Documente Academic
Documente Profesional
Documente Cultură
JANUARY 2013
This report was elaborated by TETRA TECH ES INC for the United States Agency for International Development.
DISCLAIMER
The views expressed in this publication do not necessarily reflect the views of the United States Agency for International
Development or the United States Government.
www.mledprogram.org
MEXICO LOW EMISSIONS
DEVELOPMENT PROGRAM (MLED)
ENVIRONMENTAL MITIGATION AND MONITORING PLAN.
This document was made by TETRA TECH ES. INC. within the framework of
the Mexico Low Emissions Development Program (MLED), funded by the
United States Agency for International Development (USAID), under the
contract AID-523-C-11-00001 implemented by TETRA TECH ES INC.
www.mledprogram.org
CONTENTS
ACRONYMS AND ABBREVIATIONS .................................................................................. V
PREFACE ............................................................................................................................ VII
1.0 OVERVIEW OF MLED AND THE EMMP ..................................................................... 1
1.1 USAID MLED PROJECT OVERVIEW.......................................................................... 1
1.2 USAID MLED ENVIRONMENTAL COMPLIANCE-RELATED CONTRACT REQUIREMENTS . 1
1.3 ENVIRONMENTAL MITIGATION AND MONITORING PLAN ............................................... 2
1.4 REPORTING.............................................................................................................. 4
2.0 ROLES AND RESPONSIBILITIES ............................................................................... 5
3.0 SUMMARY ENVIRONMENTAL REVIEW OF USAID MLED ACTIVITIES .................. 7
4.0 POTENTIAL ENVIRONMENTAL IMPACTS/ISSUES & MITIGATION RESPONSES . 9
4.1 ACTIVITIES W TH A NDW/C STATUS ........................................................................... 9
APPENDIX A: DUE DILIGENCE GUIDELINES ................................................................. 13
APPENDIX B: ENVIRONMENTAL SCREENING FORM ................................................... 14
APPENDIX C: POTENTIAL MAJOR ENVIRONMENTAL IMPACTS FROM MLED
ACTIVITIES AND MITIGATION RECOMMENDATIONS ........................................... 19
POTENTIAL MAJOR ENVIRONMENTAL IMPACTS FROM ACTIVITIES ...................................... 19
MITIGATION RECOMMENDATIONS .................................................................................... 20
PREFACE
This Environmental Mitigation and Management Plan (EMMP) will serve as the reference guide
for project staff and partners implementing projects under the Mexico Low Emissions
Development (MLED) program. It determines the characteristics of project impacts and outlines
steps for monitoring different types of projects that will be implemented under MLED and
mitigating their impacts. It is anticipated that the EMMP will simplify environmental due diligence
for the larger set of activities expected under MLED, and will help reduce the amount of
paperwork and time involved in these procedures, while still assuring that adequate protective
steps and mitigation are undertaken. The monitoring and mitigation activities are incorporated
into MLED Annual Work Plans and Performance Monitoring Plans. The EMMP is updated
annually in consultation with the Task Order Contracting Officer Technical Representative
(TOCOTR).
USAID/Mexico has an approved Initial Environmental Examination (IEE). Some activities were
found to have potential detrimental environmental impacts, and received classification as a
Negative Determination with conditions. Such classification requires the preparation of an
Environmental Mitigation and Monitoring Plan (EMMP). This EMMP details the potential
environmental impacts and issues, mitigation measures, and outlines monitoring measures and
a reporting schedule for the responsible parties for the Mexico Low Emissions Development
(MLED) program.
USAIDs environmental regulations (22 CFR 216), commonly known as Reg. 216, establish the
conditions and procedures for environmental reviews of the activities funded with Agency
resources, and in selected cases, for the Categorical Exclusion from these requirements.
Section 216.2 (c)(2) allows Categorical Exclusions for:
Education, technical assistance, or training programs, except to the extent that such
programs include activities directly affecting the environment (such as facilities construction)
Analyses, studies, academic or research workshops and meetings
Document and information transfers
Studies, projects or programs intended to develop the capability of recipient countries to
engage in development planning, except to the extent that they are designed to result in
activities directly affecting the environment
Activities that involve the application of design criteria or standards developed and approved
by USAID.
The regulations can be used to 1) assess the environmental effects of a number of similar
actions and their cumulative environmental impact in a given country or geographic area, 2)
evaluate environmental impacts when they are generic or common to a class of Agency actions,
or 3) review other activities that are not country-specific. Reg. 216 classifies actions/activities
under three categories:
Category 1 activities, which are considered to have no environmental impact and are
therefore part of the Categorical Exclusion list.
Per the IEE, MLED will only include activities under Categories 1 and 2. When warranted, the
project will follow USAIDs Sector-Specific Guidelines and other requirements of the IEE, the
Environmental Threshold Decisions and other relevant documents for all these activities.
Section 1.0 of this EMMP provides an overview of the USAID MLED Project, including the
environmental compliance-related contractual requirements, and defines environmental
mitigation and monitoring. Section 2.0 presents the general roles and responsibilities of USAID
MLED staff for ensuring environmental compliance. Section 3.0 presents all the project activities
and the determinations assumed in the development of this EMMP. Section 4.0 analyzes all
project activities associated with conditions, describe the potential environmental impacts, and
define mitigation measures and monitoring requirements. As noted in the USAID MLED
contract, the EMMP must be updated annually. Future updates of the EMMP will be conducted
concurrently with the Annual Work Plans and PMPs. This coordination will ensure that
environmental mitigation and monitoring are actively considered and integrated as the direction
of USAID MLED evolves and specific activities begin to take shape.
While efforts on LEDS and MRV will take all sectors of the Mexican economy into account, the
USAID/Mexico GCC Program, through its various implementing mechanisms, will focus on
specific mitigation efforts in the clean energy and forestry sectors. In these sectors, USAID aims
to provide support under the following sub-components:
1) Strengthening policies for low emissions growth;
2) Strengthening institutional and technical capacity; and
3) Creating financial architecture for investment in clean energy and REDD+.
The MLED Program will include a sector-specific Clean Energy component to reduce emissions
by promoting the use of renewable energies and energy efficient end-use technologies through
projects and interventions which impact policy development, institutional and capacity building,
and creation of financing tools.
In addition, as the primary vehicle for the overall USAID/Mexico GCC program, the MLED
Contractor will ensure that each of the above mentioned objectives is addressed and will fill
gaps which are not addressed by other implementing mechanisms. The MLED Contractor will
ensure that sector-specific efforts carried out by other implementing partners are coordinated
and integrated into the overall USAID/Mexico GCC Program.
The project will be carried out from September 1, 2011 to August 31, 2014, with an additional 2
years period.
Compliance with USAID Environmental Procedures (22 CFR 216), including appropriate
environmental mitigation and monitoring measures, should be considered an integral part of all
activity development under the GCC Program.
An Environmental Threshold Decision regarding the IEE has been issued, and the Contractor
will be responsible for implementing the specified environmental assessments and mitigation
activities stated therein. Activities with potential environmental impacts, if proposed by the
contractor, will require environmental reviews by USAID. Environmental assessments and/or
monitoring and mitigation plans will be required prior to implementation of activities in keeping
with the Environmental Guidelines for Development Activities in Latin America and the
Caribbean
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/epiq.html
Any required environmental impact mitigation measures must also comply with Mexican laws
and regulations. The Contractor will be required to report on environmental compliance of these
measures as part of regular progress reporting, and the COTR and/or the Mission
Environmental Officer will monitor the Contractors compliance randomly as part of regular
project monitoring.
1
Recent guidance documents include: Environmental Procedures Training Manual, Introduction to Environmental Mitigation
and Monitoring Plans.
2
Prevention of impacts by changes to activity design, site, or technique is the most reliable approach to mitigation; as such, this
EMMP gives preference to prevention and control measures.
1.4 REPORTING
The EMMP must be updated annually. Future updates of the EMMP will be conducted
concurrently with Annual Work Plans and PMPs. This coordination will ensure that
environmental mitigation and monitoring are actively considered and integrated as the direction
of MLED evolves and specific activities begin to take shape.
The environmental review and compliance requirements for MLED provide a comprehensive
process for assuring that: 1) all potential environmental issues are identified in the course of
project development, 2) the appropriate levels of review and authorization take place within the
project and in USAID/Mexico before any activity is launched, and 3) any project construction
adequately provides for environmental protection measures.
Before starting any new activity classified as a Negative Determination with Conditions
(NDw/C), MLED will follow a systematic approach to determine the Category and potential
impacts of the activity. The activities classified as NDw/C are included under Task 3, Subtask
3.4: Provide pilot project transaction support, and Task 4, Subtask 4.4: Grants Management.
First, MLED will conduct a detailed screening of the activity. The project will use an
environmental screening form (Appendix B) to determine the activitys type and level of impact.
Second, MLED will determine if the best construction and operating practices and mitigation and
monitoring plans address all possible environmental impacts associated with an activity. It is
anticipated that any small-scale renewable energy and energy efficiency projects under MLED
will have impacts that can be mitigated by compliance with a specific set of measures identified
for each activity. Specific mitigation measures can be found in Appendix C.
Third, MLED will identify any significant environmental impacts that could not be mitigated or
prevented through best construction and operating practices, and will provide specific mitigation
actions and a brief explanation of the environmental consequences. MLED will determine
whether other mitigation and monitoring measures can be readily identified or a full
environmental assessment is warranted (Category 3 activity).
Fourth, MLED, together with USAID/Mexico, will then decide to continue or discontinue the
activity. If the decision is made to proceed with the activity (no impact or significant impacts that
can be mitigated, and monitoring plans are deemed to be effective), then the pre-defined EMMP
plus any other mitigation measures identified will be applied when implementing the activity.
Annex B includes information regarding the due diligence procedures, as well as the
environmental checklist to be used for all MLEDICED NDw/C activities. Procedures for grants
under contract can be found in the Grants Manual; grant proposals will have to comply with the
established procedures and will have to submit the environmental assessment checklist as part
of the grants application.
USAID MLED proposes the following positions to be involved in order to meet USAID
environmental compliance requirements:
Coordinator/Task 3 Manager
The Coordinator/Task 3 Manager is responsible for the planning, management and delivery of
specific task and sub-task level activities, including oversight of task schedules and costs. The
Manager will ensure compliance with USAID regulations, serve as single point of contact for
contractors under each Task-level activity, lead the implementation of small grant programs,
and provide support to the COP on overall program coordination to ensure effective USAID
coordination. The Manager will also supervise the Technical Specialists (TS) who are involved
in the identification of potential environmental impacts associated with MLED pilot
demonstration projects. In this capacity, the Task 3 Manager will provide technical oversight and
inputs for the Environmental Review Forms and Environmental Review Reports, monitoring
implementation of the EMMP, and summarizing/analyzing EMMP data for reports.
Grants Manager
The Grants Manager has overall responsibility for the implementation of the Small Grants
Program and compliance with the MLED Grants Manual and Management Plan. The Grants
Manager will screen grant and sub-contractor activities using the Environmental Review Forms,
prepare the Environmental Review Reports in consultation with the COP and M&E, and
monitors environmental compliance of grantees.
In keeping with USAID guidance on the development of EMMPs, subsequent sections of this
EMMP focus only on those activities assessed to receive an NDw/C.
Table 1: Review of USAID MLED activities to determine those that will be subject to
NDw/C
IEE/ETD
Task Sub-task (CE OR
4
NDw/C)
Task 1: Support the development and implementation of a national Low Emissions Development
Strategies (LEDS) and subnational climate change action plans
Subtask 1.1: Prepare key studies and measurements that remain undone CE
Subtask 1.2: Support the GOM in selecting the best economic models CE
3
Note that Subtask numbers change in subsequent workplans
4
CE = Categorical Exclusion, NDw/C = Negative Determination with Conditions
IEE/ETD
Task Sub-task (CE OR
4
NDw/C)
Subtask 1.6: Support the GOM for compliance with international consultation and analysis CE
(ICA) and International Registry
Subtask 1.8 Help state develop early action plans, NAMAs and PEACCs CE
Task 2: Strengthen Mexicos systems to inventory, register and conduct Monitoring, Reporting, and
Verification (MRV) of GHG emissions
Subtask 3.1: Develop an MLED CE project inventory and pilot project selection screening
CE
criteria
Subtask 3.3: Implement awareness programs for financial institutions (FIs) and industries CE
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/epiq.html
Within these guidelines, specific chapters on small scale infrastructure and renewable energy
applicable to MLED can be found at the following sites:
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/chap2/lac-
guidelines-2-small-scale-infrastructure.pdf
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/chap6/lac-
guidelines-6-renewable-energy.pdf
MLED will screen the potential environmental impacts of grants activities using the
Environmental Review Form. The Grants Manager will work collaboratively with the USAID
COTR to determine the eligibility of the grant applications to ensure compliance with project
categories. MLED will not approve grants that are found to have a positive determination. MLED
will promote selected best practices in for small-scale infrastructure, clean energy/renewable
energy and energy efficiency projects as outlined at:
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/epiq.html
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/chap2/lac-
guidelines-2-small-scale-infrastructure.pdf
http://transition.usaid.gov/locations/latin_america_caribbean/environment/docs/epiq/chap6/lac-
guidelines-6-renewable-energy.pdf
Specific mitigation recommendations for major impacts and issues are included in Table 2. This
table summarizes the potential impacts and issues, as well as the mitigation measures by
activity and project phase (site selection and design, construction, and operation). It is important
to note that this table is not comprehensive, and does not cover every potential impact or issue
arising from MLED activities. Other potential environmental impacts and mitigation measures of
MLED activities can found in Appendix C.
Summary
Table 2 below presents the mitigation and monitoring measures proposed by USAID MLED in response to the potential major
negative environmental impacts and issues detailed in the above Section. For grants and subcontracts disbursed under this contract,
USAID MLED will use the Environmental Review Form to screen grant proposals. This will help ensure that funded proposals do not
result in adverse environmental impacts, help develop mitigation measures as necessary, and specify monitoring and reporting for
grantees and subcontractors. If activities are not currently covered under the approved IEE and ETD, the project will write an
Environmental Review Report, and mitigation and monitoring requirements will be included in agreements and contracts.
Table 2: Mitigation and monitoring measures proposed by USAID MLED in response to the potential major negative
environmental impacts and issues
RESPONSIBILITY
MAJOR NEGATIVE MONITORING &
(FOR ACTIVITY &
ACTIVITY ENVIRONMENTAL MITIGATION MEASUREs MONITORING REPORTING
COSTS)
IMPACTS INDICATOR ACTIVITY
see Chpt 2
Task 3, Contamination of soil, Apply Environmental Agreements with Monitoring: Mitigation: TSs and
Subtask 3.4 surface and ground Screening and Review enterprises to employ Quarterly Task 3 Manager
and Task 4, water Form. environmental
management techniques Reporting: Monitoring:
Subtask 4.4: Power transmission If activities are not currently Quarterly Quarterly: TS
CE projects lines/pathway may covered under the Contracts, agreements,
and grant result in the destruction approved IEE and and MoUs include Annual site visit by
projects of wetlands or other Threshold Decision, write environmental clauses M&E and Task 3 and
sensitive habitat an Environmental Review 4 Managers
Report (ERR). Design and procurement
Occupational accidents plans include
due to methane Include environmental environmental
emissions (risk of fires, considerations in all considerations
explosions, feasibility studies to ensure
asphyxiation, project developers Site visits
- Review their public information on the Internet or other publically available material;
- Hold a discussion with them regarding environment corporate responsibility; and
- Check if a written environment policy is in place, implemented, and if records are
available.
APPENDIX B: ENVIRONMENTAL
SCREENING FORM
PARTNER:
____________________________________________________________________________
Project
Name:_________________________________________________________________________
Sub-grantee or
Contractor:_______________________________________________________________
Sub-project
Name:_____________________________________________________________________
Duration (proposed start and completion
dates):____________________________________________
Geographic
Location:___________________________________________________________________
General Description of Overall Activity and Purpose (paragraph(s) describing purpose/outputs and
potential environmental impacts):
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
Category 1:
o Does the activity involve (mark yes, where applicable):
___ Provision of education, technical assistance, or training.
___ Controlled experimentation exclusively for the purpose of research and field evaluation confined to
small areas (normally under 4 ha., i.e., 10 acres) and carefully monitored.
___ Non-irrigated small-scale agriculture and proven small-scale sustainable natural resources
management activities not involving the conversion of forested or range/pasture land into agriculture,
harvesting of wild animals, or impact on waterways.
___ Repair of facilities if total surface area to be disturbed is less than 10,000 sq. ft. (approx. 1,000 sq.
m.) (and when no protected or other sensitive environmental areas (such as wetlands) could be
affected).
___ Studies or programs intended to develop the capability of recipients to engage in development
planning.
___ Limited trail or fire break development that does not involve felling of trees, significant land leveling,
impacts on waterways, or disturbance of native vegetation.
___ Small-scale rearing of non-endangered species.
___ Support for certification of sustainable activities, such as forestry, organic production, and eco-
tourism.
___ Technical studies and analyses and other information generation activities that could involve
intrusive sampling of endangered species or critical habitats.
___ Implementing a monitoring program that involves permanent plants or capture of animals.
___ Introduction of any non-native species, even as part of restoration effort.
___ Community-based certified (e.g., Forestry Stewardship Council) use of non-endangered species.
___ Light industrial plant production or processing (sawmill operation, agro-industrial processing of
forestry products)
___ Potential to significantly degrade protected areas, such as introduction of exotic plants or animals
___ Potential to jeopardize threatened and endangered species or adversely modify their habitat
(especially wetlands, tropical forests)
___ Involve the use of pesticides at any level or extensive use of herbicides
___ Procurement of timber harvesting equipment, including chain saws
Activities in Category 3 will need further environmental information development to assess the impacts,
and the assessment will need to be approved by the BEO. For activities in Category 2, the mitigation
measures planned must be reviewed to ensure they are adequate to address the impacts. Below is a list of
questions that must be answered to ensure sufficient information for a determination of the environmental
status of the proposed activity. All activities in Category 2 that are approved must include progress
reports on their environmental mitigation with their regular reports on the overall project.
4. Strategies and methods that will be used to monitor the environmental impacts
5. If environmental problems do occur, actions that you will take to control and minimize those impacts
MITIGATION RECOMMENDATIONS
General recommendations to mitigate the potential negative impacts of MLED activities are:
- Include environmental considerations in all feasibility studies to ensure project
developers understand the environmental issues and include mitigation actions in their
budget.
- Screen the potential environmental impacts of grant and sub-contract activities using the
Environmental Review Form. If activities are not currently covered under the approved
IEE and Threshold Decision, Tetra Tech will write an Environmental Review Report to
submit with the Environmental Review Form; mitigation and monitoring required will be
written into agreements and contracts.
- Promote best management practices found at the IEE/ETD report and the following link:
http://www.usaid.gov/locations/latin_america_caribbean/environment/compliance.html
Specific recommendations to mitigate the potential negative impacts from small hydro
projects: Mitigation Measure
- Avoid stockpiling soils in riverbanks and/or floodplains, thus minimizing soil coming through
run-off
- Return topsoil along the riverbank and riparian ecosystem to its original location and restore
land contours to match the original topography
- Recover all reusable materials when demolishing existing structures (e.g., damaged weirs)
- Use erosion control methods such as hay bales to prevent runoff
- Engineering requirements for drainage/erosion prevention and construction techniques for
all construction actions must be strictly enforced. These will include the provision and
- Maintain a minimum wetted channel perimeter at all control structures with a constant flow in
the river throughout the year.
- Use best management practices to preserve water quality during maintenance activities,
including good housekeeping (e.g., provision of silt traps, stockpiling of soil and debris taken
from the weir away from riverbanks, maintaining as much riparian vegetation as possible).
- Schedule activities appropriately: planning maintenance activities during the dry season to
minimize erosion and scheduling the placement of sediment capturing devices and key
runoff control measures before major land disturbing activities to minimize sediment
release.
- Construct adequate bank protection in the catchment area to prevent erosion (replanting
and maintenance of vegetation), extract coarse material from the riverbed, and use
sediment trapping devices.
- Avoid constructing sanitation or other facilities at flood-prone sites and/or near the
floodplain.
- Avoid construction during wildlife breeding seasons.
- Avoid blocking stream flow during construction.
- Maintain enough flow during spawning and survival between weir and tailrace discharge.
- To ensure minimal loss of fish habitat and provide effective fish passage for local and
migrating fish species, fish ladders and fish bypasses should be added in the design.
- Sometimes (mainly in dry seasons), the power plant should be shut down to maintain the
minimum stream flow in dry periods.
- Design infrastructure to minimize risk (e.g., design with proper grading and drainage).
- Use material appropriate to the climate.
- Establish and adhere to construction timetables that minimize disruption to the normal
activities of the construction area. Coordinate truck and other construction activity to
minimize noise, traffic disruption and dust.
- Develop and implement appropriate public safety measures during construction and
operation. Explain safety measures to the local population.
Specific recommendations to mitigate the potential negative impacts from small wind
projects:
- Identify and avoid unstable slopes and local factors that can cause slope instability
(groundwater conditions, precipitation, seismic activity, slope angles, and geologic
structure).
- Research local hydrogeology. Identify areas of groundwater discharge and recharge and
their potential relationships with surface water bodies and groundwater quality. Avoid
creating hydrologic conduits between two aquifers.
- Minimize the planned amount of land to be disturbed as much as possible. Use existing
roads, borrow pits and quarries.
- Use special construction techniques in areas of steep slopes, erodible soils, and stream
crossings.
- Construct drainage ditches only where necessary. Use appropriate structures at culvert
outlets to prevent erosion.
- Do not alter existing drainage systems, especially in sensitive areas such as erodible soils or
steep slopes.
- Apply erosion controls relative to possible soil erosion from vehicular traffic.
- Reclaim or apply protective covering on disturbed soils as quickly as possible.
- Clean and maintain catch basins, drainage ditches, and culverts regularly.
- Limit pesticide use to non-persistent, immobile pesticides.
- Save topsoil removed during construction and use to reclaim disturbed areas upon
completion of construction activities.
- Avoid creating excessive slopes during excavation and blasting operations.
- Closely monitor construction near aquifer recharge areas to reduce potential contamination
of the aquifer.
- Obtain borrow material from authorized and permitted sites.
- Dispose of excess excavation materials in approved areas to control erosion and minimize
leaching of hazardous materials.
- Limit noisy activities (including blasting) to the least noise-sensitive times of day (weekdays
only between 7 a.m. and 10 p.m.).
Specific recommendations to mitigate the potential negative impacts from biomass and
biogas projects:
- Design, construct, operate and maintain waste storage in compliance with best
management practices to minimize venting of methane from storage facilities
- Do not site waste storage in proximity to populated areas, human quarters, working areas,
etc.
- Utilize best practice methods for the design and operation of waste storage to reduce bad
odor
- Comply with best practices in the design, operation and maintenance for biogas collection to
avoid venting, minimize pipe distances (e.g., locating gas collection facilities as near as
Utilize visual impact considerations in siting and design (arrangement of towers in such a way
as to prevent their being too visible from communication paths, use of vegetation for
screening)Specific recommendations to mitigate the potential negative impacts from
energy efficiency projects:
- Provide environmental awareness training to contractors and workers involved in the Project
including handling, clean-up, reporting and disposal of contaminated material.
- Maintain appropriate spill response equipment in a readily accessible location.
- Report all spills to applicable authorities.
- Ensure vehicles with obvious fuel or oil leaks do not enter the project area.
- Incorporate management practices that prescribe the presence of mandatory spill kits, and
spill management procedures as outlined in the contingency plan.
- Frequent inspection of the electrical equipment, transformers, etc., to ensure that any leaks
are discovered promptly and repaired immediately.
- Those materials that cannot be re-used will be removed from the site and disposed of
properly.
- Development and implementation of an Environmental Management Plan that includes
contingency measures to address potential accidents or malfunctions.
- Development and implementation of an Environmental Management Plan that includes
contingency measures to address potential accidents or malfunctions.