One evening in August 2021, Mahmoud Tohami* felt a shortness of breath accompanied by a cough severe enough to wake his five-year old daughter. Mahmoud, a man in his thirties, works as a schoolteacher in the village of Bayad Al Arab, situated east of the Nile in the governorate of Beni Suef, 125km from the capital Cairo.
This was not the first time Mahmoud had experienced shortness of breath. He remembers experiencing episodes several years previously, which the doctor then diagnosed as a chest allergy, brought on by polluted air.
Only a few kilometres from Mahmoud’s village, the Egyptian army has constructed the largest cement factory in the Middle East. With an output of 12 million tons annually, the plant has one of the highest production capacities in the world.
Mahmoud is not alone in experiencing breathing difficulties. The problem affects 766,700 inhabitants of the city of Beni Suef, where fumes from the Egyptian army’s cement factory fill the sky. Since the plant was opened in August 2018, the level of air pollution in Beni Suef caused by suspended particulates (measuring less than ten micrometres) has increased by approximately 67.5%, according to the annual data on air quality produced by Egypt’s Ministry Of Environment.
In this study, we reveal the increased air pollution levels in Beni Suef Governorate following the construction of the National Company for Cement (NCC), owned by the Egyptian army, as well as an increase in mortality from respiratory diseases to 24% of total deaths in Beni Suef during 2021.
Breach of environmental law
The establishment of the Egyptian army-owned NCC dates back to the presidential decree issued in October 2018. The factory was constructed about 7.3km from the nearest conurbation, the village of Bayad Al Arab, a suburb of the city of Beni Suef, one of the governorates of Upper Egypt.
This article stipulates that the site for a planned development must be suitable for the activity of such a facility, including not exceeding permitted air pollution levels, and that total pollution from all facilities in a single area must be within permitted limits.
The executive regulations of this law specify the facilities that fall under its provisions, and the authority with the power to decide the suitability of a site, and the permitted limits for air and noise pollutants in the area where the facility is established.
Facilities subject to the provisions of this law must ensure that their activities do not result in the emission or leakage of air pollutants, that exceed the limits set by those laws and resolutions in force, and by the executive regulations of this law.
The army factory was set up under the law governing companies with limited liability. The National Service Projects Organization (the main operator for Egyptian military companies) owns 98.98% of the shares in the factory, while the remaining shares are divided between the El Nasr Company for Services and Maintenance, and the El Arish Cement Company.
The factory was constructed on an area that covers roughly five square kilometres, according to the Egyptian presidential website. During 2021, NCC production reached 10.5 million tons, 22.3% of Egypt’s total cement production. Of this, 2.5 million tons were exported, mainly to countries in Africa, according to a study paper from the Prime Holdings company.
The most polluting fuel
The NCC uses coal in its production process, the most environmentally polluting type of fuel, according to data from the Cement Industry Division (CID).
The fuel used to fire the ovens of the cement factory accounts for approximately 40% of the total emissions of the cement industry, according to the CID website.
Egypt imports coal and, since the army factory began operating, the amount of imported coal increased by almost 700% between 2017 and 2021 – from 352.2 thousand tons in 2017 to 2.8 million tons in 2021, according the Foreign Trade Bulletin, issued by the Central Agency For Public Mobilization & Statistics. Egypt imports coal from the US, Russia, France, Colombia, the UK, Germany and India, in addition to other areas not listed.
This indicates that coal imports increased by approximately two million eight hundred thousand tons in the year after the NCC opened – at the end of 2018, according to the reports in the Foreign Trade Bulletin.
The Ministry Of Environment estimates the annual cost of coal usage in the Egyptian cement industry, as per its health burden on citizens, in terms of respiratory and other diseases, to be between three and five billion dollars per annum. This was published in a press release posted on the website of the Egyptian Initiative for Personal Rights on the increased use of coal.
To make matters worse, another large cement producing factory is located a mere five-minute drive from the army plant. Titan Cement-Beni Suef, is a subsidiary of Titan Cement International, a Belgian company quoted on the Euronext stock market in Brussels, Euronext Paris, and the Athens stock exchange. The Titan Beni Suef plant uses bituminous coal and a mixture of thermal coal and petroleum coal.
The stubbornness of the Ministry of Environment
Cabinet resolution 964 for 2015, requires plants that use coal to submit data on the environmental effects of their storage and usage of coal. They are also required to limit the emission of greenhouse gases produced by burning coal, and conduct regular studies of coal-based emissions.
The law specifies the criteria for the use of coal in the cement production process, such that the level of thermal energy consumption should not exceed 4,000 megajoules per ton of black cement clinker, and 6,200 megajoules per ton of white cement clinker.
The law stipulates that the loading, storing and handling of coal be done automatically, using carefully controlled equipment, and that coal be stored in closed spaces in the operating area in the quantities needed for production for a period not exceeding 15 days. It should be kept in hemispherical storage areas or hangars, closed on three sides with the fourth side fitted with a curtain in the form of slats, allowing equipment to pass through.
However, the coal store in the NCC is an open area, with fencings enclosing it on four sides. The height of the fencings vary from just over two metres, to almost six metres. Google Earth measurement tools indicate that the area in which the factory coal is stored is less than one square kilometre – approximately 0.08 square kilometres. The coal store, located on the southern side of the factory, measures roughly 556.58 metres in length and about 152.74 metres across.
By studying Google Earth images, we were able to detect that the coal store had reached its greatest extent during January 2021. It had then been reduced in size during July of the same year and expanded again during March 2022, before shrinking in size during July of that year too.
We reached out to the Ministry of Environment to try to obtain a copy of the environmental impact study carried out by the army-owned NCC into the use of coal fuel, as stipulated by the cabinet resolution. But the ministry refused to release it on the grounds of “confidentiality”.
Increased levels of air pollution in Beni Suef
Reports from the Ministry of Environment make clear that air pollution levels in Beni Suef from suspended particulates measuring less than ten micrometres increased by approximately 67.5% during the period 2015-2021. These levels began to rise in early 2019, about a year after the NCC began operating.
The average annual concentration of particulates in Beni Suef Governorate is roughly four times higher than the proportion permitted under Egyptian law – 70 micrograms per cubic metre for residential and industrial areas. It also exceeds the legal daily limit of 150 micrograms.
Moreover, this proportion is higher than the permitted level for total solid particulates (30 micrograms per cubic meter) emitted by new cement factories that began operation in April 2015. These levels came into force after the Ministry of Environment issued guidelines for factory emissions in May 2018, and apply also to the NCC, which officially began operating in August 2018.
Suspended particulates are the main indicator of air pollution across Egypt in general, and particularly in Beni Suef, given its high urban concentration of human activity. These particulates are composed of several elements which crystallize and combine to form particles of various sizes, which are classified according to their diameter and composition and the resulting impact they have on air quality and consequently on public health.
The monthly and annual reports from the Ministry of Environment show that rates of air pollution from suspended particulates in Beni Suef increased by 17.6% in 2019, compared with 2018. This was followed by a 35.7% increase in 2020, and a further rise of 8.4% in 2021.
According to a joint study conducted by a number of research centres and universities, including the Institute For Health Metrics and Evaluation (IHME) in Washington, Egypt has the third highest global level of average concentrations of suspended particulates, which reached 104.7 micrograms per cubic metre in 2015.
World Health Organisation (WHO) guidelines make clear that exposure to air pollution presents a burden to health, with effects ranging from discomfort to disease, premature death and reduced life expectancy.
To reduce the health effects of air pollution, the WHO has produced guidelines for assessing air quality that set a safe level for fine particulates (10 micrometres) of 20 micrograms in a year and 50 micrograms in 24 hours.
The WHO regards long-term exposure to particulate levels of 70 micrograms and above as one of the direct causes of a 15% increase in mortality rates.
Total suspended particulates (TSP) refer to particulates that vary in diameter from 0.1 to 10 micrometres, and which remain airborne for long periods. They have a relatively slow sedimentation rate, which is dependent on natural conditions, including humidity, wind, heat, etc. Suspended particulates are the most dangerous of air polluting particles, because they can reach and settle in the lungs.
A level of 70 micrograms also breaches the licensing conditions governing Egypt’s industrial facilities, issued in 2017. These conditions stipulate that cement-producing plants that use coal must keep to a total solid particulate emission level of “50 microgram/cubic metre for an average concentration over 15 minutes.”
If 40% of thermal energy comes from burning hazardous waste, the permitted level for granting a license drops to 10 micrograms/cubic metre for a 15 minute concentration. And for cement factories burning hazardous waste carbon dioxide emissions must not exceed 50 micrograms/cubic metre.
Cement factories must install automatic monitoring and must check levels of dioxins and furans through sample collections over a six-to-eight hour period. This must be carried out at least once every three months. Automatic monitoring of suspended solid particulate levels in the air within the industrial facility must also be carried out, while taking into account the prevailing wind direction.
The danger of using coal
A report from the Environmental Justice Atlas makes clear the danger of using coal in cement production, given the location of cement factories in the most populous areas, and the effect on between 20 and 40 million Egyptian citizens.
The report adds that significant public and environmental concerns have been ignored and that emissions of sulphur dioxide (SO2), nitrogen oxides (NOX) and mercury have in all likelihood produced acid rain as well as respiratory illnesses and foetal transmission of neurotoxins. This is because of the solid fine particles produced by using coal in cement production.
Cement factories have also used imported coal, with no evidence of any improvement in methods of transporting or production.
Increased mortality rates from respiratory disease
Deaths from respiratory diseases in Beni Suef have increased from 1,390 in 2017, or 8.8% of total deaths, to 5,027 in 2021 – representing 24.4% of all deaths in the governorate, according to annual report on births and deaths from the Central Agency For Public Mobilization & Statistics.
Deaths from respiratory conditions in Beni Suef Governorate have been on the rise since 2018. After accounting for 8.8% of deaths in 2017, they rose to 24.4% in 2021. Over the period 2017 to 2021, respiratory deaths rose by 261%, an increase of 3,637 deaths compared with the period before the NCC opened, according to Central Agency For Public Mobilization & Statistics figures.
Weak resources for environmental protectionThe Ministry of Environment suffers from a lack of resources and is hampered by a decrease in its budget. The last five years has seen a fluctuation in financial commitments to the environmental sector. Budget allocations rose by approximately 34.3% between 2018 and 2021, but fell by 34.8% in 2021-2022, before rising again by 25% in 2022-2023. This is despite an inflation rate of 40.3% for February 2023, and a decline in the value of Egyptian pound of approximately 208% for the period 2016 to 2023, according to figures from the World Bank and Google Finance.
