Apart from any non-developmental controversies or considerations that sometimes dominate the public debate on the role of special economic zones in Lebanon, the Special Economic Zone of Tripoli (SEZT), established pursuant to Law No. (18) of 2008, emerges as an instrument entrusted with stimulating the industrial, commercial, and export sectors and enhancing employment opportunities in North Lebanon. Assuming – and with the aspiration that – the existence of a genuine intention to activate this vital facility, a fundamental preliminary question arises: How can balanced governance be established that ensures the attraction of investment and the achievement of economic growth, while at the same time safeguarding natural resources and protecting the environment – particularly within a Lebanese and local context facing escalating environmental challenges?
Lebanon is facing a pressing environmental and economic reality, as evidenced by the available data. In the absence of an integrated national solid waste management plan, Lebanon’s production of solid waste is estimated at approximately 6,500 tons per day, or nearly 2.37 million tons annually, according to estimates by the United Nations Development Programme (UNDP).
These structural imbalances are reflected with greater clarity in the city of Tripoli, where the environmental problem manifests itself with heightened severity in the vicinity of the landfill commonly referred to in the media as the “Waste Mountain.” Investigative journalistic reports and environmental studies, based on on-site assessments, indicate that the landfill has exceeded 45 meters in height and that it contains more than 2 million cubic meters of accumulated waste, as reported in an article published by *Al-Safir Al-Arabi* on 28 November 2022 under the title “Tripoli’s Waste – the Mountain of Death Is Disintegrating”. Despite the landfill’s closure from a regulatory standpoint, it continues to generate polluting leachate that infiltrates the adjacent shoreline and nearby sea, threatening terrestrial and marine ecosystems not only in Tripoli, but across North Lebanon as a whole. This reality is further compounded by high levels of pollution resulting from the uncontrolled burning of waste, as well as emissions from vehicles, private generators, and industrial activities – phenomena that constitute some of the principal sources of air quality degradation and risks to public health in Lebanon’s coastal cities, including Tripoli.
This reality reveals a clear gap between the scale of escalating environmental challenges and the capacity of public administration, at both the national and local levels, to address them in a sustainable manner – a gap that is not limited to deficiencies in planning or shortages of resources, but rather reflects an unexploited opportunity to reconnect economic development with environmental protection within an integrated governance approach. Within this context, a strategic question with a practical dimension emerges: How can the Special Economic Zone of Tripoli, in light of its legal, geographical, and institutional configuration, be enabled to evolve from a mere space for attracting investment into an effective instrument that contributes to reducing environmental and economic challenges, rather than exacerbating them?
There is no doubt that the legal framework governing the Special Economic Zone of Tripoli does not confine it to a “investment space” in the narrow sense but rather establishes it as a public entity with an independent institutional status. Law No. (18) of 2008 provides for the establishment of the “General Authority of the Special Economic Zone of Tripoli” and grants it legal personality as well as administrative and financial autonomy, while empowering it to “undertake all acts and dispositions necessary to achieve its objectives,” including the Zone’s management, regulation of its affairs, and development and operation of its infrastructure in accordance with special rules. This legal arrangement reflects a clear orientation toward removing the Zone from the logic of traditional administration and enabling it to perform an effective developmental role, provided that its powers are properly operationalized and its instruments effectively deployed.
This institutional approach is further strengthened when considering the geographical reality and spatial scope of the Zone. Decree No. (1791) dated 23 April 2009 granted the Special Economic Zone of Tripoli authorization to occupy and exploit an area of 500,178 square meters and designated this area as an “initial space for the launch of the Special Economic Zone, which may be expanded at a later stage”. The significance of this element does not lie in its numerical value alone, but rather in its functional implications: the allocated area is located along the seafront and adjacent to the Port of Tripoli, thereby placing the Zone in a geo-economic position that, in principle, enables it to assume the role of a regional logistics, industrial, assembly, and services platform, provided that it is integrated within a clear operational vision.
From the perspective of sustainable local development, it would be both incorrect and risky to understand this spatial characteristic as a purely investment-related advantage, rather than as an element within an integrated urban–environmental system. The Special Economic Zone, by virtue of its location and legal function, cannot be managed as an island detached from its urban and environmental surroundings, but rather as a development catalyst that must take into account its interconnections with the city, the port, the coastline and marine environment, as well as the pre-existing environmental pressures in Tripoli and the North. In this respect, the importance of linking the operation of the Special Economic Zone – from its early inception – to considerations of urban planning, natural resource management, and environmental impact mitigation becomes evident, in a manner that transforms its legal and spatial advantages into tools for addressing part of the existing imbalances, rather than reinforcing or exacerbating them.
Here, the importance of the legal framework governing the Special Economic Zone emerges as a practical gateway for transforming environmental challenges into enforceable operational obligations. Within this context, it is necessary to pause and look at Environmental Protection Law No. (444) of 29 July 2002, which, for the purpose of “prevention of all forms of degradation and pollution and the promotion of the sustainable use of natural resources”, established a set of governing operational principles, foremost among them the precautionary principle, the “polluter pays” principle, and the principle of preventing the degradation of natural resources, as obligations applicable to every natural or legal person, whether public or private.
There is no doubt that linking these principles to the legal basis governing the operation of the Special Economic Zone of Tripoli moves them from the realm of generality into that of actual – indeed, potentially optimal – application. In this regard, Decree No. (2267) dated 15 June 2009 Concerning the Determination of Environmental Protection Conditions and Public Health Requirements in the Special Economic Zone of Tripoli, expressly places upon the Authority the duty to ensure environmental protection and to guarantee that entities operating within the Zone comply with the provisions of the Environmental Protection Law; and in particular its core principles. It further obliges the Authority to cooperate with the Ministry of Environment, to adopt preventive measures, to combat and reduce pollution, and to require polluters to bear the resulting costs. The same Decree also provides that the Authority shall establish the “Environmental and Health Conditions and Standards” applicable to institutions operating within the Zone, on the basis of the Environmental Protection Law and its implementing decrees.
Accordingly, transforming the Special Economic Zone of Tripoli into an effective instrument for reducing environmental and economic challenges does not constitute a departure from the existing legal framework; rather, it represents a sound operationalization of what the applicable legal texts already provide, particularly when this role is incorporated within the environmental impact assessment framework adopted in Lebanon. In this regard, Decree No. (8633) of 2012 governing Environmental Impact Assessment procedures expanded the scope of projects subject to assessment to include “any modification, addition, or expansion to an existing project if it is likely to result in significant environmental impacts”, thereby confirming that environmental considerations are not a subsequent element, but an integral component of economic and developmental decision-making.
In light of the above, it becomes evident that the issue at hand does not lie in an inevitable conflict between economic development and environmental protection, but rather in how this delicate intersection is managed within an available and operationalizable legal and institutional framework. The Special Economic Zone of Tripoli, by virtue of its independent legal foundation, strategic geographic location, and clearly defined regulatory and operational powers, possesses all the prerequisites enabling it to move from a position of being affected by surrounding environmental crises to one of contributing to their resolution, through the deployment of its legal and operational instruments to transform existing environmental challenges into investment and development opportunities with added value.
Within this framework, integrating the environmental dimension into the operational model of the Special Economic Zone of Tripoli is not considered a constraint on investment nor an additional burden upon it; rather, it constitutes a rational gateway to less polluting and more efficient patterns of activity, contributing to making the environment a productive component of economic decision-making rather than an external cost. This is translated in practical terms through managing the Zone according to a clear operational logic based on the classification of activities according to their environmental impact, the imposition of measurable mitigation and monitoring measures, and the linking of investment incentives within the Zone to defined environmental compliance indicators.
There is no doubt that this approach enables the transformation of certain existing environmental burdens in “Al-Fayhaa” into value-added “green” investment opportunities, in areas such as waste management, sorting and recycling, less polluting energy, low-emission logistics services, and the monitoring of air and water quality. This demonstrates that attracting investment is not achieved through the relaxation of standards, but rather through governance that enhances the linkage between economic activity and its environmental impact, by means of clear operational standards, implementation partnerships with municipalities, universities, and civil society, and periodic measurement and disclosure programmes that strengthen trust and render environmental compliance an integral part of the investment-attraction equation, rather than an additional burden upon it.