The implementing partner will incorporate conditions set forth in this IEE into their work plans. G. LIMITATIONS OF THE IEE Generally this IEE Amendment does not cover major activities involving: 1. Classes of substantial actions normally having a significant effect on the environment pursuant to 22CFR 216.2(d)(1): i. Programs of river basin development; ii. Irrigation and water management; iii. Agricultural land leveling; iv. Drainage projects; v. Large scale agricultural mechanization; vi. Resettlement projects; vii. New land development; viii. Penetration road building and road improvement; ix. Power plants; x. Industrial plants; xi. Potable water and sewerage projects; Activities affecting endangered species or introducing exotic species. Support to extractive industries (e.g. mining and quarrying). Support for activities that promote timber harvesting. Construction, reconstruction, rehabilitation, or renovation work. Activities involving support to agro-processing, industrial enterprises, and regulatory permitting. Activities involving support to industrial enterprises, and regulatory permitting. Potential activity components dealing with privatization of industrial facilities or infrastructure with heavily polluted property. Project and Sub-grantees preparation, project and Sub-grantees feasibility studies, and infrastructure investments for projects that may have a potentially significant impact on the environment. Procurement or use of genetically modified organisms (GMOs). DCA or GDA programs. Any of the above actions would require another amendment to the IEE approved by the BEO. H. REVISIONS Pursuant to 22 CFR 216.3(a) (9), if new information becomes available that indicates that activities covered by the IEE might be considered “major” and their effect “significant,” or if additional activities are proposed that might be considered “major” and their effect “significant,” this Initial Environmental Examination will be reviewed and, revised by the MEO with concurrence by the BEO. It is the responsibility of the USAID COR to keep the MEO, REA and BEO informed of any new information or changes in the activity that might require revision of the IEE. APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:
projects Pesticide shops with limited safety equipment (PPE) available Source and subsidize (cost share) the purchase of quality PPE for beneficiaries, and make it a condition for receipt of assistance. High Pesticide shops with limited sprayer replacement parts available Training for pesticide shops Med Limited resources for extension Do demonstration farms and field days. High Most farmers are unaware of acute and chronic health risks from use of pesticides Do repeated training on pesticide risks and safety High Some farmers use fumigants containing aluminum phosphide for grain stores in their homes (note: not allowed in this PERSUAP) Do repeated training on pesticide risks and safety High Very little use of PPE by farmers mixing and applying pesticides Do training on proper PPE to use; subsidize quality PPE and encourage the development of professional pesticide spray services. High Over- and under-applications of pesticides and no record-keeping Do repeated training on calibration & application. Promote the development and use of spray and record-keeping services organized or channeled through cooperatives or associations. Med Pesticides applied at wrong time of day and/or with winds too high Do repeated training on application timing risks and encourage the development of professional pesticide spray services. Med Back-pack sprayers leak onto spray applicators’ backs; leaks soak into clothing, run down into their boots, run down their arms and into gloves/onto hands Do repeated training on sprayer maintenance and encourage the development of pesticide spray services. High Some empty pesticide containers are thrown into the field or along the road Do repeated training on proper disposal (rinse, puncture, bury). Encourage the development of professional pesticide spray services trained to collect and dispose of containers. Med Most farmers will not pay for hybrid seed or fertilizers ATT has as its goal to encourage and provide access to these inputs High Positive Pesticide System Opportunities in Ghana GEPA has produced and biannually updates a list of pesticides registered for import and use in Ghana
The PER and the annexes provide substantial resources to support compliance with these requirements, as detailed in the table below. In addition, IPM/Safer Use Requirement Key Resources Provided Pesticide recommendations and use must be governed by a set of crop- and IPM-based pest management plans. (FTF ATT, sub-grantees, demo farmers, partners and retailers are responsible for developing these plans.) Annex 1, Matrix of Ghana FTF ATT Crops, sets out in tabular format crop-by-crop, pest-by-pest chemical and non-chemical management methods recommended by this PERSUAP. This is intended to serve as the basis for a crop-specific pest management plan. See also the pest management plan for the associated Ghana Commercial Agriculture Program (GCAP). Annex 7, Analyses of Active Ingredients in Pesticides Registered in Ghana, provides toxicology information for each approved active ingredient, including human acute toxicities and chronic health issues, water pollution potential, as well as potential ecotoxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms. If pesticide use is supported, appropriate FTF ATT project staff/Sub-grantees & beneficiaries must be trained in safer pesticide use & pesticide first aid Annex 8, Training Topics and Safe Pesticide Use Web Resources, provides significant discussion of safer use training elements. If pesticide use is supported, farm compliance monitoring forms could be used Annex 9, Field Monitoring Form for Farmer Best Practices including GAP and IPM options, provides ideas for farm monitoring information to collect, and a format to collect it If pesticide use is supported, FTF ATT/Sub-grantees must be systematic in their pesticide-related and monitoring Annex 10, Farm and Project Record Keeping Associated with Pesticide Use, provides record-keeping templates/aids If pesticide use is supported, FTF ATT/Sub-grantees must track the impact of risk mitigation measures Annex 13, the EMMP, provides a template for monitoring risk mitigation actions
longicornis, Diopsis thoracica, Diopsis spp.) or deltamethrin and materials. Rice Caseworm (Nymphula depunctalis) Use resistant varieties. Ensure balanced nutrition (avoid excessive nitrogen application). Removing weedy vegetation on the levees in spring near the time of seeding. Many predators control caseworm naturally. Use wider spacing and earlier planting. Insecticides are not commonly used in northern Ghana against caseworm. False smut on rice (Ustilaginoidea virens, Entyloma oryzae) Some hybrids and varieties are more resistant than others. Avoid mechanical injuries to plants and maintain well-balanced soil fertility. Rotate to another crop, the longer the better. Use of disease-free seeds that are selected from healthy mother plants. Split nitrogen applications. Removal and proper disposal of infected plant debris. Avoid field activities when the plants are wet. Fungicides are generally not used for most smuts. Brown leaf spot (Bipolaris oryzae) Use resistant varieties. Careful use of fertilizer can do much to prevent the disease Burn or feed stubbles after harvest Hot water treatment of seeds Seed treatment with captan, thiram, or mancozeb. Rice blast (Pyricularia oryzae) Use of resistant cultivars. Destruction of infested residue. Use of certified clean or non-infested seed. Water seeding (not drill seeding). Continuous flooding. Avoid using excess nitrogen. Do not plant too early or too late. Avoid close planting in nurseries. Use application of synthetic fungicides containing mefenoxam (metalaxyl-M). Rice weeds Use an integrated weed management scheme: Perform thorough land preparation (soil tillage, fertilizer, and water management). Narrow row spacing makes the crop more competitive than the weeds, use intercropping. Place the fertilizer in such a way that the crop has access to it but the weeds do not. This allows the crop to be more competitive with weeds. Keep the surroundings of farm free of weeds, unless they are maintained and Pre-emergence: use an herbicide containing pendimethalin plus hand weeding/hoeing. Post-emergence: use an herbicide containing trichlopyr selectively control broadleaves and sedges.
Annex 5. Natural Pesticides That Have Been Commercialized Insecticides azadirachtin—component in neem oil botanical extract Bacillus thuringiensis-BT microbial Beauveria basiana microbial cartap hydrochloride marine worm (Lumbriconereis heterodopa) extract chili pepper extract botanical (spice) emamectin benzoate botanical extract garlic extract/allicin botanical extract (spice) harpin protein plant induced resistance elicitor kaolin clay inorganic mineral d-limonene citrus extract (spice) Metarhizium anisopliae microbial narrow range dormant oil paraffin oil neem oil botanical extract nuclear polyhedrosis virus (NPV) microbial Paecilomyces lilacinus microbial Paecilomyces fumosoroseus microbial pyrethrin botanical extract pyriproxyfen IGR (Juvenile Hormone mimic) ryania botanical extract soap (insecticidal) fatty acids spinosad microbial extract buprofezin IGR (Chitin Synthesis inhibitor) Fungicides Bacillus subtilis microbial Bordeaux mix inorganic (Bordeaux ingredients EPA registered) copper inorganic copper hydroxide inorganic copper oxychloride inorganic copper sulfate inorganic harpin protein plant induced resistance elicitor sulfur inorganic Trichoderma species microbial Nematocides Myrothecium verrucaria microbial tomatillo oil + thyme oil extracts (Promax) botanical + spice extracts—soil biopesticide Molluscicide iron phosphate inorganic
Annex 12: List of Institutions and Farmers Interviewed AGRO-DEALEARS Firm/organisation Location Date of Visit Contact Person Contact No, GANYE SAVELUGU 28/11/13 SUALE ABUKARI 0247436571 WUNPINI TAMALE 04/12/13 Iddi 0244290265 GANORMA TAMALE 04/12/13 HAJIA 0244845995 MAKHTESHIM AGRO-CHEMICALS TAMALE 09/12/13 OSMAN 0544348817 VA NS ADDO TAMALE 09/12/13 EVANS 0244780151 IRRIGATION SCHEMES Firm/organisation Location Date of Visit Contact Person Contact No, BONTAGA IRRIGATION SCHEME BONTAGA 29/11/13 ALI &FARMERS 0246211870 LIBGA IRRIGATION SCHEME LIBGA 02/12/13 TONO IRRIGATION SCHEME TONO 03/12/13 ISA 0244577663 GOLINGA IRRIGATION SCHEME GOLINGA 2/12/13 YEMALE 0548495406 AGRI-BUSINESS CENTRES Firm/organisation Location Date of Visit Contact Person Contact No, BUSAKA ABC SAVELUGU 28/11/13 Emanuel 0264890556 PRESBY AGRIC STATION ABC WALEWALE 03/12/13 SANDOW 0248974004 GOVERNMENT OFFICES Firm/organisation Location Date of Visit Contact Person Contact No, REGIONAL AGRICULTURAL DEV’T UNIT (RADU) TAMALE 29/11/13 0244216918 ENVIRONMENTAL PROTECTION UNIT (EPA) TAMALE 29/11/13 ABU IDRRIS &TEAM 0203247375 SAVANA AGRIC RESEARCH NYANKPALA 02/12/13 Dr. DOGBE & 0264603414
Annex 13: 2014 Ghana IFDC FTF ATT Project EMMP (Environmental Risk Mitigation & Monitoring Plan) Management Matrix ATT Activity Potential Environmental Risks & Impacts Mitigation Measures & BMPs (Best Management Practices) Monitoring Indicators M & E Responsibility Planned Monitoring (M) & Reporting (R) Frequency From ATT 2014 Annual Workplan & Project IEE Requirements Risks Associated with IFDC FTF-ATT Activities Mitigation of Risks from Sector Activities Indicators of Sector Best Management Practices Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success M = ? (continuous, weekly, monthly) R = ? (quarterly, biannually, annually) Crop & Seed Production, Processing, Testing Input (potentially pesticide) Risks: Negative Determination with Conditions IEE, page 5: “the preparation and BEO approval of PERSUAPs” No analysis done of new integrated pest management technologies including pesticide risks Complete the 2013 ATT PERSUAP PERSUAP done. PERSUAP recommendations followed, as practicable. Baseline: No PERSUAP M&E Specialist M=Continuous R=Annually Safer pesticide management practices not implemented. Implementation of the SUAP and compliance with recommended Safer Use Measures. Results of inspection visits at randomly selected farms. AOR, MEO and/or REA M&R (biannual) Use of pesticides with high toxicity or potential to adversely impact the environment. Conduct training on safer pesticide use and pesticide first aid. Conduct training on maintenance of appropriate PPE and application equipment. Conduct training on safe pesticide selection, purchase, handling, storage Pesticide safety and PPE usage understood and used by target farmers Training records maintained. Pesticide usage records maintained (per templates and forms in Annexes 9 and 10) Baseline: ..% of target Sub-grantees report to ATT Grants Manager
and disposal practices. farmers using PPE. TBD after baseline survey. Workplan, page 3: “..developing public institutions’ and private businesses’ capacities to introduce new technologies and supply agricultural inputs in collaboration with other stakeholders” The word “inputs” can include pesticides; it can also include preventive Integrated Pest Management (IPM) tools/tactics Promotion or Use of non-EPA registered pesticides, certain RUP pesticides Promotion or Use of banned pesticides Preventive Integrated Pest Management (IPM) inputs (tools/tactics) not known, or understood, or used If pesticide inputs might be promoted, it would likely be done through sub-grantees working with agrodealers. Thus sub-grantee grant language would contain wording on which pesticides might be supported, as part of IPM, and which cannot be supported in any way. Sub-grantees to perform training on IPM tools and tactics recommended in the PERSUAP, including pesticides, as well as pesticide use safety. Grants contain IPM and safe pesticide use language as recommended by PERSUAP No PERSUAP rejected pesticides promoted or used with AID resources Preventive IPM tools and tactics understood and used for maize, rice and soybean target farmers Training records maintained. Baseline: ..% of target farmers using unregistered, rejected, or banned pesticide. TBD after baseline survey. Sub-grantees report to ATT Grants Manager M=Continuous R=Annually
Activities involving land and water management improvement, watershed management, soil erosion control: Negative Determination with Conditions Workplan, page 6: “In the project context, ISFM technologies are not only limited to integrated soil fertility management but encompass a wide range of technologies, including land preparation, planting, harvesting and post harvest handling.” Risk of slash and burn with forest degradation, loss of biodiversity, loss of topsoil and loss of soil fertility. Train on and use soil tests, crop rotation, composting, fallow periods, fertilizers, ISFM, and no burning. Low risk of topsoil loss due to small size of parcels and low slope of land Low risk to forestry and biodiversity, due to uniformity and relatively small parcels tilled (of total available) Presence of soil test results Soil test recommendations followed and amendment use Crop rotation practiced Baseline: .. of target farmers using ISFM practices. TBD after baseline survey. ISFM Advisor M&E Specialist M=Continuous R=Annually New Seed Varieties, and GMO Introduction Risks: Negative Determination with Conditions, and Deferral for GMOs Workplan page 6 “…developing and disseminating improved seed” Agroclimatic zone not appropriate Introduction of exotic invasive species, displacing local biodiversity Ensure that imported genetic material and seeds are adapted to Tamale Savannah environment Ensure that imported genetic material and seeds are certified to be not contaminated with seed from other species Only adapted certified seeds used Baseline: ..% of target farmers using improved seed. TBD after baseline survey. Seed Advisor M&E Specialist M=Continuous R=Annually
Workplan page 22 “Build research capacity for genetically engineered seed” Lack of USAID biosafety analysis Local knowledge on GMOs is insufficient Commission a USAID biosafety analysis and check with national biosafety authorities for any new GMOs that are introduced for research Science based publications and information materials Work closely with PBS on biosafety issues Publications and information materials disseminated Baseline: No Biosafety Study Seed Advisor M&E Specialist M=Continuous R=Annually Small Grant Facility Risks: Negative Determination with Conditions Workplan page 28 “Grants mechanism…to expand the availability and use of new technologies” New technologies could include provision of pesticides New technologies could include manufacture of soy processors and agric machinery spare parts New technology could include processing soybean to soy milk Grants contain language and grantees follow PERSUAP recommendations on allowed and rejected pesticides Grants contain language and grantees follow good manufacturing and processing practices (see Annex 1) Percent of grantees following PERSUAP recommendations Percent of grantees following good manufacturing and processing recommendations Baseline : % each of target manufacturers and processors understand and use good manufacturing and processing practices. TBD after baseline survey. Sub-grantees report to ATT Grants Manager M&E Specialist M=Continuous R=Biannually
Fertilizer System and Deep Placement Risks: Negative Determination with Conditions Workplan pages 17 & 20, “..promoting the judicious use of mineral fertilizers in combination with locally available soil amendments..” & “Strengthen ISFM and Fertilizer Supply Chain” Potential users not trained in integrated soil fertility management (ISFM) Little use of local soil amendments Perform training in proper fertilizer handling, storage, use and application techniques and fertilizers are employed according to the best practices, promoting ISFM Percent of beneficiary farmers using ISFM Baseline: % of target farmers understand and use ISFM practices. TBD after baseline survey ISFM Advisor M&E Advisor M=Continuous R=Annually