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The Automated Directives System (ADS)
The ADS is USAID's directives management program. Agency policy directives, required procedures, and helpful, optional material are drafted, cleared, and issued through the ADS. Agency employees must adhere to these policy directives and required procedures.
Under the ADS Series 200 - Programming Policy, Chapters 201 and 204 have particular relevance to environment and environmental compliance.
| 201.3.7.1 |
Statement of Strategic Objective
Effective Date: 01/31/2003 |
MANDATORY. At the time of approval, a Strategic Objective must:
- Incorporate the findings of mandatory technical analyses (gender, environment and conflict mitigation, as appropriate) and incorporate actions that will overcome any identified, significant obstacles to achieving desired results under the SO.
| 201.3.8.2 |
Environmental Analysis
Effective Date: 01/31/2003 |
MANDATORY. This analysis is required by Sections 118(e) and 119(d) of the Foreign Assistance Act of 1961, as amended, and may not be waived, modified, or eliminated by the responsible Bureau for country-level Operating Unit Strategic Plans.
Biodiversity: All country-level Operating Unit Strategic Plans must include a summary of analyses of the following issues: (1) the actions necessary to conserve biological diversity, and (2) the extent to which the actions proposed meet the needs thus identified. For additional information, contact the Biodiversity Team based in the Bureau for Economic Growth, Agriculture, and Trade (EGAT). Tropical Forestry: For country-level Strategic Plans that cover countries that have any part of their territory within the tropics, each Strategic Plan must also include (1) a summary of their analyses of the actions necessary to achieve conservation and sustainable management of tropical forests and (2) the extent to which the actions proposed meet the identified needs. For additional information, see the additional help document, PPC Summary Description of FAA sections 118(e) and 119(d) Requirements for Preparing Strategic Plans [PDF], and contact the Forestry Team, a part of the Bureau for Economic Growth, Agriculture and Trade (EGAT).
Exemption. This analysis is not mandatory for Pillar or Regional Strategic Plans that cover multiple countries (although in many cases the analysis may be desirable).
Note: The Environmental Analysis described above is not the same as the Environmental Review described in 201.3.12.2 section b. (The latter is a Federal requirement for the obligation of funds.) Given the interrelated character of environmental issues, Operating Units may wish to save time by conducting the Environmental Analysis and the Environmental Review during the development of the Strategic Plan. Given, however, that Environmental Reviews often require relatively detailed knowledge about planned activities, it may not always be possible to conduct the Environmental Review while developing the Strategic Plan.
| 201.3.12.2 |
Pre-Obligation Requirements
Effective Date: 01/31/2003 |
MANDATORY. Operating Units must ensure that all pre-obligation requirements labeled as “mandatory” in this ADS section have been met before USAID-appropriated funds are obligated and activities approved. The completion of these requirements must be adequately documented.
Many, although not all, of the pre-obligation requirements are based on statute or regulation...
b. Environmental Review. An Initial Environmental Examination (IEE), Request for Categorical Exclusion (CE), Environmental Assessment (EA), or other appropriate action under the USAID Environmental Procedure must be completed for the program, activity, or substantive amendment and approved by the relevant Bureau Environmental Officer before the obligation of funds as mandated by Federal Law. (see the mandatory references 22 CFR 216 and ADS 204.)
Adequate review of environmental considerations normally requires a relatively detailed description and analysis of planned interventions; recommended, mitigative measures; and local public participation in the review process.
If Operating Units do not allocate resources and define such details at the pre-obligation planning stage, they must, at minimum, request and receive from their Bureau Environmental Officer a written approval of their request to defer review and incorporate appropriate conditions precedent to disbursement. This approval will ensure proper environmental review before disbursement. Operating Units must be prepared to modify and fund revisions to the SO and its activities, if necessary, in accordance with the USAID Environmental Procedure.
- Biosafety. If an activity will potentially involve the use of genetically modified organisms in research, field trials, or dissemination, the activity must be reviewed and approved for compliance with applicable U.S. requirements by the Agency Biosafety Committee in Washington before the obligation of funds and before the transfer, testing, or release of biotechnology products into the environment.
- The biosafety review that is reviewed and approved is limited to the safety aspects of the proposed activity and often involves external peer review or demonstration of comparable safety oversight by other expert U.S. federal agencies. This biosafety determination is separate from, and should precede and inform, the 22 CFR 216 environmental impact assessment process. Since it precedes the 22 CFR 216 process, Operating Units should budget adequate time and funding in the design process for this review. It is difficult to predict the amount of time needed, since reviews are highly dependent on the amount of analysis and information provided, whether other expert Federal Agency biosafety reviews have been completed, whether additional information will be required, and whether external peer reviews will be undertaken. Therefore, it is important for an Operating Unit to contact USAID/Washington as early in a design process as possible to ensure timely handling.
- Biosafety review cannot be waived or delegated to the field. Additional ADS guidance on compliance with this requirement is in development and will be incorporated into the ADS as it becomes available. Please consult directly with Agency biosafety staff, such as the Agency Environmental Coordinator, who is based in the Bureau for Economic Growth, Agriculture and Trade and the Bureau for Global Health if there is a potential for the use of genetically modified organisms.
- Global Climate Change. If an Operating Unit will potentially undertake global climate change activities, the Global Climate Change team based in the Bureau for Economic Growth, Agriculture, and Trade (EGAT) must review and approve the activity for compliance with the Knollenberg Amendment, as described in the mandatory reference, Guidance on Complying with the Knollenberg Amendment for Climate Change-Related Programs.
| 201.3.12.6 |
Activity Planning Step 2: Conduct Activity-level Analyses as Needed
Effective Date: 01/31/2003 |
Environmental Analysis. Drawing upon the previous environmental analysis during strategic planning (201.3.8.2) and the information from the pre-obligation requirement for environmental impact (201.3.12.2 section b), Operating Units should incorporate the environmental recommendations into activity planning. Often additional environmental analyses may be useful to activity design and should be undertaken at this time.
| 201.3.12.13 |
Activity Planning Step 9: Additional Planning Considerations
Effective Date: 01/31/2003 |
At this point in the process, additional planning considerations include:
Completion of any remaining environmental review requirements described in 201.3.12.2 section b. For example, if an Operating Unit received permission from its Bureau Environmental Officer to defer environmental review at the pre-obligation stage, the Operating Unit must complete the appropriate environmental review - either an Initial Environmental Examination (IEE), Request for Categorical Exclusion (CE), Environmental Assessment (EA), or other appropriate action under the USAID Environmental Procedure - before approving an activity or disbursing funds. (see the mandatory references, 22 CFR 216 and ADS 204)
| 201.3.12.14 |
Activity Planning Step 10: Determine and Meet Remaining Pre Obligation Requirements
Effective Date: 01/31/2003 |
This step applies only when funds have not already been obligated at the Strategic Objective Level. (see 201.3.12.2) By completing steps one through nine above, operating Units will have met many of the pre-obligation requirements related to adequate planning. At this point, remaining pre-obligation requirements should be reviewed in detail based on knowledge that is now available on the scope and nature of planned activities, the entities involved, and their proposed relationship with USAID. This review will make it possible to meet the requirements related to environmental reviews, statutory reviews, gender analysis, and Congressional notification. If the obligating official is different from the approving official, it may be helpful to use the additional help document, Model Checklist for Pre-Obligation Requirements. For more information about country prohibitions and restrictions, see 201.3.3.4.
If an activity will be implemented in one or more host countries but will not be managed by country-based USDH staff and captured in country-level reporting, a standard one-page Activity Information Sheet must be prepared by the Activity Manager, as described in ADS 203.3.9.
| 201.3.12.15 |
Activity Planning Step 11: Prepare Activity Approval Document (AAD)
Effective Date: 01/31/2003 |
MANDATORY. Operating Units must document all program-funded activities in writing through an acceptable Activity Approval Document. The Activity Approval Document certifies that appropriate planning for the activity has been completed. Program-funded activities may cover a range of outputs and encompass multiple A&A instruments.
There is no required standard format for Activity Approval Documents. Different types of documentation may be used in different situations, and are generally referred to as to “Activity Approval Documents.” Approving officials, obligating officials, SO Teams, and others who may be involved in the Operating Unit's activity design and approval process are responsible for exercising proper judgment in determining when planning is adequate and sufficiently documented to support activity approval. Any existing Mission Orders may also be consulted to determine the most appropriate documentation for a given Operating Unit. At a minimum, Activity Approval Documents must:
- Summarize how the environmental review requirements set forth in 201.3.12.2 section b have been met.
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