Initial environmental examination program/activity data: Program/Activity Number

APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED: (Type Name Under Signature Line)
CLEARANCE:
Mission Director: ____________________________ Date: ________

Harry M. Lightfoot

CONCURRENCE:
Bureau Environmental

Officer: ____________________________ Date: 8/4/00

Carl M. Gallegos Approved: X

Disapproved: _________

File No: 30Benin2 SO1 HEPS II.iee.doc (AID/W)

CLEARANCE:

General Counsel

(Africa Bureau) Date: 8/21/00

Mary Alice Kleinjan

ADDITIONAL CLEARANCES: (Type Name Under Signature Line)
Mission Environmental

Officer: ____________________________ Date: ________

Karen Kent
Project Manager: _____________________________ Date: _________

Yvette Malcioln, BET Leader

Regional Environmental _________________________ Date:__________

Officer: Rebecca J. Niec

INITIAL ENVIRONMENTAL EXAMINATION

PROGRAM/ACTIVITY DATA:
Program/Activity Number: 680-0227

Country/Region: Benin/Africa

Program/Activity Title: SO-1 Basic Education Reform in Benin

Sub-activity: Health Education in Primary Schools Phase II (HEPS II)

1.0 BACKGROUND, SOAG, AND SUB-ACTIVITY DESCRIPTION
1.1 Background
SOAG:
USAID/Benin has consolidated its Basic Education Reform program into a new SOAG Amendment. All activities carried out under the Basic Education Strategic Objective are included in the SOAG. This IEE serves to create a SOAG Level IEE that consolidates IEE determinations for all Basic Education SOAG activities in one IEE. These activities and determinations are as follows:

• 
  24ben1.iee – Health Education for Primary School (HEPS) - Categorical exclusion and negative determination with conditions.
  
• 
  25ben1.iee – Technical Training for Primary School Leavers and Dropouts - Negative determination.
  
• 
  IEE for Children’s Learning and Equity Foundations (CLEF) Program 680-0208 - Categorical exclusion.
  
• 
  27ben2.iee – Primary Education Teacher Training Project (PETTP) - Categorical exclusion.
  
• 
  27ben4.iee – Primary Education NGO Project (PENGOP) II - Categorical exclusion.
  
• 
  28ben1.iee – Technical Skill Training for Youth (TSTY) - Categorical Exclusion and Negative determination with conditions.
  
• 
  29ben1.iee – Equity and Quality in Primary Education (EQUIPE) - Categorical Exclusion.
  
• 
  29ben2.iee - Peace Corps Interagency Agreement - Categorical Exclusion and negative determination with conditions.
  

HEPS II:
In FY 1995, USAID initiated the Health Education for Primary Schools (hereinafter referred to as HEPS I) activity to promote health practices and hygiene in primary schools through community participation and pupil education. This $5 million activity provided 5 years of support to health education in primary schools through school support groups and local NGOs trained by a U.S. PVO Medical Care Development International (MCDI). Over the life of this activity, more than 1800 teachers from more than 350 schools were trained; children's knowledge in hygiene and sanitation, malaria, diarrhea, nutrition and AIDS met or surpassed targets; behavior change targets with regard to use of latrines and urinals and hand washing after latrine use were surpassed; 335 latrines and 259 water points were installed (compared to the initial objective of 300 and 200 respectively); and targets for strengthening local NGOs and Parent's Associations (APEs) were largely met.

The HEPS II activity will expand upon the HEPS activity to reach more schools in the same zones.
1.2 SOAG Description
The Basic Education Strategic Objective is "More children receive on an equitable basis a basic education which prepares them for productive roles in society". This objective will be accomplished through the following intermediate results.
Intermediate Result 1: Improved key pedagogical systems and inputs for delivery of quality basic education
USAID/Benin will assist the Ministry of Education (MOE) develop an appropriate curriculum and pedagogical materials for classroom use. Teachers will be trained to more effectively use the new curriculum, through the PETTP program. The FQL tracking system recently put in place at the MOE will be used to monitor decentralized needs and assist in the procurement and delivery of educational inputs such as textbooks, desks/benches, and teaching materials to the classrooms. FQL data will also be used to track fundamental quality indicators related to recruitment of teachers, school infrastructure, school mapping and the improvement of school sanitary environment, through the HEPS program. These activities will improve the internal efficiency of the education system and will reduce the high drop out and repeater rates.
To address the needs of those who drop out of school as well as those who decide not to continue secondary education, USAID/Benin will continue to support the Songhai Center and will develop an expanded program in technical and entrepreneurial training, after an in‑depth analysis of the needs for and track record of such training.
Intermediate Result 2: Increased equity of access to primary schools
USAID/Benin will continue to strengthen Parents' Associations through our work with local NGOs, and assist the national network for girls education in the implementation of its action plan. The network will sensitize the public to the needs and advantages of educating girls and will identify ways to overcome cultural barriers to girls education. The Mission and the MOE will address gender awareness issues in curricula, textbooks, and teacher training modules. The public and the local media will play a larger role in sensitizing the greater community to equity and access issues.
Intermediate Result 3: Maintained sufficient financing for primary education
USAID/Benin will assist the MOE develop a financial planning tool that will track how much is spent on education by subsector (primary, secondary, etc.), by category (salaries, textbooks, teacher training, etc.) and by source of financing (GOB, donors, as well as parents etc.). USAID/Benin will continue to work with the MOE and the MOF to ensure that there is adequate financing for the essential components of the reform program, (such as teacher training, textbooks, and girls' education). The Mission will assist the MOE develop a procedures manual for budgeting, financial management and internal control systems. USAID/Benin will continue to monitor improvements in the GOB's overall

financial management capability.

Intermediate Result 4: Increased civil and government participation in basic education
Education should not only be the concern of the MOE, but the concern and responsibility of all. USAID will help the MOE work more effectively with other ministries and other agencies such as the Education Commission of the National Assembly. It will assist the MOE to mobilize the media in disseminating information about the importance of a basic education. The Mission will continue to support NGOs and Parents' Associations in their attempt to play a larger role. The World Education project has impacted positively on the quality of school management and infrastructure. In numerous cases, parents have contributed to solving the following problems: teacher shortages, lack of adequate classrooms, and a lack of proper management of school funds. USAID will support NGOs and, through them, Parents' Associations in their efforts to become more involved in educational decision making. It will also encourage the government to support private initiatives to promote children's education.
Intermediate Result 5: Improved institutional capacity for educational planning, management and accountability
The focus of this IR is to assist the GOB in establishing a strengthened central capacity that will allow for a more decentralized and efficiently functioning educational system. USAID will help the government devolve more power to local government and to local school districts. We will also help foster the linkages between them. The Mission will further facilitate the decentralization process through better use of education data both at the central and regional levels, and the development of a central and regional planning and management capacities. It will support the MOE in adopting systemized procedures that will ensure maximum use of resources. To that effect, the Mission will assist the MOE in creating a planning unit to efficiently plan and budget education programs. The planning unit will take into account FQL norms to provide data to the MOE so as to promote a better informed decision‑making process and to facilitate equitable procurement of inputs at the classroom level.

By the end of the year 2003 following changes are expected in Benin's basic education system:

• 
  a 78% gross enrollment rate, with an equal proportion of girls as boys;
  
• 
  an increased completion rate from 21% to 42% with a leaving exam pass rate of 90%;
  
• 
  communities participating in school level management decisions;
  
• 
  learning materials used by competent teachers to teach relevant and useful skills in most of
  

the primary schools in Benin;

• 
  funds properly managed and accounted for at all levels of the primary education system;
  
• 
  technical skill training pilot programs for school leavers and primary school graduates
  

enabling them to find employment;

• 
  more than 200,000 student's knowledge about health and hygiene issues increased in over 600 schools; and
  

• 
  at least 4000 school leavers and dropouts will have received technical and entrepreneurial training; most of whom (at least 60%) will be in gainful employment.
  

1.3 Sub - Activity Description
The objectives of HEPS II remain the same as those for HEPS I:

1. 
   Increase primary school children's knowledge on hygiene, sanitation, nutrition and the prevention of stated prevalent diseases;
   
2. 
   Improve the primary school sanitary environment by providing an adequate number of latrines, urinals, water points and hand washing facilities to meet the FQL level;
   
3. 
   Improve primary school children's sanitary and hygiene practices;
   
4. 
   Strengthen the participation of the APE and school health committees in improving primary school children's sanitary and hygiene practices thus, expanding the sphere of influence into the community.
   

Activities to achieve these objectives will consist of the following:

1. 
   Training, skills transfer, and supervision/monitoring: MCDI will work in collaboration with local NGO's (trained under HEPS I) to provide training, skills transfer, and supervision/monitoring to teachers, school directors, APEs and local health committees. The training will be in the subject areas cited in objective 1 above as well as in supervision and monitoring. It will also include the publishing of training modules and educational materials. MCDI will work with the Ministry of Education to incorporate messages and materials into the national curriculum.
   

2. 
   Construction of sanitary facilities: Through micro-project grants to local NGOs trained under HEPS I, MCDI will construct latrines and cisterns or other water sources based on (Fundamental Quality Level) FQL standards. Through collaboration with other international NGOs and donors, additional latrines and cisterns will be funded by other sources in schools targeted by MCDI health education interventions. MCDI will also work with the Ministry of Education to develop a school infrastructure maintenance manual for APEs and school personnel.
   

3. 
   Implementation of a pilot de-worming activity: this activity will be jointly implemented with the Integrated Family Health Project (PROSAF) in the Banikora sub-prefecture of the Alibori Department only. After an initial 36 schools, it is anticipated that the pilot activity will be expanded to cover all 68 schools in the sub-prefecture.
   

Expected Results:

• 
  Approximately 3000 teachers trained in the use of participatory methods and the health education modules
  
• 
  477 additional school groups equipped with didactic materials for health education training.
  
• 
  Health education provided to more than 400 schools in the Atlantique, Mono, Couffo, Borgou and Alibori departments.
  
• 
  Approximately 395 sanitary infrastructure micro-projects (225 latrines and 170 cisterns or other water sources) implemented based on FQL standards in the project area.
  
• 
  Approximately 120 additional sanitary infrastructure micro-projects (96 latrines and 37 cisterns) funded from sources other than USAID in the target schools based on FQL standards.
  
• 
  Capacity of approximately 477 schools and APEs to improve primary school childrens' sanitary and hygiene practices strengthened.
  
• 
  Capacity of approximately 477 APEs to carry out the latrine and water point maintenance strengthened.
  
• 
  50% of school district heads visiting schools twice per year using an instrument that monitors the state of the sanitary infrastructures, the organization of the hand washing and the hygienic practices of the students.
  
• 
  50% of school district heads and school directors will be using monitoring and supervision tools developed by HEPS at least twice annually.
  
• 
  70% of teachers applying the HEPS questionnaire on the modules developed by HEPS after the modules have been presented to the students with the participatory problem solving method once per year.
  
• 
  A document developed with the Ministry of Education and MCDI for school building and sanitary infrastructure maintenance that will include provision of a budget line item in the school budget for repairs and painting of school buildings, water points, etc.
  

These activities will take place in the same target zones as HEPS I, the Atlantique, Mono, and Borgou. Due to decentralization plans, the department of Mono has (on paper) been divided into Mono and Couffo and the department of Borgou into Borgou and Alibori. Administrative structures to support these new divisions are not yet in place.

0. 
   COUNTRY AND ENVIRONMENTAL INFORMATION (BASELINE INFORMATION)
   

Atlantique Department

The population of this department is approximately 1,066,373 with 644 primary schools and 167,936 students. Aid et Action, DANIDA, GTZ, the World Bank, and the Government of Japan have funded latrine projects in Atlantique.
Atlantique has an area of 3,222 square kilometers. It is bordered on the south by the Atlantic Ocean, in the west by the Mono department, where the Aheme lake, the rivers Couffo and Aho constitute the natural limits of the west boundary, and in the east by the Oueme department. The Atlantique's coastline is a sandy littoral corridor, of a width of 2 to 5 kilometers and is bisected by lagoons and coastal wetlands. The majority of the lagoons and wetlands are salty. In the Aheme and Nokoue lakes, the degree of salinity has increased considerably since the 1960's following construction of the Cotonou port. The climate is considered sub-equatorial, with rainfall decreasing from south-east (1400mm) to north-west (900mm). There are two distinct rainy seasons, the longest being April to July and a short season from October to November.
The department's central zone is formed by a laterite plateau with an average altitude of 200 meters and descending toward the Oueme and Couffo valleys and the Lama depression. The soil is of a ferrous type, with a sandy to sandy-loam texture at the surface and a sandy-clay at a deeper level.
There are two principal geological formations: recent and terminal continental. In the recent formations the soils are principally of two types, littoral, bordering the ocean and with a width of 1 to 10 kilometers; and alluvial, very well developed along the Mono, Oueme and So rivers. The terminal continental is more extensive and is composed of a sandy-clay formation which can be sub-divided into two types. The first is labeled superior term and is hard laterite, several meters thick, and reddish in color. At the base of the superior term is a level of stone and gravel whose thickness is variable according to region and forms a series of ironbearing sandstone, which forms an outcropping in certain places.
The principal rivers in the Atlantique are the Couffo, which flows through the department for a length of 50 kilometers before emtying into lake Aheme; the So, which also flows for a length of 50 km before emtying into lake Nokoue. Flooding is not uncommon in these rivers, causing problems not only to villages found along their banks, but also to villages bordering the lakes into which the rivers flow. A minor river is the Sossou, which flows into lake Toho. Additionally, there is a series of interior wetlands, small lakes, and lagoons the length of the coastline.
Mono/Couffo Departments
The population of these two Departments (formerly Mono) is 676,377 with 428 primary schools and 93,587 students. These departments comprise an area of 3800 square km. The area is bordered on the north by the Zou department, the south by the Atlantic ocean (with a coastline of approximately 40 km), the east by the Couffo river, the Aheme lake and the Aho river and in the west by the Togo border which is the Mono river. The climate is similar to that of the Atlantique department.
There are three major morphological units; (a) a group of plateaus, comprising in the north the Aplahoue plateau, and in the southeast the Come-Bopa plateau; (b) the central depression of Tchi, which is the western extension of the Lama depression, with a southwest/northeast orientation; and (c) a grouping of medium and low river valleys and complex lakes and coastal lagoons.
The geology of the Mono is composed of 85% sedimentary series and 15% granite-gneiss series. The base granite-gneiss occupies the northern part of the province up to the boundary of the Klouekanme. In this series, water is found in the alterites or in the fractures found in the series. The depth of well varies greatly.
The principal river is the Mono river, with a length of 300 km, and originating in Togo. Important rivers which drain into the Mono are the Saledo and the Devedou-Sazue. The river/lagoon complex of the Couffo-Aheme is composed of the Couffo river of 125 km and empties into Lake Aheme. Important lakes are the Aheme (shared with the Atlantique department), Toho and Bopa-Come.
Borgou/Alibori Department
The population of these two departments is 827,925 with 397 schools and 66,254 students. This area is 51,000 square km, approximately 45% of the country's land surface. It is bordered in the north by the Niger river and the Republic of Niger, in the south by the Zou department, in the east by the Federal Republic of Nigeria, and in the west by the Atacora Department and the Republic of Burkina Faso.
The departments are characterized by a "continental sudano-guinean" climate, which progressively changes to a "sahel-sudanian" type in the extreme north. There is one dry season, November to March, and one rainy season. The maximum rainy periods are the beginning of September in the sudano-guinean zone (Borgou) and in August in the sahel-sudanian zone (Alibori). Rainfall is approximately 1200mm in the south and decreases to 700-800mm in the north.
The three principal geological units from west to east are: (1) gneiss with a amphibolite aspect, asssociated with the crystalline formations of the granulites, granite or volcano sediments; (2) migmatites of the axial zone in the center part of the department; and (3) gneiss, granite and migmatites of the Mikki-Perere zone and granite-gneiss of Save-Ouesse, Tchaourou with the presence of volcanic rock and volcanic sediment.
The principal river is the Oueme in the south, and important semi-permanent rivers in the north, flowing into the Niger, principally the Mekrou, the Alibori and the Sota.
3.0 EVALUATION OF ISSUES WITH RESPECT TO ENVIRONMENTAL IMPACT POTENTIAL
SOAG:
SOAG activities in general as described in Section 1.2 are in the area of education, technical assistance, and training. These activities do not have an effect on the natural or physical environment. A few activities have training or micro-projects components that involve small -scale construction, agriculture or other activities.

HEPS II:
The Training, skills transfer, supervision/monitoring and pilot de-worming activities under HEPS II will not affect the natural or physical environment.

MCDI's strategy for latrine and water point construction under HEPS II will follow closely that used under HEPS I, with some modifications based on lessons learned. It is, therefore, not expected that the latrine and water point construction activities will result in significant adverse environmental effects.
An analysis of environmental issues and compliance with IEE conditions under HEPS I follows:
Over the five years of implementation of HEPS I the 335 latrines and 259 water points installed have not resulted in any significant adverse environmental effects. Regular monitoring of this activity, including site visits, by USAID/Benin and a mid-term and final evaluation of project activities have shown that, in general, the latrines and water points are appropriately located, well constructed and well maintained.
The Initial Environmental Examination for HEPS I contained four recommendations/conditions. MCDI has addressed these conditions as follows:

1. 
   In certain "wet zones" where the water table is high,, location and structure of latrines will be done only after consultation with villages affected.
   

Based on consultation with the beneficiary communities and other resource persons, all latrines constructed under HEPS I were of the simple pit type with cement construction and screened vent pipes to reduce insect breeding and odor. A problem with flooding was experienced at a few sites near the Mono river. At these sites, the level of the river periodically rises high enough to flood the latrines. Since this situation occurs only rarely, every 5 to 10 years, the risk was underestimated at the time of construction. For these sites, MCDI condemned the latrines. The Departmental level Ministry of Education civil engineer is looking into possible solutions for these specific cases. In other areas where the water table is particularly high (near Grand Popo and Athieme), MCDI has constructed latrines on raised foundations and used a sealed vault construction. Multiple pits and adjustable squatting slabs will enable continued use of these latrines when the first pit is full.

2. 
   In villages bordering Lake Aheme and similar areas, attention will be required in the placement of so that foundations are not eroded.
   

MCDI did in fact find high levels of erosion around latrines in this and other similar areas. The two primary measures taken to prevent erosion, in addition to careful site selection for the latrines have been: 1) the planting of Vetiver grass, obtained from the International Institute of Tropical Agriculture (IITA) research station in Benin, to control erosion around latrines and in school yards in general, and 2) initiation of a rigorous monitoring plan, including observation sheets that are used by APEs and other school personnel for periodic inspection of latrines to identify erosion problems early. In some cases special meetings with APEs and school directors were held to bring their attention to the importance of this problem and the need for better monitoring. The HEPS I final evaluation found that the problem of erosion is generally being addressed by these measures.

3. 
   In a few cases, where below ground cisterns are located, latrine site selection will meet the same criteria with respect to the placement of latrines near wells, i.e., sufficient distance allowed to separate latrines and below ground cisterns.
   

All cisterns constructed under HEPS I were above ground. In addition, 8 wells and approximately 65 water points from closed systems (municipal water systems) were constructed. In the case of the sites with wells, latrines were located an average of 200 meters away. Most of the wells were in sandy soil with an average depth of 10 feet.

4. 
   The "Grantee" in consultation with the Direction of Hygiene and Sanitation will be responsible for assuring that all latrines are properly placed, constructed and monitored.
   

All latrines and water points constructed under HEPS I were sited and constructed in collaboration with the Ministry of Education's departmental level civil engineer, who is also involved in monitoring.

5. 
   The health education activity of the project will assure that adequate information is made available to schools and communities so that they may adequately monitor latrine conditions following completion of the project.
   

Under HEPS I, considerable time and effort was invested in creating and implementing a monitoring program that involves simple monitoring checklists that are used by APEs, school personnel, and students to monitor and maintain sanitation infrastructures. The training of local NGOs, APEs, and school personnel in the importance of monitoring and maintenance, in the use of these instruments, and in the technical aspects of conducting regular maintenance was an important aspect of project activities.

In addition to the points discussed above, MCDI has made the following observations during implementation of HEPS I:

• 
  The two to three years initially anticipated for the latrines to fill up was an underestimation. The two to three years was based on a calculation of 120 children/latrine. In reality there are an average of 300 children/latrine and the latrines are not yet full after three years. This is in spite of an estimated utilization rate of 25% (i.e., 25% of the children use the latrine each day), which is quite high.
  
• 
  Initially, latrines were constructed with multiple pits running the length of a 2 - 4 cabin latrine rather than with one pit under each cabin. In this way, adjustable squatting slabs can be used to shift to a new pit when one is full. Initially, ventilation pipes were placed behind each cabin with the hope that there would be sufficient air flow from the farthest front pit to the pipe. MCDI found that placing ventilation pipes at each end of each pit (i.e., at the sides of the latrine block) is more effective because it provides two ventilation pipes per pit and direct ventilation and insect control to each pit.
  
• 
  In the initial IEE, the issue of cleanliness and the importance of teaching hand washing after latrine use was raised. Under HEPS I, the mid-term evaluation found that 77% of students washed their hands after latrine use (57% with soap and water and 20% with water only). Performance on this behavior change indicator exceeded the targeted 50%.
  
• 
  In the initial IEE the potential for leakage from poorly constructed cisterns was pointed out. MCDI has not found leakage of cisterns to be a problem. The cistern maintenance program promoted by MCDI requires annual draining of the cistern to check for cracks and for cleaning and disinfecting with Bleach.
  

Under HEPS II, latrine and water point construction is expected to follow the same general pattern as for HEPS I, with the majority of latrines being simple pit latrines and a few requiring raised foundations and closed vault construction. All latrines will employ the improved side ventilation pipe configuration. Cisterns will all be above ground and the same conditions for siting latrines an adequate distance from wells and other ground water sources will be maintained. As reflected in the expected results section of under Section 1.2 "Activity Description" above, HEPS II will put even greater emphasis than HEPS I on building the capacity of school district heads, APEs and school personnel to monitor and maintain their sanitary infrastructures. Working with the Ministry of Education to include a line item in school budgets to cover maintenance and repair will further ensure that this important aspect of project sustainability is realized.

4.0 RECOMMENDED MITIGATION ACTIONS (INCLUDING MONITORING AND EVALUATION)
SOAG:
For those activities with negative determinations with conditions, mitigative activities are described in the corresponding IEEs for those activities.
HEPS II:
No specific mitigative actions are recommended. The following recommendations are made with respect to monitoring.

1. 
   In areas where erosion is a problem, solutions should continue to be sought regarding the appropriate placement, construction and management of latrines in these areas. The continued and more extensive use of Vetiver grass and other erosion control plantings should be an important part of this initiative.
   

2. 
   The grantee, in consultation with the MENRS civil engineer in each department where the project is implemented, will be responsible for assuring that all latrines are properly placed, constructed, and, monitored and that adequate monitoring will continue after completion of the HEPS II activity.
   

5.0 SUMMARY OF FINDINGS
The purpose of this IEE is two fold: 1) to create a SOAG level IEE covering the entire Basic Education Reform Program in Benin, and 2) to make a determination on the second Phase of Health Education in Primary Schools (HEPS II) subactivity.
SOAG Level IEE: All activities of the Basic Education Strategic Objective have been consolidated into a new SOAG Amendment. These activities have been described in detail in previous IEEs and environmental determinations have been made for them as described in the Background section of this IEE. SOAG activities in general (as described in section 1.2) qualify for Categorical Exclusion pursuant to 22 CFR 216.2(c)(2)(i) "Education, technical assistance, or training programs." Four of the current activities being carried out under the SOAG have included training and micro-projects components that involve small-scale construction, small-scale agriculture or other small-scale activities. Negative determinations with conditions have been approved for these activity components. All new activities under the SOAG will continue to be reviewed and IEE amendments will be prepared if they do not meet the Categorical Exclusion criteria.
HEPS II: The 3 year, $3.4 million HEPS II activity will expand upon the HEPS activity to reach more schools in the same zones. The objectives of HEPS II are to: 1) Increase primary school children's knowledge on hygiene, sanitation, nutrition and the prevention of stated prevalent diseases; 2) Improve the primary school sanitary environment by providing an adequate number of latrines, urinals, water points and hand washing facilities to meet the FQL level; 3) Improve primary school children's sanitary and hygiene practices; and 4) Strengthen the participation of the APE and school health committees in improving primary school children's sanitary and hygiene practices thus, expanding the sphere of influence into the community. Activities undertaken to achieve these objectives include, training, skills transfer, supervision/monitoring, construction of sanitary facilities, and implementation of a pilot de-worming activity.
The training, skills transfer, supervision/monitoring and pilot de-worming activities will not affect the physical or natural environment and are recommended for a Categorical Exclusion as per 22 CFR 216.2(c)(2)(i) and 22 CFR 216.2 (c)(2)(viii). The construction of sanitary facilities will not result in a significant adverse environmental impact, providing that the two recommendations in Section 4 above are followed: 1) In areas where erosion is a problem, solutions should continue to be sought regarding the appropriate placement, construction and management of latrines in these areas. The continued and more extensive use of Vetiver grass and other erosion control plantings should be an important part of this initiative, and 2) The grantee, in consultation with the MENRS civil engineer in each department where the project is implemented, will be responsible for assuring that all latrines are properly placed, constructed, and, monitored and that adequate monitoring will continue after completion of the HEPS II activity. As per 22 CFR 216.3(a)(2)(iii) a Negative Determination with Conditions is recommended for the construction of sanitary facilities.

Attachment 1
Guidelines for Small-Scale Development Activities
(To be Used in Connection with WVRP Food For Work, or Food For Agriculture Programs, esp. Latrine construction, Well drilling, Road Rehabilitation and Construction of Health Stations and Other Buildings)
A. Latrines

Community sanitation programs should be established at each primary site and, where feasible, in surrounding areas, to promote family latrine use. A sanitation coordinator, sanitation assistants and a health advisor should conduct training and other educational activities to stress the importance of hygiene and proper sanitation to good health and will advise residents on latrine placement. WV should provide latrine slabs to interested local residents. The local residents will furnish quarry stone, sand and water for the slab production, will dig the latrine pits and will be responsible for transporting the slabs to the pits (wherever possible).

WV will, for the purpose of this activity, be familiar with established technical standards and specifications for the construction and siting of improved pit latrines, as formulated under low cost sanitation programs in other countries in Africa.
The WV Water Staff will have overall responsibility for the siting and construction of the latrines. A decentralized approach will also be taken for latrine construction to ensure full community involvement.
B. Rehabilitation and Construction of Water Points

WV proposes to rehabilitate existing boreholes and wells and establish new hand-dug and drilled wells. It is assumed that each water point will be equipped with hand pumps.

In the course of activity implementation, WV will work with established technical standards and specifications for the construction of hand-dug and drilled wells, and those for hand pump installation, operation and maintenance.
Final water point site selection will be made in conjunction with the community leaders and host country personnel. A decentralized approach will be taken to ensure community participation and knowledge transference at all stages of well construction/rehabilitation.
The WV Water Staff and/or the Health Program Manager will train peri-urban and village outreach workers in community education for the correct utilization of the well and pump and the proper use and treatment of water (including the transport and storage of water), and the general relationship of water to health.
C. Road Rehabilitation

Roads associated with the target communities will be improved through the construction of drainage fields/ditches, culverts or drifts, and small bridges, where necessary. Local labor and simple tools will be used to maximize local input and minimize cost.

The WV Operations Manager, in coordination with the government enterprise responsible for construction and maintenance of highways, will have overall responsibility for the rehabilitation of existing roads. All roads rehabilitated will be on existing compacted earth roads. No new roads will be constructed.

D. Health Education

Village health volunteers and MOH-supported Community Health Workers will be trained to provide health training and monitoring in a wide range of areas, including sanitation and clean water, growth monitoring, traditional birth attendant training, school-based health programs, immunization and nutrition, and AIDS/STD awareness and behavior modification. Groups will be formed and trained to provide appropriate health messages to the local population on a variety of health issues, including AIDS, nutrition, hygiene, sanitation, water, immunization, and childcare.
II. Impacts and Mitigation
The following environmental issues will be addressed by WV during implementation of the FFW activities:
A. Water Point Rehabilitation and Construction
1. The extraction of groundwater from wells can cause well and aquifer pollution unless correct siting, construction, and usage procedures are adhered to. Consequently:
a. All well siting will be the ultimate responsibility of the WV Water and Sanitation Coordinator. All wells will meet the siting requirements in terms of acceptable distance from latrine installations, proper drainage of excess water and other sources of possible groundwater contamination.
b. All wells shall be constructed and/or rehabilitated based on established technical standards and specifications for siting, construction and usage. This will include proper sampling and analysis of water to assure safety of water supply (i.e., levels of boron, nitrate, conductivity, chloride, pH, etc.) and a determination of the maximum number of wells that a given aquifer can sustain based upon yield estimates. Where the rehabilitation process may require abandonment of the existing wells, abandonment shall be done in a manner that ensures non-pollution of the aquifer.
c. All wells will be lined with concrete well rings to prevent possible contamination by parasites and disease-causing bacteria.
d. All wells will be sealed and a hand pump mounted to prevent contamination entering into the well shaft. A concrete apron will be constructed to ensure correct drainage of waste water away from the well head. The well head will incorporate an access lid, which will be secured with a padlock.
e. All wells will be thoroughly disinfected after construction. Disinfection of wells shall be done in a manner that ensures no increase in pollutant concentration following the disinfection process.
f. All well intervention will be accompanied by a community participation water and health education program.
2. Constructing new water sources can encourage migration of the population and the expansion of displaced person camps. To avoid this possible effect, WV will ensure that wells will be constructed, to the extent possible, in locations where the population currently live or traditionally lived and are returning.
B. Latrine Construction
1. Unless correctly sited, latrines can be responsible for well and aquifer pollution. Consequently:
a. All latrine siting and construction will be the ultimate responsibility of the WV Water and Sanitation Coordinator.

b. All improved latrine construction shall be done according to established standards and specification for construction and siting of improve latrines.

c. In unstable ground, the latrine will be lined.
d. Where existing latrines are close to a source of water such as a river or in an areas of high water table, the latrine shall be moved to higher ground.
e. All latrine intervention will be accompanied by a community participation personal hygiene and health education program.
C. Health Post and Other Building Construction
Although the construction and rehabilitation of small-scale buildings is expected to be minor, adverse environmental effects from construction and construction material can occur. Consequently:
a. The majority of materials used will be of local origin and will not contain any hazardous materials such as asbestos or formaldehyde. Excess construction material will be recycled wherever possible and disposal of unusable material will be done in an environmentally sound manner.
b. Construction will not require the use of any heavy equipment, such as bulldozers or large cranes.
c. If paint is used, empty cans will be disposed of in an environmentally safe manner away from areas where it can contaminate water sources.
d. Areas of construction and/or rehabilitation will be controlled to minimize erosion. Any runoff from the construction site which may be high in suspended solids or which may cause disruption to local drainage patterns will be monitored closely by WV and will be immediately addressed.
e. During the construction, measures will be taken to minimize standing water. If suppression of mosquitos is found to be needed in standing water, soap will be added to the water to kill the larvae. No synthetic chemical pesticides will be used.
f. During the construction, measures will be taken to minimize dust and noise. Local village labor is expected to walk to the construction site and to use latrines already in the vicinity.

g. Care will be taken to improve the surroundings of health centers. Trees and grass will be planted and/or other measures taken that will add aesthetically to the renovation site while minimizing opportunities for destructive runoff and erosion.

D. Road Rehabilitation
Although the reconstruction of earth roads is expected to be minor, adverse environmental effects from construction and construction material can occur. Consequently:
1. The majority of materials used will be of local origin and will not contain any hazardous materials. Excess construction material will be recycled wherever possible and disposal of unusable material will be done in an environmentally sound manner.
2. Wood stumps and brush removed from the roadway will be used by the volunteers for firewood and other recyclable uses.
3. WV will ensure that efforts will be made at road reconstruction sites to avoid soil erosion and will immediately address any potential erosion problems.
4. WV will ensure that proper reclamation (i.e., re-landscaping and re-planting), is undertaken at all areas used to obtain construction materials (i.e., dirt and rocks) for the road rehabilitation.
5. Construction will not require the use of any heavy equipment.
6. WV will follow existing roadways except where it may be justified to modify road routes slightly in order to: 1) achieve a more direct route between two points (minimize unnecessary curves or slightly straighten them out) in the interest of energy efficiency; and 2) avoid environmentally significant areas (i.e., wetlands, waterbodies, forest stands).
III. Monitoring
A. Water Point Rehabilitation and Construction
The WV Water Staff, with input from local government organizations for rural water will have overall responsibility for monitoring ongoing water point rehabilitation and well construction progress. Samples of water from water points will be tested for water quality monitoring. Selected and trained community members and government staff will have the continued responsibility to monitor water quality and general well conditions after project completion.
B. Latrine Construction
The WV Water Staff has the responsibility for ongoing monitoring of the latrine construction phase. Selected and trained community members and government staff will have the continued responsibility to monitor the latrine status after project completion.
C. Health Post Rehabilitation
The WV Water Staff has the overall responsibility for ongoing monitoring of building construction and rehabilitation. Selected and trained community members and government staff will have the continued responsibility to monitor construction status after project completion.
D. Road Rehabilitation
The WV Operations Manager has the overall responsibility for ongoing monitoring of the road rehabilitation. Selected and trained members of the community, together with local government staff will have the continued responsibility to monitor and maintain the rehabilitated roads after activity completion.
IV. Evaluation Program
During the implementation of this program each well and latrine will be subject to local community and government staff approval and evaluation.
During the life of the activity, and as long thereafter as USAID continues to fund activities conducted by WV, USAID and WV field staff will review any data collected by WV and the concerned government departments, and assess it for possible changes in the characteristics of the water supply and sanitation interventions.

Environmental issues will be one of the key items addressed during any monitoring and evaluation. Also, USAID (and WV) will closely monitor implementation and will utilize the recently published Africa Bureau "Environmental Guidelines for Small Scale Activities in Africa", copies of which are available from Mission staff.

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