Gaza Solid Waste Management Project (WB-P121648)

  • Palestine, West Bank, Gaza
Geographic location where the impacts of the investment may be experienced.
Financial Institutions
  • World Bank (WB)
International, regional and national development finance institutions. Many of these banks have a public interest mission, such as poverty reduction.
Bank Risk Rating
Environmental and social categorization assessed by the development bank as a measure of the planned project’s environmental and social impacts. A higher risk rating may require more due diligence to limit or avoid harm to people and the environment. For example, "A" or "B" are risk categories where "A" represents the highest amount of risk. Results will include projects that specifically recorded a rating, all other projects are marked ‘U’ for "Undisclosed."
Voting Date
Mar 31, 2014
Date when project documentation and funding is reviewed by the Board for consideration and approval. Some development banks will state a "board date" or "decision date." When funding approval is obtained, the legal documents are accepted and signed, the implementation phase begins.
A public entity (government or state-owned) provided with funds or financial support to manage and/or implement a project.
  • Water and Sanitation
The service or industry focus of the investment. A project can have several sectors.
Potential Rights Impacts
  • Cultural Rights
  • Healthy Environment
  • Housing & Property
  • Right to Health
  • Right to Water
Only for projects receiving a detailed analysis, a broad category of human and environmental rights and frequently at-risk populations.
Project Cost (USD)
$ 35.26 million
Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Bank Documents
Primary Source

Original disclosure @ WB website

Updated in EWS Jun 22, 2017

Disclosed by Bank Dec 15, 2010

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Early Warning System Project Analysis
For a project with severe or irreversible impacts to local community and natural resources, the Early Warning System Team may conduct a thorough analysis regarding its potential impacts to human and environmental rights.
This project is assigned Category A for environmental & social considerations. Bank document state that the overall Risk Rating for this project is High, due to the complexities associated with the project in terms of location in the Gaza Strip and the associated constraints. These constraints include (a) the limited Palestinian Authority's control over the Gaza Strip; (b) the limitations on materials and persons entering the Gaza Strip, subject to permissions issued by the Government of Israel; (c) proximity of the new landfill from the borders with Israel; and (d) delays in finalizing the compensation to landfill land owners. According to the World Bank the proposed project is classified Environmental Category 'A' in accordance with World Bank Operational Policy 4.01, 'Environmental Assessment,' as it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. The Al-Fukhari landfill site is underlain by fresh water aquifers, which constitute the main source of drinking water and irrigation water for Gaza. Bank documentation notes the risk of leachate, water that has percolated through a solid and leached out some of the constituents, being released to the adjacent soil and reach[ing] the groundwater which will 
cause high organic load and acidic conditions to the reached groundwater. The Bank claims that the project will be designed for "zero" leachate and drainage discharge into the ground and surface water resources. However, it is important to note bank documentation also states that, uncontrolled dumping of waste would contaminate groundwater and soil, attract disease-carrying rats and insects, and even cause fires due to the production of methane from decomposing organic waste. Sources: *World Bank Documentation, * APPLICABLE SOCIAL AND ENVIRONMENTAL STANDARDS -Environmental Assessment (OP/BP 4.01) -Involuntary Resettlement (OP/BP 4.12) ENVIRONMENTAL ASSESSMENT According to the Bank's Project Appraisal Document, the Project is classified Environmental Category A as it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. This document also states that a full environmental impact assessment will be carried out as part of project preparation to ensure the design takes into account mitigation measures. Bank documents note that the proposed project site in southern Gaza is underlain by fresh water aquifers, which constitutes the main source of drinking water and irrigation water for Gaza. Although Bank documents state that the project will be designed for 'zero' leachate and drainage discharge into the ground and surface water resources, the Environmental and Social Impact Assessment (ESIA) for the project reported long term potentially irreversible impacts to ground water resources by leachate if proper mitigation measures are not considered in project design. Environmental impact, it continues, would also result in the vicinity to the proposed landfill site from the increased traffic of solid waste disposal trucks from the various communities in middle and southern GS. The project will generate also landfill gas during the operational and decommissioning phases. Environmental impacts during the construction phase (such as dust emissions, soil erosion, water pollution, noise etc.) would be temporary and reversible (emphasis added). The Bank also notes that the possibilities of chance finding sites of cultural property value are not high but still exist. INVOLUNTARY RESETTLEMENT The Bank's Operational Policy OP 4.12 applies because of direct adverse impacts expected on two groups of people at the Al-Fukhari (Sofa) landfill site: the waste pickers at the Al-Fukhari (Sofa) landfill as well as to the families impacted through the land acquisition for Al-Fukhari (Sofa) component. While the proposed Project would not result in involuntary physical relocation of people the Project would, however, result in the loss of income of vulnerable people now involved in resource recovery, i.e. waste picking and recycling. Sources: *World Bank Documentation CONSULTATION PROCESS According to the Bank documentation consultation and participatory techniques were employed during the process of the Environmental and Social Impact Assessment (ESIA), as well as for the preparation of the two Abbreviated Resettlement Action Plans (ARAPs). The Project's key consultation activities were divided into two steps: 1) the scoping and preparation of the ESIA and ARAPs and; 2) after drafting the ESIA and during the review of findings. A scoping session was conducted in Gaza on Thursday December 8, 2011 and was attended by a wide range of stakeholders including various municipalities, JSC from different Governorates of Gaza Strip, MDLF, SWMC, Palestinian Water Authority, Environmental Quality Authority, NGOs, academics, Consultants and neighboring communities to the landfills who were invited through individual invitations. According to the ESIA, two landowners inventory survey and multiple waste pickers inventory survey were completed for the preparation of the ARAPs. After submitting the Draft ESIA, two public consultation workshops were held for reviewing the findings of the ESIA, one hosted by the Rafah municipality on January 18, 2012, and the other hosted by the MDLF in Gaza City on May 5, 2012 for the northern section of the project. Similarly, the Bank documents report, Secondary data collection involved the review of information in previous reports and studies. Moreover, structured site visits were undertaken to collect primary data directly from stakeholders in order to garner their perceptions about the project's predicted impacts. The most important tools included Structured, Questionnaire, Focus Group Discussions (FGD), Semi Structured Interviews (SSI) and Informal Unstructured Interviews as well as public consultations through plenary events. Sources: *World Bank Documentation ENVIRONMENTAL AND HUMAN RIGHTS RISK ASSESSMENT The following analysis is based on findings from the Project's three-volume, 500+ page, environmental and social impact assessment in which the Project's negative impacts, listed as loss of soil; air, water, and noise pollution; loss of land; loss of birds; public health risks; and risk of flora and non-avian fauna, are addressed. RIGHT TO CULTURE The Gaza Strip is an influential location within the Middle East due to a number of religious, historic, and commercial factors. The ESIA for the project states the area is considered the birth place of most biblical religions with a good number of religious structures still remaining and functioning. Economically, these historic sites contribute to the tourism of Gaza and are subject to the Ministry of Tourism and Antiquities. While the Bank documentation does not report any antiquities or cultural heritage sites in the vicinity of the Johr al Deek or El-Fukhary sites, it does, however, recognize that the extensive excavation that will be carried out, up to 20 meters, could lead to finding any antiquity or culturally valuable object[s because of] the long history of the region. In the event that a cultural heritage object is uncovered the World Bank states that the Ministry of Tourism and Antiquities should be informed so as to adequately handle this object in order to preserve the cultural value it represents. Land located near the El-Fuhkary site has been used for olive tree cultivation for generations. Olive trees have more than just an economic significance for Palestinians. Palestine has some of the world's oldest olive trees dating back 4,000 years and some have been passed down from generation to generation. Culturally, the trees represent Palestinian resistance and resilience because they are draught-resistant and grow under poor soil condition. In Arab traditions, the olive branch is a symbol of peace. Any obstructions or alterations of the olive trees have the potential to infringe on local communities' rights to Palestinian culture/religion. The following questions may be relevant to determining whether you or your community's right to culture has been adversely affected by the investment project: -Do the land, natural resources, or other sites affected by the investment project have a cultural significance for your community? -Have your traditional practices or knowledge been affected since the beginning of the investment project? - What opportunities (legal or other) are available if you feel that your right to take part in cultural life has been restricted or denied? - Has your community has been discriminated against because of its culture as a result of this proposed project? Sources *World Bank Documentation * * RIGHT TO HOUSING AND PROPERTY According to the World Bank, Operational Policy 4.12, Involuntary Resettlement, is triggered when project activities result in (a) loss of land or other assets which have as effect: relocation or loss of shelter, loss of assets or access to assets, loss of income sources or means of livelihood (whether or not the affected 
persons must move to another location); and (b) restriction of access to legally designated parks and protected areas that result in adverse 
impacts on the livelihoods of affected persons. The proposed project will involve both direct displacement resulting from loss of lands as well as economic displacement resulting from adverse impacts on existing livelihoods based on waste picking & recycling. Economic displacement: The project is expected to affect those involved in both the formal sector (working under formal organizations including municipalities) and informal sector (waste pickers, street pickers, and informal traders) involved in the Solid Waste Management sector. The two main triggers for OP 4.12 are (1) land acquisition required to expand and construct the El Fukhary landfill; and (2) the implementation of stronger security systems at the landfill and transfer stations. Access to the facility, Bank documentation states, will be restricted censed operators and the number of informal waste pickers currently benefiting from the sites will not be allowed to have access to recyclables as it is currently the case. The restriction of informal workers activities in the area is expected to start during the construction phase as well. Restricting these groups, who are currently entering freely, from reaching the landfill, will result in significant negative impact on their source of livelihoods. The field work revealed that affecting the livelihoods of these groups may result in increased level of poverty and vulnerability. Land/Property displacement: The current Al Fukhari (Sofa) landfill area is approx. 26.64 dunum (26,460 square meters), and 472 dunums (472,000 square meters) will be added to the existing landfill to construct the main landfill station, a reception and recycling unit, and five cells for the future extension of the landfill. The Bank notes that due to its large-scale land requirements (Al Fukhari/Johr Al Deek landfill sites, Transfer Station, composting projects) the Project will have social and environmental impacts arising from the construction, operational, and decommissioning phases. World Bank documentation states, For Al-Fukhari (Sofa), an ARAP has been prepared to address the impacts of expropriating 215 dunums (215,000 square meters) of land which affects 70 owners who are heirs of five main families based in Gaza. None of the landowners live on this site, nor do they have any physical assets on the site. These lands are adjacent to and/or partially encroach onto the Israeli-imposed 500 meters wide security buffer zone which means there is restricted land use and this is an area of heightened security. ESIA findings, the bank continues, indicate that these are low revenue generating rain-fed lands with limited wheat and olive production. A former key source of income (olive groves) was destroyed during the 2008 conflict. The lands are also adjacent to a 17 year old dumpsite owned and used by the Rafah Municipality, as well as to a planned wastewater treatment plant to be financed by the Islamic Development Bank. The Israeli Defense Ministry has provided the Bank and financing partners with its agreement that the project's landfill boundaries may reach to 400 meters from the borders. The legality of the land expropriation for this project has been established through a final court decision and also confirmed by an independent Palestinian legal land expert. The required financing for land acquisition is available through the Ministry of Finance and also the Joint Services Council for Solid Waste Management in Rafah, Khan Younis and Middle Gaza Strip (JSC-KRM). An Abbreviated Resettlement Action Plan (ARAP) has been developed to address impacts related to landowners whose properties will be acquired and for workers whose sources of income will be drastically impacted by the proposed construction of the El Fukhary Sanitary Landfill at Al-Fukhari (Sofa) in Gaza Strip and the Khan Younis transfer station. The ARAP includes surveys and consultation with a portion of the Project Affected Persons (PAPs) people who are directly affected, socially and economically by Bank-financed projects that were conducted as part of the ESIA. These consultations often resulted with a momentary or non-monetary compensation on behalf of the MDLF or local municipalities in exchange for land, and thus employment, acquisition. While Bank documents state that, Under this project, all affected people (i.e., including waste pickers) will be provided resettlement assistance as per OP 4.12, the Bank has no legal obligation to compensate these people since, under Palestinian legislation, only people and entities entitled for compensation are those with registered property rights, for example, registered landowners, leaseholders, users and those with registered third party rights. Thus, if the Bank decides to allocate 'compensation' funds elsewhere, waste pickers at the Al Fukhari (Sofa) landfill, and those affected near transfer stations, will have no legal right on the basis of which they can bring a claim for compensation for loss of income before a court. According to Bank documents, the Palestinian National Authority (PNA), through the Ministry of Local Government (MoLG) and the Municipal Development and Lending Fund (MDLF), have conducted comprehensive assessments of these impacts as part of the ESIA and have developed a Resettlement Action Plan (RAP), which covers all activities that have the potential to result in impacts to land use and the physical and economic displacement of people living on and/or using the land required/disturbed by the Gaza Solid Waste Management Project. According to World Bank documentation, the resettlement assistance (compensation) offered to each affected land owner will consist of land purchase which is calculated on the basis of replacement cost at market value. For the few land owners with smaller landholdings, the ARAP may consider whether a land for land swap is an option if this is preferable or available to affected parties bearing in mind land scarcity in Gaza. It is important to note, Under the OP 4.12, lost income resulting directly from project implementation should be compensated. Palestinian law, however, does not recognize compensation for such lost income. The Bank claims that the project would not result in involuntary relocation of people as the current land owners have expressed interest in selling or leasing the land. However, this should be carefully examined, as Bank documents also state that Some farmers were willing to sell their lands in an open market whilst others prefer to not sell, if given the option. The proposed Project would the bank notes, result in the loss of income of people now involved in resource recovery and the project will be designed with provisions for compensating these people. According to Bank documents, the Palestinian National Authority (PNA), through the Ministry of Local Government (MoLG) and the Municipal Development and Lending Fund (MDLF), have conducted comprehensive assessments of these impacts as part of the ESIA and the (ARAP), which covers all activities that have the potential to result in impacts to land use and the physical and economic displacement of people living on and/or using the land required/disturbed by the Gaza Solid Waste Management Project. It is important to note that, under the OP 4.12, lost income resulting directly from project implementation should be compensated. However, Palestinian law does not recognize compensation for such lost income. Given these considerations, the following survey questions related to the rights to land and property should be raised by communities and individuals affected: -Do you or any of your family members make money by picking, selling, or trading waste? -Will this project affect your ability to make money? -Will any loss of income resulting from this project seriously affect your ability to meet your basic needs and/or the needs of your household? -Are you currently employed by local business or municipalities involved in the Waste Management Sector? -Have you and your community had an opportunity to provide meaningful input at each stage of the project design and planning, including on economic resettlement plans, and provide suggestions about alternatives to relocation? - Has the land provided following relocation been adequate and of an equal or better quality than the land previously occupied? - If you were resettled, do you feel that you received adequate compensation for your land, housing, or crops? - What options do you have (legal or otherwise) at your disposal in the event that you feel that your right to property or adequate land or employment has been compromised? Sources: *World Bank Documentation RIGHT TO WATER The ESIA reported long term potentially irreversible impacts to ground water resources by leachate if proper mitigation measures are not considered in project design. Leachate contains a host of toxic and carcinogenic chemicals, which may cause harm to both humans and environment. This issue is of critical importance since the El-Fuhkary site is underlain by fresh water aquifer, which constitutes the main source of drinking and irrigation water for southern Gaza Strip. Experts report that, contamination of groundwater resources is often due to waste leachate percolating through the soil layers in the event of rainwater. In such cases, the migration of the contaminants would be uncontrolled and may reach the groundwater. Thus, leachate-contaminated groundwater can adversely affect industrial and agricultural activities that depend on well water. The use of contaminated water for irrigation can decrease soil productivity, contaminate crops, and move possibly toxic pollutants up the food chain as animals and humans consume crops grown in an area irrigated with contaminated water. Local communities may find the following questions relevant to assessing whether they may be suffering a human rights violation resulting from the construction or operation of the Project: -Does the company or its subsidiaries have a policy or program to ensure that its activities do not affect communities' and individuals' right to water? -Has your access to good and affordable water in sufficient quantity been affected since the beginning of the investment project? - Has the quality of local resources necessary for subsistence (e.g. crops, herbs, game, etc.) decreased as a result of the Project's environmental impacts? Sources: *World Bank Documentation * new/LEACHATE%20IUG.pdf * Jagloo K. (2002). Groundwater risk analysis in the vicinity of a landfill, a case study in Mauritius, Royal institute of technology, Stockholm. RIGHT TO HEALTH AND A HEALTHY ENVIRONMENT The environmental impacts of the project are divided between the southern section of the project (El-Fukhari site) and the northern section of the project (John Al Deer site), and are grouped into the construction phase, the operational phase, and the decommissioning phase. According to World Bank documentation each phase will generate different environmental impacts that will require different mitigation measures. Environmental impacts due to construction of the landfill cells at El-Fukhari and Johr Al Deek as well as the proposed transfer stations and composting plants include: (1) Changing the topographic features of the area and, hence, changing water drainage properties which could divert surface water drainage streams to un-preferred locations. (2) Negatively affecting local air quality due to dust emission caused by wind erosion and vehicle exhaust emissions from vehicles and machines (generators, loaders, excavators ... etc.) during construction. Bank documentation states the inhalation of dust particles in excessive amounts can be harmful to the health of both workers and nearby residents, and that users of nearby roads and scattered farm houses visitors may experience some disturbances due to dust generation. (3) The generation of landfill gas. The ESIA states, the generation of landfill gas could cause negative impacts on the environment, including: (a) the methane gas when present in air with concentrations between 5-15% it could have an explosion potential which causes a safety risk; (b) the migration of the landfill gas through the soil could cause acidification of the groundwater due to the reaction between carbon dioxide in the landfill gas and the water to produce carbonic acid; (c) the flaring/combustion of landfill gas causes air emissions of CO2, CO, NOx, PM 
and trace gases that impact the air quality in adjacent areas; and (d) both methane and carbon dioxide are greenhouse gases where methane has much 
more global warming potential than carbon dioxide (25 times in 100 years lifetime). (4) Odors from decomposition, landfill leachate, and landfill gas. Bank documentation states that, due to the nature of landfills, the odors produced can potentially be quite powerful and mainly contains a complex mixture of ammonia and hydrogen sulphide. While the gas will be collected by a gas collection and flaring/energy recovery system as advocated by the proposed project, odorous gas may still escape the collection system or leak out. (5) Noise impacts from construction works include noisy activities related to machine operation in addition to the noise generated from the trucks entering or leaving the site. The Bank states, noise at transfer stations can be considered negative and of medium significance depending on the nature of the neighboring areas. Local communities may find the following questions relevant to assessing whether they may be suffering a human rights violation resulting from the construction or operation of the Project: -Do you feel that your natural environment (air, water, land, animals, and plants) has changed since the start of the investment project? -Where will hazardous waste be disposed of and what impact is this likely to have on the local environment? -What means do you have to seek redress if the environmental impact of the proposed operations become a problem for local communities and/or the local ecosystem? -Do you have reasons to believe that your health and/or your access to health services could be affected as a result of the planned investment Project? -Have you as an employee or an inhabitant of a nearby community experienced any health issues since the advent of the Project's activities? -Does the Company have a policy or program to ensure that its activities do not cause public health problems or affect people's right to health? Sources: *World Bank Documentation
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