Bna Emmp November 2023

ENVIRONMENTAL MITIGATION
AND MONITORING PLAN

FEED THE FUTURE BANGLADESH NUTRITION
ACTIVITY
Version 3: November 27, 2023
Environmental Mitigation and Monitoring Plan
November 2023
ENVIRONMENTAL MITIGATION
AND MONITORING PLAN
FEED THE FUTURE BANGLADESH NUTRITION
ACTIVITY
Contract Number: 72038818CA00005

Agreement Officer’s Representative (AOR) Name: Farhad Hossain
Activity Start Date and End Date: October 1, 2018 to September 30, 2028
Submitted by: Ramakrishnan Ganesan

Chief of Party, Feed the Future Bangladesh Nutrition Activity
Abt Associates
Concord Bilkis Tower, 40/6 Madani Avenue
Gulshan 2, Dhaka 1212, Bangladesh
Email: Ram_Ganesan@abtassoc.com
Submitted to: Kh. Farhad Hossain
Submission Date: November 27, 2023
Disclaimer:
This document is made possible by the generous support of the American people through the United
States Agency for International Development (USAID). The contents are the responsibility of Abt
Feed the Future Bangladesh Nutrition Activity Page | 1

November 2023
Associates and do not necessarily reflect the views of USAID or the United States Government.

November 2023
REVISION HISTORY
Date Version Author Notes
June 15, 2019 1 Feed the Future First created
Bangladesh Nutrition
Activity
March 31, 2022 2 Feed the Future Resubmitted the updated version addressing
Bangladesh Nutrition USAID comments
Activity
November 27, 2023 3 Feed the Future Updated to reflect changes arising from
Bangladesh Nutrition Modification 12 (August 2023) of the prime
Activity award, relevant initial environmental examinations
(IEEs), and the Activity’s Fiscal Year (FY) 2024
work plan

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ABBREVIATIONS
ADS Automated Directives System
AIR Agro-input retailers
CDCS Country Development Cooperation Strategy
CE Categorical exclusions
CFR Code of Federal Regulations
CO2 Carbon dioxide
DAE Department of Agricultural Extension
EA Environmental assessments
EDD Environmental due diligence
EIS Environmental impact statement
EMMP Environmental mitigation and monitoring plan
EMMR Environmental mitigation and monitoring report
FY Fiscal Year
IEE Initial environmental examination
IR Intermediate result
MMC Market Management Committee
MT Metric Ton
NDC Negative determination with conditions
PERSUAP Pesticide evaluation report and safer use action plan
SBC Social and behavior change
SS Scoping statement
USAID United States Agency for International Development
WASH Water, sanitation, and hygiene
ZOI Zone of Influence
ZOR Zone of Resilience

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Table of Contents
REVISION HISTORY.................................................................................................................................................2
ABBREVIATIONS.......................................................................................................................................................3
1. PURPOSE.............................................................................................................................................................5
2. ACTIVITY SUMMARY.....................................................................................................................................5
2.1. ACTIVITY GOAL AND RESULTS FRAMEWORK...............................................................................................5
2.2. TECHNICAL APPROACH..................................................................................................................................6
2.3. BRIEF DESCRIPTION OF FY 2024 ACTIVITIES................................................................................................8
3. SITE-SPECIFIC INFORMATION....................................................................................................................9
3.1. LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT.............................................................................9
3.2. APPLICABLE ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS.....................................9
3.2.1. National Agricultural and Environmental Policies.............................................................................10
3.2.2. USAID Environmental Regulations and Requirements.....................................................................12
3.3. LESSONS LEARNT THROUGH IMPLEMENTATION..........................................................................................12
4. ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK..........................................................................14
4.1. POTENTIAL RISKS BY RESULTS AREAS........................................................................................................15
4.1.1. Result 1: Increased consumption of nutritious, diverse, balanced, and safe diets by households......15
4.1.2. Result 2: Increased social and economic empowerment of women and adolescents.........................16
4.1.3. Result 3: Increased adoption of improved WASH behaviors............................................................17
4.2. DUE DILIGENCE...........................................................................................................................................20
5. ENVIRONEMNTAL MITIGATION, MONITORING, AND REPORTING PLAN.................................20
6. CLIMATE RISK MANAGEMENT.................................................................................................................24
7. ANNUAL REPORTING...................................................................................................................................26
8. CONCLUSION...................................................................................................................................................26
ANNEX A: ENVIRONMENTAL REVIEW CHECKLIST...................................................................................28
ANNEX B: ENVIRONMENTAL MANAGEMENT SYSTEM FLOW CHART................................................32

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1. PURPOSE
This Environmental Mitigation and Monitoring Plan (EMMP) describes how the Feed the Future
Bangladesh Nutrition Activity (the Activity) meet s the requirements of the 2022 Feed the Future Initial
Environmental Evaluation (IEE) and Threshold Determinations (Asia 22 - 104), the 2023 Activity IEE
and Threshold Determinations (Asia 22-165), as well as the United States, USAID, and Government of
Bangladesh’s laws, regulations, and policies relevant to these activities. It also addresses climate change
vulnerability and mitigation plans in the agriculture value chain and water, sanitation, and hygiene
(WASH) value chain sub-sectors as they are interrelated. This EMMP describes the procedures to be
implemented by the Activity to recognize potential negative environmental impacts of program actions
and act to avoid, prevent, reduce, mitigate, or offset those potential negative environmental impacts.
EMMPs are required for USAID-funded projects, as specified in Automated Directives System (ADS)
204 when the 22 Code of Federal Regulations (CFR) 216 documentation governing the project (e.g., the
IEE) specifies mitigation measures are needed. EMMPs are an important tool for translating applicable
IEE conditions and mitigation measures into specific, implementable, and verifiable actions.
An EMMP is an action plan that clearly defines:

1. Mitigation measures. Actions that reduce or eliminate potential negative environmental impacts
resulting directly or indirectly from a particular project or activity, including environmental limiting
factors that constrain development.
2. Monitoring indicators.1 Criteria that demonstrate whether mitigation measures are suitable and
implemented effectively.
3. Monitoring/reporting frequency. Timeframes for appropriately monitoring the effectiveness of each
specific action.
4. Responsible parties. Appropriate, knowledgeable positions are assigned to each specific action.
5. Field monitoring/issues. Field monitoring needs to be adequately addressed, i.e., monitoring dates,
observations, issues identified, and resolution. This field is primarily for documentation during
implementation.
The EMMP is a living document and has been updated to reflect changes arising from Modification 12
(August 2023) of the prime award, relevant IEEs, and the Activity’s Fiscal Year (FY) 2024 work plan. It
will be reviewed against the IEE and updated as needed over the life of implementation, e.g., annually
after approval of the Activity’s work plan, when new sites are identified, new activities are designed, or
changes in scope are made through award modifications and IEE amendments.
2. ACTIVITY SUMMARY
2.1. Activity Goal and Results Framework
The Activity contributes to improvements in nutrition outcomes of household members, with an emphasis
on children under the age of five years, pregnant and lactating women, and adolescent girls and boys in
the country’s Feed the Future Zone of Influence (ZOI) and the Zone of Resilience (ZOR). Three results
underwrite this goal: 1) consumption of nutritious, diverse, safe, and balanced diets by households; 2)
social and economic empowerment of women and social empowerment of adolescents; and 3) adoption of
WASH practices (see Figure 1). The Activity integrates a strong focus on gender equality and social
1
Monitoring indicators differ from performance indicators, which are the measures that USAID uses to detect progress toward
the results included in a Results Framework.

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inclusion across all three result areas—achieving improvements in all three result areas is necessary to
positively affect nutritional outcomes.
Figure 1. Feed the Future Bangladesh Nutrition Activity Results Framework
The Activity’s unique approach integrates social and behavior change (SBC) and market development to
catalyze sustainable improvements in nutrition and WASH in the ZOI and ZOR. Past market systems
projects have incorporated SBC approaches in a limited manner, dulling their effect on dietary changes
and nutritional outcomes. Past SBC initiatives addressing nutrition constraints have focused on
interpersonal, one-way communication, which has limited sustainability. In comparison, emerging SBC
approaches that build on marketing, product design, and environmental nudges can be more effective in
influencing behaviors, norms, and decision-making. Meanwhile, growing evidence shows that WASH is
inextricably linked to nutrition outcomes and gender equality can promote household crop diversity,
nutritious food purchases, and dietary diversity.
The Activity’s hypothesis is if the project increases access to and demand for nutritious foods and quality
WASH products in local markets, increases diversity of homestead production and improves female and
adolescent empowerment through SBC and market development interventions, then the Activity will
sustainably improve nutrition and WASH behaviors and practices that will in turn improve nutrition
outcomes in the ZOI and ZOR.

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2.2. Technical Approach

The Activity will strengthen supply, demand, and the environment (including environments and norms
favoring gender-equitable access and utilization) for nutritious foods and WASH products and behaviors
in the ZOI and ZOR using an integrated SBC and market development approach.
The Activity has selected a set of actors and entry points based on its analysis of agriculture-WASH-
nutrition pathways and key constraints to improved nutrition in the ZOI and ZOR that the Activity can
address with a facilitative, market systems approach. Given significant variances across individual
districts and the unique challenges in each district, the Activity will adopt a flexible approach to
implementation. The Activity will work with common actors across results to the extent feasible, and the
needs of each district will drive implementation. These actors include:
 Market system actors. The Activity will catalyze changes with haat/bazar vendors (and their
organizing structures, Banik Samity,2 and Market Management Committees [MMCs]), mobile
sales agents and their suppliers, female entrepreneurs (identified through women’s microfinance
and agro-producer groups), and retailers and suppliers (private sector firms) who can spur
demand for nutritious foods and improved WASH products and influence consumer preference
and behaviors.
 Women’s microfinance and agro-producer groups. These well-established groups are influential
sources of economic and social support for women in the ZOI and ZOR and are themselves
strong consumer bases that can promote changes in nutritious foods and WASH product
purchases. The Activity will work through these structures and their members to spark dialogue,
offer social support, promote income generation for female entrepreneurs, and build demand
among members as consumers of nutritious foods and WASH products.
 Institutions engaging school-going adolescents. Institutions engaged in organizing and enabling
school children to catalyze social change, such as BIID Foundation and Innovision Consulting
Private Limited, have wide-reaching platforms to promote adolescent empowerment, as well as
improved nutrition and WASH practices among adolescents, their families, and their
communities. In collaboration with Directorate of Secondary & Higher Education, the Activity
will engage with such institutions at a national level to facilitate and institutionalize activities, and
with adolescent nutrition clubs in schools in targeted localities in the ZOI and ZOR.
 Public sector actors. The Activity will collaborate with relevant public sector actors (such as
Department of Agricultural Extension (DAE), Dhaka Water Supply and Sewerage Authority,
Department of Public Health Engineering, Local Government Engineering Department,
Directorate of Secondary & Higher Education, National Nutrition Services to leverage their
skills, resources, and platforms through collaborative implementation. The Activity will also aim
to transfer proven approaches to relevant public sector actors for national scale-up.
The Activity will be implemented in selected districts and upazila in the ZOI and ZOR. To maximize
impact, the Activity will conduct its nutrition-sensitive interventions in select upazilas where USAID has
current Feed the Future projects and USAID investments, including in the areas of livestock, horticulture,
aquaculture, agriculture infrastructure, and digital agriculture. The Activity will also be implemented in
districts where USAID has active market development and value chain activities to promote synergies,
such as the Innovation Lab for Food Systems for Nutrition project. Because the Activity’s expected
results require household-level changes, it will target the upazilas as they are close enough to the
community to influence behavior change while also facilitating engagement with the private sector and
central government departments.
2
Banik Samity is a trader’s association, the private sector counterpart of the MMC.

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2.3. Brief Description of FY 2024 activities

The Activity's implementation is structured around three interdependent and synergistic results. Result 1
will increase consumption of nutritious, diverse, safe, and balanced diets by all members of households;
Result 2 will catalyze improvements in empowerment for women and adolescents; and Result 3 will
ensure healthy environments for safe, improved diets. To maximize impact across results, the Activity
will work through their intersection points and through existing platforms and organizations, relevant
actors, and current opportunities.
Result 1: Increased consumption of nutritious, diverse, balanced, and safe diets by households
To increase the consumption of nutritious, diverse, balanced, and safe diets by households, the Activity
will improve the availability of affordable, diverse, nutritious, and safe foods, by facilitating access within
markets and household gardens/fields and by generating demand for these foods and balanced diets and
strengthening household capacity to utilize them. The Activity aims to enhance access to diverse and
nutritious food in local markets by collaborating with market system actors and establishing linkages with
both public entities (like municipalities and government departments) and the private sector. The Activity
will use USAID funds for technical assistance through ethnographic research and training, while market
system actors will use their own funds or funds from local government departments for infrastructural
improvements. Additionally, the Activity will strengthen the capacity of and linkages among private
sector actors to make improved, nutrition-sensitive productive inputs available in areas with limited
access and to increase sales. The Activity will focus solely on providing technical assistance, training, and
social behavior change communication activities. While private and public sector partners are encouraged
to set up demonstration plots, they must independently finance all agro-inputs, including seeds, fertilizers,
etc. Furthermore, to promote household utilization of nutritious foods, the Activity will target and reshape
nutrition-related attitudes, perceptions, and behaviors, focusing exclusively on technical assistance,
training, and social behavior change communication activities.
Result 2: Increased social and economic empowerment of women and adolescents

To enhance the social and economic empowerment of women and adolescents, the Activity will
collaborate with key actors and groups, aiming to foster attitudinal changes and create new opportunities
within social and physical environments. This effort focuses on increasing participation in decision-
making, access to, and control over resources for women and adolescents. The interventions will center
around providing technical assistance, training, and social behavior change communication, aligning with
the Activity’s strategy to support vendors, facilitate entrepreneurial activities, and encourage normative
changes around nutrition and WASH, as well as to bolster nutrition, WASH, and gender activities in
schools, and mobilize adolescent groups for community engagement. To complement the Activity’s
technical assistance to school going adolescents, public and private sector actors will be expected to
finance all agro-inputs (such as seeds, fertilizers, etc.) for demonstration plots they may set up in schools,
and to finance any installation and upgrading of WASH facilities in schools.
Result 3: Increased adoption of improved WASH behaviors

To increase adoption of improved WASH behaviors, the Activity will expand access to safe drinking
water, enhance sanitation facilities, and promote sustainable hygiene practices in targeted areas. Key
interventions include partnering with public and private sectors to improve households’ access to basic
and safe drinking water, training local latrine producers to increase access to improved sanitation
solutions, and supporting hygiene product marketers to increase supply and demand of appropriate
technologies. Towards these, the Activity will work closely with private firms such as Lixil and RFL
Plastics, public entities like Dhaka Water Supply and Sewerage Authority and Department of Public
Health Engineering, NGOs, community groups, and financial institutions, to tailor products, strengthen
regulations, and facilitate community engagement. The approach integrates behavior change and social
norms, ensuring gender and social inclusion, particularly addressing women's and girls' specific needs in

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sanitation and menstrual hygiene management. Additionally, the strategy considers climate resilience,
adapting to environmental changes affecting water resources, and ensuring the economic viability of
solutions, with support from diverse funding sources including corporate social responsibility, micro-
finance, and public investment. This multi-faceted approach aims to tackle the complex challenges of
WASH in Bangladesh by not only increasing access to technologies and infrastructure but also shifting
behaviors and norms for long-term impact.
3. SITE-SPECIFIC INFORMATION
3.1. Locations Affected and
Environmental Context
The Activity is primarily focused on the 21
south-central and southwest districts of the
country (see map), called the Feed the Future
ZOI, and two districts in the southeast part of
the country called the Feed the Future ZOR.
These regions include areas with some of the
highest poverty and malnutrition rates, in
addition to coastal areas vulnerable to the
effects of climate change. Priority has been
given to areas (e.g., production of safe and
nutritious food, climate-smart agricultural
technology promotion, increased resiliency
of the targeted community, food safety
issues, etc.) where activities can be
integrated with ongoing food security and
other USAID programs. In addition, the
program and activities will primarily target
small farmers and the food and nutrition-
insecure poor people in the urban and rural
areas.
3.2. Applicable
Environmental and Social
Laws, Policies, and Regulations
Bangladesh is highly vulnerable to natural disasters and climate hazards, and its population has low
resilience to these stressors. The natural resource base, including forests and wetlands on which half the
population depends, has been over-exploited and degraded.3 Therefore, biodiversity conservation is a
priority in USAID Bangladesh’s Country Development Cooperation Strategy (CDCS). The monsoon
floods of July 2020, coupled with prolonged inundation and the COVID-19 pandemic, were the worst in a
decade. Accordingly, the CDCS takes a strategic approach to addressing some of these shocks by
designing activities to build resilience through climate mitigation and adaptation.
Bangladesh is one of the world’s most densely populated countries with a population of more than 169
3
Bangladesh Planning Commission. Environment, Forestry and Biodiversity Conservation: Background Paper for Seventh Five
Year Plan (2016-2020). 2016

November 2023
million living in 147,570 square kilometers including rivers.4 Bangladesh has been ranked as the 6th most
vulnerable country in the world in terms of risks from natural hazards. The biggest threats to development
and livelihoods are tidal surges, salinity, flooding, river erosion, and cyclones, which are unfortunately
regular features that pose challenges to food and nutritional security for a large part of the rural areas.
Bangladesh also faces other challenges from growing urbanization, declining land availability,
infrastructure shortages, energy supply constraints, governance issues, etc.
The agriculture sector continues to be the leading contributor to methane emissions, and the energy sector
is the second highest and most growing. Emissions from the power industry increased 142% from 2005 to
2017 while emissions from the transport sector increased 94% during the same period. 5 Changes in land-
use patterns and the waste sector are also significant contributors to total emissions.
Bangladesh’s emissions grew 59% from 1990 to 2012 and the overall trend of emissions growth is
increasing. In 2016, Bangladesh’s carbon dioxide (CO2) emissions per capita was 0.46 metric ton (MT),
compared to 0.18 MT in 19976. In the ranking by CO2 emissions per capita of 180 countries, Bangladesh
is ranked 73rd, comparable to Greece and Kiribati. Compared to the United States, which is at the top of
the rankings with CO2 emissions per capita of 15.56 MT in 2016, Bangladesh has 97% lower CO2
emissions per capita. Bangladesh’s 2017 CO2 emissions were 82.77 MT, up from 79.64 MT the year
before, a change of 3.9%.7
3.2.1. National Agricultural and Environmental Policies
Bangladesh has several laws, policies, and national strategies that address environment, tropical forests
and biodiversity, and water and sanitation, several of which have been amended over the past decade in
an effort to increase enforcement of environmental protections. However, environmental laws and
policies are not well enforced on the ground, and the assessment team found instances where the agencies
described above have little capacity or strategy to enforce these laws and policies. The main laws,
policies, and national strategies that have been developed to address tropical forests and biodiversity
protections in Bangladesh are summarized and discussed in the section below. For the purposes of this
EMMP, only the major laws and policies are discussed here, and this list is not exhaustive.
The National Agriculture Policy 2018 promotes a sustainable agriculture production system by increasing
productivity through proper management of natural resources. The policy also provided importance on
promoting effective technologies suitable for adverse soil-water fertilizer-crop management practices to
protect the environment.8 The National Agricultural Extension Policy may encourage the development of
marginal forest lands for agriculture, or the National Industrial Policy may encourage industrial expansion
and pollution at the cost of forests, wetlands, or ecologically sensitive areas. The National Shrimp Policy
is an effort to reduce the impact of shrimp farming on coastal areas and mangroves but may not be
sufficient to address unsustainable harvesting of wild shrimp for farms or the destruction of mangroves
that occur on the southeast coast.
Bangladesh Water Act 2013 is a framework Law to integrate and coordinate the water resources
management in the country. The Water Act will establish a new, integrated approach to the protection,
improvement, and sustainable use of country's rivers, lakes, estuaries, coastal waters, and groundwater.
4
Population and Housing Census 2022: National Report (Volume 1)
5
https://publications.europa.eu/en/publication-detail/-/publication/41811494-f131-11e8-9982-01aa75ed71a1/language-en
6
https://knoema.com/atlas/bangladesh/co2-emissions-per-capita
7
https://ycharts.com/indicators/bangladesh_carbon_dioxide_emissions,
https://www.bp.com/en/global/corporate/energy-economics/statistical-review-of-world-energy.html and
https://www.iea.org/countries/bangladesh/
8
https://bangladeshbiosafety.org/wp-content/uploads/2021/03/National-Agricullture-Policy_2018_English.pdf

November 2023
The Bangladesh Water Law has established the right to access water. Access to drinking water and water
for domestic usage is considered as basic right. Section 3(2) of Bangladesh Water Act 2013 states the
“...right to potable water, use of water for hygiene and sanitation shall be treated as a universal right." The
act protects any water bodies (ponds, lakes) used for safe drinking water supply, more urgently in the
disaster-stricken areas such as haor,9 baor,10 or any other water bodies to be protected to ensure safe
place, movement, and sanctuary for birds. According to the National Policy for Arsenic Mitigation, 2004
and the National Implementation Plan for Arsenic Mitigation in 2004, carry out public awareness
campaigns to warn about consuming arsenic-contaminated water, to take remedial measures against
arsenic poisoning and to inform that arsenicosis is not contagious, social exclusion is not justified and
various alternative arsenic-safe water supply options are available. The policy also mandated the carrying
out screening and monitoring of all potential contaminated tube wells with the objective of identifying
arsenic contaminated wells, arsenic patients, and the population at risk.
The Bangladesh Water and Sanitation Strategy 2014 (amended 2021) also mandated giving due
consideration to local values and cultural practices in sanitation improvement programs including choice
of technologies; continuing and expanding the reach of the National Sanitation Campaign and include
specific campaign programs targeting the potential latrine users; developing a set of sanitation
technologies, ranging from basic hygienic latrines to water borne sewerage system, as appropriate in
specific situations; developing markets for various types of hygienic latrines (i.e., conversion of
unhygienic latrines, changing from shared to single household use latrine and introducing latrines to
people still practicing open defecation) and upgrade existing hygienic latrines; providing adequate public
toilet facilities at places where people congregate, such as, bus stations, boat terminals, market and parks
and provide mobile toilets or other suitable facilities for public gatherings like public meetings and fairs. 11
The policy also pursued organic waste recycling through composting, biogas, and reuse derived fuel.
The importance of forests and biodiversity are enshrined in the Bangladesh Constitution. Article 18A
safeguards environmental protection and sustainable development. As Table 2 indicates, some laws
protect environmental quality broadly, as well as specific laws for forests, wetlands, fisheries, and coastal
habitats in Bangladesh. Some laws deal with specific threats to forests, like the Brick Burning and
Control Act, 1989, which was amended in 1995 and strengthened in 2013, to reduce the impact of brick
kilns on forests and agricultural land. However, these laws have not been enforced sufficiently to protect
forests from being used as a source of fuel wood for kilns, or the growth of brick-making industry.
Bangladesh also has a system of environmental courts, established through the Environment Court Act,
2000, but it is unclear whether these courts are able to enforce penalties or prevent environmental laws
from being broken. Several national policies (Table 2) also exist to direct the work of government
agencies in the management of forests and biodiversity, but in many cases, the purposes of some policies
may run counter to others, or to laws that protect forests and biodiversity.
The Government of Bangladesh formulated an Environment Policy in 1992. The objectives of

Environment Policy are to:
 Maintain ecological balance and overall development through protection and improvement of the
environment,
 Protect the country against natural disasters,
 Identify and regulate activities that pollute and degrade the environment,
 Ensure environmentally sound development in all sectors,
9
Haor: A low-lying area on a floodplain that partially dries up during the dry season.
10
Baor: An oxbow lake, formed when a river meander is cut off from the mainstream by sediment deposition, resulting in a
water-filled isolated curve.
11
https://www.psb.gov.bd/policies/nswsse.pdf

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 Ensure sustainable, long term and environmentally sound use of all national resources, and,
 Remain actively associated with all international environmental initiatives to the maximum possible
extent.
Bangladesh has ratified several international environmental conventions including Convention on

Biological Diversity, Convention on International Trade in Endangered Species of Wild Fauna and Flora,
Convention on the Conservation of Migratory Species of Wild Animals, Convention on the Control of
Transboundary Movements of Hazardous Wastes and their Disposal, Ramsar Convention, United Nations
Framework Convention on Climate Change, and so on.12
3.2.2. USAID Environmental Regulations and Requirements
22 CFR 216 is the US federal regulation defining USAID’s pre-implementation environmental impact
assessment process. The output of this process is documenting requests for categorical exclusion (CE),
IEEs, and environmental assessments (EA). Other related mandatory provisions are mentioned in
USAID’s ADS - especially, but not limited to ADS 201 and 204.
Within this framework, it is USAID's environmental policy to:

 Ensure that the environmental consequences of A.I.D. financed activities are identified and
considered by A.I.D. and the host country prior to a final decision to proceed and that appropriate
environmental safeguards are adopted,
 Assist developing countries in strengthening their capabilities to appreciate and effectively evaluate
the potential environmental effects of proposed development strategies and projects, and to select,
implement, and manage effective environmental programs,
 Identify impacts resulting from A.I.D.'s actions upon the environment, including those aspects of the
biosphere that are the common and cultural heritage of all mankind, and
 Define environmental limiting factors that constrain development and identify and carry out activities
that assist in restoring the renewable resource base on which sustained development depends.
3.3. Lessons Learnt through Implementation

The Activity supported the public and private sector market actors such as agro-input companies and
agro-input retailers (AIR) to build the capacity of the beneficiaries to a) develop homestead gardens for
growing nutritious and diverse vegetables using good homestead gardening practices, b) promote
environmentally friendly technology of vermicompost, tricho-derma, pheromone trap, yellow sticky
cards, and coco peats, etc., c) use improved latrines, d) promote safe water filters to rural consumers in
ZOI and ZOR which involves the use of environment-friendly filter papers that are renewable and
biodegradable, and e) promote awareness on using and disposing of environment-friendly hygiene
products and services.
Homestead production: The Activity, in collaboration with agro-input companies and DAE, built the
capacities of AIRs and homestead producers on: (a) integrated pest management, including resistance
issues with pesticides, advantages of environmentally friendly technologies, health hazards and
environmental effects from fertilizers and pesticides, and safe handling practices (including use of
personal protective equipment), (b) pesticide evaluation report and safer use action plan (PERSUAP) -
rejected or unapproved pesticides (only for AIRs), (c) not promoting or using uncertified seeds, (d)
advantages of crop rotation and intercropping, (e) safe disposal of plastic seed packets, and (f) post-
harvest handling techniques (homestead producers only). The Activity’s key observations and learning
12
http://www.moef.gov.bd/html/protoco/protocol_main.html

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were:
 The Activity observed that many market actors and homestead producers were neither aware of the
negative environmental effects of plastic packets nor the health hazards of using pesticide in food
production, the importance of promoting and using only certified seeds, and integrated pest
management techniques (in particular, the advantages of environment-friendly technologies).
 Market actors/farmers required more time to comprehend the health and environmental hazards,
requiring the Activity to explain these in detail during training sessions and to reinforce these during
follow-up visits. AIRs and homestead producers positively received this intervention and started
practicing recommended actions in their business as well as daily life. Homestead producers
capacitated by the Activity rely primarily on environment-friendly technology and were observed to
be disposing of seed packets appropriately. Further, most AIRs capacitated have begun to stock and
sell environment-friendly technologies promoted by the Activity.
Improved sanitation: The Activity builds the capacity of rural sanitation entrepreneurs and rural
households on the following: (a) the importance of every household member using improved sanitary
latrines to reduce open defecation, ultimately reducing transmission of vector-borne diseases and
environmental contamination, (b) promoting Sato pans, particularly relevant for climate-vulnerable and
water-scarce areas, since they require a lesser amount of water, (c) proper installation of latrines (at least
10 meters from water source, and on a raised platform), and (d) community awareness building on
appropriate practices for emptying latrines, and promotion of double-pit latrines for proper disposal of
fecal sludge in situ. The Activity’s key observations and lessons learned from these were:
 Sanitation entrepreneurs and communities learned about the various benefits of improved latrine
models, among which is the reduction of health hazards by restricting vectors from encountering
feces, reducing foul odors, and preventing the leaching of harmful substances into the soil or
groundwater. They also learned how to utilize the locally available and natural building materials
such as bamboo, wood, and thatch which can be used for the superstructure, which absorbs less heat
and is better ventilated, compared to typical brick and concrete structures. The improved latrine,
along with its superstructure made of locally available materials, has seen increased demand in the
market and households. For substructure, a concrete slab/ring is used. In terms of environmental
friendliness, while concrete is durable and can ensure the longevity of the latrine, its production
process and carbon footprint are considerable drawbacks. The sanitation entrepreneurs seem to be
more interested in selling the improved latrine, and similarly, households are keen to buy the
superstructure that is made of timber, wood, and thatch instead.
 As a result of investing in improved latrines, the rural households have witnessed positive changes in
their households in terms of reduction of bad odor and spill of fecal waste lying around their
household. The households say this not only keeps their household and communities’ areas clean but
also reduces risks of waterborne diseases. The latrine producers on the other hand are also
emphasizing these environmental benefits to other potential rural consumers to market their products
better.
Safe drinking water: This Activity has been supporting a private sector partner to promote safe water
filters to rural consumers in the ZOI and ZOR, which involves the use of environment-friendly filter
papers that are renewable and biodegradable. To ensure the safety of the consumers, the inputs used to
develop the filters also comprise food-grade ingredients. Another essential feature of the water filter is it
does not require the consumption of any form of energy such as electricity which is one of the great
lessons for the consumers. The Activity along with the private sector partners continues rural household-
focused promotional campaigns which emphasize the benefits of the product and how the users should
properly manage and dispose of the water filters once they have used them which was unknown to them.
The Activity has also been supporting a private partner to market safe drinking water from its rural

November 2023
community water treatment plant. The Activity ensured, through the grant agreement, that the
private partner will:
● Test water quality from the plant regularly through an authorized entity,
● Avoid pesticides and disinfectants due to its potential health and environmental hazards,
● Safely dispose of wastewater,
● Follow Standard Conditions for Small Scale Enterprises in the installation of the plant (installation of
the plant is not funded by US Government), and
● Site wastewater facilities in a way that minimizes their potential for contaminating water supply
sources, or for exposing human populations to waterborne contaminants; avoid siting water supply
and wastewater facilities in flood-prone areas; and design water supply facilities to protect water
quality, minimize the potential for contamination, and minimize operation and maintenance costs.
Hygiene: The Activity partnered with the private sector to build awareness of hygiene entrepreneurs and
adolescents to use environment-friendly hygiene products and services including sanitary pads and
dispose of the residuals safely for decomposition. The Activity’s key observations and lessons learned
from these were:
 Due to stigma and normative barriers, the market actors and adolescents were neither aware of the
negative environmental effects and health hazards of unsafe disposal of non-biodegradable hygiene
products.
 Market actors and adolescents required more time to comprehend the health and environmental
hazard aspects; the Activity was explained in detail during training sessions.
 In addition, the Activity promotes reusable sanitary napkins as an environmentally friendly solution.
Both the users and the sellers received this product positively due to its convenience (i.e., not
requiring disposal).
4. ANALYSIS OF POTENTIAL ENVIRONMENTAL

RISK
In the IEEs, environmental impacts may result in three threshold decisions: CE, negative determination
with conditions (NDC), and significant environmental impacts. CE refers to activities presumed to have
negligible environmental impacts and thus do not require an EA or an environmental impact statement
(EIS). NDC applies to activities that could potentially cause significant adverse environmental impacts
but can proceed if specific conditions and mitigation measures are implemented. Lastly, activities
expected to have significant environmental impacts fall under the requirement for a comprehensive EA or
EIS, involving a detailed study of these impacts, public involvement, and the development of mitigation
measures to minimize adverse effects. The section below summarizes the threshold decisions identified in
IEEs applicable to the Activity’s FY 2024 workplan.
4.1. Potential Risks by Results areas

4.1.1. Result 1: Increased consumption of nutritious, diverse, balanced, and safe diets
by households

November 2023
Threshold
FY 2024 Activities Activity Description and Potential Environmental Impacts
Decision
Intermediate result (IR) 1.1: Increase access to diverse, nutritious, safe foods in local markets
Sub IR 1.1.1 Increase accessibility and affordability of diverse, nutritious, safe foods in local markets
(a) Test new models that increase The Activity will use USAID funds for technical assistance CE per Reg.
access and demand for nutritious through ethnographic research and training. 216.2(c)(2)
food (xiv)
Sub IR 1.1.2: Improve food safety and hygiene, and reduce food loss and waste in the local market.
(a) Continue to facilitate market Interventions are related to technical assistance, training, and CE per Reg.
management committees social behavior change communication activities. Market 216.2(c)(2)
/business associations to prioritize management committees / business associations will use their (xiv)
infrastructural improvements that own funds or funds from local government departments for
impact food loss and waste and infrastructural improvements.
create an enabling environment
for women vendors & customers
(b) Refine interventions for Interventions are related to technical assistance, training, and CE per Reg.
improving food safety, food loss, social behavior change communication activities. 216.2(c)(2)
and waste behaviors and practices (xiv)
of food vendors in the markets
(c) Test market-based model for Interventions are related to technical assistance, training, and CE per Reg.
wet food waste recycling social behavior change communication activities. Public and 216.2(c)(2)
private partners will use their own funds for installation, (xiv)
operations, and maintenance of recycling technologies.
Sub IR 1.2.1: Increased diversity of homestead production
(a) Scale-up nutrition education Interventions are related to technical assistance, training, and CE per Reg.
and year-round homestead social behavior change communication activities. Private 216.2(c)(2)
production of diverse fruits and partners may establish demonstration plots but will use their (xiv)
vegetables with the private sector own funds for all agro-inputs (such as quality seeds, compost,
vermi-compost, bio-fertilizers, and bio-pesticides)
(b) Scale-up nutrition education Interventions are related to technical assistance, training, and CE per Reg.
and year-round homestead social behavior change communication activities. The Activity 216.2(c)(2)
production of diverse fruits and will establish demonstration plots (for example, the Activity (xiv)
vegetables with Department of will finance fencing of demonstration plots) with technical
Agricultural Extension assistance from DAE. However, agro-inputs (such as quality
seeds, compost, vermi-compost, bio-fertilizers, and bio-
pesticides) will be provided by the Activity’s private sector
partners using their own funds.
(c) Test approaches to increase Interventions are related to technical assistance, training, and CE per Reg.
consumption of balanced diets by social behavior change communication activities. For backyard 216.2(c)(2)
improving homestead production poultry, households will purchase their poultry feed, medicines, (xiv)
of indigenous fish and backyard disinfectants, etc. as per guidance from public and private
poultry extension services. For indigenous fish cultivation in household
ponds, Activity’s private partners may establish demonstration
ponds but will use their own funds for all relevant inputs (such
as fish fingerling, fish feed, and aqua medicines)
Sub IR 1.2.2: Improve access to and use of quality productive inputs
(a) Test approaches to increase Interventions are related to technical assistance, training, and CE per Reg.
access to location- and season- social behavior change communication activities. Public and 216.2(c)(2)
specific, value-added nutritious private sectors will promote location specific high value crops (xiv)
crops that can be cultivated in homestead gardens using their own
funds.
Sub IR 1.2.3: Improve access to and use of post-harvest, food processing, and storage technologies

November 2023
Threshold
Decision
(a) Integrate improved homestead Interventions are related to technical assistance, training, and CE per Reg.
post-harvest practices, storage social behavior change communication activities. 216.2(c)(2)
techniques, and food safety (xiv)
practices into homestead
production interventions
(b) Test approaches to promote Interventions are related to technical assistance, training, and CE per Reg.
small-scale food processing social behavior change communication activities. 216.2(c)(2)
among homestead producers (xiv)
Sub IR 1.3.1 Increase demand for nutritious, diverse, balanced, and safe diets
(a) Revise and refine SBC Interventions are related to technical assistance, training, and CE per Reg.
messages based on research social behavior change communication activities. 216.2(c)(2)
findings to deliver through (xiv)
existing communication channels
(b) Test approaches to engage Interventions are related to technical assistance, training, and CE per Reg.
religious leaders at scale social behavior change communication activities. 216.2(c)(2)
(xiv)
Sub IR 1.3.2 Improve household food safety practices
(a) Address food safety, loss, and Interventions are related to technical assistance, training, and CE per Reg.
waste among consumers and social behavior change communication activities. 216.2(c)(2)
homestead producers (xiv)
4.1.2. Result 2: Increased social and economic empowerment of women and

adolescents
Threshold
Decision
IR 2.1: Increase economic and social empowerment of women
Sub IR 2.1.1: I Increase access to income by women and Sub IR 2.1.2: Increase women’s agency for
entrepreneurship and improved household nutrition practices
(a) Test approaches to facilitate Interventions are related to technical assistance, training, and CE per Reg.
the public sector to increase social behavior change communication activities. 216.2(c)(2)
women’s entrepreneurship and (xiv)
agency for improved household
nutrition practices
(b) Test approaches to facilitate Interventions are related to technical assistance, training, and CE per Reg.
the private sector to expand social behavior change communication activities. 216.2(c)(2)
coverage of initiatives that engage (xiv)
women as producers or suppliers
(c) Test approaches to facilitate Interventions are related to technical assistance, training, and CE per Reg.
microfinance institutions in social behavior change communication activities. 216.2(c)(2)
adopting a business model that (xiv)
integrates entrepreneurship and
agency support with their ongoing
financial services outreach
(d) Continue approaches to Interventions are related to technical assistance, training, and CE per Reg.
provide entrepreneurship and social behavior change communication activities. 216.2(c)(2)
agency support directly (xiv)
Sub IR 2.1.3: Strengthen enabling environment for women's participation in local market

November 2023
Threshold
Decision
(a) Strengthen market committees Interventions are related to technical assistance, training, and CE per Reg.
to foster an inclusive environment social behavior change communication activities. 216.2(c)(2)
at market centers, enabling active (xiv)
participation of women in local
markets
IR 2.2: Increase social empowerment of adolescent
Sub IR 2.2.1: Improve adolescents’ nutrition and WASH-related knowledge and skills for improved behaviors and
Sub IR 2.2.1 Strengthen adolescent’s role as champions in families and community, and Sub IR 2.2.2: Strengthen
adolescents' role as champions in schools, families and communities
(a) Support institutions working Interventions are related to technical assistance, training, and CE per Reg.
with school-going adolescents to social behavior change communication activities. Public and 216.2(c)(2)
scale up interventions that enable private partners may establish vegetable gardens within schools, (xiv)
adolescents to become catalysts of providing students with practical experience in understanding
healthy wellbeing the importance of nutritious food consumption and dietary
diversity. The partners will utilize their own funds for agro-
inputs (high-quality seeds, compost, vermi-compost, bio-
fertilizers, and bio-pesticides), as well as for installing and
upgrading WASH facilities in the schools.
4.1.3. Result 3: Increased adoption of improved WASH behaviors
Threshold
Decision
IR 3.1 Increase utilization of safe water behaviors
Sub-IR 3.1.1 Increase supply of and demand for safe water services and technologies for household use/domestic
purposes
(a) Test approaches to improve The Activity will use USIAD funds to build capacity NDC per Reg.
functionality of household and households and communities in operations and maintenance of 216
community water supply solutions water supply solutions (such as rainwater harvesting, or piped
installed by the public sector and water supply systems) that were installed by the public sector
development partners and development partners but are not functional currently and
increase awareness of the importance of safe drinking water.
The potential environmental impacts are:
 Damage to sensitive ecosystems or endangered species due
to improper site selection
 Environmental pollution due to improper disposal of
packaging material for safe water and water treatment
products
 Chemical effects from non-food grade water treatment
products
 Water treatment plants established by the public sector or
development partners do not comply with Government of
Bangladesh regulations
(b) Test approaches to increase The Activity will use USAID funds to increase awareness about NDC per Reg.
access to basic drinking water safe drinking water, with a focus on initiatives led by private 216
through private sector, social sector, social enterprises, and civil society for piped water
enterprise, and civil society-led solutions, as well as technical assistance to these organizations
piped water solutions towards improving business plans and marketing strategies.
Alongside this, the Activity's private sector partners will

November 2023
Threshold
Decision
allocate their own funds to install tubewells for extracting
groundwater, which will then be channeled through the piped
water systems. The potential environmental impacts are:
products
products
(c) Scale up access to safe Through the Activity, USAID funds will be directed towards NDC per Reg.
drinking water through private- raising community awareness about the benefits of safe 216
sector community water treatment drinking water, as well as technical assistance to private sector
plants community water treatment plants to improve their business
plans and marketing strategies. The private sector partners will
use their own funds for construction, operations, and
maintenance of the plants, and to extract groundwater which
will then be treated in these plans. The potential environmental
impacts are:
products
products
(d) Refine approaches to promote The interventions are related to technical assistance, training, CE per Reg.
adoption of water safety plans in and social behavior change communication activities only. 216.2(c)(2)
communities to increase (xiv)
utilization of appropriate
household water storage
technologies
IR 3.2 Increase utilization of improved sanitation services
Sub IR 3.2.1 Increase access to and demand for improved sanitation services in the community
(a) Scale up the latrine producer The Activity will use USAID funds to promote and train latrine NDC per Reg.
training and promotion of single- producers in the construction of improved latrines, with a focus 216
pit latrines on environmentally safe and sustainable designs.
Complementing this, the Activity's private sector partners will
use their own funds to manufacture and distribute the necessary
materials, ensuring a robust supply chain for these improved
sanitation solutions. The potential environmental impacts are:
 Improper siting of wastewater facilities
 Contamination from sanitation facilities up gradient from
or dug over shallow clean drinking water supplies

November 2023
Threshold
Decision
 Contamination of groundwater supply with pathogens
 Contamination of water supplies, damage to water quality
and/or transmission of disease at other locations if waste is
not properly handled and treated during or after servicing
 Construction can cause injury to people or animals
(b) Test approaches to upsell The Activity will utilize USAID funds to demonstrate and NDC per Reg.
improved sanitation solutions that promote advanced sanitary solutions that align with consumer 216
meet consumer aspirations better preferences and have reduced environmental impacts. Private
and could have lower sector partners of the Activity will be responsible for the
environmental impacts production and supply chain enhancement of these sanitation
products, using their own financial resources to support this
effort. The potential environmental impacts are:
 Improper siting of wastewater facilities
 Contamination from sanitation facilities up gradient from
or dug over shallow clean drinking water supplies
 Contamination of groundwater supply with pathogens
 Contamination of water supplies, damage to water quality
and/or transmission of disease at other locations if waste is
not properly handled and treated during or after servicing
 Construction can cause injury to people or animals
IR 3.3 Increase utilization of improved hygiene behaviors
Sub IR 3.3.1 Increase supply and demand for menstrual hygiene management products and services
(a) Partner with the private sector Interventions are related to technical assistance, training, and CE per Reg.
to increase the adoption of social behavior change communication activities. 216.2(c)(2)
menstrual hygiene practices (xiv)
among women and girls
Sub IR 3.3.2 Improve handwashing and home hygiene practices
(a) Improve hand and home Interventions are related to technical assistance, training, and CE per Reg.
hygiene practices through the social behavior change communication activities. 216.2(c)(2)
implementation of product-led (xiv)
solutions and behavioral change
initiatives
4.2. Due Diligence

The Activity will, where possible, raise environmental awareness, promote environmentally and socially
sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of
environmental compliance and governance, and promote public participation in decision-making and
access to justice in environmental matters.
The Activity will include environment compliance considerations in all aspects of program
implementation through the implementation of this EMMP and climate risk management and will
promote and train local counterparts on environmental requirements and standards across all the
activities. Such proposed activities will be included in annual work plans, and results will be reported in
annual performance reports.
The Activity will designate qualified staff to train the Activity personnel (including sub-grantees and sub-
contractors), coordinate the implementation of mitigation measures, monitor, and reporting. Should the
designated staff lack special technical knowledge to identify any special environmental impact, they will

November 2023
receive guidance and support from the Abt Associates’ Home Office environmental compliance team.
Before the launch of each activity receiving an NDC designation, the designated staff will conduct an
environmental due diligence (EDD) review using the Environmental Review and Assessment Checklist
(Annex A) and follow the environment management systems flow chart (Annex B) for appropriate
approvals. Sub-contracts and grants to other organizations must incorporate contract agreement
provisions stipulating compliance with 22 CFR 216 and ADS 204 and the IEE.
The EDD process will document existing environmental and social concerns and foreseeable
environmental effects resulting from the activities. If the EDD results in a finding of potential significant
environmental impact, a scoping statement (SS) and EA will be done by the Activity before the start of
activities. The terms of reference for SSs and/or pesticide evaluation reports and safer use action plan, SS,
and EA Report must be reviewed by Monitoring and Evaluation Officer and approved by Asia Bureau
Environmental Officer. If the EDD review determines that activities can follow best practices and
standard conditions and no further assessment is required, each activity will be conducted in compliance
with this EMMP in a manner consistent with good design and implementation practices.
5. ENVIRONEMNTAL MITIGATION, MONITORING,

AND REPORTING PLAN
Environmental mitigation, defined as the implementation of measures designed to reduce the undesirable
effects of a proposed action on the environment and social attributes and assets, is essential for achieving
environmentally and socially equitable sound activity design and implementation. Environmental
monitoring is a necessary complement to mitigation to attest that proposed mitigation works and should
be a normal part of monitoring project results. Mitigation and monitoring are a critical part of
environmentally sound design and implementation. Mitigation minimizes adverse environmental and
social impacts. Monitoring assesses whether the mitigation measures are being implemented, sufficient
and effective, recorded and reported.
The Activity will monitor activities with a NDC threshold determination regularly (Section 4.1). If the
Activity modifies activities, the EMMP will be amended accordingly. In addition, though mitigation
measures are not applicable for activities with a CE, the Activity will integrate climate change adaptation
and mitigation measures into training, capacity building, and SBC interventions where applicable. Table 1
below summarizes FY 2024 activities with a NDC threshold determination, and the corresponding
mitigation and monitoring plan.

November 2023
Table 1: FY 2024 EMMP
Project/ Identified Monitoring

Mitigation Measure(s) Responsible Field Monitoring
Activity/Sub- Environmental Monitoring Indicator(s) and Reporting
Parties Plan
Activity Aspects or Impacts Frequency
IR 3.1 Increase utilization of safe water behaviors
Sub-IR 3.1.1 Increase supply of and demand for safe water services and technologies for household use/domestic purposes
a) Test approaches  Damage to The Activity will train all BNA 100 percent of BNA staff,  Quarterly WASH The Activity staff
to improve sensitive staff, staff of private sector partner staff, and report Program will observe a sample
functionality of ecosystems or partners, and household/community  Immediate Manager of household and
household and endangered species households/communities members responsible for incident community water
community water due to improper site responsible for operations and operations and report (if supply solutions
supply solutions selection maintenance of the water supply maintenance of water required) supported by the
installed by the  Environmental solutions, associated with this supply solutions trained at Activity and assess:
public sector and pollution due to intervention on Standard least once (a) accuracy of due
development improper disposal Conditions for Water and diligence, (b) extent
partners of packaging Wastewater Activities. Data sources: to which the O&M
material for safe  Training attendance protocols are being
water and water The Activity will not assess sheet followed by trainees,
treatment products compliance of public and private  Training module/s and (c) perceptions of
partners, and beneficiaries on the water quality and
 Chemical effects
their compliance to Standard the water supply
from non-food
Conditions for Water and solution.
grade water
Wastewater Activities.
treatment products
 Water treatment
plants established
by the public sector
or development
partners do not
comply with
Government of
Bangladesh
regulations
(b) Test Same as above Same as above Same as above  Same as Same as Same as above
approaches to above above
increase access to

November 2023

Parties Plan
basic drinking
water through
private sector,
social enterprise,
and civil society-
led piped water
solutions
(c) Scale up access  Same as above Same as above  Same as above  Same as Same as Same as above
to safe drinking above above
water through
private-sector
community water
treatment plants
IR 3.2 Increase utilization of improved sanitation services
Sub IR 3.2.1 Increase access to and demand for improved sanitation services in the community
(a) Scale up the  Improper siting of The Activity will train latrine  All latrine producers  Quarterly WASH The Activity will
latrine producer wastewater producers on the following: trained on mitigating report Program visit a sample of new
training and facilities  Site wastewater facilities in a actions during on-  Immediate Manager latrines installed to
promotion of  Contamination way that minimizes their boarding, and at least incident assess whether they
single-pit latrines from sanitation potential for contaminating once in two years report (if are sited properly,
facilities up water supply sources, or for subsequently. required) and that HH members
gradient from or exposing human populations to have knowledge on
dug over shallow waterborne contaminants. Data sources: appropriate FSM
clean drinking  Build latrines and similar  Training attendance procedures.
water supplies sanitation facilities down sheet
 Contamination of gradient of water supply wells.  Training module/s
groundwater supply As necessary, evaluate depth of
with pathogens the water table including
 Contamination of seasonal fluctuations. Pit
water supplies, latrines should not be installed
damage to water where the water table is
quality and/or shallow, or the composition of
transmission of the overlying deposits makes
disease at other groundwater vulnerable to

November 2023

Parties Plan
locations if waste is contamination.
not properly  Devote adequate attention to
handled and treated identifying and addressing
during or after social barriers to using latrines.
servicing  Ensure that a reliable system
 Construction can for safely emptying latrines
cause injury to and transporting the collected
people or animals material off-site for treatment
is used. Properly
decommission pit latrines. Do
not leave pits open. Fill in
unused capacity with rocks or
soil.
The Activity will not assess

compliance of the latrine
producers or beneficiaries on the
guidelines above.
(b) Test Same as above Same as above Same as above Same as above Same as Same as above
approaches to above
upsell improved
sanitation solutions
that meet
consumer
aspirations better
and could have
lower
environmental
impacts
6. CLIMATE RISK MANAGEMENT

Following the approved climate risk and vulnerability analysis for the new USAID/Bangladesh CDCS, this type of activity was found to have "high climate
risk". The climate risk management process followed five different steps: anticipated project element, climate risks, climate risk rating, ways to reduce the

November 2023
risk, and risk management options. The climate risk profile describes the major types of risks that climate change poses to the Feed the Future Zone/
southwestern Bangladesh. Climatic risk rating is done based on the characterization of climate risk; assign a qualitative risk rating for each climate risk: low,
moderate, or high. The level of risk increases both as the severity of negative impact increases and as the probability of negative impact increases. Moderate
to high climate risk management options are addressed in the summary table, based on the risk rating and available resources to address those risks during
project or activity design and implementation. The Activity will embed risk management in project activities.
Table 2: Activity climate risk management summary
Risk
Tasks/Illustrative Intervention Climate Risks How Risks are Addressed Climate Risk Management Options
Rating
Result 1: Increased consumption of  Drought and irregular Medium Drought and irregular rainfall:  Integrated Approach: Climate-smart
nutritious, diverse, balanced, and rainfall patterns.  Facilitate water-saving irrigation systems agriculture practices not only address
safe diets by households  Increased temperatures (e.g., drip irrigation). climate risks but also contribute to
affect crop yield.  Use of drought-resistant crop varieties. improved food security and sustainable
IR 1.2: Increase availability of and rural development.
 Soil erosion due to  Risk Acceptance: Some degree of irregular
access to diverse, nutritious, safe  Community engagement: Involving local
intense rainfall. rainfall is accepted, with adaptation
foods from homestead production companies in decision-making and
strategies in place.
Increased temperatures: implementation enhances local capacity to
Task: Promotion of climate-smart deal with climate risks and ensures the
agriculture practices.  Planting season crop varieties.
sustainability of interventions.
 Training farmers in changing fruit and
vegetable planting and harvesting  Technology and Innovation: Adoption of
This includes the adoption of drought-
schedules to adapt to temperature shifts. improved farming technologies can
resistant crops, improved soil
Soil erosion: increase resilience and productivity,
management inputs, efficient water
offering opportunities for economic
uses techniques, and sustainable  Introduction of soil conservation
growth.
farming practices techniques
Result 3: Increased adoption of  Water scarcity due to High Water Scarcity:  Resilient infrastructure: Facilitate to
improved WASH behaviors prolonged droughts.  Facilitate rainwater harvesting systems and building of WASH infrastructure that is
 Flooding leads to promote water reuse strategies. resilient to climate extremes and enhances
Task: Strengthening WASH contamination of water  Facilitate drought-resilient water supply community health and well-being.
infrastructure and practices in sources and destruction systems, such as deep bore wells.  Community empowerment: Engaging local
response to climate variability and of sanitation facilities. companies and producers in WASH
change. Flooding and Contamination: management increases adaptive capacity
 Increased incidence of
water-borne diseases due  Elevating water storage and sanitation and sustainability.
This includes improving water supply
to changes in facilities in flood-prone areas.  Health and well-being: Improved hygiene
systems, sanitation facilities, and
temperature and rainfall practices contribute to better health
hygiene practices in the face of

November 2023
Risk
Tasks/Illustrative Intervention Climate Risks How Risks are Addressed Climate Risk Management Options
Rating
climate-related challenges. patterns. Water-borne Diseases: outcomes, particularly in the face of
 Promoting hygiene education to prevent climate-induced health challenges.
disease spread.

November 2023
7. ANNUAL REPORTING
Annually, the Activity will prepare an Environmental Mitigation and Monitoring Report (EMMR) and
submit it to USAID Bangladesh and the USAID Environmental Compliance Database
(https://www.usaid.gov/environmental-procedures/compliance-database). This report will summarize the
effectiveness of mitigation measures, issues encountered, resolutions, and lessons learned. As appropriate,
attachments such as site photos, verification of local inspections, product warranties, etc. should also be
included.
8. CONCLUSION
The EMMP transcends mere compliance; it embodies the Activity’s unwavering commitment to
responsible and sustainable development. The Activity integrates environmental considerations into every
facet of its implementation, thereby safeguarding natural resources and securing the well-being and
prosperity of the communities. This plan establishes a robust foundation for a sustainable future, one
where development and environmental conservation advance in tandem.

November 2023
USAID APPROVAL OF EMMP

Approval:
[NAME], Activity Manager/A/COR [required] Date
Clearance:
[NAME], Mission Environmental Officer [as appropriate] Date
Clearance:
[NAME], Regional Environmental Advisor [as appropriate] Date
Concurrence:
[NAME], ________ Bureau Environmental Officer [as appropriate] Date
DISTRIBUTION:

November 2023
ANNEX A: ENVIRONMENTAL REVIEW CHECKLIST

November 2023

November 2023

November 2023

November 2023

November 2023
ANNEX B: ENVIRONMENTAL MANAGEMENT

SYSTEM FLOW CHART

November 2023
www.feedthefuture.gov

USAID Cooperative Agreement Number: AID-388-18-CA-00005
Feed the Future Bangladesh Nutrition Activity

Abt Associates Inc.
Concord Bilkis Tower, 13th Floor
40/6 Madani Avenue
Gulshan 2, Dhaka 1212, Bangladesh

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ENVIRONMENTAL MITIGATION

AND MONITORING PLAN

Contract Number: 72038818CA00005

Submitted by: Ramakrishnan Ganesan

Submitted to: Kh. Farhad Hossain

Submission Date: November 27, 2023

Feed the Future Bangladesh Nutrition Activity Page | 1

Feed the Future Bangladesh Nutrition Activity Page | 2

Feed the Future Bangladesh Nutrition Activity Page | 3

Feed the Future Bangladesh Nutrition Activity Page | 4

Feed the Future Bangladesh Nutrition Activity Page | 5

An EMMP is an action plan that clearly defines:

Feed the Future Bangladesh Nutrition Activity Page | 6

Figure 1. Feed the Future Bangladesh Nutrition Activity Results Framework

Feed the Future Bangladesh Nutrition Activity Page | 7

2.2. Technical Approach

Feed the Future Bangladesh Nutrition Activity Page | 8

2.3. Brief Description of FY 2024 activities

Result 2: Increased social and economic empowerment of women and adolescents

Result 3: Increased adoption of improved WASH behaviors

Feed the Future Bangladesh Nutrition Activity Page | 9

Feed the Future Bangladesh Nutrition Activity Page | 10

3.2.1. National Agricultural and Environmental Policies

Feed the Future Bangladesh Nutrition Activity Page | 11

The Government of Bangladesh formulated an Environment Policy in 1992. The objectives of

Feed the Future Bangladesh Nutrition Activity Page | 12

Bangladesh has ratified several international environmental conventions including Convention on

3.2.2. USAID Environmental Regulations and Requirements

Within this framework, it is USAID's environmental policy to:

3.3. Lessons Learnt through Implementation

Feed the Future Bangladesh Nutrition Activity Page | 13

Feed the Future Bangladesh Nutrition Activity Page | 14

● Safely dispose of wastewater,

4. ANALYSIS OF POTENTIAL ENVIRONMENTAL

4.1. Potential Risks by Results areas

Feed the Future Bangladesh Nutrition Activity Page | 15

Feed the Future Bangladesh Nutrition Activity Page | 16

4.1.2. Result 2: Increased social and economic empowerment of women and

Feed the Future Bangladesh Nutrition Activity Page | 17

4.1.3. Result 3: Increased adoption of improved WASH behaviors

Feed the Future Bangladesh Nutrition Activity Page | 18

Feed the Future Bangladesh Nutrition Activity Page | 19

4.2. Due Diligence

Feed the Future Bangladesh Nutrition Activity Page | 20

5. ENVIRONEMNTAL MITIGATION, MONITORING,

Feed the Future Bangladesh Nutrition Activity Page | 21

Table 1: FY 2024 EMMP

Project/ Identified Monitoring

Feed the Future Bangladesh Nutrition Activity Page | 22

Project/ Identified Monitoring

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Project/ Identified Monitoring

The Activity will not assess

6. CLIMATE RISK MANAGEMENT

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Table 2: Activity climate risk management summary

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