For the second consecutive year, Egypt has maintained its position as the ninth most polluted country among the top ten globally, according to the report released by the Swiss air quality monitoring company IQAir in March 2024. The report mentioned that this pollution is primarily due to “transportation, industry, and the open burning of solid organic waste,” which causes health damage to citizens and disrupts ecosystems.

Despite the record high levels of pollution caused by industry, the Egyptian government seems inclined to excessively relax measures aimed at reducing pollution in favor of investment. Last week, the Cabinet approved amendments to certain articles of the Executive Regulations of Environmental Law No. 338 of 1995, in a manner that facilitates procedures for investors and supports the industry and investment sector, as later explained by Egypt’s Minister of Environment, Yasmine Fouad.

The draft decision to amend the Executive Regulations of the Environmental Law aims, according to the official website of the Cabinet, to simplify and expedite the procedures for obtaining environmental approvals by facilitating the reception of environmental studies and expressing opinions on them. The project also includes a new system that allows existing establishments to submit environmental review plans, in addition to developing the work system for environmental consultants and specialists. Moreover, some environmental requirements and standards have been updated to align with current needs and facilitate their application to existing establishments. The environmental record system has also been developed to allow for electronic submission.

However, observers who spoke to Zawia3 expressed their concerns that the law might permit further environmental violations in favor of investors, which would exacerbate current pollution levels, harm the environment, and negatively impact citizens’ health, especially in light of the lack of effective implementation of the government’s plans aimed at improving the climate and protecting the environment or obligating investors to strict regulations regarding environmental pollution levels.

Ahmed El-Saidy, a lawyer specializing in environmental affairs, told Zawia3 that the recent amendments serve the interests of investors at the expense of the environment and citizens’ health, without considering the sustainable development aspects enshrined in the Egyptian Constitution.

According to El-Saidy, the Egyptian Constitution emphasizes the importance of achieving sustainable development that considers all aspects of development—not just economic support, but also adherence to rules and conditions that ensure environmental safety and protect citizens’ health within comprehensive programs aimed at achieving development without compromising any of them.

This type of development, which considers all these aspects, is termed “incomplete development,” meaning it is unsustainable and may benefit the state for no more than five or six years before it starts facing the significant damages resulting from it. For this reason, the Egyptian legislator emphasized the importance of sustainable development.

El-Saidy notes that countries suffering from environmental risks, like Egypt, whether in Africa or Latin America, tend to restrict environmental impact assessment procedures and make them more complex to protect the environment and health, ensuring that there are no risks related to increasing pollution levels. However, the opposite is happening in Egypt.

He points out the contradiction between these measures and the Egyptian Constitution, which obliges the state to protect citizens’ rights to a healthy and clean environment, one of the most important human rights as recognized by the United Nations in 2022.

It is worth mentioning Article 46 of the Constitution, which states: “Every person has the right to a healthy and sound environment. Its protection is a national duty, and the state is committed to taking the necessary measures to preserve it, prevent harm to it, and use natural resources wisely to ensure sustainable development and guarantee the rights of future generations.”

A High Price

According to World Bank estimates, environmental degradation resulting from air pollution costs Egypt about 5% of its annual gross national product, or $2.4 billion annually.

The health burdens resulting from air pollution in Greater Cairo alone were estimated at around 47 billion Egyptian pounds ($979 million) in 2016-2017, equivalent to 1.35% of the GDP, according to another World Bank report issued in 2019. The cost of health losses caused by air pollution from burning fossil fuels in Egypt was estimated at more than 100 billion Egyptian pounds ($2.08 billion), equivalent to 2.8% of GDP in 2018, according to a report issued by Greenpeace in 2020.

Industrial pollution causes a range of diseases, including respiratory diseases, cardiovascular diseases, cancer, and skin diseases.

According to the Ministry of Planning and Economic Development, individuals bear nearly double the global average in current health expenditure as direct payments, amounting to more than 62%. Household spending on health is about 10% of their monthly income. It is also worth noting that government spending on health in Egypt does not exceed 1.5% of GDP, half of the constitutionally mandated percentage.

El-Saidy believes that the recent measures adopted by the state are aimed at supporting investment and investors without considering the environmental risks. He points out that an investor who harms the environment is a “bad investor,” as they only focus on making profits without considering the minimum standards for public safety and environmental security.

The lawyer specializing in environmental affairs explains that while supporting and encouraging investment is important for the Egyptian state, it should not come at the expense of citizens’ health and lives, especially since the medical costs of industrial pollution might exceed many times the profits these projects generate.

He warns that some foreign investors may exploit these relaxations to establish projects that lack international standards for environmental protection, particularly those related to industries reliant on coal, carbon, and high-risk materials in terms of pollution.

The health bill that Egypt will pay due to the spread of diseases caused by pollution and the damage to the tourism sector from pollution, especially as some international bodies have repeatedly warned tourists to Egypt about water and air pollution, is expected to be double due to the leniency with environmental impact assessment procedures related to industry. It was necessary to emphasize the importance of activating environmental impact studies that were previously done superficially and involving citizens in decision-making instead of passing amendments that ease the procedures. According to El-Saidy.

According to the IQAir index, the average air pollution level in Egypt with PM2.5 particles was about 42.4 micrograms per cubic meter in 2023, compared to 46.5 in 2022 and 29.1 in 2021, the year in which Egypt ranked better than the previous two years, specifically in 27th place globally.

The World Health Organization recommends that the level of air pollution with PM2.5 particles should not exceed five micrograms per cubic meter, noting that only seven countries and regions around the world in 2023 achieved the standards recommended by the WHO: Australia, Estonia, Finland, Grenada, Iceland, Mauritius, and New Zealand, along with three islands: Polynesia, Bermuda, and Puerto Rico.

Expansion in Harmful Industries

Notably, Egypt tops the list of countries heavily reliant on the most environmentally harmful industries, such as cement and steel, with no clear standards to ensure environmental quality and compliance with environmental protection.

For example, Egypt was among the top 12 cement producers from 2010 to 2020, producing an estimated 50 million tons of cement in 2020, according to Statista.

Additionally, Egypt is the largest steel consumer in the Middle East and North Africa, according to a 2020 report by the Organization for Economic Cooperation and Development. The country produced 7.3 million tons of steel in 2019 and ranked 23rd in the list of the top 50 steel-producing countries in the world, according to the 2020 World Steel Association report.

In 2014, the government approved the use of heavy polluting coal in cement manufacturing to mitigate the rising natural gas prices and energy shortages, while the fuel mix for cement production was previously 60% natural gas and 40% heavy fuel oil, according to a 2016 report led by the European Bank for Reconstruction and Development.

Cairo is among the world’s most polluted cities, according to Forbes magazine. This ranking was based on analyzing data on ambient air pollution, noise, and the intensity of artificial lighting in 48 cities worldwide and ranking these cities based on the combined pollutants. Cairo scored 95.8361 out of 100 points, nine points ahead of Delhi, which ranked second.

The primary source of air pollution in Egypt comes from fine particles of types PM2.5 and PM10. These particles primarily originate from transportation, industry, and the open burning of solid organic materials.

Due to its proximity to surrounding desert areas, much of the dust blows in from the surrounding lands, and air quality in Cairo ranges between 10 and 100 times more polluted than globally acceptable standards. The lack of rain exacerbates the situation due to the cleansing effect of rainfall. The air over Cairo is often thick and gray and appears as fog. Carbon monoxide emitted from vehicles mixes with PM particles.

Industrial energy contributes to the third-highest concentration of fine particles in Cairo (17%), where the city hosts a third of the country’s industry. Most of these industries rely on natural resources, such as iron, steel, bricks, cement, power plants, and fertilizers. Only a few industrial factories have appropriate waste treatment facilities, despite pollution reduction projects.

The Ministry of Environment participates in the third phase of combating industrial pollution and establishing environmentally friendly industrial zones in the city under an agreement between the government and the United Nations Industrial Development Organization (UNIDO) in 2022.

Lack of Oversight and Effectiveness

There is a noticeable absence of legal protection for public and environmental health. There have been no parallel improvements to updating the lenient air pollution standards, enforcing Egyptian air quality standards, or developing fuel quality specifications on the legislative agenda for environmental work in Egypt. The weak legal protection reflects in the scarcity of environmental cases due to weak environmental governance, such as environmental inspection and oversight, and difficulty in accessing information, according to environmental researcher Mohamed Younes in a study published by the Alternative Policy Solutions Center.

Younes also believes that “the Egyptian government relies on investment in economic solutions to reduce air-polluting emissions, but the pattern of government interventions conditioned on economic returns to address local pollution problems remains a biased measure in favor of the economy over public health and the local environment. These policies stem from the same capitalist economic systems that target quick profits at the expense of natural resources, resulting in the current disruption of the ecosystems around us.”

High Risks

According to the Carnegie Center for Studies, Egypt increasingly faces environmental challenges due to rising temperatures, sharp declines in water resources, subsidence, increased salinity, and natural disasters. Environmental impacts will include macroeconomic disruptions linked to scarcity and shocks.

The Egyptian government has launched a series of measures, many of which coincided with the COP27 climate conference held in Sharm El-Sheikh in 2022, notably the “National Climate Change Strategy 2050.” According to official websites, this strategy includes long-term national plans aimed at avoiding the negative impacts of climate change while preserving the achievements in development and economic progress by 2050. The strategy has received significant attention from the Egyptian authorities and their various concerned institutions and is seen as a serious attempt to avoid the negative local and global consequences of climate change, especially concerning developmental and environmental aspects.

Years before this, in 1994, Egypt signed the United Nations Framework Convention on Climate Change and then the Kyoto Protocol in 2005, participated in most related international forums, and ratified various laws related to environmental and climate protection.

Cairo also launched the first National Adaptation Strategy for Climate Change and Disaster Risk Reduction in 2011, then adopted the Paris Agreement to strengthen global action to combat climate change in 2016, and then prepared the Low-Emission Development Strategy in 2018, culminating in the launch of the Climate Change Strategy 2050.

Despite all the agreements signed by Cairo and all the announced strategies, the risk of investment remains looming over citizens and the Egyptian land, with the lack of optimal application of standards, increasing citizens’ doubts about the expected environmental impact of creating more opportunities for foreign and domestic investment within the country.