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Environmental Assessment of the Sudan

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ENVIRONMENTAL ASSESSMENT OF THE SUDAN LOCUST CONTROL PROJECT 650 - 0087 United States Agency for International Development Mission to Sudan Khartoum, Sudan August, 1988 TABLE OF CONTENTS COVER PAGE TABLE OF CONTENTS LIST OF ACRONYMS AND ABBR3EVIATIONS SECTION 1.0 Executive Summary 2.0 Purpose of Assessment 2.1 AID Environmental Procedures 2.2 Programmatic Environmental Assessment for Locust Control 2.3 Environmental and Pesticide Legislation/Sudan 3.0 Scoping Procedure 4.0 Proposed Action and Alternatives 4.1 Elack.ground 4.2 Project Goals, Purpose and Output 4.3 Other Donor Activities 4.4 Analysis of Alternatives 4.4.1 Economical 4.4.2 Political 4.4.3 Environmental 5.0 Environment to be Affected by Action 5.1 Human Population 5.2 Farks. Reserves and Sanctuaries 5.3 Rare, Endangered and Migratory Species 5.4 Agricultural Resources 5.4.1 Mechanized Rainfed Sector 5.4.2 Rainfed Traditional Sector 5.4.3 Pastoralists 6.0 Environmental Assessment of Action 6.1 Selection of Insecticides for Locust/Grasshopper Control 6.1.1 USEPA Registration Status of Selected Insecticides and Recommendations of the L/G PEA 6.1.2 Field Testing of Selected Insecticides 6.1.3 Selection of Pesticides for Sudan Program 2 6.3 Application Methods and Equipment 6.3.1 Aerial 6.3.2 Ground C.14 Acute and Long Term Environmental Tox.icological Hazards 6.5 Efficacy of Selected Insecticides for L/G Control 6.6 Effect of Selected Insecticides on Non- Target Organisms and the Natural Environm 6.7 Conditions Under Which Insecticides are to Used 6.8 Availability and Effectiveness of Other Insecticides and/or Non-Chemical Measures 6.9 Ability of GOS to Regulate or Control the Destruction, Storage, Use and Disposal of Selected Insecticides 6.10 Provisions for Training Applicators and Users of Selected Insecticides 6.11 Provisions for Monitoring the Use and Effectiveness of the Selected Insecticides 7.0 Environmental Impact of Action 7.1 Adverse Environmental Effects 7.2 Relationship Between Short Term Impacts and Long Term Benefits 8.0 Mitigation of Environmental Impact 8.1 Environmental/Health and Safety Monitoring 8.1.1 Environmental Monitoring (Residue) 8.1.2 Environmental Monitoring (Non-Target Organisms) 8.1.3 Health and Safety Monitoring 8.1.4 Clothing and Personal Protective Equipment 8.2 Insecticide Application in Ecologically Sensitive Areas 8.3 Management of Locust and Grasshopper Insecticide Containers 9.0 List of Preparers 10.0 References 10.1 People Contacted 10.2 Documents Utilized APPENDICES A. Recommended Technical Assistance and Commodities for Mitigation of Environmental and Health/Safety Impacts 3 LIST OF ACRONYMS AND ABBREVIATIONS- AID/W Agency for International Development, Washington CFR U.S. Code of Federal Regulations CICP Consortiim for International Crop Protection DLCOEA Desert Locust Control Organization for Eastern Africa EA Environmental Assessment EEC European Economic Community EPA U.S. Environmental Protection Agency FAO Food and Agriculture Organization GOS Government of Sudan IPM Integrated Pest Management L/G Locust and Grasshopper MOANR Ministry of Agriculture and Natural Resources MOFEP Ministry of Finance and Economic Planning PEA Programmatic Environmental Assessment PPD Plant Protection Department RRC Regional Rehabilitation Commission TA Technical Assistance TAMS TAMS, Inc. ULV Ultra Low Volume UNESCO United Nations Educational, Social and Cultural Organization USAID Agency for International Development, Khartoum, Sudan. WHO World Health Organization 4 1.0 Executive Summary USAID/Sudan intends to develop and implement a project to strengthen the capabilities of the Government of Sudan (GO) Plant Protection Department' (PPD) to predict and control locust and grasshopper outbreaks and to develop a structure within PPD for the safe handling, storage and use of pesticides. USAID's assistance in this multi-donor Medium Term Locust Project will be in the for njof provisions of pesticides and technical assistance for the Core Locust Control Activity and decontamination and destruction of pesticides and contaminated soil in the Pesticide Disposal Ativity. This assistance will contribute to increased food availability by establishing the institutional capacity of the GO to effectively implement locust and grasshopper control activities and to maintain safe handling, storage and use of pesticides. The Environmental Assessment (EA) was prepared as a critical element of the project design, in compliance with AID's environmental procedures at 22 CFR 216. The EA identifies and analyses the environmental and health/safety issues of the proposed. projects. The Programmatic Environmental Assessment (PEA) of Locust and Grasshopper Control in Africa and Asia (TAMS/CICP, 1988) forms the technical basis for the findings and recommendations of the EA, including a determination of the scope of the technical and policy issues to be examined in assessing the environmental impacts of large-scale use of insecticides for control of locust in Sudan (2.0 and 3.0). As the Medium Term Locust Control Project also includes the Pesticide Disposal. Activity, this is a phased EA, and this portion deals only with the Core Locust Control Activity. The EA will be amended in the future to include the disposal activity. After careful analysis of-the alternatives for control, it was determined that a chemical program utilizing primarily ULV insecticides applied in a judicial and well managed program is the most efficaceous, economical and environmentally sound approach. Due to its previous good results in Sudan. Fenitrothion will be the primary insecticide used initially in the Medium Term Locust Project. Alternatives such as Malathion, Carbaryl, Chlorpyritos, Bendiocarb, Lambda-cyhalothrine and tralomethrine will be introduced and field tested to gain experience with their use (6.1). These recommendations are subject to final approval of the L/G PEA (TAMS/CICP. 198R). Sudan is a large Country with a very diverse environment. The ma.jority of the locust outbreaks take 1 place in the northern two-thirds of the country. Included in this area are several national parks, refuges and sanctuaries. These institutions must receive detailed consideration before a decision is made for locust control in or near their boundaries (5.2 and 5.3). Through the efforts of the multi-donor Medium Term Locust Control Program and the efforts of the GOS, PPD, an active, viable and responsive Locust Control Unit will be established. This Unit will be able to function independently in times of recession and expand to meet the needs in times,oT emergency. Throughout the Medium Term Project, the Unit will be enhanced by Specialized Technical Assistance provided by FAO. Regional environmental mitigation measures under this project include provisions for technical expertise in the areas of environmental monitoring, pesticide safety and health. Mitigation methods also include special procedures for locust control in ecologically sensitive areas. Physical procurements will include test kits and supplies for cholinesterase monitoring. 2.0 Purpose of Assessment 2.1 AID Environmental Procedures It is AID policy to ensure that the environmental consequences of AID-financed activities are identified and considered by AID and the host country prior to a final decision to proceed and that appropriate environmental safeguards are adopted (AID 1980). This policy is embodied in the legal requirements set forth at Title 22 of the Code of Federal Regp.lations, Part 216, "AID Environmental Procedures" (22 CFR 216). The EA for the Sudan Medium Term Locust Control Program is based on the reauirements of 22 rFP r'IA­ 2.2 Programmatic Environmental Assessment for Locust Control In early 1967 AID/W initiated a number of activities related to implementation cf its commitment to the use of environmentally acceptable pesticides in locust and grasshopper (L/G) control programs in Africa and Asia, including preparation of a F'EA per 22 CFR 216.6 (d) of L/G control in Africa and Asia; and staging of field testing programs to study the efficiency and environmental impact of certain pesticides for the control of locusts and grasshoppers in Africa (AID, 19B7). Reports resulting from these activities were available at the time of preparation of this EA, and provided the technical background for many of the findings and recommendations contained herein. 2.3 Sudan: Environmental and Pesticide Legislation A global environmental legislation in Sudan is non-existent up to this date. Certain legislation concerning the different environmental components are present in a general form especially in the punitive section where violation on forests, water, sanitation, etc. are being discussed and indemnities are set. The first legislation ever to be set by the PPD was that established in 1920. Evidently, pesticides were not used then and it concerned organizing the population for manual control of grasshoppers/locusts. It also punished farmers for not announcing the presence of swarms in their localities. The pesticide legislation in Sudan was drafted-., in 1974. This Act is entitled "The Pesticide Act of 1974", and deals wholly with registration, manufacturing and importation of pesticides. An amendment to this law has been drawn in 1987 enlargirg the parts concerned with trade and distribution of pesticides. A draft Environmental Law is presently undergoing revision by assigned personnel in the Attorney General's Office whereby a global law for the protection of the environment is sought. 3.0 Scopina Procedure AID/W Environmental
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