<h3 dir="ltr" style="text-align: justify;">Introduction</h3>
Egypt is experiencing significant urban growth across the country. The government is expanding its social housing programs, while public and private investors are racing to build new cities. The government&rsquo;s sustainable development agenda shows an interest in sustainable buildings and includes frameworks to encourage their construction. However, Egypt faces serious climate change risks that may undermine these efforts. The continuous rise in temperatures and extreme heat events increase the dependency on mechanical cooling in residential buildings to achieve thermal comfort and have adverse consequences on occupants&rsquo; health. This cost is not distributed equally across society, but disproportionately impacts those who are least able to absorb it&mdash;lower-income groups&mdash;especially with the steady uptick in energy prices.&nbsp;
Egypt adopted the first mandatory energy efficiency code for residential buildings, the Egyptian Code for Improving Energy Efficiency in Buildings (ECP 306-1), in 2005 to ensure that buildings are both energy-efficient and thermally comfortable for occupants, but the code includes no verification mechanism to guarantee that buildings meet these standards. As a result, most newly built residential housing is not code compliant. This failure is not just technical, it is political.
<h3 dir="ltr" style="text-align: justify;">The Existing Code</h3>
According to the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), thermal comfort is a person&rsquo;s subjective sense of satisfaction within a specific environment. It is assessed based on several personal and environmental metrics such as predicted mean vote (PMV), predicted percentage of dissatisfied (PPD), a person&rsquo;s activity level, insulation offered by clothing, operative temperature, relative humidity, and air velocity (ASHRAE, 2020).
Egypt&rsquo;s energy efficiency code, ECP 306-1, initially covered only residential buildings (Housing and Building Research Council [HBRC], 2005a), but the government extended it to commercial and governmental buildings in 2007 and 2010, respectively (Hanna, 2015). ECP 306-1 sets specific standards for some primary building elements and systems, including external walls and roofs, HVAC (heat, ventilation, and air conditioning) systems, natural ventilation, and lighting systems (HBRC, 2018).
Chapter 3 of the code identifies thermal comfort as a key objective, but it presents no comfort standard metrics. The standards in the code, such as wall and roof thermal resistance values and solar heat gain limits, are heat transfer proxies, none of which measure the comfort of the occupants (HBRC, 2005b).
Chapter 4, on natural ventilation, lists the recommended thermal comfort targets for Egypt&rsquo;s hot, arid climate: a temperature of 21.8&ndash;30&deg;C, relative humidity of 20&ndash;50%, and an air speed of 0.5&ndash;1.5 m/s (HBRC, 2018). But these are recommendations, not mandatory standards. In the same chapter, a section titled &ldquo;Ventilation for Thermal Comfort&rdquo; presents guidelines and metrics for air changes per hour, window opening ratios, airflow, and air quality, none of which ensure that the building achieves the recommended temperature, relative humidity, or air speed levels. Chapter 4 of ECP 306-1 defines the thermal comfort target as a combination of temperature, humidity, and air speed levels, while Chapter 5, on mechanical ventilation, specifies the minimum forced airflow rates for bathrooms and kitchens but without provisions for verifying occupant comfort (HBRC, 2018). All these chapters define comfort for Egypt&rsquo;s specific climate, but they stop short of regulating it: buildings may be compliant with all code requirements and still not provide thermal comfort for the occupants, especially in Egypt where summer temperatures may exceed 40&deg;C.
<h3 dir="ltr" style="text-align: justify;">Non-Enforcement of the Code</h3>
Although compliance with ECP 306-1 became mandatory in 2008 to obtain construction and building licenses, research on code enforcement conducted by Edeisy and Cecere (2018) found that compliance is thus far virtually nonexistent in the residential sector. The same study concludes that stakeholders such as developers, contractors, and occupants have little awareness of ECP 306-1 and its requirements.
ECP 306-1 is not the only code that has gone unenforced by the government. In 2010, Egypt adopted the Green Pyramid Rating System (GPRS), a voluntary green building certification that aims to evaluate building sustainability according to local climate and environmental needs. Nevertheless, Fahmy (2025) found that the GPRS framework lacks important sustainability and comfort metrics such as PMV, PPD, and operative temperature. It only provides for hardware controls to allow the control of indoor environmental parameters such as air temperature and speed and window operability. In 2025, the New Urban Communities Authority made a real advancement in regulation by making the GPRS certificate mandatory for new buildings in five cities starting from June 2026: New Administrative Capital, New Cairo, New Alamein, New Mansoura, and New Damietta (EnterpriseAM, 2026). The effect of this is yet to be seen.&nbsp;
The root cause of non-compliance is structural. Building permits are usually issued through a system fragmented across local authorities, governorates, and specialized administrative bodies. In addition to the government&rsquo;s limited monitoring capacity, the permitting process does not provide a mechanism to ensure building compliance with the code after approval or during construction.&nbsp;
<h3 dir="ltr" style="text-align: justify;">Who Absorbs the Cost?</h3>
The impacts of this neglect are not equally distributed. They are concentrated in low-income and social housing projects, where minimizing costs has always been the primary driver of construction decisions.
In 2014, Egypt launched a national social housing program aimed at delivering 700,000 housing units for low-income populations in newly developed cities (Hanafi et al., 2024). These housing units are nearly identical in design and construction materials. The outer wall consists of five layers: a single 120 mm hollow red brick block, cement plaster on the exterior, a rough dry mix finish coat, cement plaster on the interior, and smooth acrylic paint. There is no insulation, no air gap, and no thermal break (Ebaid, 2023). The 120 mm hollow red brick wall cannot achieve the total thermal resistance values recommended in Chapter 3 in ECP 306-1.&nbsp;
The cost minimization strategy externalizes the cost to the occupants, both in the form of higher energy bills, particularly during the summer months, and in heightened health risks. Studies on low-income housing in Cairo, Egypt show that the current building envelopes pose a profound risk to occupants' health by exposing them to extreme indoor temperatures and poor indoor environmental quality. Such thermal conditions are associated with heat-related illnesses like sleep disruption, heat stress, fatigue, and respiratory complaints (Nessim et al., 2026a). Another study found that typical behavioral adaptations by occupants, such as opening windows or using fans, were insufficient to cope with the extreme heat conditions (Nessim et al., 2026b). Poorly performing envelopes thus not only affect a household&rsquo;s pocketbook, but also subvert a core function of housing, which is to provide shelter that enhances well-being and a healthy environment, and protects occupants against extreme outdoor conditions.
The blame rests firstly with the cost-minimization logic of contractors and secondly with regulators who approved the design of units and ignore construction monitoring and verification. Neither the recommended building envelope performance targets (e.g., thermal resistance) nor the thermal comfort targets (e.g., air temperature) outlined in ECP 306-1 have been met. The occupants of these units do not have the luxury of choosing the more thermally comfortable housing available to the upper-middle and upper classes in Egypt
<h3 dir="ltr" style="text-align: justify;">What a Comfort Code Would Look Like</h3>
In 2022, the United Kingdom incorporated a new standard into its building regulations, Part O, which aims to mitigate overheating in residential buildings. Building compliance can be handled by either local authorities or privately registered approved firms , which support decentralization and helps avoid administrative bottlenecks. Separate from the energy code, the new pre-construction standard requires designers to prove that the indoor temperatures will remain acceptable during the summer by limiting excessive solar gains. Two compliance methods are suggested in the standard to demonstrate the building&rsquo;s resilience to excessive heating: 1. a simplified method, entailing a manual checking of blueprints against window-to-floor-area limits; and 2. dynamic thermal modeling, in which a computer simulation illustrates heat flow inside the space (Government of the United Kingdom, 2021). This is an example of a comfort-specific standard, adopted to ensure the occupants&rsquo; comfort inside the buildings, not only how much energy the building will consume.
Another example is the Evaluation Standard for Indoor Thermal Environment in Civil Buildings in China. In 2012, Chinese researchers, instead of adopting ASHRAE 55 or ISO 7730 wholesale, established a national thermal comfort standard based on local field measures across the different climate zones in China (Du et al., 2023). Covering both the design and post-construction phases, the standard evaluates occupants&rsquo; comfort and provides a thermal indoor environment grade or score to the building, separate from the mandatory HVAC design code that identifies the calculations and parameters needed to design HVAC systems. This new standard treats thermal comfort as its own measurable metric, regardless of building performance results.
ECP 306-1 already includes recommended ranges of air temperature, relative humidity, and air speed. What is lacking are guarantees to ensure that buildings comply with those standards before and after construction, enforced using design guidelines or computer simulations coupled with field inspections.
<h3 dir="ltr" style="text-align: justify;">What Needs to Change</h3>
Three key changes to the existing regulatory framework for building permits in Egypt, if adopted, would improve occupants&rsquo; comfort considerably.
First, ECP 306-1 must make the recommended comfort ranges specified in Chapter 4&mdash;21.8&ndash;30&deg;C, 20&ndash;50% relative humidity, and 0.5&ndash;1.5 m/s of air speed&mdash;mandatory, with proof of compliance required in both the design and post-construction phases. This measure requires no additional legislation or regulations, but only the will to enforce the standards already enshrined in ECP 306-1.
Second, the government must ensure the critical inspection of the composition and performance of the building envelope before granting the building permit, when the initial required documents are submitted, and throughout the construction phase. Since local authorities are the only bodies that can address the gap between document compliance and the actual building, this requires serious investment in their capacities.&nbsp;
Third, the government must introduce significant reforms to the general approach to government-built housing projects. Cost minimization cannot remain the ultimate goal given its discriminatory impact on more vulnerable communities.&nbsp;
Egypt has a mandatory building code that can provide energy-efficient and thermally comfortable housing. International precedent shows that verifying thermal comfort is feasible in the pre- and post-construction phases. What is lacking in the Egyptian case is the regulatory will to hold buildings to the standards it has already established. Acknowledging this defect is the first step toward developing policies that effectively address the issue and improve the indoor environmental quality for those who suffer the most.
<hr>
References
<ul style="text-align: left;">
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
American Society of Heating, Refrigerating and Air-Conditioning Engineers. (2020). ANSI/ASHRAE standard 55-2020: Thermal environmental conditions for human occupancy.
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Du, H., et al. (2023). The Chinese thermal comfort dataset. Scientific Data, 10, 646. https://doi.org/10.1038/s41597-023-02568-3
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Ebaid, M. A. (2023). Building for a sustainable future: Investigating the thermal performance of innovative and local wall materials in an Egyptian housing unit. HBRC Journal, 19, 275&ndash;299. https://doi.org/10.1080/16874048.2023.2268290
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Edeisy, M., &amp; Cecere, C. (2018). Energy efficiency for Egyptian housing: Code compliance and enforcement. The International Journal of the Constructed Environment, 9(3), 1&ndash;15. https://doi.org/10.18848/2154-8587/CGP/v09i03/1-15
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Egyptian Housing and Building Research Council. (2005a). Egyptian code for improving the efficiency of energy use in buildings, part 1: Residential buildings (ECP 306-2005). Ministry of Housing, Utilities and Urban Communities.
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Egyptian Housing and Building Research Council. (2005b). Egyptian code for improving the efficiency of energy use in buildings, part 2: Commercial buildings, chapter 3: Building envelope (ECP 306-2). Ministry of Housing, Utilities and Urban Communities.
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Egyptian Housing and Building Research Council. (2018). Egyptian code for improving the efficiency of energy use in buildings, part 1: Residential buildings, chapters 3&ndash;5: Building envelope, natural ventilation, and mechanical ventilation (ECP 306-1, 2018 ed.). Ministry of Housing, Utilities and Urban Communities.
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
EnterpriseAM. (2026, August 5). Egypt&rsquo;s mandatory green building rule is live, but who pays for it isn&rsquo;t settled. https://enterpriseam.com/egypt/hardhats/egypts-mandatory-green-building-rule-is-live-but-who-pays-for-it-isnt-settled/
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Fahmy, A. (2025). Unveiling barriers and proposing strategies for green building practices adoption in Egypt: Perspectives primarily from architects and engineers. Journal of Engineering and Applied Science, 72(204). https://doi.org/10.1186/s44147-025-00777-8
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Government of the United Kingdom. (2021). Approved document O: Overheating (2021 edition, effective June 2022). Ministry of Housing, Communities and Local Government. https://www.gov.uk/government/publications/overheating-approved-document-o
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Hanafi, A. M., Moawed, M. A., &amp; Abdullatif, O. E. (2024). Evaluating energy efficiency and thermal performance in Egypt&rsquo;s social housing: Climate responsive design and material impact in hot desert environments. Journal of Engineering Research, 8(6). https://www.researchgate.net/publication/387786175
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Hanna, G. B. (2015). Energy efficiency building codes and Green Pyramid Rating System. In A. Sayigh (Ed.), Renewable energy in the service of mankind vol I (pp. 597&ndash;608). Springer. https://doi.org/10.1007/978-3-319-17777-9_54
</li>
</ul>
<ul>
<li dir="ltr" style="font-size: 10pt; text-align: left;" aria-level="1">
Nessim, A., Elbanhawy, A., El Harraky, N., Bakry, R., Abdelkader, A., Narayanan, V., Hashemi, A., &amp; Khalifa, M. (2026a). Health under heat: Assessment of overheating in Cairo&rsquo;s low-income housing. Ain Shams Engineering Journal, 17(8), 104283. <a href="https://doi.org/10.1016/j.asej.2026.104283">https://doi.org/10.1016/j.asej.2026.104283</a>
</li>
<li dir="ltr" style="font-size: 10pt;" aria-level="1">
Nessim, A., Elbanhawy, A., El Harraky, N., Bakry, R., Abdelkader, A., Narayanan, V., Hashemi, A., &amp; Khalifa, M. (2026b). Occupant behaviour as a climate adaptation mechanism in low-income housing: Evidence from Al-Asmarat Housing Project in Cairo, Egypt. IOP Conference Series: Earth and Environmental Science, 1656(1), 012007. https://doi.org/10.1088/1755-1315/1656/1/012007
</li>
</ul>

آراء

Commentaries

الإسكان

Housing

التنمية الشاملة

Inclusive Development

تغير المناخ

Climate Change

السياسات الاقتصادية

Economic Policies

التخطيط العمراني

Urban Planning

من يتحمل تكلفة الفجوة؟ أكواد البناء في مصر وتكلفة الراحة الحرارية

Who Pays for the Gap? Egypt’s Building Codes and the Cost of Thermal Comfort

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