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Sustainable Development and Environmental Impact Assessmentin Egypt: Historical Assessment

RIFAAT ABDEL WAHAAB∗

National Research Centre, Cairo, Egypt

Summary. The achievement of sustainable development demands the integration of environment anddevelopment. To achieve sustainable development requires a close collaboration and cooperation betweenenvironmentalists and the decision-makers. The evidence is that in developing countries (Egypt, as anexample) the gap is widening rather than closing. Intensive research programs are needed, for instancein the field of sustainable development and urban environmental management, to narrow that gap. Envi-ronmental Impact Assessment (EIA) has become a management tool for achieving acceptable forms ofenvironmentally sound development and sustainability; at best it is proving nothing more than a permitto move a project ahead.

It is recommended that indicators for sustainable development and their progress be fully monitored.Performance indicators should always be established, not only for project implementation, but also duringand after the implementation process to make sure that all mitigation measures are satisfactorily imple-mented. This can be achieved by linking the license granting authority for action to the actual implemen-tation of these measures. To secure the environmental sustainability of an environmental project, it is alsoimportant to have the EIA document as an integral part of the license application document, and to makeit available to inspectors during their necessarily frequent inspection visits.

Keywords: Egypt, environmental assessment, EIA, laws, sustainable development

Introduction

The linkages between a country’s national econ-omy and natural resources and environmental sec-tors are very important. Land, water, energy, andnatural resources are vital inputs into the agricul-tural and industrial sectors. Natural and culturalresources provide the major attractions for foreigntourists. Generally exports of oil, together with thetourism and industry are major sources of foreigncurrency. The economy also is the major stressor

∗ Dr Rifaat Abdel Wahaab is Professor of environmental sci-ences at the National Research Centre, Cairo. He began hisprofessional career in industrial pollution and control and sincethen he has continued to work in diverse areas of environmen-tal management and strategy. He is actively managing and par-ticipating in many of Egypt’s environmental plans: the nationalwater quality monitoring network, Egyptian environmental sec-tor assessment and the preparation of Egyptian environmentalinitiatives (e-mail: [email protected]).

of the environment, for instance, production in theindustrial and agricultural sectors contributes topollution of the air and water, and the genera-tion of solid and hazardous wastes. Consumptionactivities lead to the production of solid waste, andcreate demand for wastewater treatment services.

A strong economy can be a key factor in theprotection of the environment, as profitable busi-nesses can better afford to invest in environmen-tal protection. Similarly, high per capita incomeimplies a greater ability to pay for environmen-tal services, such as solid waste collection anddisposal, and wastewater treatment. In addition,higher incomes are strongly correlated with ahigher demand for environmental quality.

Egypt’s national environmental policy was lastelaborated in the National Report on Environmentand Development prepared for the United NationsConference on Environment and Development in

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Rio de Janeiro (1992). This report, compiled by aselected group of Egyptian scientists and expertson the environment, established Egypt’s environ-mental policy in the fundamental principles of sus-tainable development and sound environmentalmanagement. The report then identified fourteenpriority environmental programs, ranging from themanagement of fresh water resources and the pro-tection of soils on agricultural lands, to controllingurban air pollution and properly managing solidand hazardous waste.

The objectives of this review article are:i) to provide a general understanding of sustain-able development, its principles and requirements;ii) to examine the evolution of environmental pol-icy in Egypt during the past few decades, andEgypt’s commitment to sustainable developmentand environmental protection; iii) to assess theimportance of the Environmental Impact Assess-ment (EIA) process as a tool to achieve sustain-able development. Several recommendations forimproving the EIA process in Egypt are identi-fied, taking into consideration the existing leveland pace of socio-economic development, and itsimplication on environmental policy, and hencesustainable development.

Environmental policy in Egypt:historical overview

Though, Egypt has a long history of environmen-tal legislation (Table 1), the major problem liesin weak regulatory compliance and enforcement.Egypt also does not lack environmental plans,but rather, lags in the use and application ofthese plans. An overview is provided below of theevolution of environmental policy in Egypt sincethe 1960s, it follows three distinct environmentalmanagement paradigms, namely the ‘anti growthparadigm,’ the ‘limits of growth paradigm,’ andthe ‘sustainable development paradigm.’ Theseare similar to those transforming the processes ofenvironmental policy making and implementationworldwide. Since the 1960s, Egypt’s developmentpath may be categorized by three distinct pol-icy orientations, namely the socialist era (1960s),the open door policy era (1970s–mid 1980s), andeconomic reform and structural adjustment era(1990s).

Egypt in the post-revolutionary era:the anti-growth paradigm

The 1960s saw the emergence of environmentaleconomics as a separate branch of economics.During this period, it was felt that growth anddevelopment, and the protection of the envi-ronment could not go hand in hand. Hencemost theories that developed during this periodwere anti-growth (Pearce et al., 1989; Pearce andTurner, 1990; Welford, 1998).

Environmental policy during this period wasmainly focused on a regulatory fix to environ-mental problems using the ‘command-and-controlapproach.’ This approach addressed what wasin a final discharge rather than the source ofthe problem. The meat-axe regulatory approachof this period was very effective in managingenvironmental problems; however, environmen-tal management during this period was regardedby industry with little enthusiasm and it passedthe cost of pollution control on to the consumer(Welford, 1998).

During the 1960s, the Egyptian governmentenacted a series of laws that socialized the econ-omy, and set in an inward oriented developmentstrategy, popularly known as import substitu-tion. Banking, insurance, foreign trade, whole-sale trade, and the majority of manufacturingenterprises were nationalized and large-scale Stateenterprises dominated the economy. The five-yeareconomic plan of 1960 led to significant expan-sion of industry and production. The objectives ofthe welfare-oriented social policy were to improvewelfare distribution, and raise the population’shealth and education levels. Economic and socialdevelopment programs included an extensive sys-tem of price controls and comprehensive pro-grams were designed in health, housing, waterand sanitation, education, employment, and socialsecurity sectors.

Extensive industrial development during thisera resulted in environmental deterioration, as themajor thrust was economic growth. As is evi-dent from Table 1, in spite of the existence ofvarious laws, and the enactment of new lawsrelating to the environment (Law 93/1962; Law53/1966 for agriculture and the use of agricul-tural pesticides, Law 38/1967 concerning pub-lic cleanliness; etc.), weak enforcement of laws

Sustainable Development and Environmental Impact Assessment in Egypt 51

Table 1. Environmental laws and decrees in Egypt since 1947

EnvironmentalL/D No. Year Description sector

L 62 1947 Rural hygiene, health units, public bath solid wasteL 45 1949 Regulates the use of loudspeakers noiseL 192 1955 Concerning Antiquities Authority historical areasL 371 1956 Concerning public shops airL 372 1956 Concerning recreational places airMD 126 1958 Specifications of plant oil processing airMD 236 1958 Concerning treatment of grain airL 21 1958 Industrial regulations (storage and disposal) solid wasteMD 994 1959 Specifications of rubber workshops airL 148 1959 Civil Defense airMD 193 1959 Occupational Safety in Mines and Quarries airMD 754 1960 Water Committee waterL 93 1962 Drainage of wastewater waterPD 421 1962 Ratifying Marpol Convention waterPD 2703 1966 High Committee for water waterMD 50 1966 Concerns the use of agricultural pesticides solid wasteL 53 1966 Concerning agriculture and regulated pesticides pesticidesL 53 1966 Agriculture agricultureL 38 1967 Cleanliness law solid wasteMD 28 1967 Prohibited hunting of wildbirds beneficial to agriculture biodiveristyL 72 1968 Prevention of oil pollution of sea water waterPD 864 1969 Establishing Committee for Air Pollution Control airL 144 1969 Protected fish from explosives biodiveristyMD 331 1970 Executive Committee of Water waterMD 470 1971 Maximum limits of air pollutants airPD 2828 1971 Established the Egyptian Antiquities Authority cultural hertiageMD 58 1972 Specifications of animal farms airMD 63 1972 Specifications of Paper and Paper Pulp Workshops airMD 65 1972 Specifications for metal welding workshops airMD 444 1972 Use of Ionizing Radiation airPD 961 1972 Permanent Committee for Control of Sea water Pollution waterL 66 1973 Traffic airL 66 1973 Traffic noiseL 1 1973 Concerning hotels and touristic establishments tourismL 2 1973 Concerning supervision of touristic areas tourismMD 291 1974 Implementing Law 66/1973 airMD 380 1975 Specifications of industrial and commercial buildings airL 31 1976 Control of Solid Waste Management solid wasteL 106 1976 Regulating Building Activities airL 27 1978 Control of Potable Water Sources waterL 57 1978 Treatment of ponds and marshes waterMD 240 1979 Adding a level for SO2 in ambient air airMD 7/1 1979 Specifications of potable water waterL 31 1979 Local administration solid wasteL 59 1979 New Urban Communities landuseMD 349 1979 Created to addres wildlife management biodiveristyL 137 1981 Labor airL 27 1981 Mines and Quarries airL 52 1981 Protection against smoking airL 137 1981 Labor occupational healthL 137 1981 Labor—addresses noise noiseL 3 1982 Urban Planning airMD 600 1982 Implementing Law 3/1982 airMD 1 1982 Implementing Law 52/1981 airMD 380 1982 Technology of Pollution air

Continued

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Table 1. Continued

EnvironmentalL/D No. Year Description sector

L 48 1982 Protection of the River Nile from Pollution waterMD 170 1982 Establishment High Committee of the Nile waterMD 380 1982 Technology and Pollution waterL 3 1982 Urban Planning LanduseMD 2344 1982 Authorized to arrest violators biodiveristyMD 701 1982 Established protected areas and prohibs handing. biodiveristyMD 472 1982 Regulation of hunting in Sinai and protecting areas. biodiveristyMD 55 1983 Safety and health in the workplace airMD 8 1983 Implementing Law 48/1982 waterGCD 59 1983 Cairo Cleaning and Beautifying Authority solid wastesPD 284 1983 Collection and disposal of garbage and solid waste solid wastesMD 55 1983 Safety and health in the workplace solid wastesMD 55 1983 Safety and health in the workplace—exposure limit to noise noiseL 117 1983 Protects archeological and historical sites landuseL 116 1983 Control use of land for non-agricultural purposes LanduseMD 36 1983 Concerning regulating building on agricultural land agricultureL 102 1983 Natural Reserves natural protectoratesL 102 1983 Natural Reserves natural protectoratesPMD 1067 1983 Implementing Law 102/1983 natural protectoratesMD 66 1983 Prohibited hunting of birds in Egypt biodiveristyL 12 1984 Irrigation and drainage waterMD 43 1985 Regulation of drainage and waterways waterPMD 1476 1985 Executive Committee for Industrial Drainage to the Nile waterL 101 1985 Tourism development and environmental protection natural protectoratesL 4 1994 Protection of shores and ports from pollution waterL 213 1994 Legitimize the role of MPWWR waterPMD 338 1994 Standards for discharge substances by all industries waterL 4 1994 Hazardous waste management solid wastesL 4 1994 Management of Natural Reserves waterMD 1995 Private cleaning of canals by MPWWR water

L LawPD Presidential DecreeMD Ministerial DecreePMD Prime Ministerial DecreeMPWWR Ministry of Public Work and Water Resources

was the norm. State owned industrial enterpriseswith massive investments in Soviet-style industrialplants were given water and electricity virtuallyfree of charge. These distortions in the pricesof production inputs (water, energy, wastewa-ter, etc.) provided little economic incentives forState dominated enterprises to rationalize theuse of their resources, and resulted in wastefuland polluting industrialization. Untreated indus-trial and domestic wastewater generated by indus-trial areas in major cities was disposed of intothe Nile and canals. Due to overall low levelsof socio-economic development, environmental

awareness—other than health related issues—wasnon-existent. The major environmental problemsof this era were the alleviation of poverty andmeeting basic human needs.

Egypt during the open-door era (1973–1984):the limits to growth

The 1970s witnessed the first United NationsConference on Human Environment (First EarthSummit), the establishment of the United Nations


Environment Program (UNEP), and the begin-ning of combining business and environmentalaspects in the international arena. In 1979, the‘Club of Rome’s’ renowned The Limits of Growthconcluded that even under the most optimisticassumption, the world could not support the rateat which the world’s population and economy weregrowing for more than two decades. In response,environmental legislations were passed, regula-tions promulgated, and efforts and resources werefocused on clean up and control (regulatory fix).In Western Europe and the USA, enforcementwas strengthened through an environmental per-mit structure.

Regulations mandated the preparation of EIAfor new projects as a requirement for approvingand granting permits to operate. Similar to the1960s, the response of industry was largely reac-tive with investments in end-of-pipe technologicalsolutions to ensure compliance with the ever-increasing regulations, and conditions attached tooperating permits.

In contrast to the slow economic and socialdevelopment during the second half of the six-ties (the impact of the 1967 war), the economy,however, grew rapidly from the mid-1970s due tothe ‘Open Door’ Policy that slightly liberalized theeconomy by encouraging foreign investment andthe private sector, and limited the predominantroles of the State and public sector. Moreover,the Government of Egypt continued to maintainits socialist welfare policy. In spite of the slightlyencouraged foreign investment, and the increaseof the private sector, the development strategyremained focused on import substitution. Eco-nomic growth during this period required realloca-tion of resources to meet the needs of industrialgrowth and the rapidly growing population. Thisperiod witnessed high demands on housing, trans-portation, food, services, and industrial productionas a result of rapid population growth and urban-ization; all of which resulted in extensive environ-mental deterioration in the name of development.The perception was that much of the waste gen-erated could be assimilated in the environment.

Environmental management in Egypt duringthe ‘Open Door’ era followed a similar path tothe 1960s, with the promulgation of new laws andministerial decrees. As evident from Table 1, newlaws were enacted during this era, such as Law

48/1982 concerning protection of the River Nileand waterways from pollution, Law 102/1983 con-cerning Natural Protectorates, Law 137/1981 con-cerning Labor, and Law 3/1982 of urban planning.

Moreover, in 1980, a Ministerial Committeefor Environmental Affairs was established fromrelated ministries reporting to the Council ofMinisters. Then, a new committee was estab-lished to coordinate environmental activities, andit was to report to the Prime Minister. In 1982,the presidential decree no. 631 was issued, andthe Egyptian Environmental Affairs Agency wasestablished as the coordinating body for environ-mental policy making in Egypt. During this period,Egypt also participated in various regional andinternational conventions and protocols concern-ing the environment.

Egypt during the economic reform era(1985–Present): sustainable development

Worldwide development: sustainable development.The 1980s witnessed a shift in thinking. The con-cept of ‘zero growth’ was replaced by sustainabledevelopment, which essentially involved meetingthe present needs without compromising the abil-ity of future generations to meet their own needs(Bruntland, 1991). The Bruntland Report intro-duced the concept of ‘more with less,’ i.e. the needto produce more value from goods and serviceswith less material and energy consumption, andless waste and emission production.

Pearce et al. (1989), showed how sustainabledevelopment might be achieved through marketforces and regulations. It showed that economicgrowth and the preservation of the environmentare not necessarily incompatible.

The 1990s, which saw the Second Earth Sum-mit (1992), might be regarded as the period ofstrategic action, both on part of government andindustry. Agenda 21 (1992) was the outcome ofthe Earth Summit, a global consensus and politi-cal commitment on how governments, enterprises,non-governmental organizations, and all sectors ofhuman life and action can cooperate to solve theenvironmental problems threatening human lifeand society. The 1990s also witnessed the Sec-ond United Nations Conference on Human Settle-ments ‘The City Summit’ held in Istanbul in 1996.

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‘The City Summit’ set human settlements at thecore for achieving sustainable development.

Egypt: The Pursuit for Sustainable Development.With the increasing interest rates and collapseof oil prices in the mid 1980s, Egypt was left ina difficult financial position. Inflation and unem-ployment rates rose dramatically, while the growthrate declined. Egypt’s inability to service its debtled to a decrease of capital inflows, an accu-mulation of back payment, and an increase ininflation and unemployment (UNEP, 1993). Sincethe mid-80s, the World Bank and the Interna-tional Monetary Fund (IMP) exerted pressure onthe government of Egypt (GOE) for structuraladjustment and resource allocations. Accordingly,the GOE started an economic reform programin 1992. The economic reform program aims attransforming the Egyptian economy from a cen-trally planned, inward looking economy to a onethat is market-based and outward oriented. Theeconomic reform program included: the deregula-tion of interest rates and the foreign exchangesregime, the reduction of government spendingthrough gradual removal of subsidies, the imple-mentation of a privatization program, the intro-duction of a new capital market, the abolishmentof investment licensing, and the revision of thetrade regime (i.e., the reduction of the level oftariffs and ratification of GATT). In 1994, Egyptsigned the General Agreement on Tariffs andTrade. In 1995, Egypt joined the World TradeOrganization. With the reduction and eliminationof most subsidies, the role of the State in the pro-vision of social services was greatly constrained(EPIQ, 1998).

Amidst hard economic times—in line withinternational shifts—Egypt announced its desireto achieve the goal of sustainable developmentand this has been reflected in the process of envi-ronmental policy formulation. During the early1990s, policy makers realized that high populationand urbanization growth rates have exerted greatpressure on Egypt’s limited natural resources. TheEgyptian government’s environmental objective isas stated in the Cabinet of Minister’s Egypt andthe 21st Century (EEAA, 1997), “Egypt adoptsan environmental policy that supports sustainabledevelopment programs taking environmental con-siderations into perspective and provides a life fit

for its citizens” (EPIQ, 1998). However, in view ofthe alarming results of a number of research stud-ies on air and water pollution in the region, theGovernment is aware that it must take decisivesteps to change the present developments. Lately,in contrast to past weak enforcement, the govern-ment is actively committed to the enforcement ofenvironmental laws.

On the environment front, Egypt has under-taken several major environmental protectionmeasures during the 1980s and 1990s. Most impor-tant developments include:

— drafting of several environmental plans such asEgyptian Environmental Action Plan (EEAA,1992),

— issuance of several laws and ministerial decreesconcerning the environment such as Law4/1994,

— in 1997, a Specific Minister of State for theEnvironment was appointed.

In 1994, Law 4 of the Environment was formu-lated by a group of Egyptian experts representinggovernmental and non-governmental institutionsand research institutions. The law was issued tofill the various legislative gaps in existing environ-mental regulations, and to strengthen the power ofEgyptian Environmental Affairs Agency (EEAA).Law 4 provides the EEAA broad authority, to reg-ulate air pollution, control hazardous substancesand waste management, and control discharges tomarine waters. Law 4 made four major contribu-tions to the Egyptian Environmental sector, whichhave been further clarified in the executive regu-lation 338/1995:

— made EEAA responsible for the overall coor-dination and management of environmentalaffairs,

— addressed the air quality issue, and through itsexecutive regulations, set the first air emissionstandards in Egypt,

— addressed coastal zone management in a com-prehensive manner; examining marine- andland-based pollution sources,

— made important provisions for a permittingsystem for hazardous waste handling, as wellas disposal and treatment.

The law gives EEAA an array of tools for imple-menting and enforcing these provisions. The law


motivates polluters to follow a more sound envi-ronmental behavior by setting standards (tradi-tional tools), requiring new projects to prepareEIAs, allowing for an adjustment period for indus-trial establishments, forcing them to comply withregulations, and offering economic incentives forthe first time in Egyptian Law. Penalties are calledfor in the law as a last resort. The Law stipulatesthe responsibilities of the EEAA in environmentalmanagement, and creates a special fund to supportenvironmental activities. The law also recognizesthe important role of NGOs in decision-makingin the area of the environment. Moreover, Arti-cle 5 of the Law gives the EEAA the authorityto periodically gather public and national envi-ronmental information, to set up environmentaleducation programs, and to participate in theirimplementation.

Thus, there has been a growing change inthe way environmental policies, programs, andprojects are formulated and implemented. Thenew environmentalism—characterized by greaterprecision in factoring environmental costs andbenefits into policy making—puts local people inthe center of environmental strategies, diagnosesand addresses behavioral causes of environmentaldamage, and recognizes the political dimensionsof environmental reform. The principles, whichcharacterize the new environmentalism in forcetoday, include:

— setting priorities carefully; not all problems canbe solved at once,

— recognizing that sustainable development iscentered upon economic, environment, social,demographic, and health issues and the fullinvolvement and participation of local people,

— economizing, where possible, on scare admin-istrative and regulatory capacity, but recog-nizing that some controls and regulations arerequired and must be enforced,

— working with, rather than against, the privatesector, using market forces where feasible toachieve environmental improvements,

— involving the public, and improving access togood information. Public participation requiresraised awareness and the creation of new com-munication channels to allow all groups, espe-cially the poor to utilize them.

Sustainable development: theoretical approach

Background

An important recommendation of the UnitedNations Conference on Environment and Devel-opment (the Earth Summit) held in Rio deJaneiro, in 1992, was that individual countriesshould prepare strategies and action plans thatcontain real commitments and targets, and sus-tainable measures in order to make progress onthe problems affecting the environment of thewhole world. Agenda 21 (1992)—one of the Sum-mit’s major outputs—calls for a comprehensiveprogram of actions needed throughout the worldto achieve a more sustainable pattern of devel-opment for the next century. Agenda 21 placedgreat emphasis on the need for all sectors of soci-ety to participate in the formation of effectivenational strategies for sustainable development.Since the Summit, many countries are trying torelate sustainable development to their nationalpolicy-makers. The GOE is also pursuing the goalof sustainable development in its national pol-icy. Sustainable development, is viewed as a vitalnecessity to reconcile the two basic aspirations ofthe Egyptian society, namely economic develop-ment and job creation, and environmental protec-tion of limited natural resources.

Definition and principles

The term ‘sustainable development’ was broughtinto common use by the World Commissionon Environment and Development. Its muchquoted—but vague—definition refers to the devel-opment which “seeks to meet the needs andaspirations of the present without compromisingthe ability to meet those needs of the future,”(Brundtland, 1987).

A less imprecise definition given Brundtland(1991), is: “a process in which the exploitation ofresources, the direction of investments, the orien-tation of technical departments and institutionalchange are all in harmony, and enhance both cur-rent and future potentials to meet human needsand aspirations.”

The World Bank uses the term EnvironmentallySustainable Development (Serageldin and Steer,1994). This has been defined in terms of its three

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interrelated dimensions as follows:

— economic and financial sustainability: growth,capital maintenance, efficiency of use ofresources and investments.

— ecological sustainability: ecosystem integrity,carrying capacity, and protection of species,biodiversity and natural resources.

— social sustainability: equity, social mobility,social cohesion, participation, empowermentof people, cultural identity, and institutionaldevelopment.

The Earth Summit and its debates about sus-tainability have shown the world that there is nolonger any way of separating environment anddevelopment. The two principles of environmentand development were encapsulated in Principles3 and 4 of the Rio Declaration as follows:

Principle 3: The right to development must befulfilled, so as to equitably meet developmentand environmental needs of present and futuregenerations.

Principle 4: In order to achieve sustainabledevelopment, environmental protection shall con-stitute an integral part of the development processand cannot be considered in isolation from it.

As stated in the UK Sustainable DevelopmentStrategy (1994), most societies aspire to achieveeconomic development to secure rising standardsof living, both for themselves and for future gen-erations. They also seek to protect and enhancetheir environment, now and for the future. Rec-onciling these two aspirations of society is at theheart of sustainable development. Societies pur-sue economic development to meet basic materialneeds and provide the resources to improve thequality of life.

The concern for the environment was moti-vated by several different reasons. Historically,much of the early environmental legislation wasmotivated by the concern for human health. Thoseled to measures to curb air pollution, provideclean water, and minimize risks from waste dis-posal. The concern for public health remains afundamental consideration in environmental pol-icy and extensive studies are needed in areaswhere cause and effect are harder to approve ordisapprove.

A second concern for the environment was toconserve those common natural resources that

have an economic value, and which have a poten-tially finite supply. These also include aspectsof the environment that people value for theirsake. Today, environmental concerns have broad-ened beyond the immediate environment to globalissues, such as protection of the oceans, the greatforests, the stratospheric ozone layer, and theworld’s climate. These concerns show that muchmore is at stake than human health and aes-thetic interests alone (Pierce et al., 1997). Accord-ing to Adriaanse (1993), environmental awarenessis growing in all countries of the world as peo-ple are becoming aware that they are part of theenvironment, and that all human activities bearconsequences for the environment. Governmentsare realizing that given the present environmentalquality, major efforts, social processes, and sacri-fices are needed to preserve a functional environ-ment for posterity.

Many forms of economic development makedemands on the environment: they use naturalresources, which are sometimes in limited supply,and generate by-products of pollution and waste.There is growing recognition that there are waysin which the right kind of economic activity canprotect or enhance the environment. The chal-lenge of sustainable development is to promoteways of encouraging environmentally friendly eco-nomic activity, and of discouraging environmen-tally damaging activities.

For development to be sustainable, environ-mental considerations must become a centralpart of the decision-making process within gov-ernment and industry. Environmental protectionrequires collective action. For this to happen,decisions about economic development ought totake account of the costs of potential pollutionand waste, and the value of resources that areconsumed and, conversely, of the value of anyenvironmental improvements made. Thus, a keyobjective of environmental and sustainable devel-opment policy is to ensure that environmentalcost and benefits are properly, and fully, takeninto account in public and private sector deci-sions. To assist in this, a number of supportingprinciples/requirements are now widely applied innational and international environmental policy-making.

The first principle relates to the importanceof government’s commitment to basing action on


fact, using the best scientific information available.However, when potential damage to the environ-ment is both uncertain and significant, it is nec-essary for the government to act on the basisof the precautionary principle. This principle isconsistent with the Rio Declaration, which setsout the ‘precautionary approach.’ As stated in theRio Declaration on Environment and Develop-ment 13 June, 1992. Principle 15. “Where thereare threats of serious or irreversible damage, lackof full scientific certainty shall not be used as areason for postponing cost-effective measures toprevent environmental degradation.”

The second principle relates to the importanceof ecological criteria and total human wealth.Ecological criteria mean considering the abilityof a habitat or ecosystem to sustain a popula-tion of a particular species—generally describedas the ‘carrying capacity.’ The term mainly refersto the capacity of the environment to absorb pollu-tion or waste. According to the sustainable devel-opment framework, human wealth includes bothman-made capital and natural environmental cap-ital (renewable and non-renewable resources) andother aspects of the quality of life. The chal-lenge of sustainable development is to find waysof enhancing total wealth, while using commonnatural resources efficiently, so that renewableresources can be conserved, and non-renewableresources used at a rate which considers the needsof future generations.

The third principle relates to the importanceof making people responsible for pollution andresource depletion, bear the consequences. If thepolluter, or ultimately the consumer, is made topay, then the costs of pollution, waste, and theconsumption of natural resources are brought intothe calculation of the enterprise. Environmentalpolicy in this field is guided by the ‘polluter pays’principle (OECD, 1972). The polluter pays princi-ple has been adopted by the Organization for Eco-nomic Cooperation and Development (OECD)countries since 1972.

In order to translate sustainable developmentprinciples into practice, several requirements mustbe established. Several basic requirements that setthe domain for current and future research in thefield, therefore, follows:

First, better information is needed about envi-ronmental impacts. Scientific understanding of

the environment must constantly be taken for-ward. Better health-related indicators are needed,including better understanding of the implicationsof different levels of exposure to pollutants. More-over, better indicators of the state of the environ-ment, and other information that would assist inincluding environmental effects into assessmentsof new proposals. Ongoing research in this areais targeted towards the following: i) refinementof environmental quality objectives and targetsfor environmental improvement (for broad pol-icy and monitoring purposes); ii) development ofmore specific environmental targets for differentenvironmental media and sectors of the economy;iii) understanding of the relationships betweenenvironmental factors and health; iv) improvingquality and coverage of environmental informa-tion and indicators for monitoring, such as envi-ronmental indicators and sustainable developmentindicators (Radwan, 1995).

The second requirement is the developmentof suitable mechanisms in the private sector toensure that information is brought to bear onthe decisions being taken, and brought fully intothe decision-making process, not just as an afterthought. This calls for integrating environmen-tal costs and benefits into firms’ and individu-als’ behavior. The traditional way has been toimpose regulatory requirements. But regulationmay not always be the best way of achieving objec-tives, either from an environmental, or an eco-nomic point of view. Regulations impose hiddencosts, which can lead to inefficiency and waste.There is a world-wide shift to reduce and sim-plify regulations wherever appropriate. While reg-ulatory measures will always be a major part ofenvironmental policy, economic instruments areactively pursed by many governments. Economicinstruments make environmental costs explicit,and ensure that people take account of them inmaking decisions. They also give incentives forinnovation and the development of environmen-tally friendly techniques.

Another requirement of sustainable develop-ment is that environmental considerations becomea central part of the decision-making processwithin government and industry. For this to hap-pen, better information on the way in which eco-nomic development impact on the environment isneeded. In the siting of development, both govern-ment and industry must have clear information of

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the characteristics of the various ecosystems, andthe differential impact of development on thesesystems. There are several international effortsworth noting towards regionalization and ecologi-cal zoning, that may assist in the proper siting ofdevelopment, as well as preparing required envi-ronmental impact assessments.

It is widely recognized that for development tobecome more sustainable, greater emphasis mustbe placed on resource efficiency. Thus, a fourthrequirement for sustainable development is theneed to increase resource efficiency. Many coun-tries are targeting science and technology researchtowards material reuse, waste reduction, longevity,and reparability of products, remanufacturing,recycling, and reduced transportation needs. Fac-tor Four, a new book marking the resource effi-ciency revolution, postulates that the world canquadruple resource productivity using existingtechnological knowledge. This would allow theworld to double well-being, while at the same timehalve resource consumption. It offers hope forsustainable development, especially for develop-ing countries with limited resources (Gaber andBaker, 1998).

A growing environmental consciousness in theindustrialized world as a result of two interdepen-dent processes has occurred. The first process wasa shift in mass belief systems from material valuesto a greater concern with the quality of life, andenvironmental issues with ‘post-materialist values.’The second process is the increasing exposure toenvironmental hazards and the dissemination ofenvironmental information about the environmen-tal risks involved. Thus, to increase government,business and the public’s environmental aware-ness, motivation, and willingness to preserve theenvironment, environmental policy must be basedon reliable information about the state of the envi-ronment and factors that impact on it, includingrelative risks, and the costs and benefits of ame-liorating any adverse impacts (Adriaanse, 1993).This is the main purpose of EIAs.

New tools, technologies, and regulatory shifts

Driven by the increasing cost of meeting regula-tions and liabilities associated with clean up, andincreasing public recognition of the magnitude of

emissions that evolve, source reduction/waste min-imization/pollution prevention efforts are gainingimportance. New technologies for pollution pre-vention, waste minimization, and life cycle assess-ments have become to be emphasized.

Since the early 1990s, greater focus is on theconcept of risk as a mechanism to differentiatebetween major and lesser environmental issues(Loehr, 1997), and is becoming a major decisionand policy-making tool in environmental manage-ment. Most western countries increased their levelof legislation affecting businesses with increasedemphasis on the ‘Polluter Pays Principle,’ bestavailable techniques, and best practicable environ-mental option.

Industry and sustainable development

Other developments include the establishment ofthe Business Council on Sustainable Developmentwhich published its important report ChangingCourse, and also decided to approach the Interna-tional Organization for Standardization (1996) todiscuss development of environmental standards.In parallel, the International Chamber of Com-merce (1997) developed the Business Charter forSustainable Development, which contains 16 prin-ciples of sound environmental management.

These changes in the industrialized world havepersuaded industry to take a more pro-activestand in environmental management. Industry isbeginning to recognize that sound environmen-tal management can enhance corporate image,increase profits and competitiveness, reduce costs,and obviate the need for further legislation. Evi-dence is seen in the move towards green productswith the increasing use of ‘life-cycle analysis’—looking at the environmental impact of a product‘from cradle to grave’ (Christiansen, 1991). Newenvironmental tools have emerged such as envi-ronmental auditing, environmental accounting andenvironmental management systems. Lately, somenew emerging informational measures like Eco-labeling and Eco-audits for companies have beenintroduced in some countries. The purpose of bothis to establish a higher degree of transparency forproducts, and for the public in general, using theenvironmental aspect as a marketing parameter.


Environmental impact assessment:historical overview

Over the past few decades, pollution prob-lems, and consequent environmental degradation,have been gradually aggravated. Throughout thisperiod, much attention has been given to eco-nomic development, without due regard to envi-ronmental consequences. Until the end of the1960s, nature was treated as an infinite supply ofphysical resources to be used for human bene-fit; economists were mainly concerned with alloca-tion and distribution of resources. Thus, there wasno ‘biophysical environment’ to be managed, sinceit was seen as irrelevant to the economy (Colby,1991). Projects were assessed purely in financialterms, without economic valuation of non-cashcost and benefits, and without environmental con-siderations.

During the 1970s UNEP played a lead role inthe creation of worldwide environmental aware-ness, leading to a fundamentally different valuesystem to harmonizing man with his environment.Meanwhile in the USA National EnvironmentalPolicy Act (1970) was passed, legislating for theexecution of Environmental Impact Assessment.In development and project planning, EIAs’ beganto gain wider currency, and were legislated for inother countries (UNEP, 1993).

In the 1980s, following the World Conserva-tion Strategy, a more holistic, ‘global commons’approach began to emerge, incorporating a morepositive, or at least open-minded, view of devel-opment. Many agencies developed and publishedimproved and stricter procedural and technicalEIA guidelines. In a number of land mark studies(Beanlands and Duinker, 1983; Beanlands, 1993)and conferences (Biswas and Agarwala, 1992),EIA began to be recognized in terms of its rel-evance and effectiveness, and recommendationswere formulated for improved procedures, such asscoping and monitoring.

Mudge (1993) reported that a significant andgrowing divergence is apparent between EIA the-ory, as expounded in conference papers, andscholarly publications, and EIA practice in thedeveloping world, which is still limited, largely dueto the requirements for bankable project feasi-bility studies. The results are, that an increasing

number of practitioners and observers are agree-ing that ‘EIA, a 20-year old tool for environmentalmanagement, is not living up to its full potential.’

Today, although EIA has evolved in developedand developing nations in different ways, certainprinciples are common throughout. It is a sys-tematic way of evaluating impacts of activities orprojects (called activities for simplicity) whetherthose impacts are beneficial or negative. There hasbeen substantive implementation of EIA proce-dures in developed countries, although the meth-ods of implementation vary. In addition, thereare many developing nations that have specificallytailored programs requiring EIA prior to projectapproval. Egypt is one of them.

EIA: definition and aim

Environmental Impact Assessment or ‘EIA’ forshort, is: “a process of identifying, predicting,evaluating, and mitigating the biophysical, social,and other relevant effects of proposed projects—prior to major decisions and commitments beingmade” (Ross et al., 1994). EIA focuses mainlyon problems, conflicts, or natural resources con-straints that could affect the viability of theproject. After predicting potential environmentalproblems, the EIA identifies measures to mini-mize the problems, and outlines ways to improvethe project’s suitability for its proposed environ-ment (Ross and Canas, 2000).

The aim of EIA is to ensure that potentialproblems are foreseen and addressed at an earlystage in the project’s planning and design. Ithelps project planners and engineers to shapethe project, so that its benefits can be achievedand sustained without causing inadvertent prob-lems, and helps officials make decisions about theproject.

EIA: main elements

According to OECD (1994) the following are thebasic elements for EIAs which have to be carefullycovered in any environmental project:

— environmental aspects must be fully integratedin project selection, design, and implementa-tion;

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— should address expected effects on humanhealth, the natural environment and property,social effects (including gender specific andspecial groups);

— should consider alternative project designs, aswell as required mitigation and monitoringmeasures;

— where possible, views of the affected indige-nous population should be obtained;

— should consider the carrying capacity for thezone in which the project is planned;

— off-site effects, including transboundary, andcumulative effects, should be addressed.

EIA as management tool

Like economic analysis and engineering feasibil-ity studies, EIA is a management tool for officialsand managers who must make important decisionsabout major development projects. All develop-ers are familiar with economic and engineeringstudies. Those tools provide the basis for design-ing robust, economically viable projects. EIA isnow seen as an equally important tool in design-ing a viable project. Figure 1 illustrates a generalproject cycle, showing when and how, an EIA cancontribute positively to the project cycle’s progress(Ross, et al., 1994).

In recent years, major projects have encoun-tered serious difficulties because insufficient atten-tion has been taken of their relationship with

Site selection, environmental screening, initial assessment, scoping of significant issues

Pre-feasibility

Project Concept

Monitoring and Evaluation

Implementation

Feasibility

Monitoring and post-auditing, lessons for future projects

Implementation of mitigation measures andenvironmental strategy

Detailed design of mitigation measures

Detailed assessment of significant impacts, identification of mitigation needs, input to cost benefit analysis

Figure 1. Project Cycle, showing when, and how environmen-tal impact assessment (EIA) can contribute positively to thecycle’s progress.

the surrounding environment. Some projects havebeen found to be unsustainable because ofresources depletion. Others have been abandonedbecause of public opposition, financially encum-bered by unforeseen costs, held liable for damagesto natural resources, and even been the cause ofdisastrous accidents.

EIA status in Egypt

The EEAA (1994) has been taking a proactiveapproach in working with entities concerned withthe EIA since bringing Law 4/1994 into forcein 1995. The law mandates the use of the EIAprocess in the context of licensing new, expan-sion, or rehabilitation projects as specified in theLaw’s Executive Regulations. The principles, pro-cedures, guidelines, and other operational detailswere prepared. The Executive Regulations relat-ing to Law 4 identifies establishments or projects,which must be subjected to an EnvironmentalImpact Assessment, based upon the followingmain principles:

— type of activities performed,— extent of natural resources exploitation,— location,— type of energy used to operate.

Three categories, based on different levels ofEIA required, and according to severity of pos-sible environmental impact, were identified as fol-lows: white list projects for establishments withminor environmental impact, gray list projectsfor establishments which may result in substan-tial environmental impact, and black list projectsfor establishments, which require full EIA due totheir potential impact.

It is worth mentioning, however, that the EIAprocess in Egypt has severe limitations as a toolfor ensuring that environmentally sound prac-tices are followed. The scope of review is lim-ited to the EEAA, which may lack the technicalskills to evaluate site impact or other remedies.A broader review process would allow greaterinput from other academic institutes, local gov-ernments, and NGOs; enhance the accountabilityand transparency of the EIA process. Secondly,EIAs are conducted for specific developments.Since many of the environmental impacts result,


not from a single intervention but from the clus-ter of establishments concentrated in an area.Lastly, and most importanty, the EEAA lacksthe resources and technical skills to follow-upand conduct inspections during and following con-struction, to verify that the investor has imple-mented the recommended mitigation measuresand has followed the EEAA recommendationsand/or the plan described in the EIA study (EPIQ,1998).

EIA and sustainable development

The requirement of the State to conduct an EIAin respect to activities that are likely to affectthe environment has been reflected in Princi-pal 17 of the Rio Declaration on Environmentand Development, Article 5 of the Legal Princi-ple for Environmental Protection and SustainableDevelopment, adopted by the Experts Group onEnvironment Law of the World Commission onEnvironment and Development, and in the 1987Goals and Principles of EIA developed underthe auspices of UNEP by the Working Group ofExperts on Environmental Law.

EIA process and sustainableindustrial development

EIA attempts to address how environmental dam-age can be avoided or reduced, so as to ensurethat development initiatives and their benefitsare sustainable. The directive of environmentalmanagement is to achieve the greatest benefitpresently possible for the use of natural resourceswithout reducing their potential to meet futureneeds, and the carrying capacity of the environ-ment. Taking environmental considerations intoaccount in development planning, does not implythat the pace of socio-economic progress will beslowed down, and taking environmental consider-ations into account in the various phases of theproject cycle must not be seen as placing undueconstraints on a country’s development options.

EIA is a process which attempts to identify,predict, and assess the likely consequences (envi-ronmental, social, health impacts) of proposeddevelopment activities (policies, programs, plans

and development projects). Potential problems areforeseen and addressed at an early stage in theproject planning and design. EIA is a planningtool that’s main purpose is to give the environmentits due place in the decision making process byclearly evaluating the environmental consequencesof a proposed activity before action is taken. Theconcept has ramifications in the long run becausesustainable development depends on protectingthe natural resource, which is the foundation forfuture development. Thus, the EIA as a plan-ning tool integrates the basic issues of sustain-able development. For developing countries, EIAsneed to place greater emphasis on poverty andequity issues.

The purpose of environmental assessment pro-cess is: i) to support the goals of environ-mental protection and sustainable development;ii) to integrate environmental protection and eco-nomic decisions at the earliest stages of planningand policy-making; iii) to predict environmental,social, economic, and cultural consequences of aproposed activity, and to assess plans to mitigateany adverse impacts; vi) to provide for the involve-ment of the public, department of the government,and governmental agencies in the review of theproposed activities.

For the EIA to be an effective tool for effec-tive environmental management, it must reflectthe basic components, issues, principles, and con-ditions for sustainable development. In the contextof the system for granting permission for develop-ment, it is important to be aware of the impactsof development on the environment, which maybe irreversible, or very difficult to undo. Trans-lated into the preparation of plans for industrialdevelopment, these issues need to be reflectedin policies and proposals, which make adequateprovision for development, and at the same timetake account of the need to protect the naturaland built environment. EIA is a tool for achievingacceptable forms of environmentally sound indus-trial development.

The Egyptian guidelines issued by the EEAAfor preparing EIA establish a process thatuses a systematic interdisciplinary approach, thatincludes both information gathering and deci-sion making components which provides the deci-sion makers with an objective basis for grantingor denying approval of a proposed development.

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Clearly, the EIA mandate ensures that environ-mental amenities and values are given appropriateconsideration in decision making, along with eco-nomic and technical considerations. To determinewhether the EIA process is a tool for sustainabledevelopment, it is important to analyze the differ-ent aspects of the decision making process. Theseinclude:

— the criteria for accepting an EIA;— evaluation of criteria;— requirements for decision making;— how to ensure that the project after implemen-

tation achieves sustainable development.

The criteria for accepting an EIA

EIA offers a holistic perspective to development—it addresses the environment as a whole system aswell as its components:

— the natural environment—including resources,processes, and effects related to flora andfauna, human beings, minerals, water, land, air,etc.

— the built environment—including resources,processes, and effects related to buildings,housing, roads, railways, electricity, water sup-ply, etc.

— socio-economic environment—including re-sources, processes and effects related tohuman activities, education, health, culture,economic and business, heritage, etc.

The EIA attempts to address the interde-pendencies of the three components in thedevelopment of a project that is environmen-tally sustainable. The EIA considers economicdevelopment and non-market activities that con-tribute to human/social well being, which aremajor components of sustainable development.The criteria for EIA acceptance/approval actuallyreflects the importance of both economic develop-ment, and preservation of the present and futureenvironment.

The development criteria can be dividedinto:

— land use: land use and development impactsare closely interrelated to neighborhoodimpacts and economic effects. For this reason,

the discussion of land-use and developmentimpacts is often combined with communityeffects, relocations, and economic effects,under an umbrella term of socio-economicimpacts.

— social effects: the evaluation of social and eco-nomic impacts is an important part of everyassessment. The analysis of these effects isclosely related to the analysis of land-use,development and economic impacts.

— economic effects: economic development indi-cators are clearly similar to sustainable devel-opment indicators such as:

— employment and income,— taxes, revenues, and expenditures,— land values,— existing business community.

The criteria for preserving the physical environ-ment can be described as:

— preserving historic and archaeological re-sources: this criterion helps protect historicand archeological sites from physical destruc-tion, as well as the interaction of visual, audibleor atmospheric elements that are out of char-acter with the property, or alter its setting.

— air quality, water quality, soil, and noise: thecriteria for air, water, soil, and noise pollutionare set in relation to relevant environmentallaws. These laws also protect the present envi-ronment from toxic and hazardous materialsand wastes, and provide regulations for thesafe use, transportation, and storage of suchmaterials.

— human health, vegetation, and wild life: thecriteria for human health include potentialimpacts related to hazardous materials, toxicsubstances, workers safety, and risk of upset.The assessment of vegetation and wildlifeimpacts focuses on threatened or endangeredspecies protected by law.

Evaluation of criteria

The EIA process adopts a time horizon longenough to capture both human and ecosystemtime scales, thus responding to needs of futuregenerations, as well as those current to short termdecision making. The EIA must be based on a


sound understanding of current conditions andanticipated future conditions.

EIA must be based on openness—the methodsand data used in the EIA must be accessible andtransparent to all. The EIA design must allow forensuring the participation of local communities,and all stakeholders. The evaluation of the crite-ria must take into consideration important aspectsof sustainable development, which are the cumula-tive and future effects of the activity. The impactsare weighted according to:

— the reversibility of the effect,— whether the impact is direct or indirect,— whether it is local or regional,— whether it is short-term or long-term,— whether it impacts humans, animals, or plants.

Requirements for decision making

For an EIA to be a tool for sustainable develop-ment, the following requirements are essential:

Information system and environmental indicators.Decisions about development must be based onreliable information about the state of the envi-ronment, and factors that impact on it, includingrelative risks, and the costs and benefits of ame-liorating any adverse impacts. Indicators are clearand transparent ways of presenting environmen-tal issues, and measuring whether development isbecoming more sustainable or not.

Agenda 21 recognized the priority to strengthenthe information systems needed to formulate asustainable way of development. Major efforts arecarried out by international organizations calledthe European System of Environmental PressureIndices. The principle objective is to give a com-prehensive description of environmental harmfulhuman activities (pressures) in physical units atthe aggregation level of policy field, such as cli-mate changes and dispersion of toxic substances.

Since the Earth Summit in 1991, many coun-tries and international organizations, such asthe Organization for Economic Cooperation andDevelopment (OECD, 1994), have been work-ing to develop indicators. More recently the UNCommission on Sustainable Development and theWorld Bank (World Bank, 1995) have produceddraft frameworks for indicators. While much of

the earlier work focused on environmental indi-cators, countries, and international organizationsare increasingly working to develop sustainabledevelopment indicators. However, there is, as yet,no consensus about what indicators should beincluded. Views vary from country to countrydepending on the stage of development, and thetype of economic and environmental problemsfaced. The OECD published a core set of envi-ronmental indicators in 1993 (Fig. 2). In 1999, theEuropean Commission published the EuropeanSystem of environmental pressure indices (EPI,1999).

The use of indicators offers distinct possibili-ties, since the three main functions of indicators:quantification, simplification, and communicationcontribute significantly to the assessment andaccessibility of environmental issues and infor-mation (Bell and Morse, 1999). Indicators high-light the main issues, and help both policy-makersin making decisions, and helping the public tounderstand them. Simply, they are quantifiedinformation, which help to explain how things arechanging over time.

Sustainable development is a very complex con-cept that involves many interactions between theenvironment and socio-economic activity. One ofthe ways to simplify and structure the issues andinteractions, is to apply integrated models andscenario analysis. There are a number of fac-tors, which may influence the accuracy of theresults of model-based-assessment: gaps in knowl-edge, related deficiencies in the structure of themodels, and limited reliability of available data(Hatcher, 1999). However, there are continuousefforts towards improving the systematic assess-ment of both current and future risks to the envi-ronment and development (Bakkes, 1994; Bakkesand van Woerden, 1997). The general approach isa systems analysis of environmental changes thatresult from interactions between human and envi-ronmental systems. The use of indicators is oneway of ensuring that the social, economic, andenvironmental aspects of development are, as faras possible, brought into the analysis. In order tostructure the interaction between human and envi-ronmental systems, the dynamic nature of theseinteractive systems are assessed within a drivingforce—pressure—state—impact—response frame-work (Fig. 3).

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OECD ENVIRONMENTAL INDICATORS

Reviewing

Environmental Performance

Monitoring Progress towards Sustainable Development

UN Commission

Indicators For the

Integration of

Environmental &Economic

Concerns into Sustainable

Development Policies

Sustainable Development

Indicators

Indicators For the

Integration of

Environmental Concems

Into Economic Policies

Environmental Accounting

Indicators For the

Integration of

Environmental Concems

Into Sectoral Policies

Sectoral Indicators

Indicators For

Tracking Environmental

Progress

Core Set of Environmental

Indicators

Figure 2. Types of environmental indicators.

Actions

State of the Environment

and of Natural Resources

Air

Water

Land

Natural Resources(Impact)

PRESSURES STATE RESPONSES

Human Activities

Wastes

Transport

Industry

Agriculture

Others

Economic and Environmental Agents

Administrations

Seeking Fund

Enterprises

Taxes

Societal Responses (Decisions - Actions)

Societal ResponsesDecisions - Actions)

Pressures

Information

Resources

Figure 3. The indicator’s framework.


Originally, the driving force—pressures—state—impact—response (DFPSI) framework wasused to develop environmental indicators, andthen adjusted to develop sustainable developmentindicators. According to the DFPSI model, sectorsof the economy generate wealth and welfare forhouseholds, enterprises, government, and otheractors in the country and overseas. Economicactivity, and indeed households themselves, canhowever, create pressure on the environmentthrough consumption of resources and outputof pollutants. The quality of the environment,in turn, can impact on the welfare of house-holds, individuals, and other actors. The actorsrespond to changes in the state of the economyand the environment, through behavioral andpolicy changes, which either directly affect theenvironment, or alter the pressures on it fromthe economic sectors. Responses which constrainthe activity of the economy in order to protect theenvironment, may also be regarded in some casesas pressures, since they may reduce the abilityof these sectors to generate wealth and welfare,and this, in turn, may inhibit the development ofsolutions to environmental problems.

Reporting on the state of environment in Egypt. TheEEAA is mandated to prepare an annual State ofthe Environment Report that is presented to thePresident, the Cabinet of the Ministers, and thePeople’s Assembly. This report mainly addressesthe current state of environment by theme, such aswater resources, domestic and industrial wastewa-ter, solid waste, etc. Basic information about thepresent state of the environment should be avail-able for each region.

There should be a database at the nationallevel, divided into zones, and available to the EIAteam and decision makers. The preparation of theEIA itself will be a source of information throughmeasurements, analyses, and social studies. Thisinformation can be fed-back into the technicaldatabase and used for other studies. Recently,mathematical models have been developed to pre-dict air and water quality resulting from pointsource pollutants. These models can be used topredict impacts after the implementation of theproject.

Laws and regulations

Egyptian environmental legislation has evolvedwith little consideration of the existing techni-cal, financial, legal, and administrative implica-tions of the actions to be adopted. Little emphasishas been given to issues, such as environmentalrisks and costs, variations in environmental per-formance, and carrying capacity (existing pollutionlevels of ambient water and air quality). Littleis known about the economic and social costsfor environmental compliance in Egypt (Gomaa,1997).

Because Egypt’s overall environmental pro-gram is new, the country lacks effective environ-mental policy instruments. Most of the regulatoryprocess is based on pollution discharge sanctions.Point polluters are held responsible for keepingpollution discharges below a standard, which gen-erally refers to international pollution standards.This approach is not effective, because standardsgenerally do not allow the flexibility necessaryfor the polluter and the GOE regulatory agencyto negotiate quick agreement on a complianceschedule. Instead, Egyptian regulators concentrateon informing the polluter of a violation—but thereare no provisions for phasing in compliance mea-sures after the violation has been announced.

The substance of Egyptian environmental reg-ulations may be described in the following:

— general and emission-limit based (concentra-tions of various pollutants) with no considera-tion to variable ambient carrying capacity.

— Egyptian regulations have evolved withoutconsideration of the many factors that influ-ence the firm’s environmental decisions. Reg-ulations are not sensitive to the wide variationsamong sectors, industries, and even variousestablishments within the same industrial clas-sification.

— not site-specific or reach specific (with fewexceptions), and not linked to any land useplanning regulations. In Holland, environ-mental impacts are recognized on five levels,namely: global, continental, fluvial, regional/eco-districts, and local.

— based on inadequate environmental informa-tion data with no built-in feedback system.

— has not integrated, as yet, the available know-how in regulatory development. The whole

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world is approaching environmental manage-ment in terms of best available technology(BAT), pollution abatement, monitoring, andwaste minimization. This new focus is drivenby advancements in technology. Legislation, asall other disciplines, has become a technol-ogy (know-how) that is utilizing technologicalapplications in many fields (economics, engi-neering, social sciences, finance, etc.).

For the EIA to reflect sustainable development,the laws and regulations must also do so.

Egyptian environmental regulations only setlimits for pollutants concentration. The commuta-tive effect of these pollutants is not considered.The intensity of pollution should be described,not only by the pollutant’s concentration but alsoby its load. Small quantity generators cannot beequated to large polluters. The law also disregardsthe carrying capacity of regions at the present, andas a cumulative impact in the future, which is arequirement for sustainable development.

Carrying capacity and ecological zones

In the siting of development, both governmentand industry must have clear information of thecharacteristics of the various ecosystems and thedifferential impact of development on these sys-tems. Development and delineation of ecologicalzones is one tool that ensures that environmentalconsiderations are taken by both government andindustry in the siting of development (Rees andWackemagel, 1994).

There is a general consensus in Egypt onthe importance of knowing the characteristicsof the various ecosystems, and how currentand future development (industrial, agricultural,tourism, etc.) will impact these systems. Variousorganizations (General Organization for PhysicalPlanning, Drainage Research Institute, Ministry ofPlanning, etc.) have developed baseline maps forEgypt for various purposes. There are also variousattempts towards regionalization. However, thereis little integration among these various organi-zations, and their respective mapping and zoningefforts. Moreover, delineation of ecosystems is toogeneral to allow for the site-specific characteriza-

tion necessary for both siting of development, andrelated environmental impact assessments (Gaberand Baker, 1998).

There is a wealth of international experienceand effort in the development of ecological zonesthat help decision makers better understand theenvironmental characteristics in a zone/site, itspollution receiving potential, existing environmen-tal risks, and the differential potential impact ofdevelopment on its ecosystem. It is important tonote that while ecological maps deal with themacro-level, they do not eliminate the need formicro-level investigations of environmental risks.

The development of an ecological map forEgypt requires the participation of almost allagencies and organizations dealing with develop-ment and the environment in Egypt. Of particu-lar importance is the assimilation and integrationof all current mapping efforts and existing envi-ronmental and physical land use data, in addi-tion to development plans prepared by the variousministries:

— Definition and mapping of Ecological Zonesfor Egypt which are properly linked with acces-sible and updated environmental data. Thisinformation will provide base-line data for car-rying the mandated EIA for new projects.

— Development of Zoning Maps that definesuitable areas/unsuitable for siting of variousindustries, as well as other land uses basedon the carrying capacity of the various Eco-systems. A Zoning Atlas for Egypt would aiddevelopers and industrialists in the properplanning and implementation of large indus-trial estates, and the selection of the most suit-able industries for investment.

— Egyptian regulatory and environmental insti-tutions must work towards establishing emis-sions/effluent standards that are industry andlocation specific for the various ecologicalzones. Ecological zones could serve as a majorpolicy tool in the establishment of environmen-tal regulations for various industries located inecologically different areas. This information isparticularly important in influencing the envi-ronmental decisions of economic enterprises.


EIA

EIA Accepted + EIA Accepted-------- = Environmental disasterIf not Considering the Region’sCarrying Capacity

Sustainable Developmenton the Regional Level

Sustainable Developmenton the National Level

Sustainable Developmenton the Project Level

Figure 4. System theory and levels of decision-making.

Maintaining sustainable developmentafter project implementation

Even if a decision has been made to accept aproject that agrees with the criteria for sustain-able development, there has to be some proce-dures to make sure that all mitigation measureswill be implemented during operation. This canbe achieved by linking the license granting withthe actual implementation of these measures. Itis also important to have the EIA document asan integral part of the license application docu-ments, and make it available to the inspectors dur-ing their annual inspection visits.

Post—project analysis in EIA. One of the cost-effective tools, not only for improving EIA, butalso to secure sustainability of the project is post-project analysis (PPA). PPAs are environmen-tal studies undertaken during the implementationphase of a given activity. PPAs may be undertakento ensure the implementation of the activity inaccordance with the terms imposed by the EIAStudy, or to learn from the particular activity beingstudies (UN, 1990).

In fact, EIA-Egyptian Guideline is lacking theconcept of PPA. Accordingly, there is no monitor-ing or follow-up for environmental consequencesor mitigating measures implementation.

System theory and levels of decision-making.According to the system theory, the properties ofa system are not the sum of the properties of the

elements that constitute that system. The interac-tion between the elements can make the overallproperty of the system either higher, or lower,than the collective properties of the elements.Applying this concept to the EIA review process,a number of approved EIAs in a neighboring loca-tion can lead to a polluted region (Fig. 4).

Alternatives that are compared on a regionallevel can give better solutions than local alter-natives. As an example, a WWTP can representan attractive solution of wastewater treatment foreach village. However, the cumulative effect of anumber of such plants could cause serious envi-ronmental problems. Another solution could existif a whole region is considered. It is, therefore,important that an EIA be conducted as a part ofa strategic plan on the regional level (ChemonicsEgypt, 1998).

Sustainable developmentin developing countries

Sustainable development set new challenges todeveloping countries. Developing countries arguethat they cannot be expected to divert resourcesfrom survival needs to take care of important, butless pressing, environmental matters. Clearly, thelevel and pace of socio-economic advancement indeveloping countries has important implicationsfor the efficacy with which legislature and insti-tutional structures are developed and applied forthe promotion of environmental management:

— the imperative of rapid social and economicdevelopment could influence the political will

68 Wahaab

to initiate, implement, and enforce appropriateenvironmental policies and laws;

— the development imperatives often define thelimits of resources available for environmentalprotection;

— implementing agencies often operate undersevere resource constrains;

— the relatively low levels of public awareness,particularly environmental awareness, does lit-tle to trigger a sense of urgency and resolve forpolitical and legislative action for environmen-tal management for sustainable development;

— the desire to satisfy basic social need couldvery well override even basic environmentalconsiderations.

Thus developing countries, from the authorpoint of view, experience a bigger conflict betweendevelopmental and environmental goals. Somedecisions will favor economic growth over environ-mental protection. This becomes evident in caseswhere large national projects are considered likethe Toshki Project in the south of Egypt, for whichno EIA was performed. However, even when adecision has been made to favor economic growthover the environment, the EIA should be under-taken to plan for mitigating measures to deal withthe consequences of the decision made.

Other planning issues that should be consid-ered in developing countries include:

Industries of political and strategic importance.There are some very large basic industries thatprovide inputs to other industries, such as the Ironand Steel Company, the Coke Company, the Alu-minum Company, the Textile Company, etc. Theseindustries are characterized by their very high cap-ital investments, low rate of return, and high laborintensity. Applying the current regulations to theseindustries will not solve the environmental prob-lems, whereas closure will create other types ofsocial and political stresses.

With respect to new developments with thesame socio-economic and political importance,special arrangements can be made, so that rea-sonable surcharges are paid for the environmentalviolations.

Zoning and carrying capacity. Before performingthe EIA for a project in a specific area, thereshould be criteria for the zone in which the projectis planned.

Failures of inadequate planning. An important fea-ture of the industrialization in Egypt during 1960swas the construction of new industries in themetropolitan areas along the Nile: North andSouth Cairo, particularly in Helwan and ShoubraEl-Keima, Kafr El-Zayat, and Talkha, and inAlexandria. Inadequate attention was paid tothe long-term issues of environmental deterio-ration (El-Gohary, 1993). Those are clear casesof resources depletion, and hence unsustainabledevelopment.

Pollution prevention and cleaner production. Pollu-tion prevention and cleaner production measuresdeal with pollution at its source. Since pollutionis regarded as escaping raw materials, chemicals,and products, any pollution minimization repre-sents an economic gain to the facility manage-ment, unless the implemented measure is not costeffective. With respect to the existing Egyptianindustry, pollution is mainly due to the use of oldtechnologies, and to maintenance and repair prob-lems. In addition, use of non-biodegradable sub-stances during industrial processes (which will notdecompose or get eliminated from the environ-ment). The residues of those chemicals are con-centrated through the food chain, with minutequantities magnified thousands of times (AbdelWahaab, et al., 1995).

Accordingly, the EIA for new industrial facili-ties should emphasize the implementation of thesepreventive measures. In addition, a clear vision ofthe biodegradation lines and toxicological impactof the new synthetic compounds commonly usedin industries shall be identified, assessed, andlabeled. The limits of these criteria should be partof the environmental law.

Best available technology (BAT) and the Egyptianregulations. Limits of pollutant concentration thatcan be allowed by environmental laws are relatedto the level of technology that is currently avail-able at an affordable cost. A decade ago, the lim-its for lead emissions in the air were much higher,as unleaded gasoline was not then available.

Egypt cannot regulate emissions taking intoconsideration the best worldwide available tech-nology, which can be prohibitively expensive. Onthe other hand, lowering the criteria to allow theoperation of obsolete and polluting equipment is


not acceptable. The best available technology forEgypt and related pollution limits should be spe-cific to each industry.

Successful trials have been made by the WaterPollution Research Department of the NationalResearch Center to develop, not only appropri-ate technologies for wastewater treatment, butalso low cost technologies to assure sustain-ability of the systems (El-Gohary et al., 2000).Another success story, was documented about theimplementation of a small flow wastewater treat-ment technology for rural Egypt (Gaber et al.,1993).

References

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