## Attachment 1: Using USAID Environmental Procedures Strategically 

## Charlotte Bingham, Regional Environmental Advisor, REDSO/ESA and Walter Knausenberger, Environmental Analyst and Advisor, AFR/SD/ANRE for the USAID Environment Officers Workshop July 1999 {#charlotte-bingham-regional-environmental-advisor-redsoesa-and-walter-knausenberger-environmental-analyst-and-advisor-afrsdanre-for-the-usaid-environment-officers-workshop-july-1999 .unnumbered}

Two AFR regional environmental staff offer this brief thought piece,
because we want to share our experience in applying USAID environmental
procedures, but could not be present at the Environment Officers
Workshop. We are informed by the experience of the Africa Bureau over
the past five years. The challenge for environmental officers is to
ensure compliance with the expectations of USAID's Environmental
Procedures in a re-engineered institution and, at the same time, promote
enhanced authority, responsibility and accountability in the field.

Section 1 sets the stage with a stereotypical look at how USAID
Environmental Procedures, as we sometimes encounter them, barely qualify
as compliance. Section 2 describes a way to achieve the legitimate role
of compliance with 22 CFR 216 (Reg 216) and ADS 204. Section 3 suggests
how we can use the regulation strategically and in ways that satisfy the
ultimate objectives of Reg 216 ---environmentally sound activities and
the promotion of environmental policies in order to achieve our
development mandate.

#### 1. How limited and ineffective can the use of Reg 216 be?[^1] {#how-limited-and-ineffective-can-the-use-of-reg-216-be .unnumbered}

Environmental procedures are applied at the last minute, evidenced by
the number of Initial Environmental Examinations (IEEs), the most
typical form of documentation, done in late August and September in the
race to complete obligations by 30 September. A Regional Environmental
Officer (REO) or Mission Environmental Officer (MEG) is in popular
demand and the Bureau Environmental Officer (BEG) hits the top of the
charts.

Considerations that could be part of a meaningful IEE have no chance to
influence planning and design. The IEE is perceived as a bureaucratic
hurdle or even an impediment. Using Reg 216 as an opportunity to achieve
environmentally sound development is lost.

When the IEE is an afterthought and done hurriedly, the Strategic
Objective (SO) or Results Package (RP) team is not engaged in shaping
it. The team will probably not have understood or even agreed
wholeheartedly to IEE conditions for how an activity is to proceed or
thought about resources for monitoring. Worse yet is the IEE that
commits an implementing partner to carry out conditions, but the partner
has never seen or been apprised of the IEE.

Once the IEE is approved, the SO or RP team sighs with relief and,
perhaps files it, too often never to look at it again. ADS 204 clearly
sets out this responsibility to do so, but just ask anybody on an SO
team if they know what ADS 204 is about.

The IEE, comfortable in its file drawer or lost to the SO team's
consciousness, becomes hopelessly out of synch with how activities
evolve, deferrals remain unresolved and conditions are not met.

As SO team leaders and MEOs rotate out of their positions, institutional
memory is lost. A new team leader rarely becomes aware of the IEEs (now
in the file or packed up in storage) associated with the SO's activities
and probably has forgotten ADS 204.

**Too little, too late, and mostly forgotten. Reg 216 documents that sit
in file drawers are valueless.**

#### 2. Moving Toward More Effective Compliance {#moving-toward-more-effective-compliance .unnumbered}

How do we (or should we?) move beyond the common perception that one is
following the agency's environmental procedures just fine as long as the
Mission has a signed piece of paper from the BEO? Succinctly put by one
Mission Director, faced with the need to follow-up on an IEE: "What
happened to the good old days when we just 'did' these documents? Are we
doing this now to ensure that BEOs and REOs have jobs?" Mere filing of
documents is necessary but hardly sufficient for effective compliance.
Reg 216 certainly views compliance as a process that has the objective
of environmentally sound development, but then who reads Reg 216?

*The BEO, REO and MEO read Reg 216.* We are facilitators and
gatekeepers. As facilitators we assist Missions technically by providing
information and regional perspective and by stimulating
cross-fertilization of ideas among Missions. We can encourage SO teams
to think about an environmental review and planning process and help
prepare Reg 216 documents that have environmentally sound development as
a prime objective. We can introduce new tools, approaches and sources of
information and data. As gatekeepers, we can cajole and use the "velvet
hammer" of the regulation. Compliance is mandatory, but we do try to be
"nice" and, even, logical, persuasive and supportive of enlightened
self-interest. The two roles, effectively played, can nicely complement
each other.

But it is the SO team that implements and monitors the activities for
which the Reg 216 documents are written. The team's role is pivotal, as
reflected in ADS 204.

The Africa Bureau has had considerable success with the annual portfolio
review, an optional review but the first step on the high road to using
Reg 216 strategically. At this annual check-up, preferably early in the
year prior to the R4, the MEO (with or without the REO) and the SO team
leader look over the status of all current activities and the contents
of associated IEEs and determine what IEE promises were not fulfilled
or, in some cases, either made no sense or have been overtaken by
changing events.

Together (together is a key word) the SO team and the MEO can develop a
plan---what situations need to be remedied, what new activities need Reg
216 documentation, what activities need new documentation. The portfolio
review may reveal opportunities to consolidate several old IEEs that
need modification within anew SO-level or RP IEE. Once the portfolio
review is done, the R4 section on environmental compliance is
ready-made.

The portfolio review is also an occasion to review ADS 204, pertinent
parts of Reg 216 and the often forgotten provisions of FAA 118 and 119
concerning forests and biodiversity, which call for Environmental
Assessments in specific circumstances or prohibit funding in others.
Attention can be drawn to new guidance, such as this year's tobacco
guidance, concerns regarding water quality testing for parameters such
as arsenic or issues surrounding biosafety (genetically modified
organisms in agriculture or vaccines, for example). In several cases,
the portfolio review, when assisted by the REO or SD, has become genuine
training and mentoring for the MEO.

Two other mechanisms to promote compliance are the AFR BEO's REONET
(intermittent newsletter to the field) to alert MEOs to some pesky old
issues and new ones and Mission Orders. A few Missions have requested
these and we have shared with ENI. The trouble with the Mission Order
approach is ---who reads old Mission Orders and who updates them? A
third option, suggested in ADS 204, is that the MEO be a member of each
SO team, not yet commonplace in AFR Missions.

Whatever the form of assistance that BEO, REO and MEO may offer in their
roles as gatekeepers or facilitators, the trickiest, but most
fundamental to achieving effective compliance is convincing an SO team
to take ownership of environmental commitments. When ownership occurs,
we change the perception that Missions and teams that Reg 216 is
uniquely the job of the MEO, REO and BEO happy and that one puts up with
such bureaucratic nonsense, because one has to keep them happy or that
velvet hammer might turn to stone.

**Two principles characterize effective compliance** (and the first
steps toward using Reg 216 and ADS 204 strategically):

a)  **SO teams (and their partners) must take responsibility for how
    environmental procedures affect them** and not view IEEs or other
    documents as an externally imposed requirement;

b)  **MEOs and REOs cannot operate in a vacuum.** They need to
    collaborate with an SO team and their partners in beginning,
    preparing and following up on Reg 216 processes. There is no sense
    in imposing conditions that an SO team would not realistically
    accomplish.

#### 3. Strategic Use of Reg 216---Using and Going Beyond Compliance to Achieve Results {#strategic-use-of-reg-216using-and-going-beyond-compliance-to-achieve-results .unnumbered}

How can we move from compliance to a process of considering the
environment throughout the project cycle (from planning through
implementation and closeout) and even seeing the results of compliance
as reportable results?

Once an SO team and a Mission have adopted the annual portfolio review
and begun to see Reg 216 as an SO team responsibility, it is possible to
travel the high road of using Reg 216 strategically. One result of
applying the environmental procedures in this way is to integrate
compliance or conditions into an activity design. Or, the environmental
procedures can be used as a means to leverage better results, results
that can be reported. Some examples follow.

-   **Being aware of technical and procedural options.**

USAID funds a lot of health programs. Directly or indirectly, health
programs generate medical waste. Nearly every health program can build
in awareness of medical waste issues, ranging from a small investment in
looking at policy and procedures to simply impressing upon implementing
partners the ways in which they can become proactive with those to whom
USAID is providing technical assistance. Putting medical/health waste
management and disposal practices into operation is a useful
accomplishment (and it can be reported).

-   **Promoting linkages.**

Economic growth SOs (whether agriculturally oriented or more broadly
trade. investment and enterprise oriented) as well as E/NRM SOs can
f9ster linkages that encourage adoption of environmental standards
(e.g., ISO 14001, multilateral environmental agreements), eco-labeling,
green sourcing or green certification and support growth of
environmental businesses. One Mission has made the promotion of linkages
among SOs a conscious effort. Macro and sector economic policies can
promote changes in environmental policy, as some of the recent
experience with the Asia Environment Program (AEP) and the African Trade
and Investment Reform Program (ATRIP) awards demonstrate.

Promotion of active civil society around environmental issues is
happening in several places, both promotion of environmental advocacy in
DO SOs and the use of environmental screening and review processes for
community grants under DO activities.

-   **Devolving responsibilities to partners and providing training in
    environmental review.**

The training and capacity development of USAID partners in principles
and practices of environmental assessment is a reportable result,
especially within an E/NRM SO, and with creative thinking in other SOs.

SOs of several AFR Missions follow a standardized, but flexible, process
to screen and review grants and subgrants made under an umbrella
activity. (See Africa Bureau's Environmental Guidelines for Small-Scale
Activities in Africa for a brief description or request sample IEEs of
this type.)

Several AFR Missions have versions of a road-specific environmental
screening and review process that requires the implementing partners to
perform post-IEE environmental reviews of road rehabilitation (mostly
minor or farm-to-market roads). These reviews can be done when there is
information about the specific roads and when one can reasonably know
what mitigative measures might be needed or if Sections 118 and 119 of
the FAA might be contravened. A realistic decision about the need to do
an Environmental Assessment can be made.

The devolution of responsibility to prepare IEEs to Cooperating Sponsors
of Title II PL480 development food aid activities has been a heartening
experience. The Environmental Documentation Manual for P.L. 480 Title
III Cooperating Sponsors, prepared in collaboration with the Food Aid
Management Environmental Working Group and BHR, has allowed some
sponsors to prepare IEEs without previous training or experience. The
Manual has greatly facilitated training many of the sponsors to the
point where several know more than the MEOs with whom they interact. The
annual use of an Environmental Status Report allows the sponsors to
self-report on their progress with monitoring and mitigation and has a
guided set of questions to help a sponsor determine if the IEE should be
amended.

-   **Reaping the benefits of sharing IEEs and their conditions with
    partners.**

A spin-off with one USAlD partner responsible for an agricultural
promotion project was that those who were responsible for preparing road
reviews decided to adapt the process to other activities, without
prompting by USAID. A deliberate spin-off in another location was to ask
NGOS working in a region to become informal "eyes and ears" to monitor
indirect effects of road construction, such as forest encroachment or a
lot more logging.

A CBNRM project in southern Africa with a major Development Fund has
developed a grant procedures Manual, in which environmental review plays
a significant, upfront planning role.

Coordination of USAID procedures with host country environmental
procedures has been foreseen and made coherent so that grantees can
submit one document for the approval of both entities.

Three PVOs in one country ---all proposing agricultural intensification
programs with USAID funds ---decided to combine efforts to carry out an
environmental review of lowland development, which one PVO had
independently decided was needed. It was relevant to all three PVOs and,
coincidentally but aptly, responded to the conditions laid out in their
IEEs.

-   **Leveraging Reg 216 compliance to achieve environmental assessment
    capacity development with host country agencies.**

One Mission is conducting a Programmatic Environmental Assessment (PEA)
in collaboration with the host country National Parks Authority for
roads in national parks. This PEA will not only satisfy USAID Reg 216
procedures, but more importantly aims to build the capacity of the parks
agency in environmental review, which also has environmental impact
assessment policy, and will result in a guidance document that the parks
agency can use for all its roads---not just those that USAID funds.

-   **Working with host country governments to achieve environmental
    assessment.**

One of the East Africa missions completed an Environmental Assessment
for Water Hyacinth Control that also satisfied host country
environmental procedures. As one of the first and the first
controversial Environmental Impact Assessments in that country, some
important lessons were learned about public participation and
consultation.

-   **Training and Re-inventing the MEO.**

The Africa Bureau has taken seriously the training of its MEOs to help
them understand their roles better and become more proactive. A
proactive MEO provides not only the stimulus to help SO teams achieve
compliance but becomes an active agent for environmental sustainability.
The MEO's function is described in ADS 204, but needs to be incorporated
within position descriptions. \[As one MEO said, why should I bother if
I won't even be evaluated on how well or how badly I might do at this
function?\].

MEOs maintain the best continuity and become the Mission's long-term
institutional memory, when an FSN (or sometimes a long-temt USPSC) is a
co or adjunct I\\I1:EO or when he/she is the MEO. Sometimes, however,
FSNs, feel they lack clout and/or empowerment. Can empowerment and clout
be gained through training and as re-engineering moves along?

Nevertheless, sharing the MEO role with an FSN reaps benefits beyond Reg
216. Capacity is gained as human resources are developed.

**Lesson to learn: Reg 216 and ADS 204 represent a process, not mere
documents. The people, including ourselves and all our partners, who
design, implement and monitor activities are integral to achieving
environmentally sustainable results that not only satisfy the
Environmental Procedures but make environmental sense.**

#### 4. Africa Bureau Environmental Office's Approach to Devolving Responsibility to the Field {#africa-bureau-environmental-offices-approach-to-devolving-responsibility-to-the-field .unnumbered}

In 1994/5, the Bureau sought and received approval from Agency legal and
environment staff to devolve to USAID Missions significantly enhanced
responsibility for environmental compliance and decision-making. While
delegation of authority to approve the "foundation" environmental
documentation (IEEs, EAs, etc.) is not legally possible under Reg. 216,
AFR has promoted devolution of responsibility for approval of
small-scale activities and, especially, small grants and sub-grants. The
approach rests on a strategy of environmental capacity building, which
has provided environmental guidelines, technical assistance and
environmental assessment training to upgrade Missions' and implementing
partners' capacity to carry out effective environmental review and
program implementation.

The Bureau has introduced a practical innovation, an Environmental
Screening and Reporting Form (ESF) consistent with Reg. 216 and
described in the umbrella IEE that sets forth a process for post-IEE
environmental review. Use of this tool has significantly reduced the
number of IEE actions needing to be sent to Washington. Typically, the
umbrella or SO-level IEE that facilitates delegation of responsibility
also includes a combination of the following conditions: a) preparation
of a programmatic or sectoral environmental assessment; b) training and
capacity building; c) application of a set of guidelines (including
monitoring and mitigation of impacts); d) holding SO teams accountable
for environmental soundness; and (e) creation of an on-going monitoring
process.

The primary mechanism that supports these efforts is the Environmental
Management Capacity Building Program or ENCAP. Initially developed with
the USAID/G/ENV EPAT Project, ENCAP is now carried out through the
Environmental Policy and Institutional Strengthening IQC, or EPIQ. ENCAP
sets out to strengthen environmental review, management and monitoring
capacity among USAID contractors, grantees and host country
collaborators. ENCAP has facilitated over 15 environmental assessment
training workshops in the past five years, in at least 12 countries,
reaching over 600 people in some 250 organizations working with USAID.

22 July 1999

newroad-722

##  {#section .unnumbered}

## USAID Environment Officers Workshop {#usaid-environment-officers-workshop .unnumbered}

## Charlotte Bingharn, Regional Environmental Advisor, REDSO/ESA and Walter Knausenberger, Environmental Analyst and Advisor, AFR/SD I ANRE {#charlotte-bingharn-regional-environmental-advisor-redsoesa-and-walter-knausenberger-environmental-analyst-and-advisor-afrsd-i-anre .unnumbered}

## 20 July 1999 {#july-1999 .unnumbered}

## Is Reg. 216 Ripe for Revision? {#is-reg.-216-ripe-for-revision .unnumbered}

Some food for thought and discussion...

22 CFR 216 has lasted for 20 years. Its stated purpose and policy
(216.1) remain relevant. Because it is not easy to change a regulation,
any new or revised regulation should provide a process that allows for
adaptation and flexibility without needing to change the regulation
itself.

Principle: Keep the regulation focused on objectives, policy, process
and procedure so that it can be a flexible and adaptive tool and not a
straightjacket.

Several identified wishes and needs are listed below. These are not
meant to be exhaustive. We note that some of the items deal with topical
issues, which need only be referenced in a regulation, as internal
guidance can be more easily changed than a regulation. Let us keep in
mind the question---is the Regulation broken enough to justify fixing,
when fixing is not an easy process (see commentary at the end)? Would
our efforts be better directed to strengthening implementation within
the boundaries of the current regulation?

> 1\. Create a more user-friendly regulation with greater relevance to
> current operations, especially by incorporating the principles and
> language of reengineering and the concept of SOs. Not only is the
> terminology out of date, but the operating paradigm has changed.
>
> 2\. Emphasize more the need for upstream consideration of
> environmental impacts in planning and design. Introduce newer concepts
> such as Strategic and Sectoral Environmental Assessment.
>
> 3\. Emphasize more the downstream monitoring of environmental
> compliance and the role of audits.
>
> 4\. Reference and get in touch with the fact that host countries
> increasingly have their own operative environmental procedures which
> should be taken into account (see also related Item 10).
>
> 5\. Affirm the role of MEOs and partners. \[With or without Reg 216
> revision there is need for some action, through position descriptions
> or other appropriate agency procedures to achieve greater "standing"
> for MEOs.\]
>
> 6\. Provide clearer and up-dated guidance on applying environmental
> procedures to NPA, policy reform, and sectoral or structural
> adjustment.
>
> 7\. Allow for a Negative Determination with conditions that follows
> design criteria, agency guidance or results of a Programmatic
> Environmental Assessment. \[Currently, design criteria, if they were
> to exist, would permit Categorical Exclusion 216.2(c)(xv), but a Neg
> Det with conditions would appear to be a more sensible and less risky
> way to proceed.\]
>
> 8\. Better define Negative Determination criteria, including
> characterization of possible conditions for mitigation and/or
> monitoring, which are to be implemented to justify a ND.
>
> 9\. Eliminate the Negative Declaration or link it better to design
> criteria or standards and/or to a Negative Determination with
> conditions.
>
> 10\. Reflect and reference the development of host country and
> multi-lateral environmental assessment procedures, of which there are
> many since 1980, as the regulation does not provide an easy mechanism
> that would allow USAID/Missions to use documentation produced under
> multi-lateral or host country procedures (except 216.9, which requires
> Administrator approval).
>
> 11\. Reference how the Agency intends to handle environmental
> documentation when more than one agency is involved, e.g.,
> Ambassador's Self-Help Fund, USA Army or US Navy assistance on project
> work to build roads or fix ports that would typically entail another
> type of review by USAID), monies transferred to DOA or others, funding
> situations such as the BNC in South Africa.
>
> 12\. Reference relationship of the regulation to FAA 118/119, other
> pertinent FAA provisions, Tropical Forest Conservation Act, other
> pertinent recent legislation, and key multi-lateral environmental
> agreements, etc. Indicate that future changes to the F AA or other
> legislation must be considered.
>
> 13\. Address the applicability of the Environmental Procedures or
> analogous principles to transitional, food aid, emergency and relief
> situations.
>
> 14\. Reconsider and make more specific the types of projects normally
> requiring an EA.
>
> 15\. Reference to guidance or guidelines or policy recently emerging
> issues, such as biotechnology, genetically modified organisms,
> biosafety, biomedical wastes, etc. For biosafety, we understand
> guidance is in the wings. A revised regulation could, for example,
> refer to some series of guides that would provide such information
> that could be regularly updated.
>
> 16\. Update the Pesticide Procedures regularly, and merely refer to
> them in Reg 216, rather than detailing them, so they can be adapted
> over time and be more useful to practitioners. Pesticide procedures in
> current Reg 216 have the diversionary or counter-productive effect of
> being so hard to deal with that USAID staff and partners tend to avoid
> engagement with pesticides. The result is to encourage funding for
> pesticides by others with less stringent standards or not to use them
> when they could be useful. Currently, there is insufficient emphasis
> upon Integrated Pest Management; USAID) needs to address issue of
> botanical pesticides derived from products abroad that USEP A would
> likely never register.

## Commentary {#commentary .unnumbered}

ADS 204 already addresses reengineering terminology as well as the need
to consider environmental impacts early and monitor projects/activities
during implementation. There are other documents that provide guidance
on NPA. Biosafety or other emerging issues can be covered separately
through guidance. Guidance or information that does not need to be part
of a regulation could also cover the multi-agency funding question.

Nothing appears to prevent us from promoting host country procedures
through joint reviews and assessments done in tandem and in
collaboration. Getting to the point of agreeing when host country
procedures could substitute for USAID procedures is likely to be more
difficult. Harmonization or coherence, as the World Bank sometimes
describes it, is simpler to achieve when one needs to change policy as
opposed to codified regulations.

Because the regulation already contains detailed requirements for
pesticides, it is difficult to update and change pesticide procedures to
make them more flexible, without changing the regulation itself.

In order to provide reference to design criteria or standards for a
negative determination with conditions, the regulation would also
require revision. The same can be said in order to use as our own
documentation the impact assessments produced as a result of host
country or multi-laterals' procedures and not require AA or A approvals
(A or AA for a negative declaration or A under 216.9). The need to
utilize design criteria and/or rely on documents produced by other
reliable and credible sources is especially important in the context of
a decreasing cadre of technical staff within USAID. This dwindling
technical capacity underlines our increasing vulnerability with regard
to environmental compliance.

The downside of revising Reg 216 is that changing a regulation is
time-consuming, not just on the part of the people who would do
revisions, but time-consuming, because it is a "regulation," which
requires Federal Register publication, public comment and response to
comments. Revisions of regulations can take a year or years. The process
is inevitably political and will attract the attention of varied and
conflicting groups with different agenda. There will be pressures to
weaken an environmental regulation as well as pressures to make USAID's
procedures mirror or become more like those that regulate US domestic,
federal activities.

If the Agency were to contemplate revising the regulation, US
environmental NGOs would need to be brought into the process early on,
so that they could understand and not oppose why USAID environmental
procedures might need to be different from US Council on Environmental
Quality regulations. The risk is that one might end up with less
flexible regulations.

In the final analysis, it is the ADS 204 that can evolve where Reg 216
can't, to re-interpret or improve the applicability of environmental
procedures. Also, Bureaus can develop their own supplemental guidance.
This would help for anything we want to add or explain more, but at
least a few of the concerns could not be fixed that way because they
would potentially be in conflict with the regulations ,unless GC can
help us find some creative ways to do so. This applies especially to the
dated pesticide procedures section of Reg. 216, or the negative
determination with conditions, although we could certainly explain that
in ADS 204 as a very helpful variation on the straight negative
determination.

#  {#section-1 .unnumbered}

# Attachment 2: Environmentally sound design[^2] {#attachment-2-environmentally-sound-design .unnumbered}

## What Is Environmentally Sound Design? {#what-is-environmentally-sound-design .unnumbered}

For the purposes of these guidelines, environmentally sound design (ESD)
is the design and implementation of activities and projects such that
the environmental impacts associated with meeting a particular
development objective are kept to a practicable minimum.

Environmentally sound design is prevention-based across the project
lifecycle. Prevention begins with the choice of means by which a
development objective is achieved. For example, the development
objective (or goal) of a project or activity may be to improve
agricultural productivity. Potential means to achieve this objective
include: introducing new crop varieties, promoting the use of chemical
inputs, introducing irrigation, changes to tilling and soil conservation
practices, integrated pest management, or some combination of these
measures. Environmentally sound design dictates that each alternative be
considered, and that the environmental impacts associated with each
choice be weighed alongside technical, economic, and social criteria.
Once means are chosen, environmentally sound design also takes a
prevention-based approach to the specifics of project design. Can
changes to location, construction techniques, or operating practices
significantly reduce critical environmental impacts? Finally, where
impacts cannot be prevented entirely or minimized by design choices,
environmentally sound design mandates that they be mitigated during
project operation, or remediated after the project is decommissioned.

## Environmental Assessment: A Process for ESD {#environmental-assessment-a-process-for-esd .unnumbered}

Environmental assessment (EA) is a formal process for identifying the
likely effects of particular activities or projects on the environment
and on human health and welfare. As such, EA is a tool to organize,
facilitate and document the practice of environmentally sound design.
Stated another way, environmentally sound design is the goal or
objective of any EA process. EA is useful both to project designers and
planners and to those who must assess project proposals for funding.

## Environmentally Sound Design and Sustainable Development {#environmentally-sound-design-and-sustainable-development .unnumbered}

Sustainable development is the overall objective of any process of
economic and social development. Meaningful movement towards more
sustainable development requires both (1) that development activities
themselves be sustainable, and (2) that a set of enabling conditions be
fulfilled.[^3] Because ESD occurs at the project or activity level, it
addresses this first sustainability requirement: ESD is an essential
component of designing and implementing sustainable activities.

As its name implies, ESD is concerned primarily with environmental
sustainability. Because ESD is concerned with environmental justice, it
also has an important application to social sustainability, however.
Environmental justice is the idea that the poor should not bear a
disproportionate burden of the negative economic and health consequences
of environmental degradation.

## Environmentally Sound Design and Best Development Practices {#environmentally-sound-design-and-best-development-practices .unnumbered}

ESD requires that the environmental impacts associated with projects be
identified, predicted and mitigated. This is not sufficient, however.
Environmentally sound design must adhere to a set of principles which
apply to sound project design, management and implementation *in
general.* These principles have grown out of the experience of
development organizations in the field. In very general terms, they
represent a current consensus on "best practice" in development that
includes: assuring technical feasibility, understanding the social and
policy context, securing stakeholder commitment, engaging in supportive
capacity-building, and practicing adaptive management.

### Assure technical feasibility {#assure-technical-feasibility .unnumbered}

All projects must be technically feasible. The construction techniques,
materials, and technologies employed must deliver as intended over the
lifetime of the project.

In the area of environment, technical feasibility means that the design
is appropriate and robust to the environmental conditions of the project
site. Environmental conditions include climate (patterns of rainfall,
temperature ranges), soil types, aquifer characteristics, and the
probability of extreme events such as cyclones and earthquakes. For
example:

-   Are the choices of crops or trees appropriate to climate and soils?

-   For buildings and infrastructure, are construction methods and
    materials appropriate to the anticipated use and lifetime, given
    environmental conditions?

### Understand social and policy context {#understand-social-and-policy-context .unnumbered}

Projects and activities do not exist in isolation. They are implemented
within an environmental, social, economic and institutional context.
This context can determine whether a project or activity is viable or
even desirable. Social and policy context issues particularly important
to ESD include:

**De facto and de jure national environmental and resource management
policy.** Project design and implementation should conform to national
environmental laws and regulations. They should be compatible with
national environmental strategy (as set out in National Environmental
Action Plans). However, there is often a large difference between
official environmental law or policy in Latin American countries, and
what is actually implemented and enforced in practice. Project planners
cannot assume that the protections such laws may provide in theory will
be achieved in reality. For example, the upstream drainage of a village
water supply may lie within a national park. In theory, the purity of
the water supply is secure, as its source is protected. In reality, this
may be a poor assumption.

**Local or traditional systems of resource management and allocation**.
Systems of land tenure and resource management have clear relevance to
most rural development projects. In rural areas of Latin America
countries, land tenure is often a mix of Spanish colonial and
traditional systems---and projects must frequently obtain approval for
land or resource use through *both* systems. Traditional systems of
resource management are often gender-specific. That is, the
responsibility for monitoring and managing a given resource may fall
along gender lines. Project designers can not assume that the men in a
community can speak for the women, or vice versa.

**National economic policy and ongoing policy reform**. Many Latin
American governments are pursuing sectoral or structural adjustment
programs to stimulate economic growth and international trade. Examples
of macroeconomic tools used in such programs include altering exchange
or interest rates, reducing government budgets, promoting market
liberalization, and enhancing the role of the private sector. These
reforms can influence---both positively and negatively---how resource
users manage their environment. For example, liberalization of export
laws and/or development of transport and export infrastructure can
encourage timber exports, whether or not this is a targeted activity.
Inappropriate or poorly enforced forestry policies can result in an
acceleration of deforestation or significant declines in forest
productivity.

### Secure stakeholder commitment {#secure-stakeholder-commitment .unnumbered}

Stakeholders are those groups most directly affected by the project.
This includes the intended beneficiaries, funders, and those whose use
of and access to local resources is likely to be affected. The focus of
this discussion is on residents of local communities and users of local
resources. Figure 1illustrates the importance of stakeholder commitment
when local communities or cooperatives take over a project or activity
after assistance ends---a situation very typical of small-scale
activities. Often a project only maintains its environmental soundness
if proper operation and maintenance procedures are followed; the figure
cites several examples. Without stakeholder commitment, these proper
procedures are likely to be violated. In the worst case, the project may
actually do more harm than good. (For example, if waste from a health
post sickens the community at large.)

The importance of stakeholder commitment

![](media/image1.wmf){width="5.9430555555555555in" height="2.925in"}

### Capacity Building {#capacity-building .unnumbered}

Capacity building is an essential complement to and means of securing
stakeholder commitment. In an environmental context, capacity building
means helping local users or project beneficiaries to acquire:

The knowledge or skills required to operate/maintain a project in an
environmentally sound manner

An understanding of how project activities affect environmental health,
and why these operation and maintenance practices are important. Such
understanding is essential to secure stakeholder commitment.

### Adaptive Management {#adaptive-management .unnumbered}

Under adaptive management, project implementation is adjusted in
response to feedback from the field. Adaptive management requires both
(1) project monitoring and (2) decision-making which acts on the basis
of monitoring results.

As applied to environment, adaptive management means changing project
operation or design when monitoring shows unexpected, adverse
environmental outcomes. For example, members of a community involved in
a fertilizer project may observe that algae and plant growth in a local
water body has increased markedly. This is a sign of eutrophication,
possibly caused by fertilizer run-off from fields. It probably indicates
a need to change fertilizer application processes.

Adaptive environmental management requires an *environmental monitoring
and mitigation plan,* and explicit allocation for environmental
monitoring and evaluation activity in the project budget. Monitoring and
mitigation plans identify funding sources and responsibility for
monitoring and evaluation from the onset of project design.

### Community Participation  {#community-participation .unnumbered}

The need for community participation is a clear consequence of applying
best development practices to the environmental aspects of small-scale
project design and implementation. Community or stakeholder
participation beginning early in the design process is key to at least
three of these practices:

**Assuring technical feasibility**. The detailed knowledge community
members have of local conditions is often critical in anticipating and
identifying a project's potential environmental impacts;

**Securing stakeholder commitment**. By participating in design,
implementation and monitoring participants gain *ownership* and
*responsibility*, as well as a clear understanding of objectives and
anticipated outcomes. Ownership, responsibility and understanding create
incentives to identify and mitigate adverse impacts; and

**Practicing adaptive management.** Local participants are in the best
position to monitor long-term environmental effects of project
activities; monitoring is a key aspect of adaptive management. Further,
local participants or communities need the understanding and capacity to
adapt activities to future change after donor support ceases.

Finally, community participation is an important mechanism for assuring
environmental justice. Development activities often involve tradeoffs
between economic or social development and environmental quality. These
trade-offs should not be imposed unilaterally by external authorities.
Because local residents must *live with* the environmental consequences
of activities, it is only just that they understand and have a voice in
any tradeoffs that are ultimately made.

## ESD Is Not Enough To Assure Sustainable Activities {#esd-is-not-enough-to-assure-sustainable-activities .unnumbered}

The focus of this manual is environmentally sound design, which is
necessary---but not sufficient---to design and implement truly
sustainable activities. Environmental considerations must be weighed
together with economic and social criteria. Critical questions include:
is the activity financially sustainable without continuous external
support? Do the benefits of the activity outweigh costs?

## Integrating ESD, USAID Environmental Procedures, and the Project Lifecycle {#integrating-esd-usaid-environmental-procedures-and-the-project-lifecycle .unnumbered}

Environmentally sound design should be an integral part of the project
design and implementation process, not an afterthought. USAID's
environmental procedures (summarized in Annex A) create a framework in
which to organize key ESD-related elements and tasks of the project
lifecycle. The procedures should not be treated as simply an
administrative requirement.

![](media/image2.wmf){width="8.597222222222221in" height="6.0in"}

[^1]: This is Murphy's law at work (in USAID environmental procedures),
    compiled by the one of us who thinks Murphy was an optimist.

[^2]: This chapter originally developed in support of USAID's Africa
    Bureau course, "Environmental Assessment and Environmentally Sound
    Design for Small-Scale Activities."

[^3]: Enabling conditions for achieving more environmentally sustainable
    development include: a legal and policy framework enabling
    sustainable private-sector and public initiatives; clearly defined
    national objectives related to environmental design and management;
    good information regarding national/regional environmental resources
    and conditions (assessments or management plans); sufficient host
    county capacity to implement and apply environmental laws and policy
    (includes financial resources, trained professionals, effective
    institutions); and clearly defined responsibility and accountability
    for this implementation. Note that consideration of the enabling
    conditions for economically and socially sustainable development
    would expand this list dramatically.