There are 13 unarmed guards hired directly by GIE providing security to GIE, including the project area.  According to the information provided, there has been no civil unrest targeted at GIE from local communities since its inception as the GIE provides a much needed source of employment. Health and safety (H&S) related impacts on local communities are not foreseen, and therefore PS4 is not considered applicable.  The land ownership of the project area resides with the Palestinian National Authority, and, as described above, a land lease agreement is in place. There has been no physical or economic displacement with respect to this project, therefore PS5 is not applicable. The project does not impact biodiversity, as the site is already developed as an industrial estate, therefore PS 6 is not applicable. There are no Indigenous Peoples in the project area, therefore PS7 is not applicable.  Cultural heritage is not a concern as the project will be installed on the rooftops of existing buildings, therefore PS8 is not applicable. 

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the project footprint is located within an existing industrial area, and incremental E&S impacts related to a 7 MWp rooftop PV solar infrastructure are very limited.  Key environmental and social issues applicable to this investment are labor and working conditions for workers, occupational health and safety, water use given the arid environment and the safe structural design and installation of modules on rooftops.

In accordance with the Palestinian Authority’s Environmental Assessment Policy (Resolution no. 27-23/4/2000), the client sent an Application for Environmental Approval to the Palestinian Environmental Quality Authority (EQA).  The EQA’s remit is to conduct a screening process of related E&S risks to determine if an Initial Environmental Evaluation (IEE) or an Environmental Impact Assessment (EIA) should be conducted.  Based on the nature of this project, the EQA did not require an IEE or an EIA. 

Two Environmental Assessments were conducted for GIE as a whole in the past.  The first was commissioned by USAID in 1996 and includes a description of baseline conditions and presents findings / recommendations with respect to water supply, wastewater and stormwater, solid waste disposal, traffic management, among other topics.  The second was an Environmental Assessment of Transboundary Impact of the GIE commissioned by the World Bank that was finalized in 1998.  This assessment also contained a comprehensive description of the baseline physical and biological environments, and the impact assessment spanned a number of topics including air quality, noise, groundwater and surface water. 

The client has developed a draft Environmental and Social Management System (ESMS), which includes a high-level review of project risks and impacts (included as part of a draft E&S Management and Monitoring Plan), a draft E&S Commitment Policy, contractor requirements and an organogram. The primary risks and impacts are related to occupational health and safety (OHS), water use and the hiring of day laborers.  As indicated in ESAP Action Item #1, the client will finalize its own fit-for-purpose ESMS, which will include a completion of its project-specific review of risks and impacts, an E&S Commitment Policy, an organizational framework and a site-specific Emergency Response Plan. As indicated in ESAP Action #2, as part of the ESMS, the client will ensure that the EPC contractor / O&M provider develop a site-specific and industry-specific Environment, Health and Safety (EHS) Management Plan that emphasizes OHS measures for workers, monitoring measures and is applicable to construction and operations. 

The client has on staff an Environmental Manager that will work in coordination with the EPC contractor in the implementation of the ESMS. As indicated in ESAP Action Item #3, the client will develop a Terms of Reference (TOR) for the Environmental Manager so the role and expectations are clearly defined.  For example, the Environmental Manager will be expected to (i) oversee the EPC contractor in the implementation of the EHS Management Plan and ensure the EPC contractor is aware of reporting commitments; (ii) ensure that monitoring measures indicated in the EHS Management Plan are being carried out and a monthly report is developed; (iii) ensure that induction training for new employees is being conducted; and (iv) ensure that OHS incidents / statistics are being tracked during installations.  As indicated in ESAP Action Item #4, the client will ensure that the EPC contractor has an on-site EHS Focal Point with the responsibility of implementing the EHS Management Plan in coordination with the client’s Environmental Manager and as part of the client’s overarching ESMS. 

The client also has on staff a Human Resources Manager.  See the section on “PS2 Labor and Working Conditions” for the responsibilities of the Human Resources Manager.

The project will result in a number of new jobs during construction and operations.  As the project will secure a reliable power resource for GIE for 24 hours despite the electricity shortage in Gaza, it is expected to indirectly lead to the creation of up to 800 new job opportunities due to the possibility of creating additional working shifts by (i) allowing existing enterprises to move from single shift operations to two (and some potentially to three) shifts per day; and (ii) allowing the GIP operator to extend services to more potential tenants.

As indicated in ESAP Action Item #5, the client will develop a project-specific Human Resources (HR) Policy in alignment with PS2 and in compliance with Gazan labor regulations.  The policy will specify that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, will be established by labor regulations per the Palestinian territory of Gaza. Additional workers’ benefits will include health insurance and medical assistance, among others. The client will ensure that the EPC contractor / O&M provider develop a workers’ handbook in alignment with the client’s HR Policy.

The HR Policy will include reference that workers shall not be impeded from freedom of association and collective bargaining and that workers will be able to organize among themselves and will not be discriminated against for doing so.  The policy will also specify that the client is committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties.  The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of contractual obligations.   The policy will reject the use of any form of forced or compulsory labor and the use of workers under the age of 18 years. The HR Policy will also ensure that working conditions (including health, safety and security), employee termination, prohibition to employ minors, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations are made to clear to all workers. It will apply to all workers, including those hired by contractors and sub-contractors.

The hiring of workers by sub-contractors will likely rely in part on day laborers.  Also as part of ESAP Action Item #5, the client will develop a day laborers policy that specifies minimum requirements for the use of such labor (e.g., minimum age requirements, personal protective equipment (PPE), security screening, recording of identity card, OHS induction).  There will be no workers housed on site.

As indicated in ESAP Action Item #6, the client will develop and make available a labor grievance mechanism for workers.  The client will ensure that the EPC contractor / sub-contractors inform workers of the grievance mechanism and include it in induction training. 

As mentioned under PS1, the client has on staff an HR Manager.  As indicated in ESAP Action Item #7, the client will ensure that (i) the EPC contractor and sub-contractors are providing workers with a hard copy of the HR policy; (ii) contractors and sub-contractors are hiring workers in accordance with the policy (e.g., by reviewing the development of the contractors’ policies and contracts); (iii) the new employee induction training includes an overview of the HR policy and the labor grievance mechanism; and, (iv) the day laborers policy is being implemented (identification for all day laborers, induction training, PPE available).  The HR Manager will develop monthly reports during construction on these topics.

Occupational Health & Safety

Occupational H&S risks for a PV rooftop project include working at heights (scaffolding, rooftops), exposure to electric shocks and burns, hazards from moving machinery (cranes), heavy load lifting, heat exhaustion and heat stroke if not hydrated properly.  As indicated in ESAP Action Item #8, the client will ensure that all workers on site receive basic safety training in a mandatory induction.

Given that the project involves PV (rather than Concentrated Solar Power) technology, water consumption will be minimal.  That said, Gaza relies entirely on groundwater, which is a scarce resource due to an arid environment and a context that provides limited alternative options.  There are three water wells on side (~85-meters depth) that draw brackish water from the underground aquifer. As indicated in ESAP Action Item #9, the client will ensure that the EPC contractor conduct an alternative analysis with respect to water usage during module cleaning to ensure maximum resource efficiency alongside of financial considerations. The alternatives analysis should explore the potential use of dry cleaning, steam cleaning, manual versus mechanical versus automated cleaning.

There is a reverse osmosis system in place at the GIE, although drinking water will be brought in using a certified water trucking company. Both solid and hazardous waste generated by the project will be minimal.  Solid (cardboard, plastic, construction debris and food waste) and hazardous (oily rags, paint cans, spent solvents) waste streams will be segregated.  There is an agreement between GIE and the Municipality of Gaza for the collection and transport of solid waste from the estate to the municipality’s landfill (Gohr El Deck); the landfill contains dedicated cells for hazardous waste treatment.  Acknowledging the potential limited possibilities for recycling in Gaza, the company will explore options as part of their waste management strategy. Glare is not expected to be an issue as PV panels are designed to absorb sunlight rather than reflect it, as is the case with other technologies (e.g., CSP). Moreover, given the lack of sensitive receptors in the vicinity (airports, affected communities, sensitive biodiversity), adverse impacts are not anticipated. The project is expected to generate approximately 10.5 GWh of electricity per year.  The current carbon dioxide emission performance (from fuel combustion) in Israel (nearest country with estimate) is 0.69kg carbon dioxide equivalent per kilowatt hour (CO2eq/kWh) (according to International Energy Statistics, 2014).  Using this factor, the project is estimated to reduce 7,253 tons of CO2 eq /year of greenhouse gases. In case grid stability issues made it necessary to install a central backup diesel generator, the GHG impact of the latter is expected to be neutral or positive for the following reasons: i) the new central generator would be more efficient and would work as a replacement of the current park of small backup generators present in each factory ii) the new central generator would work in hybrid mode, i.e. in parallel to the PV plant, which would supply up to 80 percent of the total energy needs, thereby reducing back-up generation emissions of up to 80 percent with respect to the current practice.  

As noted in the project description, there are no landowners or communities directly impacted by this project. Those most likely to be interested in the project are beneficiaries of the increased power supply (GIE tenants), workers of GIE who will see the construction works and nearby communities through which project-related materials will be transported. As identified in ESAP Action Item #10, the client will develop a Communique on the project to make communities and workers within GIE aware of the nature of the project, its duration and any risks and impacts.  The Communique will also include a point of contact in the event of any community grievances (for example, those that might be associated with transport of construction materials) and will make communities and workers aware of this ESRS.  The Communique will be posted in GIE and broadcasted in a local newspaper. In addition to ESAP Action Item #10, the client will develop a simple register for recording any grievances and a fit-for-purpose procedure for responding to them.  The client will also conduct an exercise to identify if there are any other relevant stakeholders in addition to the workforce within GIE and the scattered nearby residences that should receive the Communique. 

For additional information please contact:

Name:  Mohammad Alterawi

Title: Head of Infrastructure and Renewable Energy Department

Company:  Palestine Real Estate Investment Co.

Address: Almasyoun, PADICO House, 4th Floor, Ramallah

Mail to:  m.terawi@prico.ps

Website: www.prico.ps