021 Air Qual Standards-Loeb

Task Order Number 832
Contract Number
PCE-I-00-96-00002-00
Egyptian Environmental Policy Program

Program Support Unit
CONSIDERATIONS FOR REVISING

AIR QUALITY STANDARDS IN EGYPT
Alan P. Loeb, Esq.
April 2001
PSU-21f
for
U.S. Agency for International Development, Cairo
and
Egyptian Environmental Affairs Agency
prepared under the

Environmental Policy and Institutional Strengthening
Indefinite Quantity Contract (EPIQ)
A USAID-funded project consortium led by International Resources Group, Ltd.

Fact Sheet
USAID Contract No.: PCE-I-00-96-00002-00
Task Order No. 832
Contract Purpose: Provide core management and analytical technical services to the
Egyptian Environmental Policy Program (EEPP) through a Program
Support Unit (PSU)
USAID/Egypt’s Cognizant Technical Officer: Anne Patterson/Holly Ferrette
Contractor Name: International Resources Group, Ltd.
Primary Beneficiary: Egyptian Environmental Affairs Agency (EEAA)
EEAA Counterpart: Ahmed Gamal Abdel-Rhiem
Work Assignment Author: Alan Loeb
Work Assignment Supervisor: David Colbert/Michael Colby

About the Author
Alan P. Loeb, J.D. M.P.A., is an attorney specializing in energy and the environment and a professor of
environmental studies at Johns Hopkins University. Previously Mr. Loeb served as an analyst at
Argonne National Laboratory, with clients such as the United States Department of Energy,
Environmental Protection Agency, and individual states. Mr. Loeb also practiced law with the energy
law firm Morley Caskin in Washington, D.C., and served as Senior Attorney at the U.S. Environmental
Protection Agency. He is a frequent advisor to federal agencies and international organizations on
environmental issues and regulations. He has authored or contributed to more than 50 articles, papers,
and reports in both specific and general areas of environmental law, policy, and economics. Mr. Loeb
attended Harvard University and Tulane Law School, receiving his law degree in 1979. He is licensed
to practice law in both Louisiana and Washington, D.C.
Alan P. Loeb, Esq.

18 9th Street, N.E.
Washington, D.C. 20002
202/544-7920
e-mail: loeb.alan@prodigy.net
ii
Table of Contents
List of Tables ..................................................................................................................................... v

Foreword........................................................................................................................................... vi
Acronyms and Abbreviations............................................................................................................ vii
Summary............................................................................................................................................ 1
1. Introduction .................................................................................................................................... 5
1.1 Tasks Covered ........................................................................................................ 5
1.2 Target Air Pollution Problems in Egypt .................................................................. 7
2. Comparison of Pollutant Standards ................................................................................................. 9
2.1 Survey of World Air Pollution Standards ................................................................ 9
2.2 Survey of World Ambient Air Quality Standards .................................................... 9
2.2.1 Conventional Pollutants: Health-based Ambient Air Quality,
Visibility, and Acidification .....................................................................10
Standard Level Concentrations ........................................................... 10
2.2.2 Hazardous Air Pollutants .........................................................................13
2.3 Survey of World Stationary Source Emission Standards ........................................14
2.3.1 Comparison of Programs..........................................................................15
2.3.2 Qualitative Observations on the Egyptian Stationary Source Emission
Standards .................................................................................................16
2.3.3 Views about the Egyptian Emission Standards .........................................17
Stringency of the Standards................................................................ 17
2.4 Survey of World Mobile Source Emission Standards .............................................18
2.4.1 Vehicle Emission Standards .....................................................................18
Other Observations ........................................................................... 20
2.4.2 Fuel Standards ........................................................................................21
2.5 General Comments on the Standards......................................................................22
2.5.1 Relationship of Emission and Ambient Standards ....................................22
2.5.2 Guidance for Formulating New Standards:
Targets and Timetables ............................................................................23
2.5.3 Air Quality and Public Opinion................................................................26
2.6 Process: The Need for Regular Review and Revision of Standards.........................28
3. Observations on Administration of the Air Pollution Program ......................................................29
3.1 Administration of the Air Pollution Law ................................................................29
3.1.1 Procedures ...............................................................................................29
3.1.2 Staff and Resources..................................................................................29
3.1.3 Proposal for a Permit System ...................................................................30
3.2 Development of Sound Methodologies ..................................................................30
3.2.1 Basis for the Standards.............................................................................30
3.2.2 Methods for Testing and Compliance.......................................................31
4. Conclusions and Recommendations...............................................................................................32
4.1 The Cautious Approach .........................................................................................32
4.2 Practical Steps .......................................................................................................32
Appendix A: The Egyptian Air Quality Program ............................................................................ A-1
A.1 Background: Egyptian Environmental Laws ....................................................... A-1
A.1.1 Prior Efforts to Address Environmental Issues ...................................... A-1
A.1.2 The 1994 Environmental Law ............................................................... A-1
iii
EEAA Powers .................................................................................A-1
A.2 Air Pollution Standards under Law 4/1994.......................................................... A-2
A.2.1 Health-based Ambient Air Quality Standards........................................ A-2
A.2.2 Stationary Source Emission Standards .................................................. A-3
A.2.3 Mobile Source Emission Standards ....................................................... A-6
Appendix B: U.S. Air Quality Standards..........................................................................................B-1
B.1 Development of U.S. Air Quality Regulation .......................................................B-1
B.2 Structure of U.S. Air Quality Regulation.............................................................B-2
B.3 Air Quality Standards ..........................................................................................B-4
B.3.1 Health-based Ambient Air Quality Standards.........................................B-4
National Ambient Air Quality Standards.......................................B-5
B.3.2 Visibility Standards................................................................................B-6
B.3.3 Hazardous Air Pollutants .......................................................................B-7
Regulation of HAPs under the 1990 Amendments ........................B-9
B.4 Stationary Source Emission Standards ...............................................................B-10
B.4.1 New Sources........................................................................................B-10
B.4.2 Existing Sources ..................................................................................B-14
B.5 Mobile Source Emission Standards ....................................................................B-15
B.5.1 Vehicle Emission Standards .................................................................B-15
B.5.2 Fuel Standards .....................................................................................B-18
Appendix C: European Union Standards..........................................................................................C-1
C.1 Ambient Air Quality Standards ............................................................................C-1
C.2 Stationary Source Emission Standards .................................................................C-1
C.3 Mobile Source Emission Standards ......................................................................C-1
C.3.1 Vehicle Emission Standards ...................................................................C-1
C.3.2 Fuel Standards .......................................................................................C-3
Appendix D: Standards Issued by International Organizations ........................................................ D-1
D.1 World Health Organization ................................................................................. D-1
D.2 Financial Institutions........................................................................................... D-2
D.2.1 The World Bank Group......................................................................... D-3
D.2.2 Regional Development Banks ............................................................. D-10
D.3 Trade Assistance Organizations ........................................................................ D-11
D.4 World Trade Organization ................................................................................ D-11
D.5 International Organization for Standardization.................................................. D-11
Appendix E: Meetings and Interviews .............................................................................................E-1
Technical Glossary ...............................................................................................................Glossary-1
iv
List of Tables
Table 1. Summary of World Air Pollution Standards.................................................................................... 9
Table 2. Comparison of Health-based Ambient Air Quality Standards ...................................................... 10
Table 3. Comparison of Hazardous Air Pollutant Standards....................................................................... 14
Table 4. Comparison of Standards for Gasoline-fueled Passenger Cars ..................................................... 19
Table 5. Comparison of Fuel Standards for Gasoline-fueled Passenger Cars............................................. 21
Table A.1. Law 4/1994 Executive Regulations, Annex No. 5:
Maximum Limits of Ambient Air Pollutants..................................................................................... A-3
Table A.2. Law 4/1994 Executive Regulations, Annex 6, Table 1: Overall Particles.............................. A-4
Table A.3. Law 4/1994 Executive Regulations, Annex 6, Table 2: Maximum Limits of
Gas and Fume Emissions from Industrial Establishments................................................................. A-4
Table A.4. Maximum Limits on Emission from Fuel-burning Sources.................................................... A-5
Table A.5. Egyptian Vehicle Emission Standards ..................................................................................... A-6
Table B.1. Conceptual Organization of the Clean Air Act (as amended 1970) ........................................ B-3
Table B.2. Conceptual Organization of the Clean Air Act (as amended 1990) ........................................ B-3
Table B.3. National Ambient Air Quality Standards (as amended 1997) ................................................. B-6
Table B.4. Hazardous Air Pollutants and Source Categories Established
by November 15, 1990 ....................................................................................................................... B-8
Table B.5. NSPS Issued for Select Source Categories............................................................................. B-10
Table B.6. Tailpipe Standards for Gasoline-Powered Vehicles, 1977-1993........................................... B-15
Table B.7. Tier 1 Tailpipe Standards for Vehicles Beginning 1994 ....................................................... B-16
Table B.8. Tier 2 Light-duty Full Useful Life Exhaust Emission Standards.......................................... B-17
Table C.1. EU Ambient Air Quality Standards.......................................................................................... C-1
Table C.2. EU Standards for Passenger Cars ............................................................................................. C-2
Table D.1. WHO Ambient Air Quality Guidelines.................................................................................... D-1
Table D.2 WHO Other Pollutants Proposed for Standards by EU............................................................ D-2
Table D.3. World Bank Air Emission Guidelines: Parameters and Maximum Values ............................ D-5
v
Foreword
Through competitive bidding, the United States Agency for International Development (USAID) awarded a multi-
year contract to a team managed by International Resources Group, Ltd. (IRG) to support the development and
implementation of environmentally sound strategic planning, and strengthening of environmental policies and
institutions, in countries where USAID is active. Under this contract, termed the Environmental Policy and
Institutional Strengthening Indefinite Quantity Contract (EPIQ), IRG is assisting USAID/Egypt with implementing
a large part of the Egyptian Environmental Policy Program (EEPP).
This program was agreed to following negotiations between the governments of the United States, acting through
USAID, and the Arab Republic of Egypt, acting through the Egyptian Environmental Affairs Agency (EEAA) of
the Ministry of State for Environmental Affairs, the Ministry of Petroleum’s Organization for Energy Planning,
and the Ministry of Tourism’s Tourism Development Authority. These negotiations culminated with the signing of
a Memorandum of Understanding in 1999, whereby the Government of Egypt (GOE) would seek to implement a
set of environmental policy measures, using technical support and other assistance provided by USAID. EEPP is a
multi-year activity to support policy, institutional, and regulatory reforms in the environmental sector, focusing on
economic and institutional constraints, cleaner and more efficient energy use, reduced air pollution, improved solid
waste management, and natural resources managed for environmental sustainability.
USAID has engaged the EPIQ contractor to provide Program Support Unit (PSU) services to EEPP. The PSU has
key responsibilities for providing overall coordination of EEPP technical assistance, limited cross-cutting expertise
and technical assistance to the three Egyptian agencies, and most of the technical assistance that EEAA may seek
when achieving its policy measures.
The EPIQ team includes the following organizations:
• Prime Contractor: International Resources Group
• Partner Organization: Winrock International
• Core Group:
- Management Systems International, Inc.
- PADCO
- Development Alternatives, Inc.
• Collaborating Organizations:
- The Tellus Institute
- KBN Engineering & Applied Sciences, Inc.
- Keller-Bliesner Engineering
- Conservation International
- Resource Management International, Inc.
- World Resources Institute’s Center For International Development Management
- The Urban Institute
- The CNA Corporation.
For additional information regarding EPIQ and EEPP-PSU, contact:
United States of America: Egypt:
EPIQ Prime Contractor EEPP-PSU
International Resources Group, Ltd International Resources Group, Ltd
1211 Connecticut Ave, NW 21 Misr Helwan Agricultural Road
Suite #700 Office 62, 6th Floor
Washington, DC 20036 Maadi, Cairo
Telephone: (1-202) 289-0100 Telephone: (20-2) 380-5150
Facsimile: (1-202) 289-7601 Facsimile: (20-2) 380-5180
Contact: Douglas Clark Contact: Harold van Kempen
vi
Acronyms and Abbreviations
ADB Asian Development Bank GHG greenhouse gases
AfDB African Development Bank GJ/hour Giga Jjoules per hour
Amer. America or American GOE Government of Egypt
As arsenic gpl grams per liter
Assns. associations gpm grams per mile
BACT best available control technology GVWR gross vehicle weight rating
BAT best available technology H2SO4 sulfuric acid
BS black smoke HAP hazardous air pollutant
C carbon HC hydrocarbon
C.F.R. Code of Federal Regulations HCl hydrochloric acid
CAAA Clean Air Act Amendments of 1990 HEW U.S. Department of Health,
CAIP Cairo Air Improvement Project Education, and Welfare
CASAC Clean Air Science Advisory HF hydrogen fluoride
Committee Hg mercury
Cd cadmium HLDT1 heavy light-duty truck category 1
Cl chlorine HLDT2 heavy light-duty truck category 2
CNG compressed natural gas hr hour
CO carbon monoxide IDB Inter-American Development Bank
CO2 carbon dioxide IFC International Finance Corporation
Cu copper ILO International Labor Organization
D.C. Cir. Federal Circuit Court for IQ intelligence quotient
Washington, D.C. ISO International Organization for
D.C. District of Columbia (Washington, Standardization
D.C., U.S.) Jan. January
D.D.C. Federal District Court for Jul. July
Washington, D.C. kg kilogram
D.O.E. U.S. Department of Energy kg/t kilogram per ton
Dec. December km kilometer
EA environmental assessment LAER lowest achievable emission rate
EBRD European Bank for Reconstruction lb pound
and Development
LDT1 light duty truck category 1
EC European Community
LDT2 light duty truck category 2
EEAA Egyptian Environmental Affairs
Agency LDV light duty vehicle (passenger cars)
EIA Environmental Impact Assessment LEV low emission vehicle
EMS Environmental Management System LEV2 phase 2 LEV
EPAP Egyptian Pollution Abatement LRTAP Long-range Transport of Air
Project Pollutants (treaty)
EPIQ Environmental Policy and LT long ton (2,240 lbs.)
Institutional Strengthening LVW loaded vehicle weight
Indefinite Quantity Contract m, m3 meter, cubic meter
et al. et alii (and others) MACT maximum achievable control
et seq. et sequens (and the following one or technology
ones) Mar. March
EU European Union max maximum
F fluorine MCW municipal waste combustor
F. Supp. Federal Supplement mg milligram
FCC fluid catalytic cracker mg/dscm milligram per dry cubic meter at
Fed. Reg. Federal Register standard conditions
FGD flue gas desulfurization mg/Nm3 milligram per normal cubic meter
g/hr grams per hour mgms milligrams
g/km grams per kilometer MIGA Multilateral Investment Guarantee
g/m grams per mile Agency
g/MJ grams per mega joule ML/gallon mililiter per gallon?
vii
mmBtu million British thermal unit SIP State Implementation Plan
MT Montana SO2 sulfur dioxide
MW megawatts SO3 sulfur trioxide
MWe megawatts of electricity SOx sulfur oxides
MY (vehicle) model year Stat. U.S. Statutes at Large
NAAQS National Ambient Air Quality SULEV Sports utility LEV
Standards TOC total organic compounds
NESHAPS national emission standards for TSP total suspended particulates
hazardous air pollutants TW test weight
Ni nickel U.S. United States
NMHC non-methane hydrocarbons U.S.C. United States Code
No. number UK United Kingdom
NO2 nitrogen dioxide ULEV, ULEV 2 Ultra-low emission vehicle
NOx nitrogen oxides UN ECE United Nations Economic
NSPS New Source Performance Standards Commission for Europe
NSR New Source Review UN United Nations
NTE not to exceed USAID United States Agency for
O3 ozone International Development
OPIC Overseas Private Investment U.S. EPA United States Environmental
Corporation Protection Agncy
PAH poly-aromatic hydrocarbons v. versus
Pb lead VOCs volatile organic compounds
PM, PM10, PM2.5 particulate matter; particulates vol. volume
with an aerodynamic diameter of 10 WHO World Health Organization
(or 2.5) microns or less wt. weight
ppb parts per billion WTO World Trade Organization
ppm parts per million yr year
ppmv parts per million by volume Zn zinc
PRIDE Project in Development and the
Environment
_g/dl microgram per deciliter
PSD prevention of significant
deterioration _g/m3 microgram per cubic meter
Pub.L. public law _m micron
reg-neg regulatory negotiation process § section
RFG reformulated gasoline > is greater than
SD South Dakota < is less than
> is greater than or equal to
viii
Summary
The United States Agency for International Development (USAID) has a long-standing interest in
environmental issues in Egypt. From the 1980s to the mid-1990s its undertakings were primarily
building and rehabilitating infrastructure such as water and wastewater treatment plants and networks.
Concern shifted in the early 1990s to areas of the country outside the two urban centers of Cairo and
Alexandria. In Greater Cairo, efforts shifted from building infrastructure to institutional development
so the utilities could operate in a more business-like manner, in line with the Government of Egypt’s
(GOE) efforts to de-control the economy.
At the same time, both the GOE and USAID were becoming increasingly aware that urban Cairo was
suffering from ever-increasing pollution, especially air pollution. USAID funded several short-term
efforts to assess the situation, including a study in 1994, the Project in Development and the
Environment (PRIDE), which identified the seriousness of public health impacts from air pollution.
USAID and the GOE then laid plans for a massive project to address air pollution—the Cairo Air
Improvement Project (CAIP). CAIP contains a number of discrete projects targeted to specific local
needs.
Given the serious nature of the air quality problems, USAID has instituted a new project under the
Environmental Policy and Institutional Strengthening Indefinite Quantity Contract Program (EPIQ) to
provide resources to address air quality problems in Egypt. USAID is currently funding the Egyptian
Environmental Policy Program (EEPP), which operates at a level aiming to address policies that affect
Egypt’s environment over the long term. The Program Support Unit (PSU) of the EEPP is charged with
completing 14 tasks during its first tranche of operation—among them to assess the air quality
standards set by Egypt in its “Environmental Law” (Law 4 of Year 1994 and Executive Regulations).
As an important step, USAID is providing funding to establish a system for periodic review and
modification of air emission standards, in conjunction with the Egyptian Environmental Affairs
Agency (EEAA).
As part of its efforts, the PSU has prepared an analysis to compare Egypt’s standards with other leading
air quality programs. The analysis surveyed all the significant national and international programs,
focusing on those standards used by the United States of America (U.S.), by the European Union (EU),
and by the World Health Organization (WHO). In addition, a series of meetings was held in Egypt with
key stakeholders (listed in Appendix E) to identify priorities for EEAA’s assessment.
Air pollution standards can be divided into two different categories: air quality standards, and
emission control standards. Because of their fundamental differences there are usually distinct
programs for control of stationary source and mobile source emissions. All these categories of
Egyptian standards were evaluated in light of world standards.
Air quality standards in Egypt were compared with those of the U.S., EU, and WHO. Analysis
showed that Egypt’s ambient air quality standards (i.e., the free air outside of buildings) are not out of
line with these standards overall, but that several changes should be made. First, because the standards
for nitrogen dioxide (NO2) and lead (Pb) are significantly less stringent than acceptable elsewhere in
the world, this report recommends that Egypt set stricter standards for these. Second, this report also
recommends that Egypt reexamine the averaging times for all standards. Third, this report recommends
that Egypt consider de-listing two pollutants: black smoke (BS), because it is obsolete and duplicates
the category for particulate matter with a diameter of 10 microns or less (PM10), and total suspended
solids (TSP), because they are solids that are too large to be inhaled deeply into the lungs and cause
health problems. Fourth, this report recommends that Egypt consider adding a standard for PM2.5,
which are small enough to be inhaled deeply into the lungs, and for volatile organic compounds
(VOCs), which will reduce ambient ozone (O3) formation.
1
2 Considerations for Revising Air Quality Standards in Egypt
In addition, at least 11 hazardous air pollutants (HAPs), which cause health damage from low exposure,
should be considered for addition to Egypt’s air quality standards. Some of these are currently listed as
substances subject to emission or workplace standards.
Emission standards for stationary sources in Egypt are organized by pollutant first, then by category
of industry to which the standards apply. By contrast, the three world programs are all organized by
source—with the U.S. standards going to the extreme of specifying type of equipment rather than
industry. Because of these basic differences, it is not possible to make a straight comparison between
Egypt’s stationary source emission standards and those of the U.S., EU, or WHO. Nevertheless, some
useful observations are possible. First, the Egyptian law is unspecific, listing pollutants in several
categories with different limits. Second, the emission standards are written as absolutes, without
averaging times, so that while they alleviate nuisances they do not necessarily reduce air pollution.
Third, the list is not comprehensive—many HAPs are missing altogether. The organizing principle—by
pollutant rather than by source—makes equitable application of the rules impossible and is extremely
difficult to administer effectively.
Egyptian stakeholders expressed the opinion that many of the emission standards—such as that for
sulfur dioxide (SO2)—are not stringent enough, and raised issues of controlling the sulfur content of
fuels as the best way to control emissions.
In addition, the standard for emissions from combustion sources is obsolete in method, using the
outdated Ringelmann method to measure the opacity of the smoke produced rather than a quantitative
analytical approach to measuring the volume, chemical composition, and size of particles composing
such emissions.
Mobile source emission standards were compared with those of the U.S. and EU (WHO does not
publish standards for mobile sources). This comparison revealed basic differences: First, Egypt is
measuring tailpipe emissions as percentage of pollutant in volume of emissions, while the other two are
denominated in grams of pollutant per distance traveled. Second, Egypt’s test protocol does not
compare easily with either that used in the U.S. or the EU; Egypt measures only CO, hydrocarbons
(HC), and BS, and does not measure non-methane hydrocarbons (NMHC), nitrogen oxides (NO), or
PM—which, as discussed earlier, would be a more useful measurement than BS. While there is no
methodology that would allow direct comparison of the standards, some observations are possible.
First, testing tailpipe emissions at a single moment fails to capture a more representative sample of real
driving conditions. In addition, testing a vehicle at idle (as the Egyptian standards do) is the moment
when emissions are at their lowest. The standards apply to all vehicles—gasoline-, diesel-, and
compressed natural gas-fueled; motorcycles, passenger cars, buses, and trucks. Large vehicles are not
likely to be able to meet the standards, while the same standards are too lenient for small vehicles,
meaning that Egypt loses an easy opportunity to make reductions in emissions.
Egypt’s mobile emission standards need to be rewritten in line with either the U.S. or EU standards.
The technologies to achieve such standards are available, costs have been reduced to acceptable levels,
and integration of such technology into vehicle design yields concurrent improvements in fuel
economy.
The other aspect of mobile emissions standards is fuel standards. Egypt already has unleaded fuel
available and should move quickly to prohibit the use of the remaining leaded fuel. Given the warm
temperatures and absence of onboard vehicle evaporative controls, it is also recommended that
volatility controls for fuel sold in urban areas be added to control formation of O3. Egypt has a decided
advantage in its vast reservoirs of natural gas and its progress toward encouraging the use of CNG as a
motor fuel. Incentives have been shown to be effective in facilitating conversion to CNG.
Considerations for Revising Air Quality Standards in Egypt 3
General considerations: Finally, there appears to be an underlying problem in Egypt that goes far
beyond the air quality standards: the lack of a widespread understanding of the connection between air
pollution and human health. Egypt is subject to an annual cycle of sand and dust storms that simply
blow away, reinforcing the concept that bad air goes away by itself. There has been little public
education concerning air pollution until very recently. However, several years with periods of
inversions that have trapped pollutants over Cairo (known locally as “the black cloud”) have increased
public awareness. Still, emitters don’t see themselves as polluters; they don’t understand the reasoning
behind the standards nor why they should be burdened with the cost or effort it takes to comply with
them.
Studying the development of the U.S. air quality program, it is possible to see what is missing from the
Egyptian program: a clear understanding of the link between air quality and protection of human
health, with regulations used to achieve emission reductions to levels that provide adequate air quality.
Stakeholders from EEAA expressed the lack of this obvious link in many ways, ranging from historical
and cultural methods of avoiding compliance to the absence in Law 4/1994 or its Executive
Regulations of guidance about penalties for those not in compliance.
Any program that has a cost or involves perceived sacrifice—and air quality control meets those two
criteria—can only go as far as public opinion will allow. There must be political will, resources for
enforcement, commitment on the part of both the government and industry, and a high degree of
acceptance among the professional and scientific communities.
It is recommended, therefore, that any process to revise the air quality standards use two central
premises as its starting point:
• Air quality standards should be set at levels that achieve protection of human health primarily,
as well as the environment, and
• Emission standards should be set at levels that bring pollutant concentrations within the air
quality standards.
In order to begin the process of setting new standards, it will be necessary to answer the main questions
key stakeholders raised. One was whether the standards should be the same throughout Egypt, or
should they vary by location. International experience argues that the standards for ambient air should
be the same everywhere. Allowing industry to relocate to areas that are not now polluted removes
incentives for modernization and introduces a number of inequities.
Systematic review of new standards is necessary on a regular basis. In the U.S., there is a requirement
for review of standards at least every 5 years, or whenever new information appears. Even with the
resources available in that country, that schedule is less than rigorously followed. For Egypt, a review
every 5–10 years seems reasonable to keep it abreast of international developments and scientific
advances.
As new standards are developed, lawmakers must also consider administration of regulations.
According to EEAA stakeholders, current procedures are not clear and enforcement authority is
inadequate. Not only do the standards conflict as now written, but methodologies for measuring
emissions are lacking as well, as is adequate administrative organization and responsibility.
A frequent complaint was that enforcement programs are understaffed and that the staff lacks resources
to do their jobs. Equipment, instruments, spare parts, vehicles, and trained staff are badly needed. One
EEAA staff member commented that although the law regulates more than 300 chemicals in indoor
concentrations, his staff couldn’t measure more than two or three of these, rendering this portion of the
law meaningless.
Another regular criticism concerned the recognition that the standards did not have a solid scientific or
medical basis—quantitative methods are essential to standard setting and standard enforcement, and
more science could be used to link the emission standards with the ambient standards. Development of
rigorous protocols must be part of the revision process, but must not become a means of postponing
implementation of the standards.
It is clear, too, that the program needs to develop specific standardized procedures and sampling
methods that have approved quality assurance or quality control practices. It will be useful to rely on
the standard methodologies that have already been adopted and are in use by international financial
organizations or the International Standards Organization (ISO). These are available, and their use
simplifies the implementation of methodologies. These will be critical for success of any standard
Egypt adopts.
Two conclusions seem clear: First, the relationship of emissions to air quality should be stressed as part
of a new approach. Second, although attainment of the health-based standards is unrealistic in the near
term, it is not appropriate to ignore the air quality standards. There has to be a way of working toward
them in a reasonable and appropriate way.
It would be appropriate to issue new emission standards without waiting for signals from ambient
standards. Various technologies and the source categories that use them should be targeted for
application of new emission standards without regard to their specific impacts on ambient loadings.
The most appropriate approach will be to issue emission standards one industry at a time, focusing on
bringing technologies in that industry up to world standards.
The first task would be to look at all the source categories and set up a scoring of various industries in
order to prioritize them into a schedule: industries emitting the problem pollutants (PM and its
precursors) in the largest amounts; industries with obsolete facilities that would make good targets for
renovation; industries that are capital-intensive and high profile. Overall emissions would decline as the
process works through the list, industry by industry.
The overriding concern will be the health and life potential of the Egyptian people. This report
concludes that it is possible to start making positive steps now.
1. Introduction
The United States Agency for International Development (USAID) has a long-standing interest in
environmental issues in Egypt. From the 1980s to the mid-1990s its undertakings were primarily
building and rehabilitating infrastructure such as water and wastewater treatment plants and networks.
Concern shifted in the early 1990s to areas of the country outside the two urban centers of Cairo and
Alexandria, and has extended to the east to the cities of Suez, Ismailia, and Port Said, throughout the
Nile Delta region, and to Upper and Middle Egypt. In Greater Cairo, efforts shifted from building
infrastructure to institutional development so the utilities could operate in a more business-like manner,
in line with the Government of Egypt’s (GOE) efforts to de-control the economy.
At the same time, both the GOE and USAID were becoming increasingly aware that urban Cairo was
suffering from ever-increasing pollution: noise pollution, uncollected rubbish, and especially air
pollution. USAID funded several short-term efforts to assess the situation, including a study in 1994,
the Project in Development and the Environment (PRIDE), discussed in more detail below, which
clarified the seriousness of the air pollution problem.
USAID and the GOE then laid plans for a massive project to address air pollution—the Cairo Air
Improvement Project (CAIP). CAIP is charged with implementing a vehicle emissions testing pilot
program, assisting the two major public transit companies to put test fleets of compressed natural gas
(CNG)-fueled buses on the streets, helping the Egyptian Environmental Affairs Agency (EEAA)
implement the National Lead Abatement Plan through providing technical expertise to private lead
smelter owners as they upgrade their facilities, and compiling data on components of Greater Cairo’s
ambient air with special emphasis on lead (Pb) and particulate matter with a diameter of 10 microns or
less (PM10).
Given the serious nature of the air quality problems, USAID has instituted a new project under the
Environmental Policy and Institutional Strengthening Indefinite Quantity Contract Program (EPIQ) to
provide resources to address air quality problems in Egypt. As an important step, USAID is providing
funding to establish a system for periodic review and modification of air emission standards, in
conjunction with the Egyptian Environmental Affairs Agency (EEAA).
1.1 Tasks Covered

Under EPIQ, USAID and the Government of Egypt (GOE) have agreed to 14 policy objectives
designed to improve environmental conditions in Egypt.1 These objectives are to be completed within
18 months, starting June 1999.
This task is designed to complete Objective 4, Tranche I, which calls for conducting an assessment of
the existing air standards in Egypt.2 The goal of this exercise is to provide analysis for the EEAA to use
in establishing a system of periodic review of emission regulations.
A team of two consultants was assigned to conduct research and prepare materials for the required
assessment. Dr. Mahmoud Nasralla, professor of environmental sciences and author of the existing
Egyptian air quality regulations, was assigned the role of team leader and consultant. The author, Mr.
Alan P. Loeb, Esq., an American attorney specializing in environmental standards and regulations, was
assigned the role of international consultant. Under his Terms of Reference, Mr. Loeb was tasked to:
1
The source document for EPIQ in Egypt is the Memorandum of Understanding Between the Arab Republic of Egypt and The
United States Agency for International Development, Egyptian Environmental Policy Program.
2
The outline does not set out a specific measure for the tranche, but footnote 1 indicates what steps to undertake and tools to use.
It has been determined that the task calls for an assessment of the existing air pollution standards.
• Review existing air emissions standards established under Law 4, Year 1994 (“the Egyptian
Environmental Law”)and prepare a brief analysis comparing the Egyptian standards with
comparable U.S. and selected international air emissions standards such as those used by the
World Health Organization (WHO) and the European Union (EU).
• Work with the local consultant and use the above analysis to conduct a series of interviews
with key stakeholders to identify—based on criteria agreed to with Dr. Ahmed Gamal,
Environmental Advisor to the USAID-funded Cairo Air Improvement Project (CAIP) and the
Egyptian Environmental Affairs Agency (EEAA)—specific air emissions standards that
should be the focus of the EEAA assessment.
• Assist in the preparation of a detailed questionnaire, using the above analysis and interviews,
and test it with a small roundtable of key stakeholder/advocates. The questionnaire was to be
distributed to relevant stakeholders before the stakeholder consultation.
• Following the stakeholder consultation, assist the local consultant in preparing an assessment
of the effectiveness of existing air emissions standards in controlling priority air pollutants,
and recommend appropriate modifications and procedures for periodic review and
modification.
This report gives an account of the first two tasks. The method used involved two phases: first, it was
necessary to survey the standards adopted by leading national programs, including the U.S. and the EU,
international organizations, and others to identify air quality standards for comparison. This was a
necessary prerequisite for the analysis. A key factor was to discover if there are world norms in air
pollution control that the Egyptian air pollution control system must meet in order to be at general
parity with other countries. While the survey conducted was intended to be comprehensive, so that all
important programs could be identified, it was not exhaustive. Programs were summarized and some
inessential aspects were not covered at all. The result, even after selective coverage, has produced an
extensive collection of materials, which are set out in appendices to this report.
Once the survey materials were assembled there followed a second phase, which was to evaluate the
existing Egyptian program to identify flaws or weaknesses in the regulations and make
recommendations for addressing those deficiencies. The evaluation has taken account of both the
written standards themselves as well as considerations relating to the Egyptian administrative system
and the emission sources. Because the analysis naturally falls into two distinct processes, this step has
been accomplished in two parts:
1. The analysis first compares the air quality standards that apply in Egypt with the standards that are
applied by selected countries and international organizations. The report examines the strengths
and weaknesses of the Egyptian program relative to these other programs to the extent such are
possible given their incompatibilities. The examination focuses on the pollutants of greatest
concern in Egypt so that public health priorities can be addressed. The analysis identifies problem
areas and offers some preliminary observations and recommendations.3
2. The analysis also evaluates other concerns about the functioning of the Egyptian air quality
program, focusing on the administration and other relevant technical or policy considerations.
This relies principally upon interviews in which I have participated, supplemented by a reading of
3
In order to complete the assignments within time and budget allocated, the analysis presented here includes secondary materials
where they could be obtained. In some cases I have drawn from copyrighted materials, including my own, which remain subject
to the proprietary protections they originally held. Material drawn from others has been referenced; not all of my own material
has been referenced herein. Nothing in this document waives any right or claim in intellectual property held by any author whose
material appears here.
a translation of the Egyptian environmental law with its Executive Regulations and experience in
solving similar problems in other countries.
While this report represents completion of the research part of this project, the analysis is more
preliminary and should be taken as a platform for discussion rather than as final conclusions.
Refinement of the analysis and the recommendations that come from it will result from the remaining
tasks in the project.
1.2 Target Air Pollution Problems in Egypt

Most concern with air pollution in Egypt centers on Greater Cairo—an area that encompasses the cities
of Cairo, Giza, and Qaliobiya—where air pollution levels rank among the highest in the world.
Before 1994 it was believed that mobile sources were the biggest air pollution problem in Cairo. In
September of that year, USAID released the report, Comparing Environmental Health Risks in Cairo,
Egypt, prepared by the Project in Development and the Environment, which became known as the
PRIDE study. This report provided a much more refined view of the problem, identifying two primary
public health concerns regarding air pollution in Cairo.
First, it determined that lead pollution was the single greatest single source of pollution damage to the
Cairo population. It found the average blood lead levels among Cairo residents to be at 30, 27.5, and
22.5 micrograms per deciliter (mg/dl) of blood for men, women, and children respectively—among the
highest ever recorded for a major city.
Based on these levels, it found that every year lead pollution in Cairo alone causes 6,500–100,000 heart
attacks, and 840–1,400 strokes, resulting in a total of 6,300–11,100 cardiovascular deaths, and an
average IQ loss of 4.25 points for every person raised in Cairo. The cost associated with the IQ loss is
estimated to be billions of dollars annually.
Virtually all of the lead in the environment starts in the air, at that time principally from leaded
gasoline. Thus, the PRIDE study did not disturb the belief that mobile sources were the source of the
most significant air pollution problem, but it did change the sense in which that initial hypothesis was
true. As a result of this information, and with advice that antiknock substitutes could be implemented
quickly at reasonable cost, in 1996 the GOE acted quickly to remove the lead from the gasoline sold in
Greater Cairo. Nevertheless, because of the dry climate, the lead that was used previously continues to
contaminate Egyptian urban environments and reenters the air through reentrainment. In addition, the
current lead loading is increased by emissions from lead smelters that continue to operate in and around
Cairo.
Second, it found that particulate matter (PM) levels in air pollution in Cairo exceeded health-based
standards by a factor of 5 to 10, with levels in Cairo higher than in any of the world’s largest cities. It
found that industrial emissions were the principal source of PM, though it had no inventory of emission
sources. It predicted that reducing PM concentrations to natural background levels might prevent
3,000–16,000 deaths and 90–270 million days of restricted activity per year
Among the other environmental health risks, it also noted high ozone levels, though its assessment was
based on incomplete monitoring data. In addition, it found high levels of the conventional pollutants
nitrogen oxides (NOx) and carbon monoxide (CO), as well as the probability of high concentrations of
toxic air pollutants such as benzene, formaldehyde, cadmium, nickel, and benzo-a-pyrene. Even
without time series monitoring data, it can be assumed that increases in road traffic since 1994 have
also increased emissions of ozone precursors, resulting in corresponding increases in ambient ozone
levels, as well as many of these other pollutants.
While new data, when it becomes available, will inform decision-makers better about current
conditions, information that is now available indicates the presence of very high levels of air pollution
in urban areas, especially in Cairo. These conditions create a significant public health problem that has
high personal and economic costs. This analysis is intended to identify institutional means of reducing
human exposure to such substances through revision of the air pollution standards and changes in
administrative mechanisms.
2. Comparison of Pollutant Standards

This section compares air quality standards used throughout the world with Egypt’s established under
the Executive Regulations of Law 4/1994. The materials used for the comparison, along with additional
information on the programs, are contained in the appendices. Of course, a standard can only be
compared with like standards. The survey indicated that the programs have fundamental differences
that, in some cases, make absolute quantitative comparisons difficult or impossible. Nevertheless, even
in these cases the exercise provides useful information and insight about the Egyptian program.
2.1 Survey of World Air Pollution Standards

A first step in carrying out the assigned task was to identify the various world standards and determine
the kinds of standards found in their programs. The results of a preliminary survey of Egypt, the U.S.,
the EU, WHO, the World Bank, other financial organizations, and the International Organization for
Standardization (ISO) are summarized in table 1.
Table 1. Summary of World Air Pollution Standards
World Bank
ISO14000
Guideline
Standard
Financial
Egypt
Other
WHO
U.S.
EU
or
Ambient * * (Federal) * *
Emissions
Stationary Sources * (Not *
pursued)
a
-Existing * (States)
-New * (Federal) *
Mobile Sources * * *
a
(Federal)
Technical Methods * * * *
Management * * * *
Practices
* Indicates existence
a
Regarding the U.S. program, this characterizes programs that are most developed and actively enforced. The exceptions that exist
for stationary sources are in programs that have only recently been pursued vigorously, such as for visibility protection, where federal
authority to regulate existing sources exists. The exceptions that exist for mobile sources are the longstanding exception for
California and the ability of other states to ‘opt-into’ participation in the California standards.
2.2 Survey of World Ambient Air Quality Standards

Analysis of world air pollution standards begins with a survey of the standards that define air quality
goals. Egypt, WHO, the U.S., and the EU have programs that approach air quality in conceptually
different ways. As noted in the appendices, the U.S. program classifies air pollutants (other than global
air pollutants) into two fundamental categories: conventional pollutants and hazardous air pollutants
(HAPs). The U.S. program is the anomaly. Other world programs do not make that formal distinction,
providing instead for the differences in toxicity by assigning lower maximum ambient concentrations.
Despite differences in organization, the programs are compatible enough to be compared, but the
distinction of ambient pollutants and hazardous air pollutants is maintained here.
2.2.1 Conventional Pollutants: Health-based Ambient Air Quality, Visibility,

and Acidification
Table 2 compares health-based ambient pollutant standards in Egypt with those issued by the WHO,
U.S. and EU. The list excludes pollutants that are toxic at low thresholds and which may be considered
HAPs.
Table 2. Comparison of Health-based Ambient Air Quality Standards
Averaging Maximum Limit Value

Pollutant
Time Egypt WHO U.S. EU
3
24-hour 150 µg/m — — 250 µg/m3
Black Smoke (BS)
Annual 60 µg/m3 — — 80 µg/m3
24-hour 230 µg/m3 — [260 µg/m3, [rescinded]
Total Suspended rescinded]
Particles (TSP) Annual 90 µg/m3 — [75 µg/m3, [rescinded]
rescinded]
Particulate Matter Annual — — 50 µg/m3 40 µg/m3
(PM10) 24-hour 70 µg/m3 — 150 µg/m3 50 µg/m3
Annual — — 15 µg/m3 —
PM2.5 3
24-hour — — 65 µg/m —
Annual 60 µg/m3 50 µg/m3 80 µg/m3 20 µg/m3
Sulfur Dioxide 24-hour 150 µg/m3 125 µg/m3 365 µg/m3 125 µg/m3
(SO2) 1-hour 350 µg/m3 — — 350 µg/m3
10-minute — 500 µg/m3 — —
3 3 3
8-hour 10 mg/m 10 mg/m 10 mg/m [proposed]
Carbon Monoxide 1-hour 30 mg/m3 30 mg/m3 40 mg/m3
(CO) 30-minute — 60 mg/m3 —
3
15-minute — 100 mg/m —
3
Annual — 40 µg/m 100 µg/m3 40 µg/m3
Nitrogen Dioxide 3
24-hour 150 µg/m — — —
(NO2)
3 3
1-hour 400 µg/m 200 µg/m — 200 µg/m3
Nitrogen Oxides Annual — — — 30 µg/m3
(NOx)
8-hour 120 µg/m3 120 µg/m3 157 µg/m3 [proposed]
Ozone (O3) 3 3
1-hour 200 µg/m — 235 µg/m
3 3
Annual 1 µg/m 0.5 µg/m — 0.5 µg/m3
Lead (Pb)
Quarterly — — 1.5 µg/m3 —
A number of observations about the Egyptian standards can be made on the standards compared in
table 2.
Standard Level Concentrations

First, ambient levels that are specified in the Egyptian standards listed in the Executive Regulations of
Law 4/1994 in Annex 5 are not out of line with world standards overall. However, when taken
individually, two of the pollutants, NO2 and Pb, are assigned standards that are significantly less
stringent the levels considered acceptable elsewhere in the world. Specific observations on the
comparisons are as follows:
• PM10. Annex 5 (of the Executive Regulations of Law 4/1994) specifies a PM10 24-hour
standard of 70 µg/m3, while the U.S. and EU standards are 150 and 50, respectively. Thus, the
Egyptian standard falls within the range of other standards. However, Dr. Nasralla points out
that the background level of PM10 from natural sources is already in excess of 70.
• SO2. Annex 5 specifies a SO2 annual standard of 60 µg/m3, while the WHO, U.S., and EU
standards are 50, 80, and 20, respectively. Thus, while higher than the WHO and EU
standards, this Egyptian standard is actually lower than the U.S. standard.
• CO. Annex 5 specifies a CO 8-hour standard of 10 mg/m3, the same as the WHO and U.S.
standards. The 1-hour standard of 30 mg/m3 is the same as the WHO standard and less than
the U.S. standard of 40 mg/m3. Thus, it is at or below the world standard.
• NO2. Annex 5 specifies a NO2 1-hour standard of 400 µg/m3, twice that of the WHO and U.S.
standards, which are at 200 µg/m3. Egypt should consider revising this standard to bring it
within the world norm.
• O3. Annex 5 specifies an O3 1-hour standard of 200 µg/m3, slightly below the U.S. standard of
235 mg/m3. It also specifies an 8-hour standard of 120 µg/m3, which is the same as the WHO
standard and slightly below the U.S. standard. Thus, the O3 standard is on a par with the world
standards.
• Pb. Annex 5 specifies a Pb annual standard of 1 µg/m3, twice that of the WHO and EU
standards, which are both set at .5 µg/m3. The U.S. standard is not comparable, as it applies
only quarterly. Because the Egyptian standard is set at twice comparable standards, Egypt
should consider revising this standard and bringing it within the world norm.
Averaging Times
Among the six pollutants listed by Annex 5 that are also listed by the U.S., EU, or WHO, there are a
number of pollutants that have multiple standards for distinct averaging times. While all of the
averaging times used in Annex 5 (with the single exception of the 24-hour NO2 standard) are used in
one or more of these other programs, the question arises whether it is really necessary to maintain all of
these standards, especially in the case of SO2, where Annex 5 gives three separate standards. But even
where there are two standards, it remains an open question whether both are required, or whether those
that exist now are the most appropriate averaging times for these pollutants. New knowledge may
change not only the level considered to be toxic but also the temporal exposure scenario in which
toxicity will arise.
Given the high particulate levels in Cairo, it is advisable to consider adopting a 24-hour standard for
PM10 to control for episodes resulting from temporary conditions such as inversions because of
mortality potential from acute exposures; high concentration episodes get washed out in the annual
average.
As part of any review, Egypt should consider reexamining the averaging times for the ambient
pollutants to determine whether current averaging times remain appropriate. Maintenance of more
standards than is necessary costs resources that could be used for other purposes. Obviously, one can
observe from table 2 that there is no single approach that has been adopted by all. On the other hand, it
may be that certain factors that are indigenous to Egypt should be taken into consideration and would
affect the determination of the standards that are most appropriate.
Considerations for De-listing Two Pollutants

In addition to the listed pollutants that correspond to pollutants now listed by other regulatory agencies,
Annex 5 includes two pollutants, both related to particulates, that are no longer commonly in use
elsewhere. Egypt should consider deleting at least one of these:
• BS. The standard for black smoke has been made obsolete by the adoption of PM10 standards
and has been dropped in other programs internationally. A strong argument can be made for
dropping it in Egypt, as it duplicates the existing PM10 standard, and its administration and
enforcement would drain scarce resources. Moreover, control of smoke emissions as nuisances
can be accomplished more efficiently through the use of Ringelmann charts. If another health-
based particulate standard is needed, it should be a PM2.5 standard, which has become the
other conventional form. The counter-argument raised by Dr. Nasralla is that a standard for
black smoke should remain because incomplete combustion is a problem in Egypt.
• TSP. The TSP ambient standard has been dropped from most programs because of the
growing understanding of the relationship between particle size and health effects. As
indicated in the appendices, beginning in the early 1990s researchers, using time series
analyses, began to see a strong association of health effects with smaller particles and to
recognize that the larger particles found in ordinary airborne dust do not constitute a
significant health concern. While the large particles create a nuisance, they do not enter the
deep parts of the lungs. Moreover, while the TSP standard ostensibly measures total
suspended particulates, in practice only the largest particles get measured and controlled,
leaving the smaller particles that affect health adversely uncontrolled. Thus, use of a standard
that includes the larger, benign particles results in lack of control of the smaller, harmful
particles. As with black smoke, it may be advisable to delete TSP as obsolete. However, Egypt
may pose a special case because of the significant natural background levels of larger
particles. It is at least debatable whether it is desirable to retain the TSP standard in Egypt as a
means of tracking the large particles because of the public interest in that information, even if
it is not a measure of health effects.4 Thus, indigenous circumstances in Egypt may warrant
that use of resources.
Additions to the List

To come up to the state-of-the-art, Egypt should also consider some additions to the lists. Two
suggestions are considered here:
• Particulates. The pollutant that is of greatest political visibility in Egypt is the PM standard.
The aforementioned studies carried out in the 1990s identified the nature of health hazards
from fine particulates as a much more significant health threat than previously realized.
Studies have also pointed to fine particles, particularly PM2.5, which is inhaled deep into the
lungs, as the greatest source of human health risk. Currently, Egypt has a standard for PM10
but not for PM2.5. Any reconsideration of the standards should, in addition to examining the
level of the PM10 standard, evaluate the costs and benefits of establishment of a separate PM2.5
standard. The health concerns are not in doubt; the only question is whether attainment of the
standard is economically feasible, assuming that the standard will be implemented if adopted.
4
To make a determination a better inventory of sources is called for. Limited data used in the PRIDE study suggests that only
about one-third of the TSP measured in Cairo results from natural sources. Thus PM10, which excludes the larger fraction most
likely to be from natural sources, is most likely to result from anthropogenic causes. These issues will need to be sorted out in
order to make a decision on the form of PM standards to retain.
• Volatile Organic Compounds (VOCs). In an interview, Cairo environmental lab manager

Nader Shehata Doas suggested the addition of a standard for VOCs. These are pollutants that
chemically combine in the ambient air to form ozone and other photochemical pollutants.
While control of VOCs is important to reduce ambient ozone formation, VOCs as a class are
not necessarily significant as health detriments. As discussed in Appendix B.3.1, the United
States Environmental Protection Agency (U.S. EPA) initially had an ambient standard for
hydrocarbon (HC) but dropped it for this reason. The proper regulatory approach for HC and
VOCs is to control them with emission standards, rather than through the ambient standard
mechanism. Thus, the addition of a VOC ambient standard is not recommended.
Visibility Impacts
While human health is universal, making consideration of ambient pollutant concentrations essential, it
is also important to take into account the impact of ambient pollutants on other air quality factors in
Egypt, such as visibility. Visibility is particularly important in Egypt for two reasons:
• Value Relating to Tourism. Visibility has a high economic value. Tourism is a major
industry in Egypt, and tourists come to experience the antiquities visually. Because of their
grandeur, they must be viewed from great distances. The impact of these monuments is
substantially reduced by visibility impairment. In addition, to the extent Egypt is seen as dirty
and polluted, tourists may choose other options and stay away. Visibility has a cash value.
• Value Relating to Public Awareness of Air Pollution. By the same token, visibility is a
condition that is, by definition, obvious to the public in Egypt, and any changes in air quality
will be noticed. Since visibility impairment is caused by particulates and ozone, which are also
ambient pollutants of great concern in Egypt, visibility acts as an indicator to the public of the
level health hazards in the ambient air.5
Because of these two values, it may be important in any consideration of conventional pollutants to
take account of not only their health effects as ambient pollutants but also their impacts on visibility
and other air quality values. Control of ambient pollutants for health reasons would not always reduce
visibility-impairing pollutants to acceptable levels. For example, since TSP is more of a nuisance
pollutant than a health threat, it could be de-listed as an ambient pollutant but still be subject to controls
under a separate visibility program. Visibility impacts are worth consideration as part of a complete
examination of the air quality program.
Acidification
Because of the significant impact of acid deposition upon historic monuments and archaeological sites,
acidification from conventional air pollutants is a significant problem in Egypt. Like visibility,
acidification has not been addressed in the Executive Regulations to Law 4/1994.
2.2.2 Hazardous Air Pollutants; Other Air Pollutants

In addition to the traditional ambient pollutants, there is a second class of air pollutants that are toxic at
lower thresholds, which the various programs have treated differently. In most programs, including that
of the EU, these are grouped with the ambient pollutants but controlled to much lower concentrations.
By contrast, in the U.S. program these are treated as a distinct class of pollutants and controlled under a
separate regulatory program.
5
Visibility degradation is caused in large part by precursor emissions that result, which are notoriously high in Egypt, especially
in Cairo.
Table 3 provides a sample of substances that may be considered for control in Egypt as hazardous air
pollutants, but which are not currently listed in Law 4’s Executive Regulations Annex 5 as air
pollutants. These include the eight substances listed as hazardous air pollutants by the U.S prior to 1990
and the eleven substances listed (or under consideration for listing) as ambient pollutants by either the
WHO or the EU. Some of these are listed in the Egyptian program under Annex 6 as substances subject
to emission standards. A more complete list would include the 188 substances currently listed by the
U.S. under section 112(b)(1) of the Clean Air Act.
The absence of a program that recognizes the exposure concerns of these pollutants, either as part of
Annex 5 of the Executive Regulations of Law 4/1994 or in a separate program, creates a gap in
coverage. For most of these substances there is no control other than by the occupational standards
listed in Annex 8, “Maximum Limits of Air Pollutants inside the Work Place According to Type of
Industry.”6 Regulation by occupational standards alone would raise the theoretical scenario that firms
using the 11 substances—or any of the substances listed in Annex 8—could control occupational
exposure levels by venting these substances to the exterior of the building where no regulatory controls
apply, rather than control them by pollution prevention (i.e., by substituting non-toxic materials).
Venting is one of the classic mistakes—it was the remedy adopted in the U.S. for controlling worker
exposure to organo-metallic compounds of lead from the 1920s on, but which resulted in diverting
attention from the exposure of the public to the lead emissions or accumulation of lead in the ambient
environment. All these considerations argue for additional standards.
In addition to the conventional pollutants and the hazardous air pollutants, there are two additional
categories of air pollutants that should be covered to make a comprehensive program. First, in addition to
contamination of the open air, an air management program may also incorporate provisions to address
indoor air quality. While in other systems a formal distinction is made between ambient (environmental)
contamination and work place (occupational) contamination, in Egypt the contamination of indoor air
quality is treated as air pollution and included within the environmental program under Law 4, for which
standards are written under the Executive Regulations. Global air pollutants are those which are only
manageable at the worldwide level. These include stratospheric ozone depletors and greenhouse gases,
"GHGs". It is useful to think of them as as impacting the atmosphere rather than the ambient air. A
comprehensive air quality management program must also take into account such additional classes of air
contamination phenomena.
2.3 Survey of World Stationary Source Emission Standards

Emission standards are direct controls on emissions into the ambient air. Various stationary source
emissions control programs were reviewed in the survey. While the stationary source emission control
programs are so fundamentally different that no quantitative comparison can be made, some useful
qualitative observations are still possible.
Table 3. Comparison of Hazardous Air Pollutant Standards
Maximum Limit Value

Pollutant
Egypt WHO U.S. EU
— 5.0-20.0 µg/m3 [regulated as [proposed]
Benzene
[Table 3.3] NESHAP]
[Annex 6, (1-30)10 3 µg/m3 [regulated as [proposed]
Arsenic
Table 2] [Table 3.3] NESHAP]
Mercury [Annex 6, — [regulated as [in research]
Table 2] NESHAP]
6
An exception is found in Article 19, which addresses radioactive substances, which corresponds to radionuclides on the HAPs
list. Additional exceptions are found in Annex 6, Table (2), for listed HAPs.
Table 2] NESHAP]
— — [regulated as —
Asbestos
NESHAP]
Beryllium
NESHAP]
Vinyl Chloride
NESHAP]
Radio Nuclides
NESHAP]
Coke Oven Emissions
NESHAP]
[Annex 6, (0.1-20) [Cd compounds [in research]
Cadmium Table 2] 10-3 µg/m3 regulated as HAP]
[Table 3.2]
[Annex 6, 1-180 µg/m3 [Ni compounds [in research]
Nickel
Table 2] [Table 3.3] regulated as HAP]
— (1-10) --- [in research]
PAH 10-3 µg/m3
[Table 3.3]
2.3.1 Comparison of Programs

The stationary source programs reviewed start with three very different organizing principles.
The Egyptian standards, set out in Annex 6 of the Executive Regulations of Law 4/1994, is organized
by the following logic: first, the categories of pollutants emitted are set out in two separate tables—one
for particulates only, the other for other types of emissions. Then the categories of industries to which
the standards apply are listed. Finally, if there is a further distinction between new sources and existing
sources, that is listed. Thus, the primary organizing principle for the standards is the pollutant emitted,
rather than the category of source from which it is emitted.
By contrast, others have used the source category, rather than the pollutant, as the organizing principle.
There are two variations on this approach. First, in its Industry Sector Guidelines (Appendix D), the
World Bank recommends a set of performance standards for control of emissions at specific categories
of industrial sources. Since these are enforced as a precondition of financing a project, they are, in
effect, sector-specific emission standards applied in a pre-construction review process. In addition to
the Guidelines, the World Bank also provides a review of generic control technologies for specific
pollutants.
Second, and at the far extreme, the U.S. standards are organized by type of equipment, rather than by
industry. The program considers an individual piece of equipment in use at a facility (rather than the
facility as a whole) to be the emission source that is the subject of regulation, and thus the rules apply
to (and are arranged by) category of equipment. Within a given facility or plant there will be numerous
emission sources that are regulated individually, each with its own set of standards for emissions of
each pollutant.
Because each of the programs is written around a different organizing principle it is impossible to make
direct quantitative comparisons of the emission standards, since one cannot know in advance the
equivalences that would allow translation from one set of standards to another. For a quantitative
comparison to be made, standards for each industry would have to be analyzed individually using
engineering judgment to determine those equivalences. Such a comparison far exceeds the resources
contemplated in this task. In consequence, this report offers no opinion as to whether the Egyptian
stationary source standards are more or less stringent than other world standards.
2.3.2 Qualitative Observations on the Egyptian Stationary Source

Emission Standards
While direct quantitative comparisons are impossible, some useful observations on the Egyptian
emission standards can be made.
First, there are many specific flaws in the standards as they are now written. For example:
• Annex 6 of the Executive Regulations of Law 4/1994, “Permissible Limits of Air Pollutants in
Emissions,” contains two tables, “Overall Particles” and “Maximum Limits of Gas and Fume
Emissions from Industrial Establishments.” It appears that the Regulations are designed to
distinguish particulate emissions from gaseous emissions. However, the second table contains
numerous substances that normally would be in particulate form, so there is not a clean and
logical distinction. As a result it is possible that both tables—and more than one
standard—could apply simultaneously. In such an instance the owner of the source cannot
ascertain which standard would apply. This ought to be clarified by revisions in the Executive
Regulations.
• The second table lists categories for heavy elements (total) and for organic compounds. These
are very unspecific and probably too arbitrary to be enforceable.
• That table also combines conventional and hazardous air pollutants. If it is intended to be
comprehensive, incorporating all air pollutants, there are numerous additional HAPs that
should be considered for addition to the list.
• The standards are denominated as mass per volume, but since no averaging periods are
specified it is implicit that they apply as absolute standards. That is, emissions at no time may
exceed the maximum. While that does provide a constraint on emissions of high
concentrations at every moment, it does not limit the aggregate amount of emissions over a
period of time. In other words, under these rules a facility is prohibited from emitting highly
concentrated emissions at any instant, but a large volume of emissions within the standard that
continues for a long period and results in many times more emissions to the environment is
perfectly legal. The standards are written to prohibit nuisances, rather than air pollution
generally.
Second, organizing the standards by pollutant, rather than by source category, is undoubtedly very
difficult to administer. Since different industries have different equipment and varied emissions, the use
of a single, uniform standard to apply to a number of industries would be arbitrary. For some industries
the standard would be easy to meet and present no burden; for others it would severely constrain
operations and cause great financial hardship if it were enforced. As a result, equitable application
would be impossible, and it would probably not be enforced. The result is that the emission reductions
that are the purpose of the standards are unlikely to be achieved. In the distant future, when stringent
levels of control for every industry become the norm, it may be economically feasible to have equal
standards for all industries, but under present conditions this is not something that achieves the program
goals.
Third, organizing by pollutant, rather than by source category, can lead to extraordinary inefficiency if
the rules are enforced as written. For most pollutants, the rules assign all sources the same standard.
But it is well known that typically the cost of control varies widely across industries and even across
types of equipment in the same industry. While the application of a single standard to all sources is, in
a sense, equitable since it places an equal responsibility on all parties, the burden of meeting the same
standard is greater for some than for others, since the costs of control are higher.
Finally, and most importantly, organizing the standards by pollutant, rather than by industry, makes
these rules extremely general. But any revision of these standards to achieve a reduction in emissions
would have to be targeted toward the specific industries or source categories that emit them. Once the
process of targeting industries for emission reductions is started, the organizing principle for the rules
would quickly become the industry, rather than the pollutant. It is something that occurs naturally.
Since these are emission standards, the controls would be on emissions by a source and would include
all the emissions from that source. By contrast, organizing an emission control effort by pollutant, so
that dozens of source categories have separate standards under each listed pollutant would be an
extremely unwieldy approach.
Even without a direct and quantitative comparison with other stationary source control programs, it is
possible to conclude that the Egyptian stationary source emission standards are outmoded and unsuited
to the task. The foregoing discussion suggests two improvements: (1) any program to amend the rules
should start from the principle of assigning appropriate emission limitations to emission sources for
each pollutant that source emits; and (2) the standards contained in Annex 6 of the Executive
Regulations to Law 4/1994 may remain while the process of replacement goes on so that regulatory
oversight can continue, but ultimately they would be supplanted by the new process.
2.3.3 Views about the Egyptian Emission Standards

In addition to the analysis, some opinions about the standards were obtained through interviews.
Stringency of the Standards

Several individuals interviewed noted that the emission standards are not stringent enough. Dr. Ahmed
Hamza, Senior Technical Advisor, Environmental Compliance Unit, Industrial Sources, EEAA,
observed that industry is complying with the standards, but the air is still polluted. “We can feel the
pollution, we get complaints from all over, but we can do nothing about it,” said Dr. Hamza.
According to Nader Shehata Doas, the emission limits specified by Law 4 and its Executive
Regulations are very lax. Some emission limits such as the SO2 standard are so lenient that no facility
will exceed them; these need to be more stringent. He noted complaints from individuals around the
cement plants, smelters, and foundries. He also noted that one can see the emissions from facilities that
use heavy fuel oil, called mazout, but when it is measured it is within the limit. Doas suggested that it
would be better to limit the high sulfur content of the fuel that gives high emissions rather than to
measure it as emissions. He also noted that uncontrolled incineration of solid waste in the streets needs
to be addressed.
Article 42(C)
A number of specific comments were directed at Article 42(C) of the Executive Regulations of Law
4/1994, which covers emissions from combustion sources. According to Dr. Ahmed Hamza, among the
standards that are too lax are those that provide limits for fuel-burning sources under Article 42(C).
EEAA has already commissioned a study to revise these. Significant emission reductions are possible.
As a general matter, one can observe that Article 42(C) is obsolete in method. One obvious flaw is that
it measures pollution from combustion sources visually using the outdated Ringelmann method. This
measures the opacity of smoke, but it tells nothing about its volume, the chemical composition of the
gaseous combustion products (such as SO2, NOx, or CO) or the size of particles composing it. Thus, the
Ringelmann method is a crude and ineffective regulatory tool that should remain in the law only for the
purpose of measuring the traditional smoke nuisance to downwind receptors, but not as a metric by
which modern air pollution problems are measured. There is no substitute for a quantitative analytical
approach.
Standards for Hospital Waste Incinerators
It was suggested above that standards be adopted by classification of facility, as is the practice in the
World Bank guidelines. There seems to be a natural tendency toward that approach. Already, without
adopting this practice as a systematic approach, some in EEAA are developing standards for specific
source categories. One example is the standards for hospital waste incinerators.
According to Dr. Nefisa S. Abo El-Seoud, Director of Environmental Engineering, Hazardous

Substances and Waste Management, EEAA, the Executive Regulations are not clear about standards
controlling emissions from hospital waste incinerators. Moreover, the standards are for emissions from
industrial establishments that are assumed to be located in industrialized areas, while in Egypt hospitals
are often located within residential areas. For this reason, the standards for emissions have to be very
strict. EEAA has developed its own air emission standards for these specific treatment units, guided by
EU materials, U.S. standards, and others. These apply technical specifications to incinerators, though
details were not made available. Dr. El-Seoud considers this change very important and has
recommended that these standards be included in the Executive Regulations.
The approach taken with respect to hospital waste incinerators appears to have all the correct elements:
it is developed based on a class of like-kind facilities, the standards are drawn from precedents
established by advanced air quality programs, and the level of the standards is driven by air quality
impacts.
2.4 Survey of World Mobile Source Emission Standards

Emissions from vehicles are affected by both emission controls and by fuels. Though each affects the
other, they are considered separately here.
2.4.1 Vehicle Emission Standards

Given the great number of standards for different classes of vehicles, direct comparison of emission
standards for mobile sources is difficult. For comparison purposes, the standards for the largest
segment of the vehicle fleet—the gasoline-fueled passenger car—have been assembled in table 4. This
should be taken as representative of other classes of vehicles.
Analysis
Several observations can be made on the information provided in the table.
Comparability of the standards. From the outset it is clear that a direct comparison of the Egyptian
standards with the U.S. and EU standards is impossible for several reasons:
• Denomination of pollutant. The Egyptian standards are written in percentage of pollutant in

volume of emissions, while the U.S. and EU are denominated in grams of pollutant per vehicle
distance traveled (either mile or km, respectively).
• Test protocol. Each regulation uses a different test procedure to measure emissions from the
vehicles, so that the design of the driving cycle used in measuring emissions affects the
quantity of pollutants actually emitted.
• Emission warranty. The regulations may apply to different lengths of warranties. That is, a
vehicle required to meet the emission standard for only 50,000 miles has much greater
emissions in its lifetime than a vehicle required to meet its standard for 100,000 miles. EU-
certified vehicles have no emission warranty.
Table 4. Comparison of Standards for Gasoline-fueled Passenger Cars
Egypt U.S. EU
Pollutant Existing New Pre-1994 Tier 1 2000 g/km
Vehicles Vehicles g/mi [g/km] (1994) g/mi
[g/km]
7% volume at 4.5% volume at 7.0 [4.3498] 3.4 [2.1128] 2.3
idle speed (600- idle speed (600-
CO
900 rotations/ 900 rotations/
minute) minute)
1000 ppm at 900 ppm at idle 1.5 [.9321] — 0.20
idle speed (600- speed (600-900
HC
900 rotations/ rotations/
minute) minute)
NMHC — — — 0.25 [.15535] —
NOx — — 1.0 [.6214] 0.4 [.24856] 0.15
65% darkness 50% darkness — — —
(opacity) or (opacity) or
Smoke equivalent at equivalent at
maximum maximum
acceleration acceleration
PM — — — 0.08 [.49712] —
Sources: The Egyptian standards are those established under Article 37 of the Executive Regulations of Law 4/1994. The U.S.
standards are those issued for gasoline-powered light-duty vehicles under section 202 of the Clean Air Act (1977) for emissions prior
to 1994, and under the 1990 Amendments (tier 1) effective 1994. The EU standards are those applicable beginning 2000, as compiled
in Michael P. Walsh, Motor Vehicle Standards and Regulations Around the World, June 3, 1999, as revised.
• Date of applicability. Of the two U.S. standards presented here, the more stringent are those
applicable to model year 1994, while the EU standards presented here are those from model
year 2000. Both sets of standards are soon to be superseded with much more stringent
standards in model years 2004 and 2005, respectively. However, presentation of these two
future standards was impossible to accomplish in a simple table because the U.S. tier 2
standards are impossible to describe except by listing numerous conditions that apply with
them. Thus, it should be understood in making the comparison that the table compares the old
U.S. standards with the new EU standards, and while these are comparable now that condition
will not pertain for long.
To make a comparison, one would have to test individual vehicles certified to one standard on the test
protocols applicable to the other; for example, by testing the emissions of a car certified with the U.S.
test protocols under the Egyptian idle test.
Accordingly, one has to read table 4 with the recognition that the absolute numbers stated there may
not represent absolute comparisons of the relative stringency of the various rules. One acknowledges
that because of these factors an absolute comparison is impossible and a more precise comparison than
this would require considerable engineering judgment.
Since there is no standard methodology that would allow the extrapolation of the emissions
performance of one test procedure to the other, there is no way to know with precision how the
Egyptian vehicle emission standards compare with the U.S. or EU standards. However, it can be
reasonably assumed that the Egyptian standards do not require vehicles to control emissions to the
world standard. Indeed, in the absence of a standard, NOx emissions are not controlled at all and may
indeed be increased by designs implemented for control of HC and CO.
Other Observations
Despite the lack of direct comparability, there are some observations that can be made about the mobile
source emission standards.
The use of a concentration-per-volume standard makes the Egyptian program suitable for tailpipe
testing for an in-use vehicle. Measuring emissions at a single moment simplifies the approach by
eliminating the need for a more complicated testing protocol. But by the same token, this testing
procedure fails to capture a more representative sample of real driving conditions as part of the vehicle
certification, making it unlikely that vehicles in driving conditions actually have the emissions they are
certified to. Emissions vary dramatically with cold start, road conditions, acceleration, etc. The
certification protocols used in the U.S. and EU for new vehicles attempt (some would say without true
success) to be representative of the whole driving cycle. By contrast, the emissions tested in the
Egyptian standard are from a vehicle at idle, when emissions are lowest. The Egyptian standards should
be changed to be in the same measures as other standards to conform to the world norm, which is
written to capture the emissions during the whole driving cycle.
Even without a direct and quantitative comparison of the Egyptian vehicle emission standards with
other standards, it is still reasonable to conclude that the Egyptian standards are obsolete and ought to
be replaced. For example, the vehicle emissions standards apply to any vehicle, including buses,
motorcycles, tractors, etc. For larger vehicles, this imposes heavy burdens that are not likely to be met;
for smaller vehicles the standards are too lenient, losing the opportunity to make reductions that could
be made easily. For other categories, such as diesel smoke, the standard is possibly too lenient and may
need to be reconsidered given the high ambient particulate levels in Cairo. Given these problems, the
rules come to be treated as unenforceable as a whole. At a minimum, it is appropriate to rewrite the
Executive Regulations of Law 4/1994 to make clarifications and tighten up the language.
Given the air quality problems that currently exist, vehicle emission standards should be significantly
tightened. Since vehicles are built to meet one set of standards or another, the only effective way to
accomplish this is to adopt one of the sets of U.S. or EU standards, which would harmonize Egyptian
standards with one or another of the world standards.7 First, all the technologies to achieve such
standards are available, and thus such a mandate would be technology-forcing only in the sense of
forced utilization rather than forced advancement of the state of the art. Second, for some standards the
technologies have been in use long enough that costs have been reduced to acceptable levels, and
integration of the technologies for emission control into total vehicle design has made possible the
concurrent improvement of other amenities such as fuel economy. Third, the elimination of gasoline
lead additives, which is the predicate for use of catalyst-equipped vehicles, has already been
accomplished in many urban centers in Egypt. Elimination of the remaining leaded gasoline would
remove the last technical obstacle to tightening the Egyptian mobile source standards. It would also
allow the introduction of more sophisticated vehicle technologies generally.
7
According to David Fratt, Home Office Project Officer at Chemonics International, contractor to USAID for the Cairo Air
Improvement Project, the Egyptian vehicle emissions standard from the Executive Regulations of Law 4/1994 is the standard that
is used as the pass/fail test for in-use vehicles. As such, it has a large impact on the ultimate success of the in-use vehicle testing
program. Fratt expressed concern that tightening the regulations would cause many cars to fail their inspections. Since the
median age of the cars in Cairo is around 18–20 years old (and possibly older in other areas of Egypt), and even recent vintage
cars don’t show better emissions because they don’t have emission control systems on them, we don’t see the decline in
emissions that occurs elsewhere with turnover of the fleet. For social acceptability, the rate of failure of in-use testing is around
20 percent in Egypt; the fail rate is higher than that now. Currently Egypt is not testing the general public’s cars, but only testing
captive fleets. These circumstances suggest that in the future there must be a separate test for in-use vehicles, apart from the
standard to which vehicles are certified. In addition, waiver provisions are appropriate.
2.4.2 Fuel Standards

Comparison of the world fuel standards is much easier than a comparison of the vehicle emission
standards. Fuel standards are product quality standards, directing refiners to produce fuels having
certain characteristics that affect emissions. Table 5 compares Egyptian standards with those in place in
the U.S. and EU.
Table 5. Comparison of Fuel Standards for Gasoline-fueled Passenger Cars
Fuel Requirement Egypt U.S. EU

Unleaded Availability yes yes yes
Prohibition on Leaded yes yes yes
Volatility Controls — yes —
Reformulated Gasoline — yes —
Oxygenated Fuel — yes —
Since 1973, the U.S. has had controls on gasoline quality, both to protect catalytic converters installed
to reduce emissions and to reduce the lead itself. In the 1990 Amendments to the Clean Air Act,
Congress banned leaded gasoline effective January 1, 1996, required the use of reformulated gasoline
in certain ozone non-attainment areas beginning 1995, and required the use of oxygenated fuels in
certain CO non-attainment areas. In 2000, the U.S. EPA mandated significant reductions in the sulfur
content of fuel, both to reduce sulfur emissions and to allow the tier 2 emission control devices to
function as designed.
The EU’s standards for gasoline quality trailed the U.S. by many years. The EU rules that existed did
not consolidate into specific requirements until 1989, when a mandate to supply unleaded gasoline was
first implemented. Recent actions have moved the EU toward the use of all unleaded gasoline.
However, there is no indication that further controls on fuel quality, such as volatility controls,
reformulated gasoline, or oxygenates have been required.
In gasoline quality controls Egypt does not lag as far behind as it does in vehicle emission controls.
Unleaded is widely available in Egypt, though leaded gasoline is still used universally in upper Egypt
and some locations in lower Egypt outside main urban areas. Leaded gasoline should be completely
eliminated so that programs on mobile source emission control can introduce vehicles that use catalytic
converters to reduce tailpipe emissions. However, because changes in fuel quality can reduce emissions
immediately, while requirement of vehicle emission controls on new cars relies on vehicle turnover and
can take many years to have an impact, changes in fuel quality are an expedient way to achieve mobile
source emission reductions. Two advancements in fuel quality seem worthy of further investigation.
First, given the consistent warm temperatures in Egypt, the absence of onboard vehicle evaporative
controls, and the persistence of ozone in urban areas, it seems appropriate to consider volatility controls
for fuel sold in urban areas. While many engineering and economic considerations would govern the
decision to develop such a program, the potential benefits could be large and rapid.
Second, given the development of new natural gas production in Egypt it also seems appropriate to
further expand the use of this alternative as a motor fuel. Natural gas consists principally of methane,
which does not contribute to ozone formation. It is for this reason that HC is no longer measured in the
U.S. as part of HC emissions as a pollutant — the indicator pollutant has been changed to non-methane
hydrocarbons (NMHC). While the use of gas would require some changes in vehicles (by contrast with
the usual relationship, in which the vehicle imposes requirements on the fuel), the costs of such
changes are more than recovered in lower fuel costs.8 At very little cost, tailpipe emissions could be
reduced. This option should be examined as part of any reconsideration of vehicle emission programs.
2.5 General Comments on the Standards

The foregoing discussion focuses on the specifics of the comparative analysis. Next, the discussion
turns to considerations pertaining to the standards generally.
2.5.1 Relationship of Emission and Ambient Standards

The development process for air quality regulation in the U.S., which is reviewed in Appendix B.1,
provides concrete lessons for diagnosing problems in the Egyptian system. By enabling an observer to
look at not only what is there but also at what is not, the account of the U.S. experience provides
specific signals about what is missing from the Egyptian program.
EEAA staff who were interviewed complain that there are deficiencies in the Egyptian system that
limit its effectiveness. One often-heard complaint was that it will be generally difficult to enforce more
stringent emission standards, as owners of emission sources often don’t see the justification for costs
they will be forced to bear. This reflects deeper problems in the structure of the law. Underlying this
perception is the absence of a clear justification for the standards. Why are they set at this level and not
some other? Is there any reason why they could not be waived in this specific case, given the burden
placed upon an individual business? Why now? The answers are not easily forthcoming from the
Egyptian system, for something fundamental is lacking. One turns to the U.S. example to identify what
is not there.
The U.S. experience shows that the use of emission standards by themselves is inadequate to address
modern environmental problems. The success of the U.S. air quality control program has resulted from
the recognition that the primary goal of a program has to be the protection of human health, and that
therefore a health-based ambient standard, which measures the quality of the air individuals breathe,
must be the anchor of the program. Without an ambient level to act as a reference point, all the
emission standards would have remained arbitrary, and there would have been no rationale to justify
significant commitments to emission control. While the regulatory mechanisms used to achieve
emission reductions should be selected on a pragmatic basis, and can vary considerably within the
cultural and legal context, the ambient standard is tied to human health and is universal and completely
transferable to any context.
Of course, the use of ambient targets to set emission standards depends upon being able to determine
quantitative relationships between emissions and ambient concentrations. If one starts with a desired
ambient level, the methods require working backward from effect to cause to determine the level of
emission reductions that would be necessary to achieve the ambient standards. The development of
such methodologies was a major scientific breakthrough of the 1960s.
Using this analysis only to determine if the existing emission standards in Egypt were quantitatively
comparable to world norms would fall short. Such an inquiry would miss the point that for a program
of air quality controls to be sustainable the process has to have a core rationale and methodologies
implemented to achieve it.
Analysis of the Egyptian standards makes clear that one of the principal deficiencies in the system is
the lack of a working linkage between the ambient standards and the emission standards. The adoption
8
According to David Fratt, many taxicabs have converted to run on compressed natural gas (CNG) in the past 3 years. There are
now approximately 20,000 CNG-fueled taxis running in Cairo. Natural gas prices are low, and after paying the installment loan
on the taxi’s conversion cost, the owners are saving substantial amounts of money.
of ambient and emission standards meets international expectations that it have standards in place, but
even if the standards themselves meet the world norms, the absence of linkage between the ambient
and emission standards makes their enforcement very difficult.
This expresses itself in tangible ways. It has been observed that the new industrial areas do not achieve
the ambient standard even if the emission standards are met.9 It would appear that the concept of setting
emission standards at levels necessary to achieve ambient standards is not being carried out in practice.
But is the reason that the emission standards are not stringent enough, or that facilities that claim to
comply with the emission standards are not in fact complying? Both arguments were expressed in
interviews. Moreover, the law is not clear on what EEAA officials should do when they find ambient
standards violated but emissions from facilities within their standards. Such issues will have to be
clarified for a successful program to be carried out.
In order for the Egyptian system to function effectively and provide a rationale to motivate compliance
it is necessary to link the ambient standards and emission standards logically and methodologically.
Given the goal of this task to recommended a process for reconsidering and replacing the Egyptian
standards, it is appropriate to identify the framework within which such standards should be
considered. Any process that is designed for revision of the air quality standards should use as its
starting points two central premises:
• Ambient standards should be set at levels that achieve protection of human health primarily, as
well as the environment.
• Emission standards should be set at levels that bring ambient pollutant concentrations within
the ambient standards.
The process—being able to justify the standards as they are—is a critical feature of the final product.
In sum, an essential mission of the new process will be to establish a methodologically valid
relationship between the ambient and emission standards. In modern air quality regulation there has to
be an inherent link, and the Egyptian process has to be designed to reflect it. This calls for a program
with a more scientific approach to link the emission standards with the ambient standards.
2.5.2 Guidance for Formulating New Standards: Targets and

Timetables
Defining air pollution as a problem raises the question of remedy. To translate air quality goals into
actual improvement, the remedy has to take form of a set of defined responsibilities for emission
sources. In the absence of a linkage between ambient levels and emissions, no one is responsible for the
ambient air, since no causal connection between emissions and their consequences would be
recognized. Once the policy has been clarified to establish functional roles for ambient and emission
standards, emissions from one source can be formally considered to be causally related to pollutant
levels in the ambient air, and then emission standards can be assigned as legal responsibilities.
The question thus turns to the process and the substance of determining the levels and deadlines for
standards. The choice of these critical elements should not be made on an arbitrary basis; it should be
pursuant to a consistent policy that has been determined in advance and cleared through a consensus
process. A number of considerations were raised in interviews that would affect the design of the
system.
9
According to Yasser Sherif, General Manager, Environics, interviewed May 2000.
Geographical Distinctions
Eng. Dahlia Lotayeff, Planning Director, Follow-up and Technical Cooperation Department, EEAA,
questioned whether the standards should be the same for facilities in the center of Cairo as for in the
desert of Aswan. That is, should there be some sort of system that applies different standards for
different areas? She suggested that the differences could be the basis for a permitting system.
Experience provides guidance on the potential pitfalls of geographic distinctions. For example, an early
version of air quality control in the U.S. enacted in 1967 under the Clean Air Act mandated a system
for setting emission standards based on the relationships of emission sources and downwind receptors.
The concept was that emission standards from individual sources would be linked to specific
receptors.10 While such a system is logically and economically appealing because it tailors emission
reductions to specific needs, it requires too much information. For such a mechanism to be workable,
one has to have an amount of information that is much too large and much too costly for a workable
administrative system. Lacking information to run such a system, the U.S. Congress turned, 3 years
later, to a simpler system of nationwide ambient standards as a compromise. The nationwide approach
was based on the conclusion that human health effects are universal and do not correspond significantly
to geographic location. The approach for ambient standards in the U.S. adopted under the 1970 Act
does not rely on a source-receptor relationship; sources are contemplated only in the physical
placement of monitoring devices, and receptors are disregarded completely. While the ambient
standards are the same nationwide, local authorities can make the necessary emission reductions in any
appropriate way that achieves the standards. This has resulted in a kind of national zoning in which
areas that are “in attainment” of the ambient standards operate with very different procedures from
those that are not.
Like the approach under the 1967 Clean Air Act, the suggestion of differential standards for Egypt has
the appeal of tailoring emission standards to the requirements of different regions. But given the
success of the simple approach adopted in the U.S., what are the arguments for differential ambient
standards in Egypt? Does Egypt present circumstances that warrant a different mechanism?
The main advantage, which is implied in the arguments made for differential standards, is that
differential ambient standards would allow less stringent emission standards for industrial zones or
areas that are not inhabited, while populated areas such as cities would have more stringent standards.
By not insisting on a single, universal ambient standard, it becomes possible to adopt more stringent
standards for the populated areas. If enforced, this would provide an incentive for polluting industries
to move from populated areas to industrial or unpopulated areas.
There are many downsides to this design. (1) The argument seems to suggest that industries located in
areas that are not meeting ambient standards should not be forced to make additional emission
reductions; instead, the ambient standards should be made less stringent so that additional emission
reductions by industries will not be necessary. It is a way of conforming the standards to existing
emissions. (2) By setting up classifications of air quality the GOE would acquiesce to allowing some
individuals to be exposed to harmful levels of air pollution within these zones on a permanent basis.
The U.S. and other air quality control systems are organized to provide the means to meet the ambient
goals: whatever levels are adopted, air quality that is not completely safe for humans is intended to be
eliminated. (3) It takes away incentives for industries to modernize. The current standards are not too
stringent, since they are all being met by new technologies that are available internationally. Meeting
the standards is now simply a matter of economics and resolve, and many industries may be at the point
10
The approach adopted by the 1967 Act has resurfaced in recent years under the Long-range Transport of Air Pollutants
(LRTAP) treaty, in which it is called an “effects-based” approach. While it is very attractive as a means of tailoring emission
controls to specific critical loads at which environmental damage is thought to begin, it relies on an information-intensive
mechanism that has failed in the past. Will it be possible to develop such a mechanism now, given much-improved information?
It is difficult to know. Certainly, the kind of information needed to run such a system is not available in Egypt.
where their equipment needs to be replaced anyway. (4) Moreover, if less stringent emission standards
are the goal, it might not work as planned. For example, if such a program results in transferring all the
lead smelters into one area, this would have the cumulative effect of concentrating their emissions in
one place. Then reliance on existing emission standards would not be sufficient to meet even a less
stringent ambient standard and a hot spot of concentrated pollution would result.
Given these downsides, a zoning of the country into categories of air quality is not a desirable program
design on a permanent basis, though it is worth considering as an interim strategy. One proviso is
necessary in the event such are adopted: the ambient target levels that meet health criteria should be
separated from the ambient standards, so that if standards for some classes of locations are adopted that
do not achieve the ambient targets it will be clear that these are areas that will not meet health targets.
Basis for Emission Standards
One can observe from the appendices that traditionally two classes of emission standards have been
applied:
Performance standards are applied when a target rate or mass of emissions is desired, but the means of
achieving those levels are not specified in rules. Tailpipe standards for new vehicles have traditionally
been in the form of performance standards. The current emission standards in Egypt are all
performance standards.
Technology standards are applied when the rules specify a technology to be used. Despite their name,
the new source performance standards in the U.S. have operated as technology standards, in that once a
technology has been adopted as the best available technology, its specifications become the de facto
standard.
In the U.S. both kinds of standards are applied, since both have a functional role. First, to meet the
ambient standards, performance standards are applied to individual sources. In addition, because the
most economical time to make emission reductions is when new sources are being built or major
modifications are being made to existing sources, the technology-based standards are applied in these
situations, regardless of the ambient air quality into which they will emit. The application of
technology standards to new sources is also important for equitable reasons: allowing new sources to
avoid the burden of installing best available technology while requiring existing sources to purchase
new equipment to reduce emissions would be seen as unfair. In the long run, it has been expected that
the regular turnover of equipment would provide an automatic upgrade of emission control equipment
over time that would offset the expansion in the economy, though some have taken advantage of
loopholes to avoid such upgrades.
Unlike the ambient standards, which are universal, there is no single best formula for determining
which among the types of standards will be the most suitable for a program. As a general rule, if one
expects to make progress, a guiding principle would be to mandate the more stringent of either the best
available technology standard or standards necessary to attain the ambient standards, though that is
merely a rule of thumb. More important is to provide a process with a list of alternatives on how to
decide that question. We can list criteria.
Form of Performance Standards
For performance standards that are adopted there are two forms that the standards can take:
Rate standards. Rate standards are those in which compliance is measured in terms of concentration
per volume or unit of output. This was the form many standards took initially in the U.S. It did not
impede economic growth because it allowed emissions at a fixed rate. If a firm doubled the size of a
plant the rate of emissions remained the same. Environmental groups began to criticize rate standards
because they allowed total emissions to increase with economic growth, so that, over time, standards
would have to be rewritten repeatedly so that a lower rate could be applied to compensate for higher
volume. In addition, because such standards are measured by concentration they are easy for industry
to comply with, since the actual concentration can be diluted with additional air until the standard is
met.
Mass emission standards. Mass emissions are those in which compliance is measured in terms of total
mass over a period. This approach enables one to measure the total environmental loadings; if the rate
of production of a plant increases, the plant must find a way to reduce the emissions per unit of
production. By measuring load rather than flow you can overcome the dilution problem. This approach
was suggested for Egypt by Nader Shehata Doas.
Of the two approaches, the mass emission approach is more stable over the long term. Setting standards
for the total amount of pollutant, rather than the rate of emissions per volume or unit, avoids the
necessity of going through successive changes of standards as economic growth increases production
with concomitant increases of emissions. An ideal approach that provides flexibility to industry is to set
performance standards on a mass/year basis with limits on short-term peaks to assure that acute
exposures do not reach hazardous levels. If standards are desired for new sources, a supplementary
requirement can mandate that they meet emission levels equivalent to those that would be met if the
project were financed through one of the world financial bodies such as the International Finance
Corporation (IFC), African Development Bank (AfDB), etc. The principal financial organizations that
impact world air quality standards are identified, but not analyzed in any depth, in Appendix D.
In Egypt, Article 10 of the Executive Regulations of Law 4/1994, which applies to numerous facilities
listed in Annex 2, requires an Environmental Impact Assessment (EIA).11 If it works according to
design this process would prevent the expansion of industry from increasing total load. This should be
taken into account when considering the form of the standards.
Deadlines
Under Article 1 of President Hosni Mubarak’s order promulgating Law 4/1994, a final date for
compliance with Law 4 was February 2000. This date was fixed by the date of issuance of the
Executive Regulations (1995), plus 3 years grace period, plus 2 years of extension, which yields the
date February 2000.
2.5.3 Air Quality and Public Opinion

Another reason to examine the general background for designing a new system of standard-setting is
the general perception of air quality in Egypt.
The U.S. experience, as reviewed Appendix B.1, shows that public opinion is a significant driver in the
development of air quality regulation. In the U.S., an air quality emergency in Donora, Pennsylvania in
1948 and news of a similar emergency in London, England in 1952 provided alarming examples that
human health could be harmed by the accumulation of pollutants in the ambient air. Drawing from
these examples, individuals began to recognize that they were being exposed to pollutants from sources
over which they had no control and considered it an inequity that could not be corrected through
voluntary market transactions. They turned to legislation to mandate relief.
While a scientific examination of public opinion was not made as part of this analysis, interviews,
discussions of recent events, and observations suggest that public opinion in Egypt currently is in an
ambiguous and transitional state.
11
See Egyptian Environmental Affairs Agency, Environmental Management Sector, Guidelines for Egyptian Environmental
Impact Assessment, Oct. 1996.
On the one hand, there is the background of traditional views. In the long course of Egyptian history
the experience has been, as it was in the U.S., that air pollution just blows away. The annual dust
storms, while not welcome, created an expectation that air quality problems are naturally caused and
temporary. Accustomed as Egyptians are to seeing dust, they have been traditionally conditioned to
look at poor ambient air quality without thinking of it as air pollution.12 It is not clear how well
understood is the relationship of air quality to human health. One can observe a certain degree of
acceptance of existing air quality as if conditions are not polluted. With the exception of removing lead
from gasoline, there does not seem to be a strong perception that the pollution is medically harmful and
has a cost. That is, in a city that has significant public health problems resulting from poor air quality,
air pollution is discussed as if it were a hypothetical problem.
On the other hand, consciousness of air pollution as a man-made and unnatural phenomenon may be
growing now. In the fall of 1999 an inversion, which has come to be known as “the black cloud,” raised
public awareness about air pollution. Although an inversion had occurred the previous year, this was
the first time the public became politically sensitive to it.13 It was clear that the phenomenon was
anthropogenic, and a concerned public turned to the government for explanations. Surveys of public
opinion now report high recognition of air pollution as an issue, and especially of mobile sources as a
cause of the pollution problem.14 While actual ambient pollutant concentrations during the black cloud
are subject to debate, it is clear that as a matter of perception the event is analogous to the Donora
incident in the U.S. and the London smog.15 The experience has raised public concern that may cause
decision-makers to reevaluate their views of the importance of air pollution control. This could result in
elevating consideration of ambient air quality in policy decision making, such that control of emissions
to improve ambient air quality becomes an active program.
The final measure of public opinion may depend to a large extent on the availability of air quality data,
either that collected from ambient monitoring or that estimated by the USEPA in its evaluation of the
black cloud incident. If data are made available to the public that show high ambient concentrations,
the demand for air pollution control in Egypt would increase markedly. On the other hand, if such data
are not made available, the public would never know and would not be in the position to demand a
remedy for the public health risk to which they are exposed.
The reason to consider these possibilities is that in the current state of flux one has to assess the degree
of public approval for air quality programs. The program suggested in this task will to some extent
shake up the status quo. In general principle, any program that has cost or involves perceived
sacrifice—and certainly air quality control meets those two criteria—can only go as far as public
opinion will allow. Is there the political will to implement a PM2.5 standard? Could emission standards
be enforced without being undermined by resistant industries? These outcomes depend upon the degree
of concern expressed by the public. If a genuine review of the air quality standards and the
implementation of a review process are to take place and be fully implemented, then there will have to
be a considerable increase in commitment from both the GOE and industry. For air quality programs to
have a tangible impact it is essential that they also attain a higher degree of acceptance among the
professional and scientific communities.
12
I am given the impression that many in Egypt accept air quality as it is in the belief that the current conditions are not polluted.
It appears stationary sources know that they are emitters, but they don’t think of themselves as polluters. With the exception of
gasoline lead, which was eliminated very quickly, no one in Egypt seems very motivated by the idea that the pollution is
medically harmful and has a cost. Without an explicit expression of the connection between emissions and ambient
concentrations, they don’t make that connection themselves.
13
According to Lee Pasarew, Director, Middle East Programs, Office of International Activity, U.S. EPA.
14
Interview with David Fratt.
15
According to Dr. Nasralla, the ambient pollutant concentrations in Cairo were much less than in either Donora or London, and
not much above Egyptian standards.
Thus, public opinion is important to the success of the program, and the consensus-building processes
that are planned for subsequent stages of this process will be important as means of developing
legitimacy for the processes that are envisioned.
2.6 Process: The Need for Regular Review and Revision of

Standards
As indicated in Appendix B, the prevailing notions about air quality standards have changed over time,
and one can expect that in the future with the growth of information they will change again. Until
world standards converge around a single set of precise norms—which will occur only when long-term
exposure/dose relationships have been completely studied—new information will continue to change
our perceptions of the ambient hazard.
In the past, the addition of new information has generally caused standards to be made more stringent,
as correlations of exposure levels to human health damage have been found at lower and lower levels.
This will not necessarily be the rule in the future. As information becomes more precise, uncertainty
factors will be reduced, allowing reductions in the margins of safety that now exist to cover
uncertainty. Such will offset increases in stringency, potentially even causing the standards to become
less stringent. Thus, one should think of the process as yielding more refined and targeted standards,
not standards that necessarily become increasingly difficult to achieve.
Currently, the ambient air quality standards used in Egypt suffer from numerous deficiencies, some of
them obvious. It is apparent from the review conducted here that enforcement of the standards as
presently written could result in a less-than-perfect targeting of scarce air pollution control resources.
Recognition of this problem calls upon Egypt to review its ambient standards to make them current
with world standards, and to revisit them on a regular basis to stay current as additional changes in
world standards are made.
A system of periodic review of the standards was advocated by EEAA’s Eng. Dahlia Lotayef as part of
a new system of science-based environmental targets. Precedents established in other countries suggest
how this may be accomplished. In the U.S., for example, the ambient standards are required to be
reviewed as a matter of routine every 5 years and may be reviewed more often as new information
appears. This requirement has been less than rigorously applied in practice, resulting in a routine
review of each standard every 5 to 10 years, approximately. While a routine review more often than
once every 5 years is undoubtedly a greater burden than Egypt will want to shoulder, a review cycle of
longer than once every 10 years is probably too great, given the rapid increase of information. In just
the last 10 years there has been a total revolution in the understanding of PM’s health effects. Thus, a
review cycle of 5–10 years, inclusive, would be a reasonable approach in Egypt.
Eng. Dahlia Lotayef was the strongest advocate for a system of periodic review of the standards. She
conceptualized it as part of an integrated strategy for air quality control in which decisions are made on
a scientific basis, rather than as reaction to pressures. Programmatic goals would be translated into a
strategic plan of action, then there would be a feedback system using indicators that measure the
parameters used in the regulations. In other words, periodic review would function as part of a whole
air quality management system.
3. Observations on Administration of the

Air Pollution Program
In addition to comparing the current emission standards, a second phase of the analysis involves
examining the administrative system in which the standards are implemented to make them tractable.
Thus, the next task of this task will be addressed to correcting deficiencies in the existing
administrative and legal framework.
3.1 Administration of the Air Pollution Law

Interviewees identified several problems in the administration of the law or proposed administrative
mechanisms that should be considered.
3.1.1 Procedures
EEAA officials consistently mentioned the need for clearer procedures and more authority for
enforcement. Interviewees expressed deep conviction that one of the most pressing items is removing
the constraints and limitations they confront in doing their jobs.
For example, as discussed above, Article 34 of Law 4/1994, which requires compliance with the
ambient standards, is potentially unenforceable if read literally. No administrative mechanism is
specified for enforcement and there is no legal tool to apply in cases of noncompliance. The program
works if a company volunteers to comply, but if it doesn’t meet the standard no process for addressing
that is stated. According to Dr. Ahmed Hamza, the Executive Regulations don’t specify the frequency
of sampling or the statistical significance of violation. The Regulations don’t tell when they should start
legal action. Other examples include the absence of protocols for testing the emissions of sources, the
difficulty in applying the standards to the various emission sources, the lack of definition in inspection
procedures, clarity in the administrative decision structure, and training in specific inspection
procedures and use of sampling equipment.
To have an enforcement program, the law must specify how to distribute the burden. A goal of an
overall administrative review will be to clarify responsibilities. According to Ahmed Ismael, consultant
for environmental inspection, EEAA, their work depends on regional branches. The efforts of the
branches are not sufficiently coordinated, resulting in duplication. Sometimes they cooperate,
sometimes not.
Article 5 of Law 4 describes the functions of EEAA: to develop strategy, action plans, standards, and to
operationalize those plans. A summary of relevant powers belonging to EEAA appears in Appendix A.
The powers granted under the law are broad. In general principle it appears to be possible to achieve all
the administrative changes, including issuance of new regulations, without statutory change. The
regulations should be reviewed as a legal document to provide definitions and make sure all the
essential elements are present.
3.1.2 Staff and Resources

A frequent complaint was that the programs are understaffed and the staff lack resources for the job.
According to Nader Shehata Doas, the staff assigned to monitor air emissions is too small; he has three
people, and while they are well trained, he needs at least two more. He complained he does not have
enough equipment or spare parts, and often lacks the cars to get people to their work. Due to these
limitations, inspections are not made by routine; they take measurements only when there is a
complaint against a facility. Dr. Ahmed Hamza says he lacks personnel, instruments, and political
commitment to enforce against a violation. He notes that in Annex 8 there are more than 300 limits for
indoor concentration of chemicals; he complains his staff cannot measure more than two or three of
these. As a result, that rule is useless and has no meaning.
Any program that is developed to provide a more scientific, quantitative approach will have to rely on
the resources needed to run such a program. At present, that is a clear deficiency.
3.1.3 Proposal for a Permit System

Esko Meloni, Senior Advisor to the FINIDA-funded Egyptian Pollution Abatement Project (EPAP), is
a strong advocate for establishment of a system of emission permits to implement the ambient
standards. In 1999 he delivered a conference paper that recounted the success of Finish authorities in
use of a permitting system to reduce emissions from the pulp and paper industry there.16 In Finland
permits are granted for 7 years, and at the end of that period they negotiate a plan to go on when the
permit is renewed. In the future the permit system will come under new EU legislation that integrates
water and air permits.
The system he advocates is to have quantitative standards implemented by an operating permit system
that states the amount of emissions from a specific facility. Such a permit system would consolidate all
emission requirements for a facility into one document, so that distinctions such as type of equipment
or geographical distinctions are clarified. The question is whether industry in Egypt is ready for that.
While a permit system works well in an advanced environmental culture, especially one in which
reliable data are the norm and expertise is generally available, it may be difficult to get industries to
agree to such a system in Egypt. Another problem is that a permitting system is appropriate for major
industries but does not cover emissions from sources such as trash burning, which are a large
contributor to particulate emissions in Cairo. The better argument is that a permit system in Egypt
should wait until a better air quality system as a whole has been adopted.
3.2 Development of Sound Methodologies

Following closely from the previous discussion, a second complaint heard in interviews was that the
methodologies for air pollution control are not on a sound technical basis.
3.2.1 Basis for the Standards

Interviewees consistently voiced recognition that the current standards do not have a solid scientific or
medical basis and that what would make them meaningful would be to put them on a sound basis. As a
matter of process, clearly there should be more science in the regulations and more planning in the
policy.
Eng. Dahlia Lotayef emphasized that targets should be on a scientific basis to achieve air quality, and
that these should be translated into a plan of action, standards, and a prioritized strategy. She suggested
that it would be appropriate to have a standing group to adopt the standards. She argued that Article 5
under Law 4 provides authority, although there needs to be appropriate linkage. Dr. Ahmed Hamza also
suggested a standing technical committee to review and put a long-term plan in place, based on
scientific considerations and representing various communities that should work together.
16
Esko Meloni, Development of Water Pollution Control in the Finnish Pulp and Paper Industry—A Case Study: Are There
Lessons to Be Learned?
Quantitative methods are essential to standard setting and standard enforcement, and more science
could be used to link the emission standards with the ambient standards. Developing rigorous protocols
must be part of the revision process. However, there is a risk that more methodologies will erect
barriers, and that in consequence progress will be slowed. The requirement of too much information, or
information obtained with excessive precision, can become a means of postponing implementation of
the standards.
3.2.2 Methods for Testing and Compliance

Interviewees had many complaints about the lack of clear methodologies for ascertaining compliance.
In general, they argued that nothing in the regulations indicates how compliance is to be measured or
how testing protocols are to be conducted. The regulations lack procedures that set out the parameters
for monitoring, the frequency of inspection, or other details.
For example, there were many complaints about implementing Article 42 of the Executive Regulations
(regarding combustion emissions). Several deficiencies were identified:
• Article 42(B) prescribes the use of chimneys for combustion sources that have total waste of
7,000 kg/hour or more. However, many emission sources do not have a chimney to take
emission measurements from, making it impossible to enforce the emission standards. The
problem occurs mostly in small, unregistered factories that do not have adequate technology
or facilities.
• The lack of specific testing protocols enables industries to produce compliance by changing
the engineering parameters at the time of measurement. Given the fact that inspections are
announced in advance, the absence of specific protocols gives companies the chance to
prepare stacks for inspections. One way the industries can create compliance is to open stack
vents to dilute the emissions to meet the standard.
The program needs to develop specific standardized procedures and sampling methods that have
approved quality assurance or quality control practices. Any such program will find it useful to rely on
the standard methodologies that have already been adopted and are in use by international financial
organizations or the International Standards Organization (ISO). These are available, and their use
simplifies the implementation of methodologies. As summarized in Appendix D, the world community
is attempting to develop standardized methodologies. These will be critical for success of any standard
Egypt adopts.
4. Conclusions and Recommendations

This analysis has great potential to stimulate fundamental change. It provides an uncontroversial
mechanism to develop the air quality programs and move them forward. A number of suggestions have
been made in this report that could provide a basis for progress. The next step would be to establish a
process that rewrites the Executive Regulations to Law 4/1994 and updates them on a regular basis.
Two questions remain open: what sort of program will it be, and how fast should it proceed?
4.1 The Cautious Approach

Interviewees typically recommended a cautious approach. Eng. Dahlia Lotayef suggested that
developing the system would take time: Each new system of regulation needs some time in the field to
be tested. Then any deficiencies or gaps can be seen. Unless there is a system to support regulation it is
not possible to know whether the deficiency comes from the regulation or the implementation.
However, from the view of an outsider there is really nothing that is required in Egypt that has not
already been worked out elsewhere, and no obstacle that has not already been encountered and
overcome. Given the resources and the commitment, the obstacles are actually very few.
As important as it will be to establish a relationship between the emission standards and the ambient
standards, the prospect for developing a reliable quantitative relationship of the two program elements
is currently a long way off. Such a relationship on a quantitative basis would require obtaining high
quality measurement of ambient concentrations, measuring emissions from all the significant categories
of sources, and developing an inventory from these measurements of the relative contribution of the
various source categories. From that exercise the appropriate emission reductions can be decided for
each category of sources and emission standards can be written.
4.2 Practical Steps

One readily sees that delaying action until all these steps are completed would take far too long, and
that the benefits of precision would be outweighed by the costs of delay. An interim strategy containing
two elements seems appropriate.
First, the relationship of emissions to ambient air quality should be stressed as part of a new approach.
As mentioned above, it is crucial that sources recognize that their emissions contribute to pollution, that
pollution is a public health problem with economic consequences, and that every increment in
emissions is an increment in ambient loadings. The historical example shows that the understanding of
the relationship does not have to wait for complete information. While it will not be possible to
quantify this relationship immediately, at least an Egyptian monitoring and enforcement program could
be organized in this way so that there will be a tie between ambient and emission standards that can be
made more quantitative as data becomes available.
Second, attainment of the health-based standards is unrealistic in the near term. Interviewees identified
a number of constraints—lack of resources, competition with other priorities, lack of expertise and
institutional capabilities, and lack of political will—that make attainment unlikely in any short-term
scenario. At the same time, it is not appropriate to go to the other extreme and ignore the health-based
ambient standards. There has to be a way of working toward them in a reasonable and appropriate way.
Since most emissions in Egypt are at high to uncontrolled levels, resulting in ambient pollutant levels
that cause significant damage to public health, it would be appropriate as an interim step to issue new
emission standards without waiting for signals from ambient standards. Given the state of generally
uncontrolled sources at present, one can assume that emission reductions in the short term will not
result in a condition of wasteful over control. Various technologies and the source categories that use
them should be targeted for application of new emission standards without regard to their specific
impacts on ambient loadings. That will have to wait until later.
Two approaches for such a program suggest themselves. The first is a schedule of emission reduction
targets for industries generally. This approach would apply a percentage reduction to all industries on
an annual basis, for example, “reduce SO2 emissions by 30 percent in 3 years, 50 percent in 5 years,
and 70 percent in 7 years.” It sounds reasonable and moderate. However, such a program is indifferent
to the relative costs of SO2 reductions to the various industries. More significantly, for many capital-
intensive industries a phased approach is anything but reasonable. Emission reduction equipment used
to meet the 3-year target might have to be scrapped to meet the 7-year target, long before its useful life
is exhausted. Moreover, adding emission controls to old equipment also does not make economic
sense. Given the advances that have been made in other programs, there is no technological obstacle in
most industries that would require an interim step. The first suggestion is not viable.
A second approach would be to rewrite the emission standards one industry at a time, and at the
effective date require that industry to move up to the world norm in a single step. Instead of reducing
emissions from all facilities by a specific percent in a given year, this alternative would make large
reductions in specific industries in given years. That way, instead of asking a company to reduce
emissions in multiple small increments it would be required to reduce emissions by replacing major
equipment with new equipment. The efficiencies will offset the cost of emission controls, and they will
get better products. Moreover, focusing on one industry at a time would avoid adverse competitive
effects on any one firm. It would be a rolling process, moving from one industry to the next as years
pass.
The first task would be to look at all the source categories and set up a scoring of various industries in
order to prioritize them into a schedule: industries emitting the problem pollutants (PM and its
precursors) in the largest amounts; industries with obsolete facilities that would make good targets for
renovation; industries that are capital-intensive and high profile. Emissions would fall as the process
works through the list, industry by industry. Targeting the resources to move one industry at a time is a
much more viable option.
The overriding concern will be the health and life potential of the Egyptian people. This report
concludes that it is possible to start making positive steps now.
Appendix A: The Egyptian Air Quality Program
The review begins with an assessment of the existing Egyptian air quality program, including
background information and the existing standards.
A.1 Background: Egyptian Environmental Laws

Like most law, the Egyptian environmental law grew out of experience with prior legislation.
A.1.1 Prior Efforts to Address Environmental Issues

Prior to the early 1990s, a variety of laws governed air pollution control in Egypt. This collection of
mandates resulted in a widely dispersed approach to environmental programs. Earlier studies found
authorities scattered among 17 ministries responsible for 81 laws, 34 Presidential Decrees, 17 Prime
Ministerial Decrees, 287 Ministerial Decrees, and 34 international environmental convention protocols.
This system was ineffective because of:
• Lack of awareness of the seriousness of environmental pollution by policy makers
• Outdated regulatory requirements (as of 1993, nearly 65 percent of the laws were at least 15
years old)
• Penalties set at rates that are trivial today
• Lack of a system to monitor, sample, and detect pollution
• Statement of standards for pollutants under existing laws as narrative rather than
quantitative.17
On May 8, 1992, the GOE issued the National Environmental Action Plan (also referred to as the
Egyptian Environmental Action Plan) calling for a comprehensive, long-term program to reverse the
trend toward deterioration of Egypt’s environment. Developed by EEAA with contributions from
international experts, the plan was designed along the lines of a World Bank document. It identified
several major environmental problems, including salinization of land, pollution of the Nile, and air
pollution.
A.1.2 The 1994 Environmental Law

Law 4 of 1994, known as the Environmental Law, superseded many provisions of law that had been
adopted before.
EEAA Powers
Under Law 4 of 1994 (Article 5), EEAA is given the powers to:
• Prepare draft laws and treaties
• Prepare studies and formulate a national plan for environmental protection
17
See Energy Conservation and Environment Project, “Re-design Report,” May 13, 1993. Prepared for USAID by Datex, Inc., at
IV-7 to IV-9.
A-1
A-2 Considerations for Revising Air Quality Standards in Egypt
• Set criteria and conditions that owners of facilities must meet before establishing their projects
and during operation
• Survey national organizations and institutes in preparing plans for environmental programs
• Conduct field follow-up implementing the criteria and conditions and take action against
violators
• Set rates and percentages to guarantee that the permitted limits for pollutants are not exceeded
• Gather data on the environmental situation in cooperation with data centers of other authorities
and use them in planning
• Set the bases and procedures for evaluating the environmental effect of projects
• Plan for environmental emergencies
• Conduct environmental training
• Conduct a national environmental survey and benefit by its data
• Prepare and publish periodic reports
• Conduct environmental education programs for citizens
• Propose economic mechanisms to encourage activities to prevent pollution
• Implement experimental projects
• Coordinate with the Ministry of International Cooperation
• Participate in preparing the plan to secure the country against leakage of dangerous materials.
A.2 Air Pollution Standards under Law 4/1994

Three kinds of standards are being applied under Law 4 and its Executive Regulations—ambient air
quality, stationary source emissions (including hazardous air pollutants), and mobile source emissions.
A.2.1 Health-based Ambient Air Quality Standards

Under Article 34 of the Executive Regulations, “The total amount of pollution emitted by all the
establishments in any one area must be within the permissible levels as indicated in Annex (5) of these
Executive Regulations.” Annex 5 sets out quantitative values for ambient air quality standards, as set
out in table A.1.
It should be noted, however, that Article 34 does not directly require the attainment of the ambient air
quality standards set out in Annex 5. By stating that “the total amount of pollution emitted by all the
establishments in any one area must be within the permissible levels,” it literally requires that the
emissions in an area meet the standards. A requirement that ambient air quality meet the ambient
standard would not have been stated in terms of emissions. Probably it can be inferred that what was
intended was that the ambient air meet the ambient standard, but as stated it is possibly unenforceable if
taken literally.
Appendix A: The Egyptian Air Quality Program A-3
Table A.1. Law 4/1994 Executive Regulations, Annex No. 5: Maximum Limits of Ambient Air
Pollutants
(Standards expressed as _g/m3 except for CO, which is stated in mg/m3)
Pollutant Period of Exposure a Maximum Limit (Ceiling)

1 hour 350 µg/m3
SO2 24 hours 150 µg/m3
1 year 60 µg/m3
1 hour 30 milligrams/m3
CO
8 hours 10 milligrams/m3
1 hour 400 µg/m3
NO2
24 hours 150 µg/m3
1 hour 200 µg/m3
O3
8 hours 120 µg/m3
Suspended Particles (measured as 24 hours 150 µg/m3
black smoke b) 1 year 60 µg/m3
24 hours 230 µg/m3
TSP
1 year 90 µg/m3
Respirable Particles (PM10) 24 hours 70 µg/m3
Pb 1 year 1 µg/m3
Source: Annex 5, Executive Regulations of Law 4/1994, p. 53; footnotes to the table are original to this report.
a
The averaging time is expressed as “period of exposure.” It is assumed that these are calculated in arithmetic mean. The U.S. rule is
that for any period other than an annual period, the applicable maximum allowable increase may be exceeded during one such period
per year at any one location. It is not specified if such a rule applies in Egypt.
b
The term “black smoke” as used in Annex No. 5 is not defined therein. However, it is described in the World Bank Handbook, at
III-10, where it is stated: “Black Smoke (BS) is a particulate measure that typically includes respirable particles smaller than 4.5 µm
in aerodynamic diameter, sampled by the British smokeshade method . . . . Its use is recommended in areas where coal smoke from
domestic fires is the dominant component of ambient particulates since this method is based on reflectance from carbon in elemental
form . . . . BS is roughly equivalent to PM10 . . . . . The BS measure is most widely used in Britain and elsewhere in Europe.”
The Executive Regulations also include standards for occupational air quality within the section on air
pollution. While these are interesting for comparison, they are not addressed in this report.
A.2.2 Stationary Source Emission Standards

The Executive Regulations prescribe both generally applicable standards and standards applicable to
fuel combustion sources.
Generally Applicable Standards
Article 36 of the Executive Regulations requires that stationary sources for which emission standards in
Annex No. 6 are applicable meet those standards.
Annex 6 expresses permissible limits of air pollutants in emissions in two separate tables, one for
particulates, and the second for other types of emissions. They are set out here in the same format.
Table A.2. Law 4/1994 Executive Regulations, Annex 6, Table 1: Overall Particles
(Expressed in mg/m3 of exhaust, unless otherwise stated)
Pollutant Industry Vintage Maximum Limit

(Ceiling) of Emission
Particulate Matter Carbon industry 50 mg/m3
Coke industry 50 mg/m3
Phosphates industry 50 mg/m3
Casting and extraction 100 mg/m3
of lead, zinc, copper
and other non-ferrous
metals
existing 200 mg/m3

Ferrous industries
new 100 mg/m3
existing 500 mg/m3
Cement industry
new 200 mg/m3
Synthetic woods and 150 mg/m3
fibers
Petroleum and oil 100 mg/m3
refining industries
Other industries 200 mg/m3
Source: Law 4/1994 Executive Regulations, Annex 6, Table 1; footnotes to the table are original to this report.
Note: No averaging periods are specified in the regulations.
Table A.3. Law 4/1994 Executive Regulations, Annex 6, Table 2: Maximum Limits of Gas and
Fume Emissions from Industrial Establishments
(Expressed as mg/m3 unless otherwise stated)

Aldehydes (measured as All 20 mg/m3
formaldehyde)
Antimony All 20 mg/m3
All Existing 500 mg/m3
Carbon Monoxide
New 250 mg/m3
Burning coke and petroleum Existing 4000 mg/m3
New 2500 mg/m3
Sulfur Dioxide Non-ferrous industries 3000 mg/m3
Sulfuric acid industry and other 1500 mg/m3
sources
SO3 + H2SO4 All 150 mg/m3
Nitric Acid Nitric acid industry 2000 mg/m3
Hydrochloric Acid (Hydrogen All 100 mg/m3
Chloride)
Hydrofluoric Acid (Hydrogen All 15 mg/m3
Fluoride)
Lead All 20 mg/m3
Mercury All 15 mg/m3
Arsenic All 20 mg/m3
Heavy Elements (total) All 25 mg/m3
Silicon Fluoride All 10 mg/m3
Fluorine All 20 mg/m3
Appendix A: The Egyptian Air Quality Program A-5

Tar Graphic electrodes industry 50 mg/m3
Cadmium All 10 mg/m3
Hydrogen Sulfide All 10 mg/m3
Chlorine All 20 mg/m3
Garbage burning 50 mg/m3
Carbon
Electrodes industry 250 mg/m3
Burning organic liquids Details 50 mg/m3
Organic Compounds unclear 0.04% of crude
(oil refining)
Copper All 20 mg/m3
Nickel All 20 mg/m3
Nitric acid industry Existing 3000 mg/m3
Nitrogen Oxides New 400 mg/m3
Other sources 300 mg/m3
Source: Law 4/1994, Executive Regulations, Annex 6, Table 2; footnotes to the table are original to this report.
Note: No averaging periods are specified in the regulations. These standards were derived from standards adopted by USEPA, WHO,
and ILO; there is no indication of the method used to adopt them. Some details of the standards remain unclear in the unofficially
translated version; they should be checked with the official Arabic text.
Standards Applicable to Fuel Combustion Sources
In addition to the general provisions, specific provisions apply to fuel combustion sources under Article
42 of the Executive Regulations:
(A) Precautions to minimize pollutants. Article 42(A) sets out several mandates to use sound
engineering practices in combustion, to not burn coal or mazout in populated or residential areas, to
limit sulfur content in fuel used near residential areas to 1.5 percent, and to dilute CO2 emissions by use
of smokestacks.
(B) Chimney heights. Article 42(B) specifies heights of various classes of chimneys.
(C) Limits on Emissions. Article 42(C) specifies emission limits from fuel-burning sources.
Table A.4. Maximum Limits on Emission from Fuel-burning Sources
Pollutant Maximum Permissible Limit

Smoke 1 Using Ringelmann Card
Dispersed Ashes 1 Ringelmann - sources existing in urban regions, or close to residential areas
2 Ringelmann - sources far from habitation
2 Ringelmann - burning of wastes
SO2 Existing, 4000 mgms/m3
New, 2500 mgms/m3
Aldehydes Burning of waste, 20 mgms/m3
CO Existing, 4000 mgms/m3
New 2500, mgms/m3
Source: Law 4/1994 Executive Regulations, Article 42(C).
A.2.3 Mobile Source Emission Standards

Law 4/1994 superseded Law 66/1973, which dealt with traffic and vehicle exhaust regulations. It
previously set out vehicle emission standards. As part of its new environmental regulations, Egypt
adopted the standards for passenger cars given in table A.5a.
Table A.5a. Egyptian Vehicle Emission Standards
Pollutant Existing Vehicles New Vehicles

7% volume at idle speed 4.5% volume at idle speed
CO
(600–900 rotations/minute) (600–900 rotations/minute)
1000 ppm at idle speed 900 ppm at idle speed
HC
65% darkness (opacity) or equivalent at 50% darkness (opacity) or equivalent at
Smoke
maximum acceleration maximum acceleration
Source: Law 4/1994 Executive Regulations, Article 37.
However, these standards may soon be revised. The following have been proposed as new standards
pending implementation of the Euro2 standards in Egypt for new cars:
Table A.5a. Egyptian Vehicle Emission Standards
Pollutant Private cars, taxis, light trucks Heavy duty vehicles

1.2% volume at idle speed 2% volume at idle speed
CO
220 ppm at idle speed 400 ppm at idle speed
HC
20% darkness (opacity) or equivalent at 20% darkness (opacity) or equivalent
Smoke
maximum load for diesel engines without loading (diesel engines)
Sources: Dr. Samir Mourad; Mahmoud Nasralla.
There are two important features listed in Article 37 regarding the applicability of the vehicle emission
standards:
• The standards do not necessarily apply throughout all of Egypt. The rules specify their
applicability is to be determined by a decree from the Minister of the Interior that will specify
the governorates in which these standards are applicable. The rules then become effective 1
year following that decree.
• The EEAA may reconsider the standards in coordination with the Ministries of Interior,
Industry, Health, and Petroleum 3 years after their issuance.
Overall, these provide that for the next 3 years Egypt will have emission control standards that are not
technology forcing. In fact, they are described as being at a level that late-1960s control technologies
would meet.
Appendix B: U.S. Air Quality Standards
The U.S. has been a leader in establishing air quality standards, policies, and programs. The U.S.
program is a well-developed articulation of mechanisms for combating air pollution problems, and
represents a set of approaches that must be considered in any comparative study.
The U.S. program is important for a second reason as well. Because many of the world’s air quality
conventions were first adopted in the U.S., the development of the U.S. program occurred on a blank
slate. By contrast, other countries that have adopted the conventions already established do not need to
consider the underlying fundamentals to the same extent. Such countries can simply adopt conventional
program elements in order to comply with international pollution norms without going through the
process of fundamental exploration and discovery that had taken place before. Thus, it is prudent, if
one wants to reexamine an air pollution program thoroughly, to look at not only the quantitative
standards in the U.S. program but also the policies and decision processes from which those standards
were derived, since these provide a window into the complex dimensions of decision-making.
B.1 Development of U.S. Air Quality Regulation

Because of the current structure of Egyptian environmental regulations, it is relevant to examine
selected aspects of the development of the U.S. air pollution program.18 The American experience
provides useful comparisons with perceived obstacles to progress in the Egyptian program.
Traditionally, in the Anglo-U.S. legal tradition, common-law rules governed responsibility for air
quality. These were principally liability rules for private legal action, supplemented with public
nuisance ordinances of local governments. Generally, these were designed to reduce emissions that
affected adjacent and downwind individuals. By contrast, no one gave serious thought to establishing
standards for the ambient air, that is, the unrestricted open air outside buildings. Beyond the immediate
proximity to a source, or a plume emitted from it, air pollution was assumed to disperse and not
concentrate to levels of any concern.19
In the late 19th Century, with the growth of emissions from new combustion sources such as steam
engines and electric power plants, especially those using soft coal, the incidence of urban smoke
increased to new dimensions.20 Many municipalities adopted anti-pollution laws to combat the
problems.21 These legal programs recognized the accumulation of emissions into an aggregate that
created an ambient pollution phenomenon, and early advocates for such laws even drove their publicity
campaigns on health and beauty. But the health considerations they recognized were limited in two
ways. First, they were limited to those that concerned sanitary health (cleanliness), rather than
toxicological health (disease caused by exposure to harmful or toxic chemicals). Second, while they
recognized the unsanitary effects of ordinary smoke, they did not yet recognize the true extent of
hazard resulting from exposure to it. To a large extent, they were concerned only with dense smoke,
18
This section is derived from Loeb, Alan, “Paradigms Lost: A Case Study Analysis of Models of Corporate Responsibility for
the Environment,” Business and Economic History, Vol. 28, No. 2, Winter 1999, at 95, as revised.
19
The 19th Century municipal smoke laws did not consider air pollution both toxicological and ambient. They might be
considered toxic to receptors that are immediately adjacent to the source or within a plume, but not to unrelated individuals in the
open air. Or they might be ambient in the recognition that smoke accumulates, but only as a nuisance in the sense that it is dirty
or unhygienic and not chemically toxic. To show that this works I would have to show the absence in those laws of provisions for
chemical toxicity in the open air.
20
Stradling, David, Smokestacks and Progressives: Environmentalists, Engineers and Air Quality in America, 1881-1951. Johns
Hopkins, Baltimore, 1999.
21
Loeb, A. P. and T. J. Elliott, “Looking Backward and Forward: A Review of Particulate Emission Control in the U.S.,”
presented at the meeting of the Fine Particle Society, Chicago, Illinois, August 24, 1995
B-1
B-2 Considerations for Revising Air Quality Standards in Egypt
and it was considered to be mostly a contributing factor in other diseases.22 Thus, they recognized that
in some circumstances smoke could accumulate sufficiently to become ambient, and they recognized
that it was unsightly and unhealthful, but they had very limited awareness of pollution toxicology,
certainly not enough to drive public demand for controls.
The first modern air pollution controversy in the U.S. was the introduction of lead additive for gasoline
in the 1920s. Leaded gasoline introduced the novel scenario that individuals could be harmed,
toxicologically harmed, by inhaling pollutants in the ambient air. While concerns for lead emissions
from vehicles forced the U.S. Surgeon General to consider the possibility of an ambient hazard, the
concept was too novel to be readily accepted as real, and in the absence of a concrete finding of
imminent harm the concern for ambient hazards was put aside.
The notion that the public health could be harmed in the ambient environment was reawakened a
generation later in Donora, Pennsylvania. On October 25, 1948, a temperature inversion settled over
the valley, trapping emissions from local industry. Over 6 days the inversion caused approximately 18
deaths out of a total population of 13,839; in addition, 26 percent of the population over age 55 suffered
disabling illness. A second episode, an inversion in London in December 1952 that caused 4,000
deaths, reinforced the lesson from Donora that emissions don’t just blow away and disperse, they
accumulate in the ambient air. These two episodes were a turning point in U.S. public opinion.
By the mid-1960s, the concept of an ambient level had become accepted as a regulatory construct. It
was decided that ambient standards should be set at levels deemed necessary to protect the public
health, and emissions would be reduced to levels that would achieve the ambient standards. It was not
until 1970 that this could be achieved scientifically, but the development of a model for linking
emissions to ambient concentrations cleared the way for establishing the regulatory structure that forms
the basis for the modern Clean Air Act. Thus, Congress established the Act with the belief that safe air
quality levels could be established and that these levels would drive the emission standards with
mathematical precision. Since the entire system would be mathematical in nature there was no room for
exception.
It would be very easy to overlook the lessons that produced modern air pollution control. Clearly, the
modern programs result from the recognition that ambient air pollution presents hazards to the public
health, and that emissions must be limited to those that achieve ambient levels that are consistent with
public health. This is a fundamental lesson has still not taken firm hold in Egypt but must if progress is
to be made.
B.2 Structure of U.S. Air Quality Regulation

The program for control of air pollutants in the U.S. originated in the 1960s under the Clean Air Act
and took its modern form in the 1970 Clean Air Act Amendments. It originally consisted of a simple
structure based on two fundamental distinctions:
• Regarding types of sources, it distinguished stationary sources from mobile sources; and
• Regarding types of pollutants, it distinguished between ambient air pollutants and hazardous
air pollutants.23
22
Stradling, supra, at 51.
23
The separation of air quality standards into two classes, conventional air pollutants and hazardous air pollutants, derives from
the historical experience in the U.S. of distinguishing between pollutants that cause damage from indirect exposure to a pollutant
concentration in the open air and those that cause damage from direct exposure to a pollutant concentrated at its source or in a
plume of emissions. The distinction is not essential to air pollution control programs—indeed, it is not generally followed in
other programs—but simply reflects the American experience in developing air pollution programs. It is worth noting that in
making the distinction of the classes categorical, the Act assumed that no pollutant could be both emitted by numerous or diverse
sources and highly toxic. Subsequent experience has proved this assumption to be invalid.
Appendix B: U.S. Air Quality Standards B-3
Within those fundamental categories further distinctions were made between state and federal
responsibilities, between new sources and existing sources, and so on. It is to be noted that the 1970
Act did not create a program for hazardous substances for mobile sources. Since hazardous air
pollutants from mobile sources were not contemplated under the 1970 Act, it is shown in table B.1 as
an empty cell.
Based on these distinctions, air pollutants covered by the Clean Air Act can be organized into a
conceptual matrix, shown in the table. It is obvious from the matrix that the Act is an ambitious attempt
to control a variety of air pollution problems with numerous programs.
Table B.1. Conceptual Organization of the Clean Air Act (as amended 1970)
Pollutant Type a Stationary Sources Mobile Sources

Conventional Pollutants - primary States - attainment of NAAQS left Strictly federal (states preempted
and secondary ambient air pollutants to states, which must adopt State except California)
(based on criteria pollutants Implementation Plans (SIPs) to -Auto emission standards (tailpipe
identified by HEW) show plan for attainment; federal and evaporative) and automotive
-Toxic potency - harmful to human government enforces SIP process fuels
health after prolonged exposure, Federal - new source performance -Aircraft emission standards and
possible secondary impacts to the standards fuels
environment
-Sources - results from numerous or
diverse sources whose emissions are
widely dispersed; exposure
measured in open air
Hazardous Air Pollutants - -National emission standards for [none]
-Toxic potency - hazardous to hazardous air pollutants (NESHAPs)
human health in small quantities or
brief exposure
-Sources - relatively few, risk is
greatest at point of emission or in
path of plume; maximum exposure
traditionally measured at the
fenceline of emission source
a
Copyright, 1997, A. Loeb.
The structure of the Act has become far more complex over time, mostly due to amendments to the Act
in 1977 and 1990. First, regarding types of pollutants, new categories of pollutants were added (i.e.,
additional sub-categories of conventional pollutants and the category of global pollutants). As a result,
the Act now distinguishes three major categories of pollutants: conventional pollutants (including
health-based ambient pollutants, acidification, and visibility), hazardous air pollutants, and global air
pollutants (stratospheric ozone depletors, and greenhouse gases). Second, programs to control these
pollutants were variously added, amended, and replaced, but for the most part greatly expanded. With
these changes, the structure of the Act can be described as in table B.2.
Table B.2. Conceptual Organization of the Clean Air Act (as amended 1990)
Pollutant Type a Stationary Sources Mobile Sources

Conventional Pollutants- primary States - attainment of NAAQS left Principally federal (with exceptions
and secondary pollutants to states, which must adopt SIPs to for California and other states under
1- Criteria Pollutants show plan for attainment; federal conditions)
government enforces SIP process -Auto emission standards (tailpipe
-Toxic potency - harmful to human
health after prolonged exposure, Federal - and evaporative) and automotive
possible secondary impacts to the -New source performance standards fuels
environment -Prevention of significant -Aircraft emission standards and
-Sources - results from numerous or deterioration (PSD), added 1977 fuels
diverse sources whose emissions
are widely dispersed; exposure
diverse sources whose emissions deterioration (PSD), added 1977 -Standards for consumer products
are widely dispersed; exposure such as lawn mowers and chain
measured in open air saws
-Includes CO, NO2, SO2, Pb, O3,
PM10, and PM2.5
2- Visibility and Other Air Quality- Prevention of deterioration of air No provisions
related Values quality in Class I areas
3- Acidification- secondary effects Acid rain program (Title IV) -Parallel provisions for sulfur
of two criteria pollutants -SO2- mandated reductions via reduction in fuels under Title II
market-based program
-NOx- technology-based standards
Hazardous Air Pollutants -National emission standards for -Vehicle emission standards -
-Toxic potency - hazardous to hazardous air pollutants provisions under § 202(l)
human health in small quantities or (NESHAPs) -Fuels standards - specifications of
brief exposure, listed in 112(b)(1) -Maximum achievable conrol reformulated gasoline (RFG)
-Sources - relatively few, risk is technology (MACT) standards for designed to reduce toxics
greatest at point of emission or in HAPs
path of plume; maximum exposure -Accidental release program for
traditionally measured at the extremely hazardous substances
fenceline of emission source -Special program for municipal solid
waste
Global Air Pollutants 1-Stratospheric ozone depletors - ban on production of ozone depleting
-Impacts - harmful to global substances; restrictions on use of existing supplies
resources, the degradation of
human health, and the environment
2-Greenhouse gases (GHGs) - CO2 and equivalents [by treaty]
-Sources - results from numerous or
diverse sources whose emissions
are widely dispersed; exposure
a
Copyright, 1997, A. Loeb.
This is a highly developed approach, with different programs tailored to fit different pollutants, and its
resource requirements are well beyond the means of many other countries. In light of this, this report
will only closely examine three types of pollution control programs—ambient air quality standards,
stationary source emission control standards, and mobile source emission control standards, which are
the same three types of standards found in the Egyptian law.
B.3 Air Quality Standards

As noted above, the Clean Air Act prescribes three categories of air quality standards—for
conventional pollutants, hazardous air pollutants, and global pollutants. Three programs that have
relevance to Egyptian air quality are examined here.
B.3.1 Health-based Ambient Air Quality Standards

The Clean Air Act prescribes very specific procedures for establishing and attaining the health-based
ambient standards.
Process for Establishment and Periodic Review of Ambient Standards
Since 1963, the federal government has been tasked with producing studies of ambient air pollution
levels for health effects. Currently these studies, known as “criteria documents,” are produced by the
research office at EPA. After 1970, in addition to the health-based primary standards, criteria were also
set for secondary standards.
Each standard represents three components:
• Level–a quantity representing the concentration in parts per million (ppm) in the ambient air.
• Averaging Time–a period of time in which the measurements are taken, set according to the
temporal nature of the pollutant hazard, and for which the standard level is the average.24
• Form–the number of exceedances, traditionally one per averaging period, that will be accepted
as compliance with the standard.
EPA is required to reconsider the ambient standards in a 5-year review cycle. The criteria document is
reviewed by the Clean Air Science Advisory Committee (CASAC) and others in a public forum and
revised if necessary. A Staff Paper is prepared by the EPA Office of Air and Radiation based on the
criteria document to determine what are the factors the Administrator should consider in setting the
standard. The staff paper is open to CASAC and public comment.
After review there is closure on the Staff Paper, and it is presented to the Administrator with
recommendations. The Administrator makes a decision to reaffirm or change the standard and formally
proposes that decision. Public hearings are held and a final decision issued, along with the reference
method and other implementation rules.
Once the EPA Administrator has issued a standard and reference method, it goes to the states, which
have the responsibility for making emission reductions from individual sources to meet the standard.
Federal emission control requirements, which apply only in specific circumstances (see below), may
also contribute to emission reductions. It is the responsibility of states to make sure that the emission
reductions in total are sufficient to attain the ambient standards.
National Ambient Air Quality Standards

The Clean Air Act of 1970 ordered EPA to issue ambient standards for the five pollutants—carbon
monoxide (CO), sulfur dioxide (SO2), hydrocarbons (HC), total suspended particulates (TSP), and
photochemical oxidants—for which NAPCA had already written criteria documents. At the time these
were issued EPA added one more pollutant, nitrogen dioxide (NO2), making it six in total. Prior to
1990, EPA dropped HC,25 added Pb.26 and changed the indicator pollutants for two
pollutants—photochemical oxidants was changed to ozone (O3), and TSP was changed to particulates
with an aerodynamic diameter of 10 microns or less (PM10). After these changes the number of
standards remained at six.
In 1997, EPA amended the standards for PM10 and ozone, and added a new particulate standard, PM2.5,
because of evidence that these finer particles cause the most significant health effects. Thus, the current
primary and secondary ambient standards consist of seven standards, five gaseous pollutants (CO, O3,
SO2, Pb, NO2) and two particulates (PM10 and PM2.5). These are set out in table B.3.
However, on judicial review of EPA’s 1997 action, the Washington D.C. Circuit Court in American
Trucking Assns. v. EPA (No. 97-1440, opinion issued May 14, 1999), vacated the PM10 standard
entirely and remanded the PM2.5 standard to EPA for reconsideration. On rehearing, issued October 29,
1999, the court reaffirmed its prior PM findings. Thus, the future of the new standards remains
24
Different averaging times may be needed for a pollutant because the time pattern of concentrations can be a determining factor
in whether the pollutant causes an adverse effect. For example, total dose of a pollutant over a relatively long period may be more
important for one adverse effect, whereas dose rate over a relatively short period may be more important for another adverse
effect of the same pollutant. In such a case two different averaging times may be needed.
25
48 Fed. Reg. 628 (1983). Although HC was dropped as an ambient pollutant, it continued as an auto tailpipe standard because
of its role as a precursor to ozone.
26
43 Fed.Reg. 46246 (Oct. 5, 1978).
uncertain at this time. While it is expected that EPA will continue to support the existence of standards
for O3, PM10 and PM2.5, their standard level concentrations or averaging times may be changed
somewhat in the near future.
Implementation of Ambient Standards
Under Section 110 of the Act, states are required to adopt State Implementation Plans (SIPs), which are
in effect commitments by them to implement controls that will bring ambient air quality levels in the
air quality control regions under their jurisdictions within the national ambient air quality standards.27
B.3.2 Visibility Standards

A second U.S. program for conventional pollutants that has implications for Egypt is the visibility
program. The program for attainment of the health-based ambient standards under the 1970 Act was
designed to reduce emissions in areas where they were most concentrated, but it did not explicitly set
out a program to deal with already-clean areas. If stringent regulations were applied to polluted areas,
that would give industries the incentive to relocate plants to areas that were not already polluted. But
that would result only in moving the pollution around, to the detriment of clean areas. To comply with
a court order,28 EPA established a program for prevention of significant deterioration (PSD) in 1974.29
Congress formally adopted a PSD program in amendments to the Act in 1977, which was to be
implemented as a permitting system. As part of these amendments, Congress adopted two programs for
visibility regulation.
New sources and major modifications. As part of the PSD program, visibility was identified as an “air
quality related value” to be considered in the permitting of new sources and major modifications to
existing emission sources.
Existing sources. The Amendments mandated a program to protect visibility in certain areas, affecting
even existing pollution sources.
Table B.3. National Ambient Air Quality Standards (as amended 1997)
Primary Standards Secondary Standards

Pollutant Standard Level Standard Level
Averaging Time Averaging Time
Concentration a Concentration a
Annual Arithmetic Mean b 50 µg/m3 Same as Primary
PM10
b
24-hour 150 µg/m3 Same as Primary
b 3
Annual Arithmetic Mean 15 µg/m Same as Primary
PM2.5 b 3
24-hour 65 µg/m Same as Primary
c
Annual Arithmetic Mean (0.03 ppm) 3-hour 1300 µg/m3 (0.50
SO2
80µg/m3 ppm)
27
The states were required to provide a schedule in their SIPs for attainment of NAAQS no later than 3 years from date of SIP
approval by EPA. If the schedule were strictly kept, that would have been approximately June 1974, although most
commentators will say that the requirement was for compliance in 1975. The 1977 Amendments extended the compliance
deadlines to December 31, 1982 for NAAQS, but in the case of CO and photochemical oxidants where a state demonstrates that
attainment is impossible despite its use of all reasonably available measures the deadline was extended to December 31, 1987.
However, further postponements were made. The Steel Industry Compliance Extension Act of 1981 provided an extension of
compliance dates for steel companies. In the Clean Air Act Amendments of 1990 Congress established many specific new
provisions for attainment programs.
28
Sierra Club v. Ruckelshaus, 344 F.Supp. 253 (D.D.C. 1972), aff'd per curiam without opinion (D.C. Cir. 1972), aff'd by an
equally divided Court without opinion sub nom. Fri v. Sierra Club, 412 U.S. 541 (1973). Visibility, particularly in Western
national parks such as the Grand Canyon, was the primary concern of the Sierra Club. R. Melnick, Regulation and the Courts:
The Case of the Clean Air Act (Brookings, 1983) 81. See T. Disselhorst, Sierra Club v. Ruckelshaus: "On A Clear Day ...", 4
Ecol. L. Quart. 739 (1975).
29
39 Fed.Reg. 42,510 (1974), codified at 40 C.F.R. Part 51.
24-hourc (0.14 ppm)

365 µg/m3
8-hourc 9 ppm None
(10 mg/m3)
CO
1-hourc 35 ppm None
(40 mg/m3)
Annual Arithmetic Mean 0.053 ppm Same as Primary
NO2
(100 µg/m3)
8-hourd 0.08 ppm Same as Primary
(157 µg/m3)
O3
1-hourd 0.12 ppm Same as Primary
(235 µg/m3)
Maximum Quarterly 1.5 µg/m3 Same as Primary
Pb
Average
Source: U.S. EPA, “National Air Quality and Emission Trends Report,” 62 Fed.Reg. 38652-38896 (Jul. 18, 1997).
a Parenthetical value is an approximately equivalent concentration used by EPA.
b TSP was the original indicator pollutant for PM standards. The primary standards were 260 µg/m3 for 24-hour average and 75
µg/m3 for annual average, and the secondary standard was 150 µg/m3 for 24-hour average; the secondary standard was not to be
exceeded more than once per year. This standard was replaced with the PM10 standard in 1987 (particles less than 10µm in diameter,
which are inhalable) as the new indicator pollutant. The TSP standard is no longer in effect. In 1997 EPA added a PM2.5 standard
because of evidence that those particles cause the most significant health effects. The annual standard for PM10 is attained when the
3-year average annual arithmetic mean concentration is less than or equal to 50 µg/m3; the 24-hour standard is attained when the
expected number of days per calendar year above 150 µg/m3 is equal to or less than 1. The annual standard for PM2.5 is spatially
averaged over designated monitors; for the 24-hour standard the form is the 98th percentile.
c Not to be exceeded more than once per year.
d The 8-hour standard is attained when the 3-year average of the fourth-highest daily maximum 8-hour concentrations is less than or
equal to the standard. The 1-hour standard is attained when the maximum hourly average concentration is less than or equal to the
standard, with one exceedance allowed per year.
As noted, the visibility standards are implemented principally through the permit process. By contrast,
the visibility provisions for existing sources, while important to critical scenic areas, are among the
least-enforced provisions of the Act.
B.3.3 Hazardous Air Pollutants

The Act creates a distinct category of national standards for separate treatment.30 By contrast with the
ambient standards, which are measured by their concentration in the open air, the point of exposure to
hazardous air pollutants is assumed to be at the fenceline of a plant that contains the source, where the
pollutants may be most concentrated. In this way the treatment of hazardous air pollutants reflects the
traditional assumptions that (1) pollutants naturally disperse in the open air, and (2) that the cause of
damage (and hence the basis for regulation) is the source-receptor relationship.
The hazardous air pollutants are given a distinct approach in their regulatory treatment. Since they are
not measured in the ambient air, there is no standard for their concentration in the open air. Instead,
they are controlled directly through emission standards. Since these pollutants are much more toxic
than the criteria pollutants, and exposure is assumed to be in concentrated form rather than diluted by
dispersion, the standards for these pollutants are much more stringent than those for the ambient
pollutants.
Regulation of HAPs Before 1990
30
This section is derived from Loeb, Alan, “Air Toxics Provisions of the Clean Air Act Amendments: Regulatory Issue
Analysis,” Report to the U.S. Department of Energy, 1992.
Under Section 112 of the 1970 Act, EPA was required to identify and list air toxics, and then apply
standards to control them with an adequate margin of safety.31 These were known as the National
Emission Standards for Hazardous Air Pollutants (NESHAPs).
Section 112 established a definition of HAPs and delegated to EPA the task of identifying and listing
those pollutants that met the definition. Section 112(a)(1) defined HAPs as those substances that caused
air pollution resulting in “ . . . an increase in mortality or . . . serious irreversible, or incapacitating
reversible, illness.” By definition, no HAP could also be a pollutant for which an ambient standard had
been established. Over time, EPA developed risk assessment methodologies to identify the substances
that met that definition.
The program established under the 1970 Act is generally regarded as a failure. Section 112(b)(1)(B)
required that standards for HAPs be set “ . . . at the level which . . . provides an ample margin of safety
to protect the public health from such hazardous air pollutant.” Because of the margin of safety
requirement, the only standards that could be set for substances that do not have identifiable health
thresholds (i.e., levels below which no health detriments can be detected) was zero. And because the
deadlines for issuing controls for a pollutant once EPA listed it were so stringent, EPA simply avoided
listing pollutants.
As a result, during the 20 years before the enactment of the 1990 Amendments, EPA listed only eight
pollutants. Three of those (asbestos, beryllium, and mercury) were listed within 90 days of enactment
of the 1970 Act to comply with its mandate that EPA immediately list HAPs for which it intended to
apply standards.32 The other five were listed sporadically thereafter. The last HAP listed for which
emission controls were issued was in 1980. EPA promulgated standards for seven of the eight listed
pollutants (see table B.4).33 At the time of enactment of the Clean Air Act Amendment (CAAA),
proceedings to establish standards for the eighth listed HAP, coke oven emissions, were ongoing.
Under the savings provision of the 1990 CAAA, Section 112(q), these standards remain in force.
Table B.4. Hazardous Air Pollutants and Source Categories Established

by November 15, 1990
Listed Air Citation (date) of Source Categories Subject to Controls

Toxics Listing a (§ in 40 C.F.R. Part 61)
Asbestos 36 Fed. Reg. 5931 Asbestos mills (§ 61.142), inactive asbestos mill waste
(Mar. 31, 1971) disposal sites and manufacturing and fabricating operations (§
61.151), active waste disposal sites (§ 61.143), and operations
that convert asbestos-containing waste material to asbestos-
free material (§ 61.155)
Beryllium 36 Fed. Reg. 5931 Extraction or processing plants for ore or beryllium
(Mar. 31, 1971) compounds, and for machine shops which work with beryllium
(§ 61.30), and rocket motor test sites (§ 61.40)
Mercury 36 Fed. Reg. 5931 Sources which process mercury ore, use mercury chlor-alkali
(Mar. 31, 1971) cells to produce chlorine gas and alkali metal hydroxide, and
incinerate or dry wastewater treatment plant sludge (§ 61.50)
Vinyl Chloride 40 Fed. Reg. 59532 Plants that produce ethylene dichloride, vinyl chloride, and/or
(Dec. 24, 1975) polymers containing any fraction of polymerized vinyl
chloride, but not equipment used in research if the equipment
does not have a capacity greater than 50 gallons (§ 61.60); (see
also
§ 61.240)
31
42 U.S.C. § 7412.
32
The Clean Air Act, § 112(b)(1)(A) (1970).
33
Provisions for air toxics are found generally under 40 C.F.R. Part 61.
Listed Air Citation (date) of Source Categories Subject to Controls

a
Toxics Listing (§ in 40 C.F.R. Part 61)
Benzene 42 Fed. Reg. 29332 Various benzene equipment (fugitive emissions) (§ 61.110),
(June 8, 1977) coke by-product recovery plants (§ 61.130), benzene storage
vessels (§ 61.270), benzene transfer facilities (§ 61.300),
chemical plants, coke by-product plants, petroleum refineries,
and hazardous waste treatment, storage and disposal facilities
(§ 61.340) (proposed to be stayed, see 56 Fed. Reg. 64217
(Dec. 9, 1991); (see also § 61.240)
Radionuclides 44 Fed. Reg. 7738 Underground uranium mines (§ 61.20) and uranium mill
(Dec. 27, 1979) tailings (§§ 61.250 and 61.220 (partly stayed, see 56 Fed. Reg.
67537)), DOE facilities (§§ 61.90 and 61.190), NRC-licensed
facilities and non-DOE federal facilities (§ 61.100), elemental
phosphorus plants (§ 61.120) (proposed to be amended, see
56 Fed. Reg. 46252 (Sep. 11, 1991)), and phosphogypsum
plants (§ 61.200)
Arsenic 45 Fed. Reg. 37886 Glass furnaces (§ 61.160), primary copper smelters (§ 61.170),
(June 5, 1980) and metallic arsenic and arsenic trioxide plants (§ 61.180)
Coke Oven 49 Fed. Reg. 36560 Rulemaking began in EPA Docket No. A-83-33; addressed
Emissions (Sep. 18, 1984) specifically in CAAA; new proposed rule produced by reg-neg
proceedings
Note: In addition to the eight substances listed here, EPA published notice of intent to list an additional 25 substances as air toxics.
See 40 C.F.R. § 61.01(b).
a Citation of original listing only; additional citations are found in the relevant C.F.R. subparts.
Regulation of HAPs under the 1990 Amendments

Frustrated with the slow pace of EPA’s risk-based listing process, Congress decided to take the listing
function away from EPA. In the 1990 Clean Air Act Amendments, Congress replaced the existing
program under section 112 with a new program that established a list of pollutants and a rolling
regulatory program to set emission limitations for them. Under Section 112(b)(1) (1990), the CAAA
established a list of 189 hazardous air pollutants for EPA to control by regulation. Section 112(b)(2)
allows EPA to add or delete compounds from the (b)(1) list. EPA granted a petition to de-list the listed
substance caprolactam, bringing the list to 188. Given the state of toxicity knowledge, the (b)(1) list
represents the legislative judgment that the public should not have to wait for full risk assessments to
be done on individual substances, and that erring on the side of over-control is warranted.
Section 112 employs a two-phase control strategy for sources of HAPs. During Phase I, under authority
of Section 112(d), technology-based standards are to be set for specific source categories. These must
apply the maximum achievable control technology (MACT). Existing sources must meet the standards
within 3 years of their issuance. During Phase II, EPA must evaluate the residual risk remaining after
the installation of MACT controls and report to Congress, which may determine whether additional
controls are necessary.
Section 112 proceeds by a process of rolling issuance of the MACT standards: EPA is required to
develop a list of source categories and rank the categories into four priority tiers. EPA will then
proceed through the category list category-by-category, in order of priority rank, to set standards for
each of the HAPs emitted by each category. Phase II follows this rolling schedule: within 8 years of the
promulgation of the original MACT standards (9 years for the first tier regulated), EPA must issue
residual risk standards for each of the categories.
The current program for hazardous air pollutants is too complex to list in detail here. With regulations
setting emission standards for several hundred source categories covering 188 pollutants, it is far
beyond the resources of this task to analyze here. However, the substances listed as NESHAPs prior to
1990 are the same as some of those listed as ambient air pollutants in other programs, making a
comparison possible.
B.4 Stationary Source Emission Standards

For regulatory treatment, stationary sources are categorized into new sources and existing sources.
B.4.1 New Sources

The Clean Air Act requires that new sources and major modifications to existing sources install best
available technologies. This term refers collectively to the NSPS or the two technology standards under
NSR: best available control technology (BACT), and lowest achievable emission rate (LAER). Most
new stationary sources are required to meet a BACT, placing much of the burden of improvement on
new sources rather than on existing sources to achieve air quality improvements, except where existing
sources make major modifications.
While these requirements establish a technology-forcing function upon plant/equipment retirement and
renovation, it also grandfathers existing sources into their emission rates—essentially uncontrolled—so
long as they do not take the actions that trigger a best available technology review. Thus, as time passes
the technologies used and the corresponding emission rates fall into two classes—those that have
undergone a best available technology review and those that remain grandfathered. Moreover, with
time, as the state of the art advances, the performance of the best technology will improve, so that the
difference between emission characteristics of the grandfathered sources and the new sources will grow
greater. This could result in very different projections of emissions.
Table B.5. NSPS Issued for Select Source Categories
Source Category Pollutants and Emission Limitations Implied Control

(Operating Practices, Certification, etc. Omitted) Technologies
Municipal waste combustors PM: Not to exceed (NTE) 34 milligrams per dry standard cubic
(MWCs) with unit capacity meter (0.015 grains per dry standard cubic foot), corrected to 7%
> 250 tons/day, constructed oxygen (dry basis) [approx. 97% removal]; 10% opacity
before 12/20/89 standard
Dioxin/furan: NTE 30 mg/dry standard cubic meter (12 grains
per billion dry standard cubic feet, corrected to 7% oxygen (dry
basis)
SO2: NTE 20% of potential emissions rate (i.e., 80% reduction
by wt. or vol.), or 30 ppm by vol. corrected to 7% oxygen (dry
basis), whichever is less stringent
HCl: NTE 180 ppmv, corrected to 7% oxygen (dry basis)
Sulfuric acid production SO2: NTE 2 kg SO2/metric ton of acid produced (4 lb/ton),
units production expressed as 100% sulfuric acid
Sulfuric acid mist: NOTE 0.075 kg/metric ton of acid produced
Opacity: NTE 10%

Fossil-fuel fired steam PM: NTE 43 nanogram per joule (ng/J) heat input
generators (construction (0.10/mmBtu); not more than one 6-minute period of > 20%
begun after 8/17/71) opacity
SO2:
-Liquid fuel (or w/wood)- NTE 340 ng/J heat input (.80
lb/mmBtu)
-Solid fuel (or w/wood)- 520 ng/J heat input (1.2 lb/mmBtu)
Nox:
-Gaseous fuel- 86 ng/J heat input (0.20 lb/mmBtu)
-Liquid fuel (or w/ wood)- 129 ng/J heat input (0.30 lb/mmBtu)
-Solid fuel (or w/wood)- 300 ng/J heat input (0.70 lb/mmBtu)
-Lignite fuel (or w/wood)- 260 ng/J heat input (0.60 lb/mmBtu)
->25% lignite fuel (or w/wood) mined in ND, SD or MT and
burned in a cyclone fired unit- 340 ng/J heat input (0.80
lb/mmBtu)
Electric utility steam PM: Standard was
generating units -All plants- NTE 13 ng/J heat input (.03 lb/mmBtu) intended by EPA
(construction begun after to be technology-
9/18/78) -Liquid fuel- NTE 30% of potential combustion concentration forcing; utilities
(70% reduction) could only meet
-Solid fuel- NTE 1% of potential combustion concentration; the SO2 standard
with FGD
Not more than one 6-minute period of > 20% opacity
(scrubber) systems
SO2:
-Liquid or gaseous fuel- 340 ng/J heat input (0.80 lb/mmBtu)
and 10% of potential combustion concentration, or 100% of
potential combustion concentration when emissions < 86 ng/J
(0.20 lb/mmBtu heat input);
-Solid and solid-derived fuel- 520 ng/J heat input
(1.20 lb/mmBtu) and 10% of the potential combustion
concentration (90% reduction); when emissions < 260 ng/J (0.60
lb/mmBtu) heat input, facilities may emit 30% of their potential
combustion concentration (70% reduction).
-Solid solvent refined coal- NTE 520 ng/J heat input (1.20
lb/mmBtu) and 15% of potential concentration
NOx:
-Gaseous fuel- from coal: 210 ng/J heat input (0.50 lb/mmBtu);
all other fuels: 86 ng/J heat input (0.20 lb/mmBtu)
-Liquid fuel- from coal or shale: 210 ng/J heat input (0.50
lb/mmBtu); all others: 130 ng/J heat input (0.30 lb/mmBtu)
-Solid fuel- bituminous, anthracite and fuel containing > 25%
lignite (w/conditions): 260 ng/J heat input (0.60 lb/mmBtu);
subbituminous and coal-derived: 210 ng/J heat input (0.50
lb/mmBtu)
->25% lignite fuel (or w/wood) mined in ND, SD or MT and
burned in a slag tap furnace- 340 ng/J heat input (0.80
lb/mmBtu)
-Fuel containing >25% coal refuse- no standard

Industrial-commercial- PM:
institutional steam -Coal- NTE 22 ng/J heat input (.053 lb/mmBtu)
generating units, applies to
units with capacities > 29 -Wood, MSW, mixtures, or oil- NTE 43 ng/J heat input (0.10
MW lb/mmBtu);
SO2: NTE 10% of potential SO2 emission rate (90% emission
reduction) or a limitations expressed in the following formula: Es
= (KaHa + KbHb)/(Ha + Hb), where Es is the SO2 emission limit,
Ka is 520 ng/J, Kb is 340 ng/J, Ha is the heat input from
combustion of coal in J, and Hb is the heat input from
combustion of oil in J
NOx:
-Natural gas and distillate oil- high heat release rate: 86 ng/J heat
input (0.20 lb/mmBtu); low heat release rate: 43 ng/J heat input
(0.10 lb/mmBtu)
-Residual oil- high heat release rate: 170 ng/J heat input (0.40
lb/mmBtu); low heat release rate: 130 ng/J heat input (0.30
lb/mmBtu)
-Coal- mass-feed stoker and coal-derived synthetic fuels: 210
ng/J heat input (0.50 lb/mmBtu); spreader stoker and fluidized
bed and lignite: 260 ng/J heat input (0.60 lb/mmBtu); pulverized
coal: 300 ng/J heat input (0.70 lb/mmBtu); lignite mined in ND,
SD or MT and combusted in slag tap furnace: 340 ng/J heat
input (0.80 lb/mmBtu)
-Duct burner in combined cycle system- natural gas and
distillate: 86 ng/J heat input (0.20 lb/mmBtu); residual: 170 ng/J
heat input (0.40 lb/mmBtu)
Small industrial- SO2:
commercial-institutional -Oil-fired units- NTE 215ng/J (0.5 lb/mmBtu)
steam generating units,
applies to units with -Coal-fired units- NTE 10% of potential SO2 emissions (90%
capacities from 2.9 MW to reduction) or 520 ng/J (1.2 lb./mmBtu)
29 MW -Coal refuse- NTE 20% of potential SO2 emissions (80%
reduction) or 520 ng/J (1.2 lb./mmBtu)
-Emerging technologies- NTE 50% of potential SO2 emissions
(50% reduction) or 260 ng/J (0.6 lb./mmBtu)
-Others- 520 ng/J (1.2 lb./mmBtu)
PM: for facilities with capacity > 8.7 MW
-Coal-fired (< 10% other fuels)- 22 ng/J (0.05 lb/mmBtu)
-Coal and other fuels- 43 ng/J (0.10 lb/mmBtu)
-Wood or wood and other fuels- for capacity > 8.7 MW, 43 ng/J
(0.10 lb/mmBtu); for capacity < 8.7 MW, 130 ng/J (0.30
lb/mmBtu);
Nitric acid plants NO2: NTE 1.5 kg/metric ton of nitric acid produced
Opacity: NTE 10%

Petroleum refineries SO2: no refining facility (except when burning to produce sulfur
or sulfuric acid) may burn fuel gas containing hydrogen sulfide
in excess of 230 mg/dscm except as emergency
-FCC unit catalyst regenerators- subject to any of three
alternatives: (1) reduce SO2, averaged over 7 days, or to 50 ppm
by volume; (2) SO2 emissions < 9.8 kg/1000 kg coke burn-off;
(3) limit fresh feed to sulfur content of 0.3% by weight, averaged
over 7 days.
-Claus sulfur recovery plants- NTE 250 ppm by vol. if controlled
by oxidation control system or other system followed by
incineration; or 300 ppm by vol. of reduced sulfur compounds
(hydrogen sulfide, carbonyl sulfide, and carbon disulfide) and 10
ppm hydrogen sulfide if controlled by system not followed by
incineration
PM:
-FCC unit catalyst regenerators- NTE 1.0 kg/1000 kg of coke
burnoff; not more than one 6-minute period of > 30% opacity per
24-hour period
-FCC emissions that pass through incinerator or waste heat
boiler in which auxiliary fuel is burned- NTE 43.0 g/MJ or 0.10
lb/mmBtu.
CO:
-FCC unit catalyst regenerators- NTE 500 ppm by vol. (dry
basis)
Volatile organic liquid Volatile organic liquids:
storage vessels (including -Vessels w/ > 151 m3 capacity and true vapor pressure > 5.2 kPa
petroleum liquid storage but < 76.6 kPa or > 75 m3 but < 151 m3 containing VOL with
vessels) (construction, true vapor pressure of 27.6 kPa or more but < 76.6 kPa- must be
reconstruction or equipped with any one of the following: (1) fixed roof in
modification commenced combination with internal floating cover equipped with seal
after 7/23/84) between tank wall and edge of the floating roof; (2) external
floating roof with double seal system between tank wall and
floating roof; (3) closed vent system and a 95% emission control
device; any equivalent
-Vessels w/ > 75 m3 containing a VOL w/ true vapor pressure of
76.6 kPa must use 95% percent efficiency control device or
equivalent
Primary copper smelters PM: dryers NTE 50 mg/dscm ro 0.022 grans per stry standard
cubic foot
SO2: roasters, smelting furnaces and copper converters NTE
0.065% by vol. (w/ exceptions)
Visible emissions: dryers and other facilities using sulfuric acid
to comply may not emit gases > 20% capacity

Stationary gas turbines NOx:
(1) For electric utility gas turbines with heat input > 107.2
gigajoules/hr (100mmBtu/hr)- NTE 0.0075 (14.4/Y) + F by vol.
at 15 % oxygen and on dry basis, where Y = mfr's rated heat rate
at mfr's rated load (kj/watt hour) or actual measured heat rate at
actual peak load, and where F = NOx emission allowance for
fuel-bound nitrogen (defined by special rules for nitrogen
content of fuel);
(2) For stationary gas turbines with heat input at peak load >
10.7 gigajoules/hr, built after Oct. 3, 1982, and stationary gas
turbines with rated base load of 30 MW or less- NTE 0.150
(14.4/Y) + F
SO2: emissions NTE 0.015 % by vol. at 15% oxygen and on dry
basis; facilities may not burn any fuel containing sulfur > 0.8 %
by wt.
Bulk gasoline terminals Total organic compounds: each loading rack must be equipped
(with throughput of with vapor collection system designed to collect TOC vapors
> 75,700 liters/day) displaced from tank truck vapor collection systems during
loading; emissions from loading NTE 35 milligrams TOC/liter
of gasoline loaded; emissions from unrefurbished vapor
processing systems constructed before 12/17/80 NTE 80 mg
TOC/liter of gasoline loaded; other equipment specifications.
New residential wood PM:
heaters -Burn rates < 2.82 kg/hr- NTE 3.55 times burn rate + 4.98 g/hr
-Burn rates > 2.82 kg/hr- NTE 15 g/hr
Equipment leaks of VOC Various equipment standards
from onshore natural gas
processing plants
Onshore natural gas SO2:
processing: SO2 emissions -Facilities w/sulfur feed rates > 5.0 long tons/day (LT/d)-
removal efficiency from 90-99.8 %
-Facilities w/ sulfur feed rates > 2. LT/d but < 5.0 LT/d- initial
reductions of 79% and 74% thereafter
VOC emissions from Standards for individual equipment, including individual drains,
petroleum refinery oil-water separators, closed vent systems, and control devices
wastewater systems
B.4.2 Existing Sources

The philosophy adopted by Congress was that decisions about the control of existing sources was best
left to state and local authorities, who had the best information on these and were best equipped to
make judgments on how the emission reduction burden should be distributed. In consequence, with
very few exceptions, existing sources are regulated by the states. In order to have their SIPs approved, a
state must assign standards to the various sources that are not assigned federal standards so that the
ambient standards will be attained.
With 50 different state plans setting stationary source standards, it is impossible to set out a general
picture of the stationary source emission standards that apply to existing sources in the U.S. Thus,
while the institutions are described here, no generalizations are made about the quantitative standards
that exist.
B.5 Mobile Source Emission Standards

Polluting emissions from new vehicles have been on a downward trajectory in the U.S. since the mid-
1960s. As new emission control technologies were added, it became possible to achieve greater control
efficiencies.
B.5.1 Vehicle Emission Standards

Mobile sources typically have shorter useful lives than most stationary sources. This is accelerated by
automakers’ marketing strategies—or planned obsolescence—that encourage motorists to turn over
vehicles before the engineering useful life has been reached. With emission standards tagged to specific
model years, Congress could count on the relatively quick replacement of high polluting cars with low
polluting cars without having to force a consumer to give up a car he had already purchased or install
add-on devices to it. As a result, emission controls for vehicles are all directed to new sources,
implemented by a blanket prohibition on sale of new cars that are not certified to the federal standards.
Historical Emission Standards
Because the newest standards in the U.S. may be far ahead of the standards that have been adopted in
Egypt, it is appropriate to include first a view of the historical standards in the U.S. It should be noted
that in addition to the federal standards that apply in 49 states there are also separate standards for
California.
The first national vehicle emission control standards in the U.S. were mandated by Congress in 1965.34
Federal standards virtually identical to the standards already adopted by California for the 1966 model
year were promulgated in 1966, which were applicable to 1968 and subsequent model year vehicles.35
From this beginning the standards have come steadily down. In 1970, Congress enacted new standards
reducing emissions by an additional 90 percent, an amount that was believed necessary to reduce
emission levels enough to achieve the ambient standards. These were superseded by new standards,
enacted as part of the 1977 Amendments. The standards that were adopted then continued in
application until superseded by those under the 1990 Amendments, which took effect in the 1994
model year. They are listed in table B.6.
Standards under the 1990 Amendments
The 1990 Amendments added new provisions establishing lower emission standards. There have been
three steps in bringing the standards lower.
Table B.6. Tailpipe Standards for Gasoline-Powered Vehicles, 1977-1993

(Standard expressed as grams per mile [grams per kilometer])
Model Year HC CO NOx

Pre-1968 (uncontrolled) 15 [9.321] 90 [55.926] 6.2 [3.8527]
1970 4.1 [2.548] 34 [21.128] —
1972 3.0 [1.864] 28 [17.399] —
34
Pub.L. 89-272, 79 Stat. 992 (Oct. 20, 1965). See 1965 USCCAN 3608 et seq. Sections 101-103 of the 1965 Act divided the
Act into three Titles and created Title II to contain the mobile source provisions. It also required HEW to make biannual progress
reports to Congress on various aspects of automotive air pollution control. In 1966, the Act was amended to authorize grants to
state and local air pollution control agencies, and to extend such programs. Pub.L. 89-675, 80 Stat. 954 (Oct. 15, 1966).
35
Proposed at 30 Fed.Reg. 17192 (Dec. 31, 1965), issued in final at 31 Fed.Reg. 5170 (Mar. 30, 1966). The regulations set
emission standards for HC and CO for passenger cars and light duty vehicles, but not for NOx. They also set out test procedures
for measuring emissions and mileage accumulation, including specifications for the fuels to use under these procedures. HEW
specified a lead additive (tetraethyl or tetramethyl) content in the test fuel of as high as 3.25 ML/gallon. See The New York
Times, Mar. 30, 1966, at 20.
1973-4 3.0 [1.864] 15 [9.321] 3.1 [1.9263]

1975-6 1.5 [.9321] 15 [9.321] 3.1 [1.9263]
1977-79 1.5 [.9321] 15 [9.321] 2.0 [1.2428]
1980 1.5 [.9321] 7.0 [4.3498] 2.0 [1.2428]
1981 and after 1.5 [.9321] 7.0 [4.3498] 1.0 [.6214]
Source: The Clean Air Act § 202(b)(1)(A) and (B) (1977), 42 U.S.C. § 7521(b)(1)(A) and (B) (1977).
Note: The standards represent only tailpipe emissions for light-duty vehicles (passenger cars). Separate standards for other classes of
vehicles (e.g., heavy-duty vehicles and diesel vehicles) and for other types of emissions (e.g., evaporative emissions) are not shown.
The standards listed are those listed by the statute. The federal standards remained unchanged from 1981 through 1989.
• Tier 1 Standards. The standards for light-duty vehicles and light-duty trucks that became
effective by operation of the statute, effective beginning in model phase year 1994 (the “tier 1
standards”) are listed in table B.7.
• NLEV Standards. Provisions of the 1990 Amendments allow states to voluntarily adopt the
vehicle emission standards issued by California. Several of the Northeastern states were very
interested in adopting the California standards for vehicles sold there. The product of
negotiations that took place is the National Low Emission Vehicle (NLEV) program. Because
the states and the automakers agreed to it, what started out as a voluntary program has become
a nationwide requirement that EPA memorialized in a regulation. As a result, the current
California standards (NOx = 0.3 gpm) apply to 2001 model year vehicles and are enforceable
as a federal regulation.
• Tier 2 Standards. On February 10, 2000 the U.S. EPA issued two sets of rules together—the
tier 2 auto emission standards and limitations on the sulfur content of gasoline (see below).36
These were effective April 10, 2000. The tier 2 standards, which automakers will be required
to phase in beginning in model year 2004, resulted from a mandated study to determine
whether tightening of the motor vehicle emission standards was warranted.37 The tier 2
standards are the first set of tailpipe standards that apply equally to all passenger cars, light
trucks, and larger passenger vehicles operated on any fuel.
Table B.7. Tier 1 Tailpipe Standards for Vehicles Beginning 1994
(Standards expressed as grams per mile)
Short Useful Life Long Useful Life

Vehicle
Fuel NMHC CO NOx PM NMHC CO NOx PM
Type
5 years/50,000 miles 10 years/100,000 miles
gas 0.25 3.4 0.4 0.08 0.31 4.2 0.6 0.10
LDV a [.15535] [2.1128] [.24856] [.49712] [.19263] [2.6099] [.37284] [.06214]
diesel 0.25 3.4 1.0 0.08 0.31 4.2 1.25 0.10
[.15535] [2.1128] [.6214] [.49712] [.19263] [2.6099] [.77675] [.06214]
36
65 Fed.Reg. 6698 (Feb. 10, 2000).
37
Under Section 202(i) of the Act, EPA was required to determine whether standards more stringent than tier 1 standards are
appropriate beginning between the 2004 and 2006 model years, considering (1) the availability of technology to meet more
stringent standards, taking cost, lead time, safety, and energy impacts into consideration; and (2) the need for, and cost
effectiveness of, such standards, including consideration of alternative methods of attaining or maintaining the national ambient
air quality standards. After the study was completed EPA was required to determine by rulemaking whether: (1) there is a need
for further emission reductions; (2) the technology for more stringent emission standards from the affected classes is available;
and (3) such standards are needed and cost-effective, taking into account alternatives. If EPA answers “yes” to these questions,
then the Agency must issue new, more stringent motor vehicle standards (the tier 2 standards). EPA submitted its report to
Congress on July 31, 1998, answering all three questions in the affirmative.
gas 0.25 a 3.4 a 0.4 a 0.08 b 0.31 a 4.2 a 0.6 a 0.10 b

[.15535] [2.1128] [.24856] [.49712] [.19263] [2.6099] [.37284] [.06214]
LDT1
diesel 0.25 a 3.4 a 1.0 a 0.08 b 0.31 a 4.2 a 1.25 a 0.10 b
[.15535] [2.1128] [.6214] [.49712] [.19263] [2.6099] [.77675] [.06214]
gas 0.32 a 4.4 a 0.7 a 0.08 b 0.40 a 5.5 a 0.97 a 0.10 b
[.19885] [2.7342] [.43498] [.49712] [.24856] [.34177] [.60276] [.06214]
LDT2
diesel 0.32 a 4.4 a — 0.08 0.40 a 5.5 a 0.97 a 0.10 b
[.19885] [2.7342] [.49712] [.24856] [.34177] [.60276] [.06214]
5 years/50,000 miles 11 years/120,000 miles

gas 0.32 4.4 0.7 — 0.46 6.4 0.98 0.10
c [.19885] [2.7342] [.43498] [.28584] [3.9769] [.60897] [.06214]
HLDT1
diesel 0.32 4.4 — — 0.46 6.4 0.98 0.10
[.19885] [2.7342] [.28584] [3.9769] [.60897] [.06214]
gas 0.39 5.0 1.1 — 0.56 7.3 1.53 0.12
c [.24235] [3.7284] [.68354] [.34798] [4.5362] [.95074] [.07457]
HLDT2
diesel 0.39 5.0 — — 0.56 7.3 1.53 0.12
[.24235] [3.7284] [.34798] [4.5362] [.95074] [.07457]
Source: 1990 Amendments § 203(a), establishing new Clean Air Act § 202(g) - (h), 42 U.S.C. § 7521(g) - (h) and Tables G and H.
Summarized in John-Mark Stensvaag, Clean Air Act 1990 Amendments, Law and Practice (Wiley, New York, 1991), at 8-12.
Definitions: LDV- Light-Duty Vehicle (passenger cars); LDT1- light-duty truck category 1 (Gross Vehicle Weight Rating (GVWR)
of 6,000 lb. or less, and Loaded Vehicle Weight (LVW) of 0-3750 lb.); LDT2- light-duty truck category 2 (GVWR of 6,000 lb. or
less, and LVW of 3,751-5,750 lb.); HLDT1- heavy light-duty truck category 1 (GVWR of over 6,000 lb., and Test Weight (TW) of
3,751-5,750 lb.; HLDT2- heavy light-duty truck category 2 (GVWR of over 6,000 lb., and TW of more than 5,750 lb.)
Note: The standards represent only tailpipe emissions for LDVs, LDTs, and HLDTs. Separate standards for other classes of vehicles
(e.g., heavy-duty vehicles) and for other types of emissions (e.g., evaporative emissions) are not shown. Standards are stated in grams
per mile ("g/m") of pollutant emitted. The standards listed are those listed by the statute.
a Phasing: 40% model year (MY) 1994, 80% MY 1995, 100% thereafter.
b Phasing: 40% MY) 1994, 80% MY 1996, 100% thereafter.
c Phasing: 50% MY) 1996, 100% thereafter.
The new rule is one of the longest and most complicated ever published by EPA. Instead of a single
standard, each automaker must meet a corporate sales-weighted average. The average changes during
the phase-in periods until ultimately there are 10 different standards below and above the average.
Indeed, EPA found the rule it had written so complex that it was unable to condense it to prepare a fact
sheet for the public.38 The only generalization is that the average emissions of the whole fleet will be
.07 gpm of NOx. Under these circumstances, table B.8 is presented as a suggestion of the range of
standards that apply. No further analysis will be pursued.
Table B.8. Tier 2 Light-duty Full Useful Life Exhaust Emission Standards
Bin No. NOx NMOG CO HCHO PM

8 0.20 0.125 4.2 0.018 0.02
7 0.15 0.090 4.2 0.018 0.02
6 0.10 0.090 4.2 0.018 0.01
5 0.07 0.090 4.2 0.018 0.01
4 0.04 0.070 2.1 0.011 0.01
3 0.03 0.055 2.1 0.011 0.01
2 0.02 0.010 2.1 0.004 0.01
1 0.00 0.000 0 0.000 0.00
Source: EPA, 65 Fed.Reg. 6698 et seq. (Feb. 10, 2000), Table IV.B.-2A.
38
EPA staff found it impossible to condense the material.
The tier 2 standards will be phased in beginning in 2004 in order to comply with EPA’s declining fleet
average NOx standard. One hundred percent of the passenger car and light truck fleets operating on
both diesel and gasoline will be required to comply on average by 2007; 100 percent of heavier trucks
up to 10,000 lbs. will comply by 2009. The NLEV standards will be phased in in a few Northeast states
starting in 1999; nationally they go into effect in 2001. California’s TLEV, LEV, ULEV, LEV2, ULEV
2 and SULEV standards are phased in by each manufacturer in a manner sufficient to comply with the
fleet average NMOG standard.
B.5.2 Fuel Standards

EPA is granted authority under Section 211(c) of the Clean Air Act to regulate fuel quality in order to
prevent pollution from fuels and additives and to protect emission control devices on vehicles using
them. In 1973, EPA issued two sets of regulations: (1) mandating the availability of unleaded gasoline
for use in vehicle equipped with catalytic converters; and (2) reducing the average lead content of
gasoline (“the lead phasedown”). Substitution of other octane additives for lead additive caused
gasoline volatility to rise, creating additional hydrocarbon emissions that contributed to growth in
urban ozone pollution.39 In the late 1980s, EPA issued a set of rules controlling gasoline volatility.
In the 1990 Amendments, Congress banned leaded gasoline effective January 1, 1996. It also enacted
two additional provisions: (1) to reduce emissions of ozone-forming VOCs and air toxics, section
211(k) requires the sale of reformulated gasoline (RFG) in certain ozone nonattainment areas. The first
phase began January 1, 1995; the second phase began January 1, 2000. The provisions regarding VOCs
apply during the high ozone season. The provisions regarding toxic air pollutants apply during the
entire year. (2) To reduce CO emissions from vehicles in CO nonattainment areas it required the use of
oxygenated fuels.
Most recently, EPA mandated significant reductions in the sulfur content of fuel, both to reduce sulfur
emissions and to protect the significant investment to be made in achieving the tier 2 emission
standards. EPA determined that while technologies existed to make significant tailpipe emission
reductions, such could not be achieved by vehicles in use with the existing fuel quality. The controls
reducing the sulfur content of gasoline will enable technologies installed by automakers to meet the
standards in use. Like the rules issued in 1973 to make unleaded gasoline available to protect catalysts,
the new sulfur rules rely on the fuel as an essential predicate for maintaining performance of emission
controls.
It should be noted that while both the vehicle standards and the fuel standards are measured principally
at the time of sale, rather than in use, the fuel standards are not emission standards per se. Instead, they
are product quality standards, directing refiners to produce gasolines having certain characteristics that
affect emissions.
39
See Loeb, A.P., “The Adolescence of Emissions Trading: A Short History and Analysis of the Lead Phasedown Lead Credit
Market,” presented as faculty at USAID Technical Leadership Training Workshop: Emissions Trading for Environmental
Protection, Energy and Environment, Washington, D.C., May 19, 2000.
Appendix C: European Union Standards
The EU has an elaborate set of policies and standards for air quality.
C.1 Ambient Air Quality Standards

The EU issued new ambient standards in Council Directive 1999/30/EC, April 22, 1999. The object of
this directive was to establish limit values and, as appropriate, ‘alert thresholds,’ for concentrations of
SO2, NO2 and NOx, PM, and Pb so as to prevent damage to human health and the environment. ‘Alert
thresholds’ are levels beyond which there is an acute risk to human health and at which immediate
steps must be taken. These standards are the minimum limit values that member states must achieve;
however, member states can establish their own more stringent limits.
Directive 96/62/EC requires that action plans be developed for zones within which concentrations of
pollutants in ambient air exceed limit values, plus any applicable temporary margins of tolerance.
In addition to the ambient standards listed in table C.1, which are either now in force or currently listed to
be applicable at definite future dates, proposals have been made to Parliament and the Council for
standards for three additional pollutants—carbon monoxide, benzene, and ozone. The Commission is also
currently carrying out research to consider proposing standards for five additional pollutants—PAHs,
mercury, nickel, cadmium, and arsenic.40 These would be integrated into the program for ambient
standards; by contrast to the U.S., in the EU rules there is no separate air toxics program.
C.2 Stationary Source Emission Standards

Standards for stationary source emissions in the EU have proved to be unavailable, since the annexes
containing the limit values for the various sources are not posted on the EU website. Stationary source
emission guidelines developed by the World Bank are used here instead.
C.3 Mobile Source Emission Standards

As in the U.S. program, the EU program for mobile sources contains rules for both vehicle emissions and
fuel quality.
C.3.1 Vehicle Emission Standards

Until the mid-1980s, vehicle emission standards in Europe were developed by the United Nations
Economic Commission for Europe (ECE) and adopted by individual countries. Because of the
consensus-based approach to rule-making, which required unanimity among the various states, the
European standards lagged behind the U.S. standards. For example, the ECE did not adopt emission
standards requiring three-way catalytic converters until 1988 (ECE regulation 83), and then only for
vehicles with engine displacement of 2.0 liters or more.
Table C.1. EU Ambient Air Quality Standards
Allowed
Pollutant Averaging Time Limit Value Alert Threshold
Exceedances
SO2 1-hour 350 µg/m3 24/yr 350 µg/m3 for 3 hrs
40
Personal correspondence Lynne Edwards, EC, to Alan P. Loeb, May 30, 2000.
C-1
C-2 Considerations for Revising Air Quality Standards in Egypt
Allowed
Pollutant Averaging Time Limit Value Alert Threshold
Exceedances
24-hour 125 µg/m3 3/yr
3
Annual 20 µg/m —
3
1-hour 200 µg/m 18/yr 400 µg/m3 for 3 hrs
NO2
annual 40 µg/m3 —
NOX annual 30 µg/m3 —
3
24-hour 50 µg/m 35/yr
PM10a 3
annual 40 µg/m —
3
Pb annual 2 µg/m —
O3 [] [proposed]
Benzene [] [proposed]
Arsenic [] [proposed]
Mercury [] [in research]
Cadmium [] [in research]
Nickel [] [in research]
Poly-aromatic [] [in research]
hydrocarbons
(PAH)
Source: Annexes to Council Directive 1999/30/EC, Apr. 22, 1999. These Annexes are not available on line. These were obtained by
personal correspondence with Lynne Edwards. Some details of European standards are provided in the World Bank Handbook,
which lists the EU standards in comparison tables; however, the discussion of European standards in the Handbook is obsolete.
Note: Since the purpose of this study is to look prospectively at opportunities for reductions, the standards listed here are only those
that have been established for future compliance. The various dates for compliance with standards for individual pollutants are set out
in the Annexes to Council Directive 1999/30/EC but not listed here. Details regarding former standards, as well as currently-
applicable standards or parts of standards that are scheduled for repeal, are set out in Article 9 of 1999/30/EC.
a The limit values presented here are from the Stage 1 PM10 program. A stage 2 program, with a 24 hour standard of 50 µg/m3 (not
to be exceeded more than 7 times per calendar year) and an annual standard of 20 µg/m3 are currently under consideration.
With the shift recently in the EU to a decision process that allow adoption of standards with less-than-
complete unanimity, it has become possible to adopt more stringent emission standards, and they have
now begun to catch up with U.S. standards.41
Table C.2 summarizes the EU standards that apply to passenger car emissions, measured as limit values
in grams per kilometer (g/km).42
Table C.2. EU Standards for Passenger Cars
Pollutant 2000 2005

Gasoline Diesel Gasoline Diesel
Carbon monoxide 2.3 0.64 1.00 0.50
Mass of hydrocarbons 0.20 — 0.10 —
Mass of oxides of nitrogen 0.15 0.50 0.06 0.25
Combined mass of hydrocarbons — 0.56 — 0.30
and oxides of nitrogen (0.5 prior (0.5 prior
standard) standard)
Mass of particulates — 0.05 — 0.025
Source: Michael P. Walsh (1999); standards represent the final conciliation values agreed on June 30, 1999.
41
Faiz, Asif, Christopher S. Weaver, and Michael P. Walsh, Air Pollution from Motor Vehicles, Standards and Technologies for
Controlling Emissions (The World Bank, Washington, DC, 1996), at 8.
42
Faiz, et al., supra, at 8.
Appendix C: European Union Standards C-3
It should be noted for comparison purposes, that the EU standards do not assign automakers the
responsibility for emission performance of their vehicles once they enter service. That is, they have no
emission warranty. Moreover, surveillance testing, recalls, and other features of the U.S. regulatory
program do not exist in the EU program. Given the deterioration in performance of emission control
devices, in-use emissions of vehicles certified to EU standards are likely to be significantly higher than
the standards over their lifetimes.43
C.3.2 Fuel Standards

Initially, European nations varied greatly in their adoption of the U.S. model. West Germany
unilaterally adopted a maximum lead content of 0.15 grams of lead per liter of gasoline (gpl) in 1975
for regular grade gasoline. The EC followed with a directive in 1978 requiring member countries to set
maximum lead content standards between 0.15 and 0.4 gpl.44 However, this did not occur with
universal agreement. Major opposition came from the United Kingdom (UK), which argued that lead
additives were important for energy conservation.45
Once the U.S. took action to strengthen its lead phase-down regulations in 1982 and 1985, the EC
followed suit. The UK reversed its position in 1983 and actually took a leadership role in making lead
reductions. The EC issued a second directive in 1985 that formally asked that member states reduce the
lead content of leaded to 0.15 gpl “as soon as they consider it appropriate.46
In the parallel to lead content rules, European countries adopted requirements for the availability of
unleaded gasoline to supply new catalytic converter-equipped vehicles. The 1985 EC directive required
the availability of unleaded gasoline by October 1, 1989. The EC set the maximum lead content
standard for unleaded at 0.013 gpl. However, only unleaded premium (minimum 95 RON/85 MON)
was required; member states were permitted, but not required, to require the availability of unleaded
regular in addition.47
43
Faiz, et al., supra, at 8.
44
Council Directive 78/611/EEC, June 29, 1978. EC directives for gasoline exclude French overseas departments.
45
Walsh, Michael P., “Other Nations Phasing Down Lead in Gas,” EPA Journal, May 1985.
46
“Directive on the Lead Content of Petrol,” 85/210/EEC, 3 April 1985, as amended by 85/580/EEC, 31 December 1985, and
87/416/EEC, 21 July 1987.
47
Automotive Engineering, Jan. 1987, p.49.
Appendix D: Standards Issued by International
Organizations
This section evaluates air quality standards worldwide. It identifies standards and the associated
policies and other factors that will be important for establishing new air quality standards in Egypt.
The approach here is to identify the actions, activities, roles and responsibilities of counterparts that
need to be in place. Its purpose is to introduce key issues and principal assumptions. It also identifies
the principal risks associated with revising the Egyptian standards and assesses the institutional
approaches to their mitigation.
D.1 World Health Organization

The most influential body in development of air quality regulation is the WHO, which produced its first
air quality guidelines in 1987. These are now embodied in a substantial document, WHO Guidelines for
Air Quality, last revised in 1999. The document contains an extensive discussion of air pollution
generally, evaluation of the health effects of specific pollutants, and methodologies for pollution
control and program management. Governments and financial institutions turn to them for an
authoritative source of information.
Most important among the issues discussed in the Guidelines are the WHO guidelines for ambient air
quality. While these are not intended as standards per se, they present the levels of air pollution below
which lifetime exposure presents no significant health risk. As such, they provide the foundation upon
which standards can be adopted. As a statement of the United Nations, these have become the universal
source of ambient standards. In addition, the WHO Guidelines also provide guidance material for
setting emission standards.
The WHO Guidelines present much valuable information that can be useful for developing the
Egyptian program. For present purposes, the focus here is on the WHO guidelines for ambient air
quality, presented in table D.1.
Table D.1. WHO Ambient Air Quality Guidelines
Pollutant Averaging Time Concentration

Annual 50 µg/m3
SO2 24-hour 125 µg/m3
10-minute 500 µg/m3
8-hour 10 mg/m3
1-hour 30 mg/m3
CO
30-minute 60 mg/m3
15-minute 100 mg/m3
annual 40 µg/m3
NO2
1-hour 200 µg/m3
O3 8-hour 120 µg/m3
Pb annual 0.5 µg/m3
Source: “WHO guideline values for the ‘classical’ air pollutants,” reprinted as Table 3.1 in Guidelines for Air Quality, WHO,
Geneva, 1999.
D-1
D-2 Considerations for Revising Air Quality Standards in Egypt
In addition to the classical air pollutants, WHO also lists guidelines for “other air pollutants,”
categorized by non-carcinogenic (Table 3.2, 39 substances) and carcinogenic (Table 3.3, 16 substances)
endpoints. Several of these other pollutants are important for this assessment, being also either
proposed for listing or under research for listing as ambient pollutants by the EU. These are listed in
table D.2.
Table D.2 WHO Other Pollutants Proposed for Standards by EU
Average Ambient Air Concentration

Pollutant
WHO EU
Benzene 5.0-20.0 µg/m3 [proposed]
[Table 3.3]
Arsenic (1-30) [proposed]
10-3 µg/m3
[Table 3.3]
Cadmium (0.1-20) [in research]
10-3 µg/m3
[Table 3.2]
Nickel 1-180 µg/m3 [in research]
[Table 3.3]
PAH (1-10)*10-3 µg/m3 [in research]
[Table 3.3]
D.2 Financial Institutions

Financial institutions, especially multilateral lending institutions, are uniquely positioned to determine
the environmental impacts of projects they finance, and in recent years they have responded to pressure
by developing policies that require project developers to meet the more stringent emission levels that
would apply in developed countries. Since they govern projects wherever located, these have become
the international standard for emission control. Following this lead, some private lenders have taken
these as a world norm to be enforced as a condition of loan approval.48
Where countries have environmental systems that do not control emissions to the world standard, or
where regulations are not sufficiently enforced, the regulations of the financial institutions act as the
principal agency of emission control. However, since by definition only new sources or significant
modifications are financed, the influence of these international organizations is limited to constraining
some additions to the emissions inventory. Existing sources are not affected directly by such
institutions.
There are three types of financial institutions that have a role in development:
• Multilateral Development Banks. There are a variety of multilateral development banks,

whose objective is to alleviate poverty and improve the quality of life through financing
projects. They use loan guarantees to finance projects private institutions will not support.
These are of two kinds, either globally focused or regionally focused. The principal global
multilateral is the World Bank Group, including the International Finance Corporation and the
Multilateral Investment Guarantee Agency. The regionals include the Asian Development
Bank, the Inter-American Development Bank, the European Bank for Reconstruction and
Development, and the African Development Bank.
48
See Andrew Giaccia and Erin Buckley Bradley, “World Bank Standards,” Independent Energy, October, 1995, at 62.
Appendix D: Standards Issued by International Organizations D-3
• Export Credit Agencies. These are bilateral public institutions set up by national governments
to support exports and investment by companies in other countries, i.e., foreign operations of
domestic companies. Their objective is to support the competitiveness and investment of their
constituents, not to alleviate poverty but to support economic growth. These do not take the
place of commercial banks, they provide support beyond that afforded by commercial
banks—insurance and loan guarantees that insure risks commercial banks are unwilling to
accept.
• Commercial Banks. These organizations have as their objective to profit by support of sound
projects with minimal risks.
Because these institutions all apply their environmental responsibilities currently, usually a
combination of local, national, and financing organization standards apply. When the standards are not
all equal, which is often the case, the most stringent standard applies.
A number of environmental policies, procedures, and/or standards have thus been set by the various
financial institutions, which apply to individual project financings. As a developing country, Egypt sees
the application of these policies when they are applied as a condition to economic development
projects.
More importantly, these various practices taken collectively create norms that industries are expected to
follow. Since all financed projects ultimately affect competitive conditions, what standards are applied
in one financing have economic consequences to the others.
There is a third reason to consider these as well. Since financial standards are already in the economy,
they provide in essence what translates into a new source performance standard. The existence of this
mechanism introduces equitable questions as companies compete and have to consider the equitable
question of how to allocate the burdens fairly under such conditions.
D.2.1 The World Bank Group

The World Bank Group is a second essential source of universal standards. As mentioned above, the
World Bank Group has three components, each of which has a somewhat different approach related to
its functional role.
The World Bank Handbook
The World Bank published a comprehensive study of pollution control strategies and standards in its
Pollution Prevention and Abatement Handbook (“the Handbook”), which first appeared in 1995. While
it contains water and air quality standards, its emphasis is overwhelmingly on air. In addition to
providing a comprehensive survey of environmental methods and management practices, Part Three of
this volume contains discussions on three subjects relating to emission control:
• Pollutants. A discussion of the substances PM, arsenic, cadmium, lead, mercury, NOx, ozone,
and SOx.
• Pollutant Control Technologies. A review of generic technologies for controlling PM,

gasoline lead, NOx, and SOx.
• Industry Sector Guidelines. A set of performance standards for control of emissions at specific
categories of stationary sources. Since these are enforced as a condition of financing a project,
they are in effect sector-specific emission standards applied in a pre-construction review
process.
Since the World Bank is involved in financing development, not in controlling emissions, it does not
have any say in emissions that do not result from new or expanded plant. In consequence, the World
Bank has not developed standards or any guidance at all regarding mobile source emissions.
The World Bank Handbook is the most commonly used reference for setting standards in project
finance. It is applied to projects even when its standards are more stringent than the local standards. But
it should be borne in mind that the World Bank guidelines, as shown in table D.3, are emission
standards, and so there is no guarantee that their application results in attainment of the ambient
standards.
Table D.3. World Bank Air Emission Guidelines: Parameters and Maximum Values
Pollutants and Emission Limitations

Source Category (Milligrams per Normal Cubic Meter [mg/Nm3] unless otherwise specified)
PM SOx NOx Metals Other Pollutants
Aluminum manufacturing 30 — — — Total fluorine: 2
HF: 1
VOC: 20
Base metal and iron ore mining — — — — —
Breweries — — — — —
Cement manufacturing 50 400 600 — —
Chlor-alkali industry — — — — Cl: 3
Coal mining and production 50 SO2
Coke manufacturing 50 — — — benzene: 5 (leaks)
VOC: 20
sulfur: recovery at least 97%
(preferably over 99%)
Copper smelting Smelters: 20 As: 0.5 —
Other sources: 50 Cd: 0.05
Cu: 1
Pb: P.2
Hg: 0.05
Dairy industry Odor: acceptable to neighbors
Dye manufacturing Cl: 10
VOC: 20
Electronics manufacturing VOC: 20
phosphine: 1
arsine: 1
HF: 5
HCl: 10
Electroplating industry VOC: 90% recovery
D-5
D-6

Foundries 20 where toxic metals
are present, 50 in other
cases
Fruit and vegetable processing — — — — —
General environmental guidelines PM: SO2: 2,000 coal: 750 (260 ng/J or dioxin (2,3,7,8-TCSS equivalent):
- 50 for >50 MWe 365 ppm) max 1 ng/Nm3
- 100< 50 MWe oil: 460 (130 ng/J or
225 ppm)
gas: 320 (86 ng/J or
155 ppm)
Glass manufacturing -50 SOx: 1,000 (up to 2,000 Pb + Cd, total: 5 F: 5
-20 where toxic metals -gas fired: 700 depending on other heavy metals, HCl: 50
are present -oil-fired: 1,800 technology and if total: 5
justified in the EA As: 1
Industrial estates -Large facilities SOx: 2,000 -Solid fuels: 750 (260 H2S: 15
(energy consumption > ng/J or 365 ppm)
10 GJ/hour): 50 -Liquid fuels: 460
-Small facilities (130 ng/J or 225 ppm)
(energy consumption < Gas: 320 (86 ng/J or
10 GJ/hour): 150 155 ppm)
Iron and steel manufacturing 50 500 (sintering) 750 (260 ng/J or 365 F: 5
ppm)
Lead and zinc smelting 20 SO2: 400 As: 0.1 F: 5
Cd: 0.05 HCl: 50
Cu: 0.5
Hg: 0.05
Pb: 0.5
Zn: 1
Meat processing and rendering 150 for smokehouses Odor
with C content < 50 Minimize impact on residents
Mini steel mills -50 2,000 750
-20 where toxic metals
are present
Mixed fertilizer plants 50 -Nitrophosphate units: NH3: 50
500 F: 5
-Mixed acid units: 70
Nitrogenous fertilizer plants 50 300 NH3: 50
urea: 50
Oil and gas development 1,000 oil: 460 (130 ng/J or VOC: 20
(onshore) 225 ppm) H2S: 30
gas: 320 (86 ng/J or Odor: not offensive at receptor
155 ppm) end (H2S at property line < 5
µg/m3)
Pesticides formulation -20 VOC: 20
-5 where very toxic Cl: 5
compounds are present
Pesticides manufacturing -20 VOC: 20
-5 where very toxic Cl: 5
compounds are present
Petrochemicals manufacturing 20 500 300 HCl: 10
Benzene:
-Emissions: 5
-Plant fence: 0.1 ppb
1,2 dicholoroethane:
-Emissions: 5
Vinyl chloride:
-Emissions: 5
NH3: 15
D-7
D-8

Petroleum refining 50 Sulfur recovery units- 460 (130 ng/J or 225 H2S: 15
150 ppm) Ni + V: 2
-Combustion units- 500
Pharmaceutical manufacturing 20 Active ingredients (each): 0.15
Class A compounds (total): 20
Class B compounds (total): 80
Benzene: 5
Vinyl chloride: 5
Dichloroethane: 5
Phosphate fertilizer plants 50 Sulfuric acid plant: F: 5
SO2: 2 kg/t acid
SO3: 0.15 kg/t acid
Printing industry VOC: 20
Cl: 10
Pulp and paper mills Recovery furnace: 100 Total S: 2 kg/t air-dried pulp H2S: 15 (lime kilns)
-Sulfite mills- 1.5 kg/t
air-dried pulp
-Kraft and other- 1.0
kg/t air-dried pulp
Sugar manufacturing -100 -Liquid fuels: 460 Odor: acceptable to residents
-Mills < 8.7 MW heat (130 ng/J or 225 ppm)
input to boiler: -Solid fuels: 750 (260
150mg/Nm3 ng/J or 365 ppm)
Tanning and leather finishing Odor: acceptable to residents
Textiles industry VOC: 20
Thermal power, new plants 50 mg/Nm3 -Total SO2: 0.2 metric Thermal plants:
ton/day MWe on first -Coal: 750 (260 ng/J
500 MWe, 0.1 tpd over or 365 ppm)
500 MWe -Oil: 460 (130 ng/J or
-Flue gases: 2,000 225 ppm)
mg/Nm3 (500 tpd total) Gas: 320 (86 ng/J or
155 ppm)
Combustion turbine
plants:
-Gas: 125
Diesel (No. 2): 165
Fuel oil (No. 6 and
other: 300
Coal < 10% Volatile
matter: 1,500
mg/Nm3
Thermal power, rehabilitation of -100 CO:
existing plants -rare cases: 150
mg/Nm3
Vegetable oil processing 50 Odor: acceptable to neighbors
Wood preserving industry VOC: 20
Source: Table 1, World Bank Handbook, at 194-95.
D-9
International Finance Corporation
A second institution within the World Bank Group is the International Finance Corporation (IFC),
which is the private sector finance arm of the World Bank. IFC provides funding and advice to private
sector ventures and projects in developing countries in partnership with private developers. It is the
largest multilateral source of loan and equity financing for private sector projects in the developing
world. The IFC generally follows the World Bank Handbook for its standards. However, in addition, it
has also established a “Procedure for Environmental and Social Review of Projects.”
Multilateral Investment Guarantee Agency
The Multilateral Investment Guarantee Agency (MIGA) was established in 1988 to offer guarantees to
encourage the flow of foreign direct investment to its developing member countries for economic
development. MIGA applies the World Bank Pollution Prevention and Abatement Handbook in its
operations. MIGA has also adopted its own environmental policies, including procedures for
consideration of project impacts, which are set out in its “Environmental and Social Review
Procedures.”49 In addition it has additional policies set out in its “Draft Environmental Assessment and
Disclosure Policies and Environmental Review Procedures.”50
D.2.2 Regional Development Banks

The world network of regional development banks have important influence on applying emission
control requirements on new projects they finance or develop. The following quick survey indicates the
practices they use.
African Development Bank
The AfDB provides assistance to private enterprises and financial institutions through term loans,
equity and quasi-equity guarantees, and underwriting and advisory services. The AfDB requires
environmental impact statements for all projects. Its environmental policies were made public in a
series of policy statements that list principles of responsible environmental management. It provides a
number of methods and measures for improving environmental performance of industry projects.
The AfDB is listed here first because it is the first line of approach to finding practices and techniques
that would be applicable in Egypt. However, research was not done to determine the level of
experience or expertise in application of air quality management tools and techniques, and other like
organizations are listed below as possible additional sources of practices and techniques.
Asian Development Bank
The Asian Development Bank (ADB) provides financial and technical assistance by extending loans
and equity investments for its developing member countries, provides technical assistance, and
promotes public and private investment. The ADB reviews the environmental impacts of its projects
and policies, encourages developing countries to develop environmental programs, and trains staff on
environmental aspects of economic development. Its environmental guidelines are not available on line
but are available by request.
European Bank for Reconstruction and Development
The European Bank for Reconstruction and Development (EBRD) offers loans, equity and quasi-equity
investments, guarantees, and advisory services to support projects in the 26 countries in central and
49
See www.miga.org/disclose/soc_rev.htm.
50
See www.miga.org/disclose/preface.htm.
Appendix D: Standards Issued by International Organizations D-11
eastern Europe in which it operates. EBRD projects are required to meet national and EU
environmental standards. Environmental assessments must be carried out, and project sponsors must
develop an environmental action plan. Environmental monitoring is required over the life of the loan.
Inter-American Development Bank
The Inter-American Development Bank (IDB) is composed of 46 member countries, 26 of which are
countries in Latin America or the Caribbean and have borrowing status. In analysis of proposed
projects, the IDB reviews environmental impacts and incorporates factors to avoid adverse impacts.
D.3 Trade Assistance Organizations

National organizations provide trade assistance such as loan guarantees and direct loans. For example,
in the U.S. the Overseas Private Investment Corporation (OPIC) provides loan guarantees for U.S.
small businesses and cooperatives. OPIC practices draw from four sets of environmental guidelines to
evaluate the environmental and social impacts of projects: (1) Environmental Handbook, revised April
1999; (2) the World Bank Handbook; (3) the IFC environmental health and safety guidelines, to
address issues not covered by World Bank Handbook; and (4) the World Bank Operational Directives.
D.4 World Trade Organization

The World Trade Organization (WTO) is not a source of project finance. However, it has a substantial
role in international environmental policy by seeking to minimize disparity in trade rules that can lead
to trade discrimination. Developing countries are under some pressure in the international community
to reconcile their environmental practices and standards to meet world norms.
D.5 International Organization for Standardization

The International Organization for Standardization (ISO) is a federation of national standards bodies
with member organizations from 111 countries. It has developed a series of specification standards for
environmental management systems, which are known collectively as ISO 14000. The series contains
six guidance standards:
• Environmental Management Systems
• Environmental Auditing
• Environmental Labeling
• Environmental Performance Evaluation
• Life-cycle Assessment
• Terms and Definitions

Of greatest interest is the guidance for Environmental Management Systems, ISO 140001.
Organizations from 42 countries participated in the drafting procedure. Under ISO 14001, companies
can voluntarily become certified; certification requires third-party auditing. There is a widespread
movement of multinational companies to become certified in order to show good corporate citizenship.
Certification is the formal recognition that a company or organization is operating an environmental
management system (EMS) that meets established standards. Unfortunately, ISO 14000 focuses on
compliance with national regulation rather than with environmental performance. Given the differences
in regulatory standards among countries, ISO 14000 does not provide a guarantee of comparable
performance.
On the other hand, the ISO 14000 series does provide a rich source of internationally-accepted
methodologies for monitoring and modeling emissions. These could be quite useful in establishing new
testing protocols in Egypt.
Appendix E: Meetings and Interviews
I departed for Cairo in the evening of Tuesday, May 2, 2000 and arrived in Cairo in the early hours of
Thursday, May 4. I departed early on May 16. In my second week I interviewed the following
individuals:
• Dr. Ahmed Gamal Abdel-Rehiem, Environmental Advisor to the Cairo Air Improvement
Project (CAIP) and the Egyptian Environmental Affairs Agency (EEAA), Ministry of State for
Environmental Affairs
• Abdelhavez H. Adelhafez , Faculty of Engineering, Cairo University, Giza
• Prof. Fawzy M. El-Mahallawy, Faculty of Engineering, Cairo University, Giza
• Dr. Ahmed Hamza, Senior Technical Advisor, Environmental Compliance Unit, Industrial
Sources, EEAA, Ministry of State for Environmental Affairs
• Ahmed Ismael, consultant for EEAA environmental inspection
• Eng. Dahlia Lotayef, Planning Director, Follow-up and Technical Cooperation Department,
EEAA, Ministry of State for Environmental Affairs
• Dr. Nefisa S. Abo El-Seoud, Director of Environmental Engineering, Hazardous Substances

and Waste Management, EEAA, Ministry of State for Environmental Affairs
• Nader Shehata Doas, GC environmental lab manager, EEAA, and
• Esko Meloni, Senior Advisor, Finnish Institute of Environment, Egyptian Pollution

Abatement Project (EPAP)
In addition, I have also interviewed:
• David Fratt, Home Office Project Officer for CAIP, Chemonics International, Washington,
D.C.
• Eng. Yasser Sherif, General Manager, Environics, Cairo
• Lee Pasarew, Director, Middle East Programs, Office of International Activity, U.S. EPA,
Washington, D.C.
In addition to these interviews my counterpart, Dr. Mahmoud Nasralla, conducted additional
interviews.
Glossary-1
Technical Glossary
Alert thresholds Levels beyond which there is an acute risk to human health and at
which immediate steps must be taken. These standards are the
minimum limit values that member states must achieve; however,
member states can establish their own more stringent limits.
Ambient air Unrestricted open air outside buildings
CO non-attainment area An area or region where the carbon monoxide (CO) levels fail to
meet the ambient air quality standard (AAQS) promulgated by a
regulatory agency. Usually non-attainment is designated when the
CO level exceeds the AAQS for a specified number of days during
an annual period.
Mazout A high boiling point, residual fraction obtained from crude oil
processing by distillation. Mazout is used as a lower cost fuel for
combustion sources such as electrical power plants, lead smelters,
etc. Use of Mazout as a fuel results in high emissions of particulate
matter, polycyclic aromatic hydrocarbons, sulfur dioxide, and other
pollutants.
Mobile source emissions Emissions from mobile vehicles such as automobiles, trucks, and
buses.
Oxygenated fuel Fuel to which an oxygen-rich compound has been added. Methyl
tertiary butyl ether (MTBE) is one of the additives commonly used
to formulate oxygenated fuel (gasoline).
Ozone non-attainment area An area or region where the ozone (O3) levels fail to meet the
ambient air quality standard (AAQS) promulgated by a regulatory
agency. Usually non-attainment is designated when the O3 level
exceeds the AAQS for a specified number of days during an annual
period.
Period of exposure Length of time that exposure to a pollutant occurs, usually exposure
above a specified concentration level.
Reformulated gasoline Gasoline reformulated to reduce pollutant emissions when used as a

vehicle fuel.
Stationary source emissions Pollutant emissions from fixed-location sources such as electrical
power plants, petroleum refineries, steel plants, etc. Stationary
source emissions are commonly emitted from confined conduits
such as stacks or ducts. These are classified as point-source
emissions. However, stationary source emissions may also include
fugitive (non-confined) emissions emitted from stock piles or
process operations
Glossary-1
‫أﻣﺮ ﻋﻤﻞ رﻗﻢ ‪832‬‬
‫ﻋﻘﺪ رﻗﻢ ﺑﻲ‪ -‬ﺳﻲ‪ -‬إي ‪100960000200‬‬
‫‪PCE-I-00-96-00002-00‬‬
‫اﻟﺒﺮﻧﺎﻣﺞ اﻟﻤﺼﺮي ﻟﻠﺴﻴﺎﺳﺎت اﻟﺒﻴﺌﻴﺔ‬

‫وﺣﺪة دﻋﻢ اﻟﺒﺮﻧﺎﻣﺞ‬
‫اﻟﻌﻨﺎﺹﺮ اﻷﺳﺎﺳﻴﺔ ﻟﻤﺮاﺟﻌﺔ اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺳﻴﺔ‬

‫ﻟﻨﻮﻋﻴﺔ اﻟﻬﻮاء ﻓﻲ ﻣﺼﺮ‬
‫إﻋـﺪاد‪:‬‬
‫أﻻن ﻟﻮیـﺐ‬
‫أﺑﺮیﻞ ‪2001‬‬
‫ﺗﻘﺮیﺮ ُﻣﻘﺪَم إﻟﻰ‪:‬‬
‫اﻟﻮآﺎﻟﺔ اﻷﻣﺮیﻜﻴﺔ ﻟﻠﺘﻨﻤﻴﺔ اﻟﺪوﻟﻴﺔ – اﻟﻘﺎهﺮة‬

‫وﺟﻬﺎز ﺷﺌﻮن اﻟﺒﻴﺌﺔ‬
‫ﻣُﻘﺪم ﻣـﻦ‪:‬‬
‫ﻣﺸﺮوع اﻟﺴﻴﺎﺳﺎت اﻟﺒﻴﺌﻴﺔ واﻟﺪﻋﻢ اﻟﻤﺆﺳﺴﻲ ‪EPIQ‬‬
‫ﻣﺸﺮوع ﻣﻤﻮل ﻣﻦ اﻟﻮآﺎﻟﺔ اﻷﻣﺮیﻜﻴﺔ ﻟﻠﺘﻨﻤﻴﺔ اﻟﺪوﻟﻴﺔ‪،‬‬
‫إدارة ﺷﺮآﺔ إﻧﺘﺮﻧﺎﺷﻴﻮﻧﺎل ریﺴﻮرﺳﺰ ﺟﺮوب اﻟﻤﺤﺪودة‬
‫ﻣﻠﺨـﺺ‪:‬‬
‫ﺗﺤ ﺘﻔﻆ اﻟﻮآﺎﻟ ﺔ اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻠﺘﻨﻤﻴ ﺔ اﻟﺪوﻟﻴ ﺔ ﺑﺘ ﺎرﻳﺦ ﻃﻮﻳ ﻞ ﻣ ﻦ اﻻهﺘﻤ ﺎم ﺑﺎﻟﻘﻀ ﺎﻳﺎ اﻟﺒﻴﺌﻴ ﺔ ﻓ ﻲ ﻣﺼ ﺮ‪.‬‬
‫وﻣﻨ ﺬ ﺑﺪاﻳ ﺔ اﻟﺜﻤﺎﻥﻴﻨ ﺎت وﺡﺘ ﻰ ﻣﻨﺘﺼ ﻒ اﻟﺘﺴ ﻌﻴﻨﻴﺎت‪ ،‬اﻥﺤﺼ ﺮت اﻻهﺘﻤﺎﻣ ﺎت اﻟﺮﺉﻴﺴ ﻴﺔ ﻟﻠﻮآﺎﻟ ﺔ ﻓ ﻲ‬
‫أﻋﻤﺎل إﻥﺸﺎء وإﺡﻼل وﺗﺠﺪﻳﺪ اﻟﺒﻨﻴﺔ اﻟﺘﺤﺘﻴﺔ ﻣﺜﻞ ﻣﺤﻄﺎت وﺵﺒﻜﺎت ﻣﻴﺎﻩ اﻟﺸﺮب واﻟﺼ ﺮف اﻟﺼ ﺤﻲ‪.‬‬
‫ﺙﻢ ﺗﺤﻮل اﻻهﺘﻤﺎم ﻣﻊ ﺑﺪاﻳﺔ اﻟﺘﺴ ﻌﻴﻨﻴﺎت إﻟ ﻰ ﻣﻨ ﺎﻃﻖ ﺧ ﺎرج اﻟﻤﺮاآ ﺰ اﻟﺤﻀ ﺮﻳﺔ ﻓ ﻲ ﻣ ﺪﻳﻨﺘﻲ اﻟﻘ ﺎهﺮة‬
‫واﻹﺱﻜﻨﺪرﻳﺔ‪ .‬ﻓﻔﻲ اﻟﻘﺎهﺮة اﻟﻜﺒﺮى‪ ،‬ﺗﺤﻮﻟﺖ اﻟﺠﻬﻮد ﻣﻦ اﻟﺒﻨﻴ ﺔ اﻟﺘﺤﺘﻴ ﺔ إﻟ ﻰ اﻟ ﺪﻋﻢ اﻟﻤﺆﺱﺴ ﻲ ﺑﺤﻴ ﺚ‬
‫ﻳﻤﻜﻦ ﺗﺸﻐﻴﻞ اﻟﻤﺮاﻓﻖ ﺑﺼﻮرة اﻗﺘﺼﺎدﻳﺔ ﺗﻤﺸﻴًﺎ ﻣﻊ ﺝﻬﻮد اﻟﺤﻜﻮﻣﺔ اﻟﻤﺼﺮﻳﺔ ﻟﺘﺤﺮﻳﺮ اﻻﻗﺘﺼﺎد‪.‬‬
‫ﻞ ﻣﻦ اﻟﺤﻜﻮﻣ ﺔ اﻟﻤﺼ ﺮﻳﺔ واﻟﻮآﺎﻟ ﺔ اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻠﺘﻨﻤﻴ ﺔ اﻟﺪوﻟﻴ ﺔ ﺑﻤ ﺪى‬

‫وﻓﻲ ﻥﻔﺲ اﻟﻮﻗﺖ‪ ،‬زاد إدراك آ ٍ‬
‫ﻣﻌﺎﻥﺎة اﻟﻤﻨ ﺎﻃﻖ اﻟﺤﻀ ﺮﻳﺔ ﻓ ﻲ اﻟﻘ ﺎهﺮة ﻣ ﻦ زﻳ ﺎدة ﻏﻴ ﺮ ﻣﺴ ﺒﻮﻗﺔ ﻓ ﻲ اﻟﺘﻠ ﻮث ﺧﺎﺹ ًﺔ ﺗﻠ ﻮث اﻟﻬ ﻮاء‪.‬‬
‫وﻗﺪ ﻗﺎﻣﺖ اﻟﻮآﺎﻟﺔ اﻷﻣﺮﻳﻜﻴﺔ ﻟﻠﺘﻨﻤﻴﺔ اﻟﺪوﻟﻴ ﺔ ﺑﺘﻤﻮﻳ ﻞ ﻋ ﺪد ﻣ ﻦ اﻟﻤﺸ ﺮوﻋﺎت ﻗﺼ ﻴﺮة اﻷﻣ ﺪ ﻟﻠﻤﺴ ﺎﻋﺪة‬
‫ﻓﻲ ﺗﻘﻴﻴﻢ اﻟﻤﻮﻗ ﻒ ﻣ ﻦ ﺑﻴﻨﻬ ﺎ دراﺱ ﺔ أﻋ ﺪﺗﻬﺎ ﻋ ﺎم ‪ 1994‬ﻋ ﻦ ﻣﺸ ﺮوﻋﺎت اﻟﺘﻨﻤﻴ ﺔ واﻟﺒﻴﺌ ﺔ )‪،(PRIDE‬‬
‫واﻟﺘﻲ أآﺪت ﻣﺨﺎﻃﺮ ﺗﺄﺙﻴﺮ ﺗﻠﻮث اﻟﻬﻮاء ﻋﻠﻰ اﻟﺼﺤﺔ اﻟﻌﺎﻣﺔ‪ .‬ﺙﻢ ﻗﺎﻣﺖ اﻟﺤﻜﻮﻣﺔ اﻟﻤﺼ ﺮﻳﺔ واﻟﻮآﺎﻟ ﺔ‬
‫اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻠﺘﻨﻤﻴ ﺔ اﻟﺪوﻟﻴ ﺔ ﺑ ﺎﻟﺘﺨﻄﻴﻂ ﻟﻤﺸ ﺮوع ﺽ ﺨﻢ ﻟﻠﺘﺼ ﺪي ﻟﻤﺸ ﻜﻠﺔ ﺗﻠ ﻮث اﻟﻬ ﻮاء ه ﻮ ﻣﺸ ﺮوع‬
‫ﺗﺤﺴﻴﻦ هﻮاء اﻟﻘﺎهﺮة اﻟ ﺬي ﺗﻀ ﻤﻦ ﻋ ﺪدًا ﻣ ﻦ اﻟﻤﺒ ﺎدرات اﻟﻤﻤﻴ ﺰة اﻟﺘ ﻲ ﺗﺴ ﺘﻬﺪف اﺱ ﺘﻴﻔﺎء اﺡﺘﻴﺎﺝ ﺎت‬
‫ﻣﺤﻠﻴﺔ ﻣﺤﺪدة‪.‬‬
‫وﻣ ﻊ أﺧ ﺬ ﺧﻄ ﻮرة ﻣﺸ ﻜﻼت ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﻓ ﻲ اﻻﻋﺘﺒ ﺎر‪ ،‬ﻗﺎﻣ ﺖ اﻟﻮآﺎﻟ ﺔ اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻠﺘﻨﻤﻴ ﺔ اﻟﺪوﻟﻴ ﺔ‬
‫ﺑﺈﻥﺸ ﺎء ﻣﺸ ﺮوع ﺝﺪﻳ ﺪ ﺑﻤﻮﺝ ﺐ ﺑﺮﻥ ﺎﻣﺞ اﻟﺴﻴﺎﺱ ﺎت اﻟﺒﻴﺌﻴ ﺔ واﻟ ﺪﻋﻢ اﻟﻤﺆﺱﺴ ﻲ )‪ (EPIQ‬ﻟﺘ ﻮﻓﻴﺮ‬
‫اﻟﻤﻮارد اﻟﻼزﻣﺔ ﻟﻤﻌﺎﻟﺠﺔ ﻣﺸﻜﻼت ﺗﻠﻮث اﻟﻬﻮاء ﻓﻲ ﻣﺼﺮ‪ .‬وﺗﻘﻮم اﻟﻮآﺎﻟﺔ اﻷﻣﺮﻳﻜﻴﺔ ﻟﻠﺘﻨﻤﻴﺔ اﻟﺪوﻟﻴ ﺔ‬
‫ﺡﺎﻟﻴًﺎ ﺑﺘﻤﻮﻳ ﻞ اﻟﺒﺮﻥ ﺎﻣﺞ اﻟﻤﺼ ﺮي ﻟﻠﺴﻴﺎﺱ ﺎت اﻟﺒﻴﺌﻴ ﺔ )‪ (EEPP‬واﻟ ﺬي ﻳﻬ ﺪف إﻟ ﻰ ﺗﻨ ﺎول اﻟﺴﻴﺎﺱ ﺎت‬
‫ﻋ ِﻬ َﺪ إﻟ ﻰ وﺡ ﺪة دﻋ ﻢ اﻟﺒﺮﻥ ﺎﻣﺞ )‪(PSU‬‬ ‫اﻟﺘﻲ ﺗﺆﺙﺮ ﻋﻠﻰ اﻟﺒﻴﺌﺔ ﻓﻲ ﻣﺼﺮ ﻋﻠﻰ اﻟﻤ ﺪى اﻟﻄﻮﻳ ﻞ‪ .‬وﻗ ﺪ ُ‬
‫ﺑﺎﻟﺒﺮﻥ ﺎﻣﺞ اﻟﻤﺼ ﺮي ﻟﻠﺴﻴﺎﺱ ﺎت اﻟﺒﻴﺌﻴ ﺔ ﺗﻨﻔﻴ ﺬ ‪ 14‬ﻣﻬﻤ ﺔ ﻋﻤ ﻞ ﺧ ﻼل اﻟﻤﺮﺡﻠ ﺔ اﻷوﻟ ﻰ ﻣ ﻦ اﻟﺒﺮﻥ ﺎﻣﺞ‪،‬‬
‫ﻣﻨﻬﺎ ﺗﻘﻴﻴﻢ اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱ ﻴﺔ ﻟﻨﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﻓ ﻲ ﻣﺼ ﺮ‪ ،‬واﻟﺘ ﻲ ﺹ ﺎﻏﺘﻬﺎ ﻣﺼ ﺮ ﻓ ﻲ ﻗ ﺎﻥﻮن اﻟﺒﻴﺌ ﺔ‬
‫رﻗﻢ ‪ 4‬ﻟﺴﻨﺔ ‪ 1994‬وﻻﺉﺤﺘ ﻪ اﻟﺘﻨﻔﻴﺬﻳ ﺔ‪ .‬وﻓ ﻲ ﺧﻄ ﻮة ﻣﻬﻤ ﺔ‪ ،‬ﺗﻘ ﻮم اﻟﻮآﺎﻟ ﺔ اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻠﺘﻨﻤﻴ ﺔ اﻟﺪوﻟﻴ ﺔ‬
‫ﺑﺘﻤﻮﻳﻞ إﻥﺸﺎء ﻥﻈﺎم ﻟﻤﺮاﺝﻌﺔ وﺗﻌﺪﻳﻞ ﻣﻮاﺹﻔﺎت اﻥﺒﻌﺎﺙ ﺎت اﻟﻬ ﻮاء ﺑﺼ ﻔﺔ دورﻳ ﺔ ﺑﺎﻟﺘﻌ ﺎون ﻣ ﻊ ﺝﻬ ﺎز‬
‫ﺵﺌﻮن اﻟﺒﻴﺌﺔ‪.‬‬
‫وﻓﻲ إﻃﺎر هﺬﻩ اﻟﺠﻬﻮد‪ ،‬أﻋﺪت وﺡﺪة دﻋ ﻢ اﻟﺒﺮﻥ ﺎﻣﺞ دراﺱ ﺔ ﺗﺤﻠﻴﻠﻴ ﺔ ﻟﻤﻘﺎرﻥ ﺔ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻤﺼ ﺮﻳﺔ‬
‫ﻣﻊ اﻟﺒﺮاﻣﺞ اﻟﻜﺒﺮى ﻟﻨﻮﻋﻴﺔ اﻟﻬﻮاء‪ .‬وﺵﻤﻞ اﻟﺘﺤﻠﻴﻞ ﺡﺼ ﺮ ﻟﻜﺎﻓ ﺔ اﻟﺒ ﺮاﻣﺞ اﻟﺒ ﺎرزة ﺱ ﻮا ًء اﻟﻤﺤﻠﻴ ﺔ أو‬
‫اﻟﺪوﻟﻴﺔ‪ ،‬ﺡﻴﺚ رآﺰ اﻟﺘﺤﻠﻴ ﻞ ﻋﻠ ﻰ اﻟﻤﻮاﺹ ﻔﺎت اﻟﺘ ﻲ ﺗﺴ ﺘﺨﺪﻣﻬﺎ اﻟﻮﻻﻳ ﺎت اﻟﻤﺘﺤ ﺪة اﻷﻣﺮﻳﻜﻴ ﺔ‪ ،‬ودول‬
‫اﻻﺗﺤﺎد اﻷوروﺑﻲ‪ ،‬وﻣﻨﻈﻤﺔ اﻟﺼﺤﺔ اﻟﻌﺎﻟﻤﻴﺔ‪ .‬وﺑﺎﻹﺽﺎﻓﺔ إﻟﻰ ذﻟﻚ‪ ،‬ﺗﻢ ﻋﻘﺪ ﺱﻠﺴ ﻠﺔ ﻣ ﻦ اﻻﺝﺘﻤﺎﻋ ﺎت‬
‫ﻓﻲ ﻣﺼﺮ ﻣﻊ اﻟﻤﺴ ﺎهﻤﻴﻦ اﻟﺮﺉﻴﺴ ﻴﻴﻦ ﻓ ﻲ اﻟﻤﺸ ﺮوع )ﺗ ﻢ ﺗﺴ ﺠﻴﻞ آﺎﻓ ﺔ اﻟﺠﻬ ﺎت ﻓ ﻲ اﻟﻤﻠﺤ ﻖ رﻗ ﻢ ه ـ(‬
‫ﻟﺘﺤﺪﻳﺪ اﻷوﻟﻮﻳﺎت ﺙﻢ ﻋﺮﺽﻬﺎ ﻋﻠﻰ ﺝﻬﺎز ﺵﺌﻮن اﻟﺒﻴﺌﺔ ﻟﺘﻘﻴﻴﻤﻬﺎ‪.‬‬
‫وﻳﻤﻜ ﻦ ﺗﻘﺴ ﻴﻢ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻘﻴﺎﺱ ﻴﺔ ﻟﺘﻠ ﻮث اﻟﻬ ﻮاء إﻟ ﻰ ﻓﺌﺘ ﻴﻦ رﺉﻴﺴ ﻴﺘﻴﻦ‪ :‬ﻣﻮاﺹ ﻔﺎت ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء‬
‫وﻣﻮاﺹﻔﺎت اﻟﺤﺪ ﻣﻦ اﻥﺒﻌﺎﺙﺎت اﻟﻬ ﻮاء‪ .‬وﺑﺴ ﺒﺐ اﻻﺧﺘﻼﻓ ﺎت اﻟﺠﻮهﺮﻳ ﺔ ﺑ ﻴﻦ اﻻﺙﻨﺘ ﻴﻦ‪ ،‬ﺗﻮﺝ ﺪ ﺑ ﺮاﻣﺞ‬
‫ﻣﻤﻴﺰة ﻟﻠﺴﻴﻄﺮة ﻋﻠﻰ اﻻﻥﺒﻌﺎﺙﺎت ﻣﻦ اﻟﻤﺼ ﺎدر اﻟﺜﺎﺑﺘ ﺔ واﻟﻤﺘﺤﺮآ ﺔ‪ .‬وﻗ ﺪ ﺗ ﻢ ﺗﻘﻴ ﻴﻢ ﺝﻤﻴ ﻊ ه ﺬﻩ اﻟﻔﺌ ﺎت‬
‫ﻓﻲ ﺽﻮء اﻟﻤﻮاﺹﻔﺎت اﻟﻌﺎﻟﻤﻴﺔ‪.‬‬
‫وﻗ ﺪ ﺗﻤ ﺖ ﻣﻘﺎرﻥ ﺔ ﻣﻮاﺹ ﻔﺎت ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﻓ ﻲ ﻣﺼ ﺮ ﻣ ﻊ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻤﻨ ﺎﻇﺮة ﻟﻬ ﺎ ﻓ ﻲ آ ﻞ ﻣ ﻦ‬
‫اﻟﻮﻻﻳ ﺎت اﻟﻤﺘﺤ ﺪة اﻷﻣﺮﻳﻜﻴ ﺔ ودول اﻻﺗﺤ ﺎد اﻷوروﺑ ﻲ وﻣﻨﻈﻤ ﺔ اﻟﺼ ﺤﺔ اﻟﻌﺎﻟﻤﻴ ﺔ‪ .‬وﻗ ﺪ أﻇﻬ ﺮت‬
‫‪2‬‬
‫اﻟﻤﻘﺎرﻥ ﺔ أن ﻣﻮاﺹ ﻔﺎت ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء اﻟﻤﺤ ﻴﻂ ﻓ ﻲ ﻣﺼ ﺮ )ﻣﺜ ﻞ اﻟﻬ ﻮاء ﺧ ﺎرج اﻟﻤﺒ ﺎﻥﻲ( ﻻ ﺗﺨ ﺮج‬
‫آﺜﻴﺮا ﻋﻦ إﻃﺎر هﺬﻩ اﻟﻤﻮاﺹﻔﺎت وﻟﻜﻦ هﻨﺎك ﺑﻌﺾ اﻟﺘﻌﺪﻳﻼت اﻟﺘﻲ ﻳﺠﺐ إدﺧﺎﻟﻬﺎ ﻋﻠﻴﻬﺎ‪.‬‬
‫ﻻ‪ :‬اﻟﺤﺪود اﻟﻤﻘﺒﻮﻟﺔ ﻟﺜﺎﻥﻲ أآﺴﻴﺪ اﻟﻨﺘﺮوﺝﻴﻦ واﻟﺮﺹ ﺎص أﻗ ﻞ آﺜﻴ ﺮًا ﻣ ﻦ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻤﻘﺒﻮﻟ ﺔ ﻓ ﻲ‬‫أو ً‬
‫اﻟﻌﺎﻟﻢ‪ .‬وﻳﻮﺹﻲ هﺬا اﻟﺘﻘﺮﻳﺮ ﺑﺄن ﺗﻘﻮم ﻣﺼﺮ ﺑﻮﺽﻊ ﻣﻮاﺹﻔﺎت أآﺜﺮ ﺹﺮاﻣﺔ‪.‬‬
‫ﺙﺎﻥﻴ ًﺎ‪ :‬ﻳﻮﺹ ﻲ ه ﺬا اﻟﺘﻘﺮﻳ ﺮ أﻳﻀ ًﺎ ﺑ ﺄن ﺗﻘ ﻮم ﻣﺼ ﺮ ﺑﺈﻋ ﺎدة ﻓﺤ ﺺ ﻣﺘﻮﺱ ﻂ اﻟﻮﻗ ﺖ ﺑﺎﻟﻨﺴ ﺒﺔ ﻟﻜﺎﻓ ﺔ‬
‫اﻟﻤﻮاﺹﻔﺎت‪.‬‬
‫ﺙﺎﻟﺜ ًﺎ‪ :‬ﻳﻮﺹ ﻲ ه ﺬا اﻟﺘﻘﺮﻳ ﺮ ﺑ ﺄن ﺗﻘ ﻮم ﻣﺼ ﺮ ﺑ ﺎﻟﻨﻈﺮ ﻓ ﻲ ﺡ ﺬف اﺙﻨ ﻴﻦ ﻣ ﻦ اﻟﻤﻠﻮﺙ ﺎت وهﻤ ﺎ اﻟ ﺪﺧﺎن‬
‫اﻷﺱ ﻮد‪ ،‬وذﻟ ﻚ ﺑﺴ ﺒﺐ ازدواﺝﻴﺘ ﻪ ﻣ ﻊ اﻟﻤ ﻮاد اﻟﻌﺎﻟﻘ ﺔ ذات ﻗُﻄ ﺮ ‪ 10‬ﻣﻴﻜ ﺮون أو أﻗ ﻞ ‪(PM10),‬‬
‫واﻟﺠﺴﻴﻤﺎت اﻟﺼﻠﺒﺔ اﻟﻜﻠﻴﺔ اﻟﻌﺎﻟﻘﺔ )‪ (TSP‬ﺡﻴﺚ أﻥﻬﺎ ﻣﻮاد ﺹﻠﺒﺔ آﺒﻴﺮة ﻻ ﻳﻤﻜﻦ اﺱﺘﻨﺸﺎﻗﻬﺎ ﺑﻌﻤﻖ ﻓ ﻲ‬
‫اﻟﺮﺉﺘﻴﻦ ﻣﻤﺎ ﻻ ﻳﺴﺒﺐ ﻣﺸﺎآﻞ ﺹﺤﻴﺔ‪.‬‬
‫راﺑﻌًﺎ‪ :‬ﻳﻮﺹﻲ ه ﺬا اﻟﺘﻘﺮﻳ ﺮ ﺑ ﺄن ﺗﻌﻴ ﺪ ﻣﺼ ﺮ اﻟﻨﻈ ﺮ ﻓ ﻲ إﺽ ﺎﻓﺔ ﻣﻮاﺹ ﻔﺎت ﻟﻠﻤ ﻮاد اﻟﻌﺎﻟﻘ ﺔ اﻟﺼ ﻐﻴﺮة‬
‫اﻟﺘ ﻲ ﻳﻤﻜ ﻦ اﺱﺘﻨﺸ ﺎﻗﻬﺎ ﺑﻌﻤ ﻖ ﻓ ﻲ اﻟ ﺮﺉﺘﻴﻦ وﻟﻠ ُﻤﺮآﺒ ﺎت اﻟﻌﻀ ﻮﻳﺔ اﻟﻤﺘﻄ ﺎﻳﺮة اﻟﺘ ﻲ ﺗﺤ ﺪ ﻣ ﻦ ﺗﻜ ﻮﻳﻦ‬
‫اﻷوزون اﻟﻤﺤﻴﻂ‪.‬‬
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‫آﻤ ﺎ ﻳﺠ ﺐ اﻟﻨﻈ ﺮ أﻳﻀ ﺎ ﻓ ﻲ إﺽ ﺎﻓﺔ ‪ 11‬ﻣﻠ ﻮث ﻣ ﻦ ﻣﻠﻮﺙ ﺎت اﻟﻬ ﻮاء اﻟﺨﻄ ﺮة إﻟ ﻰ ﻣﻮاﺹ ﻔﺎت ﻥﻮﻋﻴ ﺔ‬
‫اﻟﻬﻮاء ﻓﻲ ﻣﺼﺮ وذﻟﻚ ﻥﻈﺮًا ﻷﻥﻬﺎ ﺗﺴﺒﺐ أﺽﺮارًا ﺹﺤﻴﺔ ﻥﺘﻴﺠﺔ اﻟﺘﻌﺮض اﻟﺒﺴﻴﻂ ﻟﻬﺎ‪ .‬وﺑﻌ ﺾ ه ﺬﻩ‬
‫اﻟﻤﻠﻮﺙ ﺎت ﻣﻮﺝ ﻮد ﺡﺎﻟﻴ ًﺎ ﻓ ﻲ اﻟﻘﺎﺉﻤ ﺔ آﻤ ﻮاد ﻣﺴ ﺠﻠﺔ ﺗﺤ ﺖ ﻣﻮاﺹ ﻔﺎت "اﻻﻥﺒﻌﺎﺙ ﺎت" أو ﻣﻮاﺹ ﻔﺎت‬
‫"أﻣﺎآﻦ اﻟﻌﻤﻞ"‪.‬‬
‫ﻻ ﺡﺴ ﺐ ﻥ ﻮع اﻟﻤﻠ ﻮث ﺙ ﻢ‬ ‫وﻗﺪ ﺗﻢ ﺗﺼﻨﻴﻒ ﻣﻮاﺹﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت ﻣ ﻦ اﻟﻤﺼ ﺎدر اﻟﺜﺎﺑﺘ ﺔ ﻓ ﻲ ﻣﺼ ﺮ أو ً‬

‫ﺡﺴ ﺐ ﻥ ﻮع اﻟﺼ ﻨﺎﻋﺔ اﻟﺘ ﻲ ﺗﻨﻄﺒ ﻖ ﻋﻠﻴﻬ ﺎ اﻟﻤﻮاﺹ ﻔﺎت‪ .‬وﺑﺎﻟﻤﻘﺎرﻥ ﺔ ﻥﺠ ﺪ أن ﺑ ﺮاﻣﺞ اﻟﻤﻮاﺹ ﻔﺎت‬
‫اﻟﻌﺎﻟﻤﻴ ﺔ اﻟﺜﻼﺙ ﺔ ﺗﻘ ﻮم ﺑﺘﺼ ﻨﻴﻒ اﻟﻤﻮاﺹ ﻔﺎت ﺡﺴ ﺐ اﻟﻤﺼ ﺪر‪ ،‬وﻃﺒﻘ ًﺎ ﻟﻠﻤﻮاﺹ ﻔﺎت اﻷﻣﺮﻳﻜﻴ ﺔ ﻳ ﺘﻢ‬
‫اﻟﺘﺼﻨﻴﻒ ﺡﺴﺐ ﻥﻮع اﻟﻤﻌﺪات وﻟﻴﺲ ﻥﻮع اﻟﺼﻨﺎﻋﺔ‪ .‬وﺑﺴ ﺒﺐ ه ﺬﻩ اﻻﺧﺘﻼﻓ ﺎت اﻷﺱﺎﺱ ﻴﺔ ﻓﻠ ﻴﺲ ﻣ ﻦ‬
‫اﻟﻤﻤﻜ ﻦ ﻋﻤ ﻞ ﻣﻘﺎرﻥ ﺔ ﻣﺒﺎﺵ ﺮة ﺑ ﻴﻦ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻤﺼ ﺮﻳﺔ ﻻﻥﺒﻌﺎﺙ ﺎت اﻟﻤﺼ ﺎدر اﻟﺜﺎﺑﺘ ﺔ وﺑ ﻴﻦ‬
‫اﻟﻤﻮاﺹﻔﺎت اﻷﻣﺮﻳﻜﻴﺔ أو اﻷورﺑﻴﺔ أو ﻣﻮاﺹﻔﺎت ﻣﻨﻈﻤ ﺔ اﻟﺼ ﺤﺔ اﻟﻌﺎﻟﻤﻴ ﺔ‪ .‬وﻣ ﻊ ذﻟ ﻚ ﺗﻮﺝ ﺪ ﺑﻌ ﺾ‬
‫اﻟﻤﻼﺡﻈﺎت اﻟﻤﻔﻴﺪة‪.‬‬
‫ﻻ‪ :‬اﻟﻘﺎﻥﻮن اﻟﻤﺼﺮي ﻏﻴﺮ ﻣﺤﺪد وﻳﺪرج اﻟﻤﻠﻮﺙ ﺎت ﻓ ﻲ ﻣﺠﻤﻮﻋ ﺎت ﻣﺘﻌ ﺪدة ﺑﺤ ﺪود ﻣﺨﺘﻠﻔ ﺔ‪ .‬ﺙﺎﻥﻴ ًﺎ‪:‬‬ ‫أو ً‬
‫ﺗﻢ آﺘﺎﺑﺔ ﻣﻮاﺹﻔﺎت اﻻﻥﺒﻌﺎﺙﺎت ﻓﻲ ﺹﻮرة أرﻗﺎم ﻣﻄﻠﻘﺔ ﺑﺪون ﺗﺤﺪﻳﺪ ﻣﺘﻮﺱ ﻂ اﻷوﻗ ﺎت‪ ،‬وﺑﻴﻨﻤ ﺎ ﻳ ﺆدي‬
‫ذﻟﻚ إﻟﻰ ﺗﺨﻔﻴﻒ اﻟﻀﺮر إﻻ أﻥﻪ ﻻ ﻳﺆدي ﺑﺎﻟﻀﺮورة إﻟﻰ ﺧﻔﺾ ﺗﻠﻮث اﻟﻬﻮاء‪.‬‬
‫ﺙﺎﻟﺜًﺎ‪ :‬ﻗﺎﺉﻤﺔ اﻟﻤﻠﻮﺙ ﺎت ﻏﻴ ﺮ ﺵ ﺎﻣﻠﺔ‪ ،‬وهﻨ ﺎك اﻟﻌﺪﻳ ﺪ ﻣ ﻦ ﻣﻠﻮﺙ ﺎت اﻟﻬ ﻮاء ﻏﻴ ﺮ ﻣﺴ ﺠﻠﺔ ﺑﻬ ﺎ‪ .‬ﻟ ﺬﻟﻚ ﻓ ﺈن‬
‫ﻼ‬
‫ﻻ ﻣ ﻦ اﻟﻤﺼ ﺪر – ﻳﺠﻌ ﻞ اﻟﺘﻄﺒﻴ ﻖ اﻟﻤﺘﺴ ﺎوي ﻟﻠﻘﻮاﻋ ﺪ ﻣﺴ ﺘﺤﻴ ً‬ ‫اﻟﻤﺒ ﺪأ اﻟﺤ ﺎآﻢ – ﻃﺒﻘ ًﺎ ﻟﻠﻤﻠ ﻮث ﺑ ﺪ ً‬
‫وﻳﺠﻌﻞ ﻋﻤﻠﻴﺔ إدارﺗﻬﺎ ﺹﻌﺒﺔ ﻟﻠﻐﺎﻳﺔ‪.‬‬
‫وﻗﺪ أﻋﺮب اﻟﻤﺴﺎهﻤﻮن ﻣﻦ اﻟﺠﺎﻥ ﺐ اﻟﻤﺼ ﺮي ﻋ ﻦ رأﻳﻬ ﻢ ﺑ ﺄن ﻣﻌﻈ ﻢ ﻣﻮاﺹ ﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت – ﻣﺜ ﻞ‬
‫ﻣﻮاﺹﻔﺎت ﺙﺎﻥﻲ أآﺴﻴﺪ اﻟﻜﺒﺮﻳﺖ – ﻏﻴﺮ ﺡﺎزﻣﺔ ﺑﺪرﺝﺔ آﺎﻓﻴﺔ‪ ،‬وأﺙﺎروا ﻗﻀﺎﻳﺎ اﻟﺴﻴﻄﺮة ﻋﻠﻰ ﻣﺤﺘ ﻮى‬
‫اﻟﻜﺒﺮﻳﺖ ﻓﻲ اﻟﻮﻗﻮد آﺄﻓﻀﻞ اﻟﻄﺮق ﻟﻠﺘﺤﻜﻢ ﻓﻲ اﻻﻥﺒﻌﺎﺙﺎت‪.‬‬
‫وﺑﺎﻹﺽ ﺎﻓﺔ إﻟ ﻰ ذﻟ ﻚ ﻓ ﺈن ﻃﺮﻳﻘ ﺔ ﺗﺤﺪﻳ ﺪ ﻣﻮاﺹ ﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت ﻣ ﻦ ﻣﺼ ﺎدر اﻻﺵ ﺘﻌﺎل ﺗﺘﺒ ﻊ ﻃﺮﻳﻘ ﺔ‬
‫ﻻ ﻣﻦ اﺱﺘﺨﺪام ﻃﺮﻳﻘﺔ اﻟﺘﺤﻠﻴﻞ اﻟﻜﻤ ﻲ ﻟﻘﻴ ﺎس‬ ‫"رﻥﺠﻠﻤﺎن" اﻟﻌﺘﻴﻘﺔ ﻟﻘﻴﺎس ﻥﺴﺒﺔ اﻟﻌﺘﺎﻣﺔ ﻟﻠﺪﺧﺎن اﻟﻨﺎﺗﺞ ﺑﺪ ً‬
‫اﻟﺤﺠﻢ واﻟﺘﺮآﻴﺐ اﻟﻜﻴﻤﺎﺉﻲ وﺡﺠﻢ اﻟﺠﺰﻳﺌﺎت اﻟﺘﻲ ﺗﺘﻜﻮن ﻣﻨﻬﺎ هﺬﻩ اﻻﻥﺒﻌﺎﺙﺎت‪.‬‬
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‫آﻤ ﺎ ﺗﻤ ﺖ ﻣﻘﺎرﻥ ﺔ ﻣﻮاﺹ ﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت ﻣ ﻦ اﻟﻤﺼ ﺎدر اﻟﻤﺘﺤﺮآ ﺔ ﻣ ﻊ اﻟﻤﻮاﺹ ﻔﺎت اﻷﻣﺮﻳﻜﻴ ﺔ‬
‫واﻷورﺑﻴﺔ )ﻣﻨﻈﻤﺔ اﻟﺼ ﺤﺔ اﻟﻌﺎﻟﻤﻴ ﺔ ﻟ ﻢ ﺗﺼ ﺪر ﻣﻮاﺹ ﻔﺎﺗﻬﺎ ﻟﻠﻤﺼ ﺎدر اﻟﻤﺘﺤﺮآ ﺔ(‪ .‬وﻗ ﺪ آﺸ ﻔﺖ ه ﺬﻩ‬
‫اﻟﻤﻘﺎرﻥﺔ ﻋﻦ اﺧﺘﻼﻓﺎت أﺱﺎﺱﻴﺔ‪.‬‬
‫ﻻ‪ :‬ﻳ ﺘﻢ ﻓ ﻲ ﻣﺼ ﺮ ﻗﻴ ﺎس اﻥﺒﻌﺎﺙ ﺎت ﻣﺎﺱ ﻮرة اﻟﻌ ﺎدم آﻨﺴ ﺒﺔ ﻣﺌﻮﻳ ﺔ إﻟ ﻰ ﺡﺠ ﻢ اﻻﻥﺒﻌﺎﺙ ﺎت‪ ،‬ﺑﻴﻨﻤ ﺎ‬ ‫أو ً‬
‫اﻟﻤﻮاﺹﻔﺎت اﻷﻣﺮﻳﻜﻴﺔ واﻷورﺑﻴﺔ ﺗﻘﻴﺲ اﻟﻤﻠﻮث ﺑﺎﻟﺠﺮام ﺡﺴﺐ اﻟﻤﺴﺎﻓﺔ اﻟﺘﻲ ﺗﻘﻄﻌﻬﺎ اﻟﺴ ﻴﺎرة‪ .‬ﺙﺎﻥﻴ ًﺎ‪:‬‬
‫ﺑﺮوﺗﻮآ ﻮل اﻻﺧﺘﺒ ﺎر اﻟﻤﺼ ﺮي ﻻ ﻳﻤﻜ ﻦ ﻣﻘﺎرﻥﺘ ﻪ ﺑﺴ ﻬﻮﻟﺔ ﻣ ﻊ اﻟﺒﺮوﺗﻮآ ﻮل اﻷﻣﺮﻳﻜ ﻲ أو اﻷورﺑ ﻲ‪،‬‬
‫ﻓﻔﻲ ﻣﺼ ﺮ ﻳ ﺘﻢ ﻓﻘ ﻂ ﻗﻴ ﺎس أول أآﺴ ﻴﺪ اﻟﻜﺮﺑ ﻮن واﻟﻬﻴ ﺪروآﺮﺑﻮﻥﺎت واﻟ ﺪﺧﺎن اﻷﺱ ﻮد وﻻ ﻳ ﺘﻢ ﻗﻴ ﺎس‬
‫اﻟﻬﻴﺪروآﺮﺑﻮﻥﺎت اﻟﺘ ﻲ ﻻ ﺗﺤﺘ ﻮي ﻋﻠ ﻰ اﻟﻤﻴﺜ ﺎن‪ ،‬أو أآﺎﺱ ﻴﺪ اﻟﻨﺘ ﺮوﺝﻴﻦ أو اﻟﻤ ﻮاد اﻟﻌﺎﻟﻘ ﺔ واﻟﺘ ﻲ آﻤ ﺎ‬
‫ذآﺮﻥ ﺎ ﺱ ﺎﺑﻘًﺎ ﺗﻌ ﺪ ﻣﻔﻴ ﺪة أآﺜ ﺮ ﻣ ﻦ ﻗﻴ ﺎس اﻟ ﺪﺧﺎن اﻷﺱ ﻮد ﻓﻘ ﻂ‪ .‬وﺑﻴﻨﻤ ﺎ ﻻ ﺗﻮﺝ ﺪ ﻃﺮﻳﻘ ﺔ ﻟﻠﻤﻘﺎرﻥ ﺔ‬
‫اﻟﻤﺒﺎﺵﺮة ﺑﻴﻦ اﻟﻤﻮاﺹﻔﺎت‪ ،‬إﻻ أن هﻨﺎك ﺑﻌﺾ اﻟﻤﻼﺡﻈﺎت اﻟﻤﻔﻴﺪة‪.‬‬
‫ﻻ‪ :‬ﻗﻴ ﺎس اﻥﺒﻌﺎﺙ ﺎت ﻣﺎﺱ ﻮرة اﻟﻌ ﺎدم ﻓ ﻲ ﻟﺤﻈ ﺔ ﻣﺤ ﺪدة ﻟ ﻢ ﻳ ﻨﺠﺢ ﻓ ﻲ إﻳﺠ ﺎد ﻋﻴﻨ ﺔ ﺗﻤﺜ ﻞ اﻟﻈ ﺮوف‬ ‫أو ً‬
‫اﻟﺤﻘﻴﻘﻴ ﺔ ﻟﻠﻘﻴ ﺎدة‪ .‬آﻤ ﺎ أﻥ ﻪ ﻓ ﻲ ﺡﺎﻟ ﺔ اﺧﺘﺒ ﺎر اﻟﺴ ﻴﺎرة ﻋﻨ ﺪ اﻟﺴ ﺮﻋﺔ اﻟﺨﺎﻣﻠ ﺔ )آﻤ ﺎ ه ﻮ اﻟﺤ ﺎل ﻓ ﻲ‬
‫اﻟﻤﻮاﺹﻔﺎت اﻟﻤﺼﺮﻳﺔ( ﺗﻜﻮن اﻻﻥﺒﻌﺎﺙ ﺎت ﻓ ﻲ ﺡ ﺪهﺎ اﻷدﻥ ﻰ‪ .‬وﺑﺎﻹﺽ ﺎﻓﺔ إﻟ ﻰ ذﻟ ﻚ ﻓ ﺈن اﻟﻤﻮاﺹ ﻔﺎت‬
‫ﺗﻨﻄﺒ ﻖ ﻋﻠ ﻰ ﺝﻤﻴ ﻊ أﻥ ﻮاع اﻟﺴ ﻴﺎرات – اﻟﺒﻨ ﺰﻳﻦ واﻟ ﺪﻳﺰل واﻟﻐ ﺎز اﻟﻄﺒﻴﻌ ﻲ اﻟﻤﻀ ﻐﻮط‪ ،‬واﻟ ﺪراﺝﺎت‬
‫اﻟﺒﺨﺎرﻳﺔ‪ ،‬وﺱﻴﺎرات اﻟﺮآﻮب‪ ،‬واﻷﺗﻮﺑﻴﺴﺎت‪ ،‬وﺱﻴﺎرات اﻟﻨﻘﻞ‪ .‬وﻣﻦ اﻟﻤ ﺮﺝﺢ أﻻ ﺗﺴ ﺘﻮﻓﻲ اﻟﺴ ﻴﺎرات‬
‫اﻟﻜﺒﻴﺮة ﺵﺮوط هﺬﻩ اﻟﻤﻮاﺹﻔﺎت‪ ،‬ﺑﻴﻨﻤﺎ ﻥﺠﺪ أن ﻥﻔﺲ هﺬﻩ اﻟﻤﻮاﺹ ﻔﺎت ﻣﺘﺴ ﺎهﻠﺔ ﻟﻠﻐﺎﻳ ﺔ ﻣ ﻊ اﻟﺴ ﻴﺎرات‬
‫اﻟﺼﻐﻴﺮة‪ ،‬وهﺬا ﻳﻌﻨﻲ أن ﻣﺼﺮ ﺗُﻀﻴﻊ ﻓﺮﺹﺔ ﺱﻬﻠﺔ ﻟﺨﻔﺾ اﻻﻥﺒﻌﺎﺙﺎت‪.‬‬
‫ﻟﺬﻟﻚ ﻳﺠﺐ إﻋﺎدة ﺹﻴﺎﻏﺔ اﻟﻤﻮاﺹﻔﺎت اﻟﻤﺼﺮﻳﺔ ﻟﻤﺼﺎدر اﻻﻥﺒﻌﺎﺙﺎت اﻟﻤﺘﺤﺮآﺔ ﻓﻲ ﺽﻮء‬
‫اﻟﻤﻮاﺹﻔﺎت اﻷﻣﺮﻳﻜﻴﺔ أو اﻷورﺑﻴﺔ‪ ،‬ﺡﻴﺚ أن اﻟﺘﻜﻨﻮﻟﻮﺝﻴﺎ اﻟﻼزﻣﺔ ﻟﻬﺬﻩ اﻟﻤﻮاﺹﻔﺎت ﻣﺘﺎﺡﺔ‪ ،‬آﻤﺎ ﺗﻢ‬
‫ﺧﻔﺾ اﻟﺘﻜﻠﻔﺔ إﻟﻰ اﻟﺤﺪ اﻟﻤﻘﺒﻮل‪ ،‬ﺑﺎﻹﺽﺎﻓﺔ إﻟﻰ أن إدﺧﺎل هﺬﻩ اﻟﺘﻜﻨﻮﻟﻮﺝﻴﺎ ﻓﻲ ﺗﺼﻤﻴﻢ اﻟﺴﻴﺎرات‬
‫ﻳﺆدي إﻟﻰ ﺗﺤﺴﻴﻨﺎت آﺒﻴﺮة ﻓﻲ اﺱﺘﻬﻼك اﻟﻮﻗﻮد‪.‬‬
‫وﺗُﻤﺜﻞ ﻣﻮاﺹﻔﺎت اﻟﻮﻗﻮد اﻟﺒُﻌ ﺪ اﻵﺧ ﺮ ﻓ ﻲ ﻣﻮاﺹ ﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت ﻣ ﻦ اﻟﻤﺼ ﺎدر اﻟﻤﺘﺤﺮآ ﺔ‪ .‬و ﻳﻮﺝ ﺪ‬
‫ل ﻣ ﻦ اﻟﺮﺹ ﺎص‪ ،‬وﻳﺠ ﺐ ﻋﻠﻴﻬ ﺎ اﻹﺱ ﺮاع ﻓ ﻲ ﺡﻈ ﺮ اﺱ ﺘﺨﺪام اﻟﻜﻤﻴ ﺎت‬ ‫ﻟﺪى ﻣﺼﺮ ﺑﺎﻟﻔﻌﻞ وﻗ ﻮد ﺧ ﺎ ٍ‬
‫اﻟﻤﺘﺒﻘﻴﺔ ﻣﻦ اﻟﻮﻗ ﻮد اﻟﻤﺤﺘ ﻮي ﻋﻠ ﻰ اﻟﺮﺹ ﺎص‪ .‬وﺑ ﺎﻟﻨﻈﺮ ﻟ ﺪرﺝﺎت اﻟﺤ ﺮارة اﻟﻌﺎﻟﻴ ﺔ وﻏﻴ ﺎب وﺱ ﺎﺉﻞ‬
‫اﻟﺘﺤﻜﻢ ﻓﻲ أﺑﺨﺮة اﻟﺴﻴﺎرات‪ ،‬ﻥﻮﺹﻲ أﻳﻀًﺎ ﺑﺈﺽﺎﻓﺔ وﺱﺎﺉﻞ اﻟﺘﺤﻜﻢ ﻓﻲ اﻟﺘﻄﺎﻳﺮ إﻟﻰ ﻣﻮاﺹﻔﺎت اﻟﻮﻗ ﻮد‬
‫اﻟﻤﺒ ﺎع ﻓ ﻲ اﻟﻤﻨ ﺎﻃﻖ اﻟﺤﻀ ﺮﻳﺔ ﻟﻠ ﺘﺤﻜﻢ ﻓ ﻲ ﺗﻜ ﻮﻳﻦ اﻷوزون اﻟﻤﺤ ﻴﻂ‪ .‬وﺗﺘﻤﻴ ﺰ ﻣﺼ ﺮ ﺑﻮﺝ ﻮد‬
‫اﺡﺘﻴﺎﻃﻴﺎت ﻣﺘﻨﺎﻣﻴﺔ ﻣﻦ اﻟﻐﺎز اﻟﻄﺒﻴﻌﻲ ﺑﺎﻹﺽﺎﻓﺔ إﻟﻰ اﻟﺘﻘﺪم اﻟﺬي أﺡﺮزﺗﻪ ﻓ ﻲ ﺗﺸ ﺠﻴﻊ اﺱ ﺘﺨﺪام اﻟﻐ ﺎز‬
‫اﻟﻄﺒﻴﻌﻲ اﻟﻤﻀﻐﻮط آﻮﻗﻮد ﻟﻠﺴﻴﺎرات‪ .‬وﻗﺪ أﻇﻬ ﺮت اﻟﺤ ﻮاﻓﺰ ﻓﺎﺉ ﺪﺗﻬﺎ ﻓ ﻲ ﺗﺸ ﺠﻴﻊ اﻟﺘﺤ ﻮل ﻻﺱ ﺘﺨﺪام‬
‫اﻟﻐﺎز اﻟﻄﺒﻴﻌﻲ اﻟﻤﻀﻐﻮط آﻮﻗﻮد‪.‬‬
‫اﻋﺘﺒﺎرات ﻋﺎﻣﺔ‪ :‬وأﺧﻴﺮًا‪ ،‬ﺗﻮاﺝﻪ ﻣﺼﺮ ﻣﺸ ﻜﻠﺔ أآﺒ ﺮ ﻣ ﻦ ﺗﺤﺪﻳ ﺪ ﻣﻮاﺹ ﻔﺎت ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء‪ ،‬وﺗﺘﻤﺜ ﻞ‬
‫ﻓﻲ ﻏﻴﺎب اﻟﻮﻋﻲ ﺑﺤﺠﻢ اﻟﻌﻼﻗﺔ ﺑﻴﻦ ﺗﻠﻮث اﻟﻬﻮاء وﺹﺤﺔ اﻹﻥﺴﺎن‪ .‬ﻓﻤﺼﺮ ﺗﺘﺄﺙﺮ ﺱ ﻨﻮﻳًﺎ ﺑﺎﻟﻌﻮاﺹ ﻒ‬
‫اﻟﺘﺮاﺑﻴ ﺔ واﻟﺮﻣﻠﻴ ﺔ اﻟﺘ ﻲ ﺗﻨﻄﻠ ﻖ ﻓ ﻲ اﻟﺠ ﻮ ﺙ ﻢ ﺗﻨﻘﺸ ﻊ ﺗﺎرآ ﺔ وراءه ﺎ ﻣﻔﻬ ﻮم ﻣ ﺆداﻩ أن اﻟﻬ ﻮاء اﻟﺴ ﻴﺊ‬
‫ﺱﻴﺬهﺐ ﺑﻌﻴﺪًا ﺑﻨﻔﺴﻪ‪ .‬وﺡﺘﻰ وﻗﺖ ﻗﺮﻳﺐ آﺎن هﻨﺎك ﻗﺪر ﺽﺌﻴﻞ ﻣﻦ اﻟﻮﻋﻲ اﻟﻌ ﺎم ﻋ ﻦ ﺗﻠ ﻮث اﻟﻬ ﻮاء‪.‬‬
‫إﻻ أﻥﻪ ﻣﻨﺬ ﻋﺪة ﺱ ﻨﻮات وﻣ ﻊ اﻟﻔﺘ ﺮات اﻟﺘ ﻲ ﺗﺮاآﻤ ﺖ ﻓﻴﻬ ﺎ اﻟﻤﻠﻮﺙ ﺎت واﺡﺘﺒﺴ ﺖ ﻓ ﻮق ﺱ ﻤﺎء اﻟﻘ ﺎهﺮة‬
‫)اﻟﻤﻌﺮوﻓﺔ ﻣﺤﻠﻴ ًﺎ ﺑﺎﺱ ﻢ اﻟﺴ ﺤﺎﺑﺔ اﻟﺴ ﻮداء(‪ ،‬زاد اﻟ ﻮﻋﻲ اﻟﻌ ﺎم ﺑﻬ ﺬﻩ اﻟﻤﺸ ﻜﻠﺔ‪ .‬إﻻ أن اﻟﻤﺘﺴ ﺒﺒﻮن ﻓ ﻲ‬
‫اﻥﺒﻌ ﺎث اﻟﻤﻠﻮﺙ ﺎت ﻣ ﺎزاﻟﻮا ﻻ ﻳ ﺮون أﻥﻔﺴ ﻬﻢ ﻣﺼ ﺎدر ﻟﻠﺘﻠ ﻮث‪ ،‬وﻻ ﻳﻔﻬﻤ ﻮن اﻟﺴ ﺒﺐ ﻣ ﻦ وﺽ ﻊ ه ﺬﻩ‬
‫اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱﻴﺔ وﻻ ﻟﻤﺎذا ﻳﺠﺐ ﻋﻠﻴﻬﻢ ﺗﺤﻤﻞ اﻟﺘﻜﺎﻟﻴﻒ أو اﻟﺠﻬﺪ ﻟﻼﻟﺘﺰام ﺑﻬﺬﻩ اﻟﻤﻮاﺹﻔﺎت‪.‬‬
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‫وﺑﺪراﺱﺔ ﺗﻄ ﻮر ﺑﺮﻥ ﺎﻣﺞ اﻟﻮﻻﻳ ﺎت اﻟﻤﺘﺤ ﺪة اﻷﻣﺮﻳﻜﻴ ﺔ ﻟﻨﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﺱ ﻨﻌﺮف ﻣ ﺎذا ﻳﻔﺘﻘ ﺪ اﻟﺒﺮﻥ ﺎﻣﺞ‬
‫اﻟﻤﺼﺮي‪ ،‬وهﻮ ﻣ ﺎ ﻳﺘﻤﺜ ﻞ ﻓ ﻲ‪ :‬اﻟﻔﻬ ﻢ اﻟﻮاﺽ ﺢ ﻟﻠﻌﻼﻗ ﺔ ﺑ ﻴﻦ ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء وﺡﻤﺎﻳ ﺔ ﺹ ﺤﺔ اﻹﻥﺴ ﺎن‪،‬‬
‫ﺑﺠﺎﻥﺐ اﻟﻘﻮاﻥﻴﻦ اﻟﻤﺴﺘﺨﺪﻣﺔ ﻟﺘﺤﻘﻴﻖ ﺧﻔﺾ اﻻﻥﺒﻌﺎﺙﺎت إﻟﻰ اﻟﻤﺴﺘﻮﻳﺎت اﻟﺘﻲ ﺗ ﻮﻓﺮ ﻥﻮﻋﻴ ﺔ ﻣﻨﺎﺱ ﺒﺔ ﻣ ﻦ‬
‫اﻟﻬﻮاء‪.‬‬
‫وﻗ ﺪ ﻋﺒ ﺮ اﻟﻤﺴ ﺎهﻤﻮن ﻣ ﻦ ﺝﻬ ﺎز ﺵ ﺌﻮن اﻟﺒﻴﺌ ﺔ ﻋ ﻦ ﻏﻴ ﺎب ه ﺬﻩ اﻟﻌﻼﻗ ﺔ اﻟﻮاﺽ ﺤﺔ ﻣ ﻦ ﺧ ﻼل ﻋ ﺪة‬

‫ﻣﺤﺎور ﺗﺘﺮاوح ﺑﻴﻦ اﻟﺘﺮاث اﻟﺘﺎرﻳﺨﻲ واﻟﺜﻘﺎﻓﻲ ﻣﻦ ﻋﺪم اﻻﻟﺘﺰام إﻟ ﻰ ﻋ ﺪم وﺝ ﻮد اﻟﻌﻘﻮﺑ ﺎت اﻟﺮادﻋ ﺔ‬
‫ﻟﻠﻤﺨﺎﻟﻔﻴﻦ ﺑﻤﻮﺝﺐ اﻟﻘﺎﻥﻮن رﻗﻢ ‪ 4‬ﻟﺴﻨﺔ ‪ 1994‬وﻻﺉﺤﺘﻪ اﻟﺘﻨﻔﻴﺬﻳﺔ‪.‬‬
‫إن أي ﺑﺮﻥﺎﻣﺞ ﻳﺘﻀﻤﻦ ﺗﻜﻠﻔﺔ أو ﻳﺘﻄﻠﺐ ﺗﻀﺤﻴﺔ ﻣﺤﺪدة – واﻟﺘﺤﻜﻢ ﻓﻲ ﻥﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﻳﺘﻀ ﻤﻦ ه ﺬﻳﻦ‬
‫اﻟﻌﻨﺼﺮﻳﻦ – ﻳﻤﻜﻦ أن ﻳﻨﺠﺢ ﻓﻘﻂ ﻟﻠﻤﺪى اﻟﺬي ﻳﺴ ﻤﺢ ﺑ ﻪ اﻟ ﺮأي اﻟﻌ ﺎم‪ .‬ﻓﻴﺠ ﺐ أن ﺗﻜ ﻮن هﻨ ﺎك إرادة‬
‫ﺱﻴﺎﺱﻴﺔ‪ ،‬وﻣﻮارد ﻟﺘﻄﺒﻴﻖ اﻟﻘﺎﻥﻮن‪ ،‬ﻣ ﻊ اﻻﻟﺘ ﺰام ﻣ ﻦ ﺝﺎﻥ ﺐ اﻟﺤﻜﻮﻣ ﺔ واﻟﺼ ﻨﺎﻋﺔ‪ ،‬ودرﺝ ﺔ ﻋﺎﻟﻴ ﺔ ﻣ ﻦ‬
‫اﻟﻘﺒﻮل ﻟﺪى اﻟﻘﻄﺎﻋﺎت اﻟﻤﻬﻨﻴﺔ واﻟﻌﻠﻤﻴﺔ‪.‬‬
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‫وﺑﻨ ﺎ ًء ﻋﻠ ﻰ ذﻟ ﻚ‪ ،‬ﻥﻮﺹ ﻲ ﻋﻨ ﺪ إﺝ ﺮاء أي ﻋﻤﻠﻴ ﺔ ﻟﺘﻌ ﺪﻳﻞ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻘﻴﺎﺱ ﻴﺔ ﻟﻨﻮﻋﻴ ﺔ اﻟﻬ ﻮاء‬
‫ﺑﻀﺮورة اﺱﺘﺨﺪام ﻣﺤﻮرﻳﻦ أﺱﺎﺱﻴﻴﻦ آﻨﻘﻄﺔ ﺑﺪاﻳﺔ‪ ،‬وهﻤﺎ‪:‬‬
‫• ﺹ ﻴﺎﻏﺔ اﻟﻤﻮاﺹ ﻔﺎت اﻟﻘﻴﺎﺱ ﻴﺔ ﻟﻨﻮﻋﻴ ﺔ اﻟﻬ ﻮاء ﺑﺎﻟﻄﺮﻳﻘ ﺔ اﻟﺘ ﻲ ﺗﺤﻘ ﻖ ﺡﻤﺎﻳ ﺔ ﺹ ﺤﺔ اﻹﻥﺴ ﺎن‬
‫ﺑﺎﻟﺪرﺝﺔ اﻷوﻟﻰ ﺑﺠﺎﻥﺐ ﺡﻤﺎﻳﺔ اﻟﺒﻴﺌﺔ‪.‬‬
‫• ﺹﻴﺎﻏﺔ اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱﻴﺔ ﻻﻥﺒﻌﺎﺙ ﺎت اﻟﻬ ﻮاء ﺑﺎﻟﻄﺮﻳﻘ ﺔ اﻟﺘ ﻲ ﺗﺠﻌ ﻞ ﺗﺮآﻴ ﺰ اﻟﻤﻠﻮﺙ ﺎت ﻓ ﻲ‬
‫ﺡﺪود اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱﻴﺔ ﻟﻨﻮﻋﻴﺔ اﻟﻬﻮاء‪.‬‬
‫ﻻ ﻋﻠ ﻰ‬‫وﻣﻦ أﺝﻞ اﻟﺒﺪء ﻓ ﻲ ﻋﻤﻠﻴ ﺔ وﺽ ﻊ اﻟﻤﻮاﺹ ﻔﺎت اﻟﺠﺪﻳ ﺪة ﺱﻴﺼ ﺒﺢ ﻣ ﻦ اﻟﻀ ﺮوري اﻹﺝﺎﺑ ﺔ أو ً‬
‫اﻷﺱﺌﻠﺔ اﻟﺮﺉﻴﺴﻴﺔ اﻟﺘﻲ أﺙﺎرهﺎ اﻟﻤﺴﺎهﻤﻴﻦ اﻟﺮﺉﻴﺴﻴﻴﻦ ﻓ ﻲ ﺗﻨﻔﻴ ﺬ اﻟﻤﺸ ﺮوع‪ .‬وأﺡ ﺪ ه ﺬﻩ اﻷﺱ ﺌﻠﺔ ﻳﺘﻨ ﺎول‬
‫ﻣ ﺪى اﻟﺘﻄﺒﻴ ﻖ اﻟﺸ ﺎﻣﻞ ﻟﻬ ﺬﻩ اﻟﻤﻮاﺹ ﻔﺎت ﻓ ﻲ ﺝﻤﻴ ﻊ أﻥﺤ ﺎء ﻣﺼ ﺮ ﺱ ﻮا ًء ﺑﺴ ﻮاء أم إﻣﻜﺎﻥﻴ ﺔ ﺗﻨ ﻮع‬
‫واﺧ ﺘﻼف ه ﺬﻩ اﻟﻤﻮاﺹ ﻔﺎت ﺑ ﺎﺧﺘﻼف اﻟﻤﻨ ﺎﻃﻖ‪ .‬وﺗ ﺪل اﻟﺨﺒ ﺮة اﻟﺪوﻟﻴ ﺔ ﻋﻠ ﻰ أن ﻣﻮاﺹ ﻔﺎت اﻟﻬ ﻮاء‬
‫اﻟﻤﺤﻴﻂ ﻳﺠﺐ أن ﺗﻜﻮن واﺡ ﺪة ﻟﻜ ﻞ اﻷﻣ ﺎآﻦ‪ .‬إن اﻟﺴ ﻤﺎح ﻟﻸﻥﺸ ﻄﺔ اﻟﺼ ﻨﺎﻋﻴﺔ ﺑﺎﻻﻥﺘﻘ ﺎل إﻟ ﻰ ﻣﻨ ﺎﻃﻖ‬
‫ﻏﻴﺮ ُﻣَﻠﻮَﺙﺔ ﺡﺎﻟﻴًﺎ ﻳﻠﻐﻲ اﻟﺤﻮاﻓﺰ اﻟﻤﺘﻤﺜﻠﺔ ﻓﻲ اﻟﺘﺤﺪﻳﺚ آﻤﺎ ﻳﺆدي إﻟﻰ ﻋﺪد ﻣﻦ اﻟﻤﺴﺎوئ‪.‬‬
‫وﺗﻌﺘﺒ ﺮ اﻟﻤﺮاﺝﻌ ﺔ اﻟﺪورﻳ ﺔ ﻟﻠﻤﻮاﺹ ﻔﺎت اﻟﺠﺪﻳ ﺪة ﺑﺼ ﻔﺔ ﻣﻨﺘﻈﻤ ﺔ ﻋﻤﻠﻴ ﺔ ﺽ ﺮورﻳﺔ‪ .‬ﻓﻔ ﻲ اﻟﻮﻻﻳ ﺎت‬
‫اﻟﻤﺘﺤ ﺪة اﻷﻣﺮﻳﻜﻴ ﺔ‪ ،‬ﻳُﺸ َﺘﺮَط ﻣﺮاﺝﻌ ﺔ اﻟﻤﻮاﺹ ﻔﺎت آ ﻞ ‪ 5‬ﺱ ﻨﻮات ﻋﻠ ﻰ اﻷﻗ ﻞ أو ﻋﻨ ﺪﻣﺎ ﺗﻈﻬ ﺮ‬
‫ﻣﻌﻠﻮﻣﺎت ﺝﺪﻳﺪة‪ .‬وﺡﺘﻰ ﻣﻊ ﺗﻮاﻓﺮ اﻟﻤﻮارد ﻓﻲ اﻟﺒﻼد‪ ،‬ﻳﻌﺘﺒ ﺮ ه ﺬا اﻟﺠ ﺪول أﻗ ﻞ ﺹ ﺮاﻣﺔ ﻣﻤ ﺎ ﻳﻨﺒﻐ ﻲ‪.‬‬
‫وﺑﺎﻟﻨﺴ ﺒﺔ ﻟﻤﺼ ﺮ ﻳﻌﺘﺒ ﺮ ﻣﺮاﺝﻌ ﺔ ه ﺬﻩ اﻟﻤﻮاﺹ ﻔﺎت آ ﻞ ‪ 10-5‬ﺱ ﻨﻮات ﻣﻨﺎﺱ ﺒًﺎ ﺡﺘ ﻰ ﺗﻮاآ ﺐ اﻟﺘﻄ ﻮر‬
‫اﻟﻌﺎﻟﻤﻲ واﻟﺘﻘﺪم اﻟﻌﻠﻤﻲ‪.‬‬
‫وﻳﺠﺐ ﻋﻠﻰ رﺝﺎل اﻟﻘﺎﻥﻮن‪ ،‬أﺙﻨﺎء وﺽﻊ اﻟﻤﻮاﺹ ﻔﺎت اﻟﺠﺪﻳ ﺪة‪ ،‬اﻟﻨﻈ ﺮ ﻓ ﻲ ﺱ ﻦ اﻟﺘﺸ ﺮﻳﻌﺎت اﻟﻼزﻣ ﺔ‪.‬‬
‫وﻃﺒﻘ ًﺎ ﻟﻤ ﺎ أﻓ ﺎد ﺑ ﻪ اﻟﻤﺴ ﺎهﻤﻮن ﻓ ﻲ اﻟﻤﺸ ﺮوع ﻣ ﻦ ﺝﻬ ﺎز ﺵ ﺌﻮن اﻟﺒﻴﺌ ﺔ ﻓ ﺈن اﻹﺝ ﺮاءات اﻟﺘﺸ ﺮﻳﻌﻴﺔ‬
‫اﻟﺤﺎﻟﻴﺔ ﻏﻴﺮ واﺽﺤﺔ‪ ،‬آﻤﺎ أن اﻟﺠﻬﺔ اﻟﻤﻨﻮط ﺑﻬﺎ ﺱُﻠﻄﺔ ﺗﻄﺒﻴﻖ اﻟﻘ ﺎﻥﻮن ﻏﻴ ﺮ ﻣﻨﺎﺱ ﺒﺔ‪ .‬وﻻ ﻳﻮﺝ ﺪ ﻓﻘ ﻂ‬
‫ﺗﻌ ﺎرض ﻓ ﻲ اﻟﻤﻮاﺹ ﻔﺎت ﺑﺼ ﻴﻐﺘﻬﺎ اﻟﺤﺎﻟﻴ ﺔ‪ ،‬ﺑ ﻞ إن هﻨ ﺎك أﻳﻀ ًﺎ ﻏﻴ ﺎب ﻟﻤﻨﻬﺠﻴ ﺔ ﻃ ﺮق ﻗﻴ ﺎس‬
‫اﻻﻥﺒﻌﺎﺙﺎت‪ ،‬وﻋﺪم ﺗﻨﺎﺱﻖ ﻓﻲ اﻟﻤﺴﺌﻮﻟﻴﺎت واﻷﻥﻈﻤﺔ اﻹدارﻳﺔ‪.‬‬
‫وهﻨ ﺎك ﺵ ﻜﻮى ﻣﺘﻜ ﺮرة ﻣ ﻦ ﻥﻘ ﺺ اﻟﻌﻤﺎﻟ ﺔ اﻟﻼزﻣ ﺔ ﻟﺘﻨﻔﻴ ﺬ اﻟﻘ ﺎﻥﻮن وأن اﻟﺠﻬ ﺎز اﻟ ﻮﻇﻴﻔﻲ ﻳﻔﺘﻘ ﺮ إﻟ ﻰ‬
‫اﻟﻤﻮارد اﻟﻼزﻣﺔ ﻟﺘﻨﻔﻴ ﺬ واﺝﺒﺎﺗ ﻪ‪ .‬آﻤ ﺎ أن هﻨ ﺎك ﺡﺎﺝ ﺔ ﻣﺎﺱ ﺔ إﻟ ﻰ اﻟﻤﻌ ﺪات واﻷﺝﻬ ﺰة وﻗﻄ ﻊ اﻟﻐﻴ ﺎر‬
‫واﻟﺴﻴﺎرات واﻷﻓﺮاد اﻟﻤﺪرﺑﻮن‪ .‬وﻗﺪ ﻋﻠﻖ أﺡﺪ ﻣﻮﻇﻔﻲ ﺝﻬﺎز ﺵﺌﻮن اﻟﺒﻴﺌﺔ ﺑﻘﻮﻟﻪ أﻥﻪ ﻋﻠﻰ اﻟ ﺮﻏﻢ ﻣ ﻦ‬
‫أن اﻟﻘﺎﻥﻮن ﻳﻨﻈﻢ أآﺜﺮ ﻣﻦ ‪ 300‬ﻣﺎدة آﻴﻤﺎﺉﻴﺔ وﻥﺴﺐ ﺗﺮآﻴﺰهﺎ داﺧ ﻞ اﻟﻤﺒ ﺎﻥﻲ ﻓ ﺈن ﻣ ﻮﻇﻔﻲ اﻟﺠﻬ ﺎز ﻻ‬
‫ﻳﺴﺘﻄﻴﻌﻮن ﻗﻴﺎس أآﺜﺮ ﻣﻦ اﺙﻨﻴﻦ أو ﺙﻼﺙ ﺔ ﻣ ﻦ ه ﺬﻩ اﻟﻤ ﻮاد ﻣﻤ ﺎ ﻳﺠﻌ ﻞ ه ﺬا اﻟﺠ ﺰء ﻣ ﻦ اﻟﻘ ﺎﻥﻮن ﺑ ﺪون‬
‫ﻣﻌﻨﻰ‪.‬‬
‫وﺗﺘﻨﺎول إﺡﺪى اﻻﻥﺘﻘﺎدات اﻷﺧﺮى اﻓﺘﻘﺎر اﻟﻤﻮاﺹﻔﺎت إﻟﻰ ﻗﺎﻋ ﺪة ﻋﻠﻤﻴ ﺔ أو ﻃﺒﻴ ﺔ راﺱ ﺨﺔ‪ ،‬ﻓ ﺎﻟﻤﻨﻬﺞ‬
‫اﻟﻜﻤﻲ ﺽﺮوري ﻟﻮﺽﻊ اﻟﻤﻮاﺹﻔﺎت وﺗﻄﺒﻴﻘﻬﺎ وﻳﻤﻜﻦ اﺱﺘﺨﺪام ﻃﺮق ﻋﻠﻤﻴﺔ أآﺜ ﺮ ﺡﺪاﺙ ﺔ ﻟﻠ ﺮﺑﻂ ﺑ ﻴﻦ‬
‫ﻣﻮاﺹ ﻔﺎت اﻻﻥﺒﻌﺎﺙ ﺎت وﺑ ﻴﻦ ﻣﻮاﺹ ﻔﺎت اﻟﻬ ﻮاء اﻟﻤﺤ ﻴﻂ‪ .‬ﻟ ﺬا ﻳﺠ ﺐ أن ﻳﻜ ﻮن إﻋ ﺪاد ﻣﻮاﺹ ﻔﺎت‬
‫ﺹ ﺎرﻣﺔ ﺝ ﺰءًا ﻣ ﻦ ﻋﻤﻠﻴ ﺔ اﻟﻤﺮاﺝﻌ ﺔ واﻟﺘﻌ ﺪﻳﻞ وﻟﻜ ﻦ ﻓ ﻲ ﻥﻔ ﺲ اﻟﻮﻗ ﺖ ﻳﺠ ﺐ أﻻ ﻳﺼ ﺒﺢ أدا ًة ﻟﺘﺄﺝﻴ ﻞ‬
‫ﺗﻨﻔﻴﺬ هﺬﻩ اﻟﻤﻮاﺹﻔﺎت‪.‬‬
‫وﻣﻦ اﻟﻮاﺽﺢ أﻳﻀًﺎ أن اﻟﺒﺮﻥﺎﻣﺞ ﻳﺤﺘ ﺎج إﻟ ﻰ وﺽ ﻊ إﺝ ﺮاءات ﻗﻴﺎﺱ ﻴﺔ ﻣﺤ ﺪدة وﻃ ﺮق ﺝﻤ ﻊ ﻟﻠﻌﻴﻨ ﺎت‬
‫ذات ﻣﻮاﺹ ﻔﺎت ﻣﻌﺘﻤ ﺪة ﻟﺘﺄآﻴ ﺪ اﻟﺠ ﻮدة أو ﻣﺮاﻗﺒ ﺔ اﻟﺠ ﻮدة‪ .‬وﻗ ﺪ ﻳﻔﻴ ﺪ اﻻﻋﺘﻤ ﺎد ﻋﻠ ﻰ ﻣﻨﻬﺠﻴ ﺔ‬
‫اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱﻴﺔ اﻟﺘﻲ ﺗﻢ إﻗﺮارهﺎ واﺱﺘﺨﺪاﻣﻬﺎ ﺑﺎﻟﻔﻌ ﻞ ﻓ ﻲ ﻣﻨﻈﻤ ﺎت اﻟﺘﻤﻮﻳ ﻞ اﻟﺪوﻟﻴ ﺔ أو اﻟﻤﻨﻈﻤ ﺔ‬
‫‪7‬‬
‫اﻟﺪوﻟﻴﺔ ﻟﻠﺘﻮﺡﻴﺪ اﻟﻘﻴﺎﺱﻲ ‪ .ISO‬وهﺬﻩ اﻟﻤﻮاﺹﻔﺎت ﻣﺘﺎﺡﺔ واﺱ ﺘﺨﺪاﻣﻬﺎ ﺱ ﻮف ﻳﺴ ﻬﻞ ﻣ ﻦ وﺽ ﻊ ه ﺬﻩ‬
‫اﻟﻤﻨﻬﺠﻴﺔ ﻣﻮﺽﻊ اﻟﺘﻨﻔﻴﺬ‪ .‬وهﺬا اﻷﻣﺮ ﺡﻴﻮي ﻟﻨﺠﺎح أي ﻣﻮاﺹﻔﺎت ﺗﻌﺘﻤﺪهﺎ ﻣﺼﺮ‪.‬‬
‫وهﻨﺎك ﻥﺘﻴﺠﺘﺎن واﺽﺤﺘﺎن هﻤﺎ‪:‬‬

‫ﻻ‪ :‬اﻟﻌﻼﻗﺔ ﺑﻴﻦ اﻻﻥﺒﻌﺎﺙﺎت وﻥﻮﻋﻴﺔ اﻟﻬﻮاء‪ ،‬ﺡﻴﺚ ﻳﺠﺐ اﻟﺘﺄآﻴﺪ ﻋﻠﻴﻬﺎ آﺄﺱﻠﻮب ﺝﺪﻳﺪ‪.‬‬‫أو ً‬
‫ﺙﺎﻥﻴًﺎ‪ :‬ﺑﺎﻟﺮﻏﻢ ﻣﻦ أن ﺗﺤﻘﻴﻖ اﻟﻤﻮاﺹﻔﺎت اﻟﺼﺤﻴﺔ ﻏﻴﺮ ﻣﻨﺘﻈﺮ ﻋﻠﻰ اﻟﻤ ﺪى اﻟﻘﺮﻳ ﺐ‪ ،‬إﻻ أﻥ ﻪ ﻻ ﻳﻨﺒﻐ ﻲ‬
‫ﺗﺠﺎهﻞ اﻟﻤﻮاﺹﻔﺎت اﻟﻘﻴﺎﺱﻴﺔ ﻟﻨﻮﻋﻴﺔ اﻟﻬﻮاء‪ ،‬وﻻ ﺑﺪ ﻣ ﻦ وﺝ ﻮد ﻃﺮﻳﻘ ﺔ ﻟﻠﻌﻤ ﻞ ﻋﻠ ﻰ ﺗﺤﻘﻴﻘﻬ ﺎ ﺑﺄﺱ ﻠﻮب‬
‫ﻣﻌﻘﻮل وﻣﻨﺎﺱﺐ‪.‬‬
‫وﻗ ﺪ ﻳﻜ ﻮن ﻣ ﻦ اﻟﻤﻨﺎﺱ ﺐ إﺹ ﺪار ﻣﻮاﺹ ﻔﺎت ﻗﻴﺎﺱ ﻴﺔ ﺝﺪﻳ ﺪة دون اﻥﺘﻈ ﺎر ﻹﺵ ﺎرات ﻣ ﻦ اﻟﻈ ﺮوف‬
‫اﻟﻤﺤﻴﻄﺔ‪ .‬ﺡﻴﺚ ﻳﺠﺐ اﻻﺱﺘﻌﺎﻥﺔ ﺑﺎﻟﺘﻜﻨﻮﻟﻮﺝﻴﺎت اﻟﻤﺨﺘﻠﻔﺔ واﻟﻤﺼﺎدر اﻟﺘﻲ ﺗﺴﺘﺨﺪﻣﻬﺎ ﻣﻦ أﺝﻞ ﺗﻄﺒﻴ ﻖ‬
‫اﻟﻤﻮاﺹ ﻔﺎت اﻟﺠﺪﻳ ﺪة ﺑﻐ ﺾ اﻟﻨﻈ ﺮ ﻋ ﻦ ﺗﺄﺙﻴﺮاﺗﻬ ﺎ اﻟﻤﺤ ﺪدة‪ .‬واﻷﺱ ﻠﻮب اﻷآﺜ ﺮ ﻣﻼﺉﻤ ًﺔ ﻳﺘﻤﺜ ﻞ ﻓ ﻲ‬
‫إﺹﺪار ﻣﻮاﺹﻔﺎت ﻗﻴﺎﺱﻴﺔ ﻟﻜﻞ ﺹﻨﺎﻋﺔ ﻋﻠﻰ ﺡ ﺪة ﻣ ﻊ اﻟﺘﺮآﻴ ﺰ ﻋﻠ ﻰ ﺗﺤ ﺪﻳﺚ اﻟﺘﻜﻨﻮﻟﻮﺝﻴ ﺎ اﻟﻤﺴ ﺘﺨﺪﻣﺔ‬
‫ﻓﻲ هﺬﻩ اﻟﺼﻨﺎﻋﺔ إﻟﻰ اﻟﻤﺴﺘﻮﻳﺎت اﻟﻌﺎﻟﻤﻴﺔ‪.‬‬
‫وﺱﻮف ﺗﺘﻤﺜﻞ اﻟﻤﻬﻤﺔ اﻷوﻟﻲ ﻓﻲ رﺹﺪ آﺎﻓﺔ ﻣﺼﺎدر اﻟﺘﻠﻮث ووﺽ ﻊ ﻥﻘ ﺎط ﻟﻠﺼ ﻨﺎﻋﺎت اﻟﻤﺨﺘﻠﻔ ﺔ ﻣ ﻦ‬
‫أﺝ ﻞ ﺗﺤﺪﻳ ﺪ أوﻟﻮﻳﺎﺗﻬ ﺎ ﻓ ﻲ ﺝ ﺪول ﻳﺸ ﻤﻞ اﻵﺗ ﻲ‪ :‬اﻟﺼ ﻨﺎﻋﺎت اﻟﺘ ﻲ ﺗﻨﺒﻌ ﺚ ﻣﻨﻬ ﺎ آﻤﻴ ﺎت آﺒﻴ ﺮة ﻣ ﻦ‬
‫اﻟﻤﻠﻮﺙ ﺎت اﻟﻤﺴ ﺒﺒﺔ ﻟﻠﻤﺸ ﻜﻼت )اﻟﺠﺴ ﻴﻤﺎت اﻟﻌﺎﻟﻘ ﺔ وﻣﺸ ﺘﻘﺎﺗﻬﺎ(‪ ،‬واﻟﺼ ﻨﺎﻋﺎت ذات اﻟﻤﻨﺸ ﺂت اﻟﻘﺪﻳﻤ ﺔ‬
‫اﻟﺘ ﻲ ﺗﺸ ﻜﻞ ﻓﺮﺹ ﺔ ﺝﻴ ﺪة ﻟﻠﺘﺠﺪﻳ ﺪ واﻟﺘﺤ ﺪﻳﺚ‪ ،‬واﻟﺼ ﻨﺎﻋﺎت ذات رؤوس اﻷﻣ ﻮال اﻟﻀ ﺨﻤﺔ‬
‫واﻟﺼﻨﺎﻋﺎت اﻟﻤﻬﻤﺔ‪ .‬وﺱﻮف ﺗﻨﺨﻔﺾ اﻻﻥﺒﻌﺎﺙﺎت اﻟﻜﻠﻴ ﺔ آﻠﻤ ﺎ ﺗﻘ ﺪم اﻟﻌﻤ ﻞ ﻃﺒﻘ ًﺎ ﻟﻠﻘﺎﺉﻤ ﺔ‪ ،‬ﺹ ﻨﺎﻋ ًﺔ ﺙ ﻢ‬
‫أﺧﺮى‪.‬‬
‫وﻳﻈﻞ اﻻهﺘﻤﺎم اﻷآﺒﺮ هﻮ ﺹﺤﺔ وﺡﻴﺎة اﻟﺸﻌﺐ اﻟﻤﺼﺮي‪ .‬وﻓﻲ ﺧﺘﺎم هﺬا اﻟﺘﻘﺮﻳ ﺮ ﻥﺆآ ﺪ ﺑﺄﻥ ﻪ ُﻳﻤﻜﻨﻨ ﺎ‬
‫اﻟﺒﺪء ﻣﻦ اﻵن ﻓﻲ اﺗﺨﺎذ ﺧﻄﻮات إﻳﺠﺎﺑﻴﺔ‪.‬‬
‫‪8‬‬

021 Air Qual Standards-Loeb

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Task Order Number 832

Egyptian Environmental Policy Program

CONSIDERATIONS FOR REVISING

Alan P. Loeb, Esq.

prepared under the

A USAID-funded project consortium led by International Resources Group, Ltd.

Task Order No. 832

USAID/Egypt’s Cognizant Technical Officer: Anne Patterson/Holly Ferrette

Contractor Name: International Resources Group, Ltd.

Primary Beneficiary: Egyptian Environmental Affairs Agency (EEAA)

EEAA Counterpart: Ahmed Gamal Abdel-Rhiem

Work Assignment Author: Alan Loeb

Work Assignment Supervisor: David Colbert/Michael Colby

Alan P. Loeb, Esq.

List of Tables ..................................................................................................................................... v

• Partner Organization: Winrock International

1.1 Tasks Covered

1.2 Target Air Pollution Problems in Egypt

2. Comparison of Pollutant Standards

2.1 Survey of World Air Pollution Standards

Table 1. Summary of World Air Pollution Standards

2.2 Survey of World Ambient Air Quality Standards

2.2.1 Conventional Pollutants: Health-based Ambient Air Quality, Visibility,

Table 2. Comparison of Health-based Ambient Air Quality Standards

Averaging Maximum Limit Value

Standard Level Concentrations

Considerations for De-listing Two Pollutants

Additions to the List

• Volatile Organic Compounds (VOCs). In an interview, Cairo environmental lab manager

2.2.2 Hazardous Air Pollutants; Other Air Pollutants

2.3 Survey of World Stationary Source Emission Standards

Table 3. Comparison of Hazardous Air Pollutant Standards

Maximum Limit Value

2.3.1 Comparison of Programs

2.3.2 Qualitative Observations on the Egyptian Stationary Source

2.3.3 Views about the Egyptian Emission Standards

Stringency of the Standards

Standards for Hospital Waste Incinerators

According to Dr. Nefisa S. Abo El-Seoud, Director of Environmental Engineering, Hazardous

2.4 Survey of World Mobile Source Emission Standards

2.4.1 Vehicle Emission Standards

Several observations can be made on the information provided in the table.

• Denomination of pollutant. The Egyptian standards are written in percentage of pollutant in

Table 4. Comparison of Standards for Gasoline-fueled Passenger Cars

2.4.2 Fuel Standards

Table 5. Comparison of Fuel Standards for Gasoline-fueled Passenger Cars

Fuel Requirement Egypt U.S. EU

2.5 General Comments on the Standards

2.5.1 Relationship of Emission and Ambient Standards

2.5.2 Guidance for Formulating New Standards: Targets and

Basis for Emission Standards

Form of Performance Standards

2.5.3 Air Quality and Public Opinion

2.6 Process: The Need for Regular Review and Revision of

3. Observations on Administration of the

3.1 Administration of the Air Pollution Law

3.1.2 Staff and Resources

3.1.3 Proposal for a Permit System

3.2 Development of Sound Methodologies

3.2.1 Basis for the Standards