Part 1: The Case for Downtown Cairo and Alexandria, Egypt
This multipart case study blog post explores the challenges of applying green building standards and certification schemes to historic city cores with an application to the unique built environments of Downtown Cairo and Alexandria. To overcome these challenges, we propose a new green building standard—customized to Egypt’s historic urban fabric and based on building audits conducted in Downtown Cairo. The effort strengthens and complements Egypt’s past and challenged green building certification efforts which are similar to many countries with rich inbuilt heritage but slow-moving greening efforts. This case study was prepared based on several years the OHK team spent planning the revalorization of Downtown Cairo and developing a ten-year regeneration program currently being implemented.
This is part 1 of the blogpost and addresses the status quo before OHK’s involvement. It offers a primer on Egypt’s building efficiency standards and the “principal-agent” problem challenging historic buildings’ upgrades in Downtown Cairo.
A Primer on Egypt’s Building Efficiency Standards, Regulations, and Codes
The promulgation of Egypt’s Law 119/2008 “The Unified Building Law” in 2008 marked a reform of building energy efficiency standards, effectively establishing a system of modernized building codes and specifying the entities responsible for drafting and approving them. Decree 114/2009 “The Executive Appendix to the Unified Building Law” is particularly salient. While the former law covers the administrative and statutory elements of building regulation in Egypt, the latter specifies the actual design and building determinants that are binding upon Governorate authorities’ issuing of building permits.
The content of Egypt’s building codes per the UBL is developed primarily by the Housing and Building Research Center (HBRC), an entity that has had, since its founding, a strong affinity to American building code systems. Downtown Cairo, however, falls under another set of government-based building standards under the administration of the National Organization for Urban Harmony (NOUH), in force since 2011. While the UBL regulations handle traditional construction and urban morphology such as heights, setbacks, ventilation, HVAC systems, stairways and lifts, and building performance, the NOUH regulations are more concerned with aesthetic and historical matters.
We identify the following main obstacles to the successful application of energy efficiency regulations to Downtown Cairo’s building stock.
First: Current Codes are of Limited Relevance to Local Contexts or Sustainable Urbanism—Local government officials, as well as building owners, have expressed frustration with the UBL code’s perceived irrelevance to most of Cairo. The codes are more akin to American or European city standards, with very generous provisions for street widths and open space allocations, and limitations on heights and plot densities that correspond poorly to the existing urban fabric. Despite its European design inspirations, Downtown Cairo is not exempt from this irrelevance, and as building codes around the world increasingly begin to integrate standards that explicitly refer to urban sustainability and livability factors, the UBL will be an increasingly insufficient guide to Downtown Cairo’s long-term evolution towards sustainability.
Second: Explicit Green Considerations are Absent from the Building Codes—Regulations and standards that deal with building resource efficiency are not connected to legally enforceable building code, and it is unclear whether any such standards will make it into the formal code any time soon. Moreover, the building code is not specific to different localities within Egypt, either in terms of climatic differences or different kinds of the urban fabric, and it is unclear what mechanisms exist, if any, to exempt older construction from particular standards that would be to the detriment of the buildings’ historical value if followed to the letter. While there have been calls to introduce a green building code as more of a statutory and legally enforceable document, HBRC’s drafts of such code date from 2003 and 2007 and have yet to be implemented or integrated into the country’s Unified Building Code.
Third: Non-complementarity of Standards and Lax Enforcement of Building Codes—Regardless of the issues above, enforcement of building codes remains lax and inconsistently applied. A 2008 study by USAID, the “Housing Study for Urban Egypt”, found that of 20,000 households polled across urban Egypt, only 36.4% had building height-to-street width ratios of less than or equal to 1.5, the maximum allowed by the Unified Building Code (a stipulation that existed even before the 2008 unification of the code). Even if we assume that some of this is attributable to buildings being either in the historical or informal urban fabric and thus outside of the technical or practical reach of the codes, it still is indicative of the challenges in enforcement. In the specific context of Downtown Cairo, enforcement has still other challenges. To issue building permits, the Cairo Governorate must, among other things, ensure that proposed designs conform to the standards set in the UBL, and, for historic buildings get the approval of the NOUH on design per their guidelines and standards handbooks. It is not clear, however, what happens if those two steps are at odds and if one takes precedent.
Fourth: Codes Governing New Construction Poorly Address Rehabilitation of Existing Building Stock— Downtown Cairo occupies some 2.9 million square meters and is home to 1,492 buildings, the majority of which were built before the 1960s. Of all the building stock in Downtown Cairo, there has been very little new construction in the past two decades, and very limited space remains for future development. As a result, the current codes may only apply to very limited, one-off construction projects in the future (such as the planned demolition and replacement of certain institutional buildings in the area known as the Ministries Quarter on the southern edge of Downtown). The primary need for regulatory content will come from and have to focus on the rehabilitation of the existing building stock, much of which is historic, thus requiring a new standard. Moreover, this standard must account for the fact that of 1,492 buildings in Downtown, 294 have been registered by the NOUH as historic buildings which will pose particular restrictions on refurbishment and renovation actions.
The “Principal-Agent” Problem in Downtown Cairo
Under the prevalence of “old rent” contracts (that is, inheritable, long-term, rent-controlled leases with extremely low rental rates) in Downtown Cairo, the district’s rental economy is afflicted by a “principal-agent” efficiency problem wherein the leaseholder is the end-user of property and captures value from the low rent ceiling, but is not responsible for investing in the building or its efficiency, which is the owner’s responsibility. This is typical of the owner-tenant relationship in Downtown Cairo and results in split incentives.
The leaseholder acts as the “agent” paying rent and utility bills in exchange for the use of a given space. The building owner is the “principal” who often declines or is unable to make investments in the building because of insufficient rental income and because only the tenant benefits from reduced utility costs as a result of efficiency upgrades, for which the owner cannot raise the rent. By the same dynamics, the tenant itself has no incentive to make investments since it does not own the unit and any improvement in asset value goes to the owner (even if that value is unrealizable). For this reason, resource usage in Downtown Cairo’s rent-controlled buildings is detached from energy prices and would not respond to efficiency improvements. Even with utility prices rising considerably in Egypt in recent years, the owners have no incentive to make investments in building efficiency.
Come back and visit the OHK website to peruse our blog posts and read Part 2 about how we benchmarked green standards for certifying historic buildings based on international best-practices in North America, Europe, and the Middle East and learn about takeaways from world-leading comparable systems.
OHK helps government and private sector clients develop and implement sustainability initiatives around energy and resource efficiency in buildings, cities, and urban regeneration programs. To learn more about OHK’s work in green buildings and urban regeneration and planning, please contact us.