The project will be developed on the rooftops of existing schools; therefore, there is no associated physical or economic displacement, and PS5 is not applicable. Biodiversity values are not associated with the urban areas in which the project is located, therefore PS6 is not applicable. Indigenous Peoples are also not associated with the project areas, therefore PS7 is not applicable.  As the project will be installed on rooftops of existing buildings that are not valued fur cultural heritage, PS8 is not applicable. 

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the E&S impacts associated with the project are limited, site-specific and could be addressed through the implementation of standard good international industry practices.  The key E&S issues largely relate to the following: (i) safe access to the rooftops for EPC and O&M staff and protection against trips, falls and other hazards; (ii) the protection of school staff and students from physical harm during construction activities; and, (iii) water usage for panel cleaning during operations given the arid environment.

 In accordance with the Palestinian Authority’s Environmental Assessment Policy (Resolution no. 27-23/4/2000), the company is submitting an Environmental Approval Request to the Palestinian Environmental Quality Authority (EQA) for each of the proposed project sites.  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.  Although the EQA is requiring that Massader submit an Application for Environmental Approval for each school, the company was informed by the EQA (via a signed letter dated 8 October 2018) that an IEE or an EIA will not be required.  The EQA did request that an Environmental and Social Management Plan be developed for each site. 

The company is in the process of developing an Environmental and Social Management System (ESMS), which would be managed centrally and apply to all rooftop installations. The ESMS will describe the national, IFC and other lender requirements, present corporate policies, set out an approach for project E&S screening and provide management plans and reporting requirements, among other aspects. As indicated in the initial framework of the ESMS, EPC contractors / O&M providers and sub-contractors will be expected to align with its requirements.  The completion of the ESMS, including all elements mentioned in the rest of this section, is indicated in ESAP Action Item #1.  In an Environmental Approval Request submitted to EQA, the company made mention to the ESMS and its components.  Massader has hired SHEcon, an international E&S consultant, to undertake the development of the ESMS.

The ESMS will include an Environment, Health and Safety (EHS) corporate policy as well as other policies related to the topic of human resources (see section on ‘Performance Standard 2 – Labor and Working Conditions’).  The ESMS will also include an E&S risks and impact project screening methodology that will be used to assess the site-specific risks and impacts at each site.  A template to screen for risks and impacts will be included in the ESMS as part of the management plans (which are described in the paragraph below). The ESCOM surveys of the schools include information (such as access details and the height of the parapets) which should be used to inform the site-specific risk assessments, and the development of the necessary mitigation and management measures.  The company will conduct a site visit at each school prior to completion of the risks and impacts screening as also indicated in ESAP Action Item #1.

The ESMS under development contains two overarching management plans – one for E&S and the other for occupational health and safety (OHS).  As also indicated in ESAP Action Item #1 these plans will be designed as generic templates for the rooftop PV solar installation in the West Bank, applicable for the construction and O&M phases of the project.  As also indicated in Action Item #1, once the project-specific risks and impact screening is conducted, the management plans will be customized, as needed.  Within the management plan template, monitoring and/or means of verification of implementation will be included for each mitigation measure along with the responsible entity (e.g. Massader, EPC contractor / O&M provider or sub-contractor).  Per ESAP Action Item #2, the company will ensure that the EPC contractors / O&M providers develop their own E&S and OHS management plans in accordance with the company’s requirements. 

The ESMS will also include a template for a rooftop PV solar Emergency Preparedness and Response Plan (EPRP) that should be detailed with site specific information.  The EPRP will include actions for fire risk assessment and control systems and other emergency preparedness and planning actions.  It will also include a contact point within each school for emergency and other purposes.

Given the large number of installations, Massader will procure an EHS focal point to supervise the implementation of the ESMS during both the construction and the O&M phases of the project as indicated in ESAP Action Item #3.  This individual will either be a permanent employee or a contracted consultant who has the ability to travel within the West Bank to project sites and will work in coordination with the EPC contractors and their respective EHS staff.  As also indicated in ESAP Action Item #3, the company will ensure that the EPC contractors have an on-site EHS coordinator to ensure that measures are effectively carried out on project sites during construction.

Lastly, with respect to monitoring and reporting, the ESMS will specify the type and frequency of both company and contractor reporting as well as company auditing.

 Each rooftop installation will typically comprise a lead engineer with 4-5 technicians (generally electricians), and each EPC contractor will typically have 2-3 separate installations underway at any one time.  The lead engineers will typically be employees of the EPC contractor, and the technicians will be drawn from a pool of workers regularly employed by them.  All jobs are projected to be filled by Palestinian nationals.

As indicated in ESAP Action Item #4, the company will develop a project-specific Human Resources (HR) Policy in alignment with PS2 and in compliance with labor regulations of the West Bank as part of its ESMS.  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 the West Bank.  Additional workers’ benefits will include health insurance and medical assistance, among others. 

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 company 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. 

The hiring of workers by sub-contractors will likely rely in part on day laborers.  As part of ESAP Action Item #4, the company 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).  Also, as part of ESAP Action Item #4, Massader will develop a Workers Code of Conduct and a Gender Policy to make workers aware of sensitivities while working at schools with children present, boys and girls.

The company will ensure that the EPC contractors/O&M providers have developed and implemented their own HR policies in alignment with regulations of the Palestinian territory of the West Bank per ESAP Action Item #5.  As Palestinian labor regulations do not make reference to the topic of forced labor, the HR policy will also make explicit reference to the prohibition of its use.  The HR policy will be posted at the work site for visibility. 

As indicated in ESAP Action Item #6, the company will develop and make available a labor grievance mechanism for workers.  The company will ensure that the EPC contractors / sub-contractors / O&M providers inform workers of the grievance mechanism and include it in induction training.  As part of this action item, the company will develop an overarching induction training, covering both EHS and human resources aspects, for use by the EPC contractors / O&M providers.  In line with the company’s Code of Conduct and Gender Policy, the training will also be extended to the EPC contractors/O&M providers themselves and will include elements on gender sensitivities, such as working on sites during school hours and the use of school facilities (such as toilets).  Both the Code of Conduct and the Gender Policy (as well as all other company policies) will apply to the EPC contractors and sub-contractors.  The induction training will make explicit that anti-discrimination provisions refers to race, religion, political opinion as well as prohibited practices (e.g. discrimination in compensation, hiring, discipline, and termination of individuals who are not ill / disabled).

Occupational Health & Safety

Key OHS risks for rooftop PV project include slips and falls, working at height, potential hazards from moving machinery, heavy load lifting, exposure to electric shocks and burns, and safety issues related to PV module assembly.  During the site visits, rooftop access within the schools has also been identified as a particular risk for this project (substandard ladders to access rooftops) as well as the risk of falls from rooftops that have little to no parapet.  Objects falling into communal areas, such as school play yards, is also a concern.  Considering the summer heat, and the work occurring on an open roof (with radiant heat), construction workers might be at risk of dehydration, heat exhaustion and heat stroke if not hydrated properly during the summer months, especially during Ramadan. 

The OHS management plan developed as part of the ESMS (see section ‘Performance Standard’ 1 in this ESRS and ESAP Action Item #1) will include sections on Job Safety Analysis, Electrical Works, Working at Height, and Lifting Operations, amongst other topics.  The company will ensure that the EPC contractors / O&M providers develop their own OHS management plan in accordance with the company’s requirements per ESAP Action Item #2.  As also specified in ESAP Item #2 and as part of monitoring and reporting requirements in the ESMS, the company will ensure that EPC contractors / O&M providers will record and track any OHS incidents, including near-misses, lost time occupational injuries and the total number of lost workdays due to injuries, and that these are reported to the company on a monthly basis.

Lastly, given the high risk of falls, the company will ensure that the EPC contractors install a horizontal lifeline system or equally effective fall arrest and fall restraint system prior to construction and that is remains in place during the O&M phase, as indicated in ESAP Action Item #7.

 Given that the project involves PV (rather than Concentrated Solar Power) technology, water consumption will be minimal.  That said, water is a scarce resource in the arid environment of the West Bank.  Water for project use will be provided via tanks that are stored on the rooftops of most residential and industrial structures in the West Bank. As indicated in ESAP Action Item #8, the company will 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 and it would be provided to the EPC contractors for their utilization. 

Both solid and hazardous waste generated by the project will be minimal.  Solid (cardboard, plastic, construction debris) and hazardous (oily rags, paint cans, spent solvents) waste streams will be segregated and waste volumes recorded.  With respect to solid waste, the EPC contractors / O&M providers will establish a contractor directly with the relevant municipality for disposal into a municipal disposal site.  The company is currently exploring disposal of damaged PV panels either directly with the manufacturer or through transfer to Israel.  With respect to hazardous waste, there are no hazardous waste treatment facilities in the West Bank.  Although the Palestinian Territories have signed the Basel Convention, there is currently no mode of implementation.  In this case, the company will seek advice from the EQA on the mode of storage and/or disposal.  The EPC contractors / O&M providers will explore options for the recycling of other solid waste.  Waste associated with rooftop PV solar installations will not be introduced into the school waste management system and will always be kept away from the areas used by school staff / children. 

As mentioned in the ‘Project Description’ section, the project is expected to generate to the offtake approximately 46 GWh of electricity per annum.  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 31,740 tons of CO2 eq /year of greenhouse gases.

 Interface between the workers and the community members, particularly school children and staff may occur during access to schools, including during the movement of equipment and the use of toilets.  Although construction will be carried out during the daytime, any material/equipment handling into the site will occur after 2 PM (i.e., after school hours) to ensure that students are not present.  When construction is not taking place, school rooftops will remain locked to ensure safety. 

Other community safety measures mentioned in other parts of this ESRS include the following: (i) OHS procedures to minimize the risk of objects falling from roofs into communal areas per ESAP Action Item #2; (ii) a dedicated point of contact in each school to make school children and staff aware of the type, duration and risks of construction activity per ESAP Action Item #1; (ii) a Workers’ Code of Conduct and Gender Policy, which would apply to the EPC contractors and subcontractors, per ESAP Action Item #4.  Stakeholder consultation, which is also relevant to this topic, is described in the section on ‘Stakeholder Engagement’.  

With respect to the structural integrity of the rooftop PV design, during the pilot program, the owner’s engineer (ERES) evaluated 30 rooftops for structural integrity.  Findings revealed adequate thickness in concrete, which would allow weight bearing of panels, which are below 25 kg/m2.  The owner’s engineer plans to continue to conduct the same evaluation with respect to this project, and findings are expected to be similar.

With respect to security, as the company will be managing security using physical controls, there is no need for security guards.

 As indicated in ESAP Action Item #9, the company will develop a Stakeholder Engagement Framework (SEF) as part of its ESMS, which will include a stakeholder identification and mapping exercise for the entirety of the project, the development of project requirements with respect to community consultation and a Community Grievance Mechanism.  The community grievance mechanism will comprise a simple register for recording any grievances and a fit-for-purpose procedure for responding to them.  It will be managed by Massader’s EHS focal point and EPC contractors’ EHS coordinator will maintain a register at each rooftop installation site.

At least a two-weeks prior to construction at each site, the company will post a notice on the front entrance of the schools to make surrounding communities aware of the nature of the project, its duration and provide a point of contact to whom a community grievance can be filed (for example, those that might be associated with transport of construction materials).  In addition, a non-technical leaflet will be distributed to the dedicated point of contact in each school, containing the above information in addition to a short summary of risks and impacts to school students and staff.