presented in their entirety in **Appendix A**.

-   **Little or No Residential Resettlement.** Given the rehabilitation
    nature of the Project, little or no resettlement and relocation
    actions are anticipated. Field investigations did not reveal any
    residential structures subject to impact.

-   **Compensation of Project-Affected Persons (PAPs)**. Commercial
    activities line portions of the road within the village bazaar areas
    through which it passes and will result in a number of
    project-affected persons (PAPs). Recommended guidelines for
    compensation requirements are provided by **Appendix B** and
    incorporated by reference in the COPA provisions.

**3.2 ALTERNATIVES CONSIDERED**

**3.2.1 The "No Action" Alternative**

The Agency Procedures specifically mandate documented consideration of
the "No Action" Alternative. The "No Action" Alternative in this
instance is defined as a decision not to undertake the proposed
rehabilitation of the Kabul-Kandahar Road through use of USAID funds. In
the absence of adequate local funds and/or other international funding
sources to undertake the required rehabilitation efforts, the "No
Action" Alternative would result in the continued deterioration of the
road, bridges and drainage structures along the ROW, thereby severely
impeding the economic recovery of the Project Area and the country as a
whole. All positive benefits would be foregone. The relatively minor,
less than significant environmental impacts (such as noise and
short-term air quality impacts due to maintenance activities) and
inconveniences (such as traffic diversions) would be avoided in the
short-run. In the long-run, however, the steadily declining state of the
roadway would severely cripple Afghanistan's recovery efforts. In light
of these considerations, the "No Action" Alternative is deemed to be
neither prudent not in the best interest of Afghanistan or those with an
interest in, and attempting to assist restoration of, Afghanistan's well
being.

**3.2.2 Alternatives Considered & Eliminated From Detailed Study**

Alternative approaches to road improvements may be discussed in terms
of:

-   [Site Alternatives]{.underline}. Site alternatives generally include
    alternative routes, re-alignments, by-passes and similar actions. In
    this instance, no alternative alignments, by-passes or similar
    categories of alternatives altering the site of the Proposed Action
    actions have been determined to warrant consideration.

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-   [Design Alternatives]{.underline}. The circumstances of the
    Kabul-Kandahar Road are such that it offers few design alternatives
    with meaningful differences in their environmental implications --
    with one exception, the widths of shoulders and their safety
    implications for accommodation of non-motorized traffic (NMT) and
    emergency pull-off areas.

-   [Technological Alternatives]{.underline}. All projects conducted as
    part of the REFS Program are required to *"maximize the use of
    (locally hired) manual labor to the extent possible... and to use
    Afghan professional staff to the greatest extent possible and to
    mentor them, and give them greater management and implementation
    responsibility...*" in accordance with stated REFS objectives.[^5]
    Consideration of technologically advanced and capital intensive
    approaches to road rehabilitation in these circumstances was,
    therefore, eliminated from detailed consideration.

3.2.3 Alternatives Warranting Consideration In Detail

Of the three categories of alternatives noted above, only one design
alternative is considered to warrant consideration in detail from an
environmental (Public Health & Safety) perspective. That issue is the
provision or lack of shoulders capable of accommodating NMT and
emergency pull-off areas.

**3.2.4 Comparative Analysis**

Incorporation of 2.25-meter shoulders (rather than the currently
proposed 1.25 meters) is recommended to provide adequate space for
emergency pull-offs and to accommodate non-motorized traffic (NMT). It
is recognized that the issue is one with significant budget
implications. It is, nonetheless, identified as a Recommended Mitigation
Measure Not Included in the Proposed Action (Item 3.3 below) in
accordance with the EA Content and Format provided by 22 CFR 216.

3.3 RECOMMENDED MITIGATION NOT INCLUDED

IN THE PROPOSED ACTION

The assessment indicates that mitigation actions have been incorporated
as warranted [within]{.underline} the design of the proposed
rehabilitation activities and the procedures for implementation,
specifically the contract provisions and construction supervision
activities as will be documented item-by-item in **Section 4.0**, with
the exceptions of:

-   **Finalization of shoulder width characteristics**. The provision of
    2.25-meter shoulders on both sides of the roadway is recommended,
    particularly in areas of high NMT and pedestrian activity. And

-   **Adoption of guidelines for compensation of PAPs**. Recommended
    Guidelines are provided by **Appendix B**.

In addition to these recommendations certain mitigation actions
[beyond]{.underline} the scope of the Project have been found to warrant
consideration to ensure good environmental management once the road
becomes operational, however. These include:

-   **Traffic Safety Programs**. Initiatives in this areas are
    recommended for consideration as part of REFS Component 2. The
    recommendation is further explained hereinafter as part of **Section
    6.0** (Compliance Procedures and Other Recommendations)

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-   **Enhancement of Roadside Economic Activities**. Consideration of
    market development activities in the vicinity of the Kabul-Kandahar
    Road is recommended as companion REFS Component 1 activities.

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-   **Coordination with Other Financing Organizations**. Rehabilitation
    of portions of the Kabul-Kandahar Road may be supported by
    organizations other than USAID, including other bilateral
    organizations and the multi-lateral development banks. The
    establishment of a reasonably consistent technical/engineering
    standards for the rehabilitation activities (e.g., the widths of the
    shoulders in areas with significant levels of NMT) is highly
    recommended. A reasonable consistency in procedural standards and
    requirements is also highly recommended. Other very closely aligned
    projects such as the World Bank's Emergency Infrastructure
    Reconstruction (EIRP) will require Afghanistan's ministries to
    establish reporting procedures and will provide the ministries with
    institutional strengthening mainly to ensure conformance with
    procedures established by the Bank. Coordination of the technical
    reporting and procedures expected by the ministries by USAID, the
    World Bank, the Asian Development Bank and others is highly
    recommended so that the burden on local organizations to supply
    essentially the same information in different formats is minimized.

-   **Coordination of Future Land Use & Transport Plans**. The long-term
    land use and urban development impacts of the Kabul-Kandahar Road
    Rehabilitation Project could be more significant than the short-term
    impacts of the construction period and are largely beyond the scope
    of the Project. REFS Component 2 can assist in the
    inter-governmental action necessary to monitor land use and urban
    development impacts and ensure that they are adequately managed in
    concert with other concerned agencies.

**END NOTES -- SECTION 3.0**

[^1]: 22 CFR 216 -- Agency Environmental Procedures, Paragraph 216.6.

[^2]: Afghanistan Civil Infrastructure Assessment, August 2002, page
    411/412.

[^3]: Draft Scope of Work, Kabul-Kandahar Highway Design and
    Rehabilitation, Part VII, Item 2.5, page 4.

[^4]: REFS Contract, page C-2.

[^5]: REFS Contract, page C-2.