

“They are turning green spaces into concrete cubes!” says Sara Karim (34 years old) as she points to an area in the Sarjnar resort (5 km west of Sulaymaniyah) that used to be a “public park” that she used to frequent during her childhood years before it was transformed into a residential complex.
“I brought my two young children with me so that we could go for a walk here, but the place has completely changed and is no longer as it was, full of trees and green spaces that provided fresh air for those escaping the heat and traffic of the city. Now instead, all we find are these buildings,” Sara continues as she holds her children’s hands to return them to her car that she parked on the side of the road.
The Sarjnar area has been famous, over the past decades, as a haven for families coming to it for a walk, whether from the city of Sulaymaniyah or even from other Iraqi governorates. Its sprawling gardens are famous for being a stage for popular celebrations, especially on the Newroz holiday.
“It’s not just Sarjnar that has lost its lush trees and green spaces, but Sulaymaniyah in general,” says Sarah, looking at her two children relaxing in their back seats. “Wherever you look, you will find nothing but residential buildings, some of which are 30 stories high.” What is happening in Sulaymaniyah applies to the Kurdistan Region in general, after it witnessed rapid urban expansion since 2005, and a great openness towards vertical construction, especially after the competition of foreign investment companies in this sector, most of them Turkish and Iranian, which built tens of thousands of residential units with different specifications and prices.
Multiple specifications and lack of green spaces
A tour of the vertical residential complexes in the three governorates of the region shows that they are divided into two main categories: the first is low-cost, designated for low-income people with prices ranging between 45-60 thousand US dollars, and most of its projects lack high specifications and requirements for durability in construction and even safety standards, which makes some specialists doubt even its ability to withstand natural disasters such as strong earthquakes, in addition to its lack of green spaces.
As for the second category, it is characterized by medium to high specifications, and its prices start from 80 thousand dollars and go up to 300 thousand US dollars, part of which also lacks international safety standards and conditions, while the other section was built with solid international specifications that take into account all safety conditions and protection from disasters, but it also lacks green spaces and sometimes the basic design is violated by canceling some spaces that were declared green, by converting them into service or residential buildings, according to specialists.
The Kurdistan Region Investment Board has granted many housing projects building permits based on the investment law in force in the region, so that the number of housing units built accordingly has reached more than 220 thousand housing units of various shapes and sizes. At the same time, municipal departments also grant building permits for projects outside what is known as investment, and their number has reached more than 100 thousand housing units, according to the head of the Kurdistan Investors Union, Yassin Mahmoud Rashid, who confirmed in addition to that, the presence of more than 450 large, medium and small commercial buildings in the region.
These buildings mostly extended over green and agricultural areas, and attracted buyers from outside the Kurdistan Region, so many residents of the region known for its beautiful mountainous nature complain about the shrinking areas of forests, groves and farms, which has had direct negative repercussions on the environment, air and public health. Anwar Jabbar (45 years old), a government employee from Sulaymaniyah, says that the city and its surroundings used to be characterized by a clean environment and fresh air, so it was a destination for tourists seeking recreation. “We did not hear, as we do today, about shortness of breath, pneumonia, asthma and other diseases.”
Anwar was returning from a pharmacy, carrying a bag full of medicines, for which he paid about $100, hoping to help him treat the severe pneumonia he suffers from, according to his doctor’s diagnosis. Anwar holds the residential complexes and industrial projects in the city responsible for the pollution of the water and air, denouncing what he described as the encroachment of these projects, without taking into account the reality of the city and its environment, towards green spaces, which has caused “an increase in pollution rates and with them diseases,” according to him.
Environmental and civil activists organized gatherings and protests in May 2024 after an investment company excavated a large part of the slope of Mount Koizah overlooking the city of Sulaymaniyah in preparation for the construction of a new vertical residential complex on the slope of the mountain, which many Sulaymaniyah residents consider a symbol of the city and one of its most prominent aspects of beauty.
Koizah Mountain’s Fire
An official source in the Sulaymaniyah local government, who requested anonymity, stated that paving a single road for one of the residential complexes near Mount Koizah resulted in the cutting down of about a thousand trees, including old trees. “These trees are the lungs of the city of Sulaymaniyah,” but they are encroaching on them.
The source added: “Under the pretext of building another complex on an area of 23 dunams in the same area, large areas of gardens and farms were removed, in addition to uprooting trees, some of which were four decades old or more.”
The source estimated the number of residential units built near Mount Koizah at about a thousand units, distributed in vertical buildings, excluding villas and houses, the number of which is in the hundreds, built on a total area of 190 thousand square meters.
Investors are trying to obtain licenses to build other residential complexes in the same area, which is considered a natural landmark in Sulaymaniyah. This has led to a media and popular debate between opponents of such projects and their supporters, including company owners and beneficiaries, because the residential complexes are being built in the vicinity of the mountain, which forms part of the city’s residents’ memory.
Director General of the Department of Studies and Information at the Kurdistan Investment Board, Halo Qazzaz, stated that there are 69 housing projects in Sulaymaniyah licensed by the Investment Board, including 47 projects under construction on a total area of 6,515 dunums, and 22 new projects that obtained work and construction permits in 2023.
He says that the 47 projects consist of “56,350 housing units, 25,414 of which have been completed, and 3,936 are still under construction.”
Qazzaz confirms: “Work and construction permits were not granted for these projects until after the establishment of specific green spaces in them according to the required specifications,” noting that “according to the available information, more than 13% of the area of Sulaymaniyah is green spaces.”
However, Marouf Majeed, head of the Ayindeh Environmental Protection Organization, believes that agricultural areas are shrinking, and that residential complexes and villas are being built primarily on agricultural lands. This has led to the cutting and uprooting of thousands of trees and a significant decrease in the area of these lands around the cities, villages and countrysides of the region, including Sulaymaniyah, over the past years.
Water storage depletion
Water policy expert Ramadan Mohammed confirms that the vertical residential complexes construction projects that have been expanding for more than two decades in the region are causing environmental damage, including damage to water resources as a result of their excessive use.
Mohammed explains that the urban expansion that is currently taking place “without scientific planning or relying on a structural plan for cities and towns, greatly affects groundwater and its nutrition and leads to a decrease in the groundwater storage in the region, which leads to drought and a decrease in seasonal river levels, due to the lack of nutrition.”
The expert mentions many negatives that he has observed in vertical residential complexes: “They do not have gardens or car parks, each person is supposed to have at least four meters of gardens, and multiply by the expected number of residents of the complex, to form green spaces, and the air becomes clean.”
He adds: “Undoubtedly, all residential complexes are supposed to have water quotas, but vertical residential complexes are small in area, but their population density is high, and they do not have green spaces, so groundwater is used unfairly.”
The low supply of drinking water to residential neighborhoods in the region in general, which is almost only two hours every three days or more in Sulaymaniyah, has led citizens to resort to digging wells in recent years, before the government authorities issued a decision to ban drilling, but the decision came too late as many wells had already been dug.
A joint study by the Stop monitoring organization and the Kurdish media network Moulk News in 2022 revealed that “water waste in the region reaches 850 thousand cubic meters out of the total daily production of three million and 126 thousand cubic meters, at a cost of up to 340 million dinars (about 231 thousand US dollars).”
Stop member, Farman Rashad, says that “the number of wells in Erbil alone is 1,240 wells, in addition to the drilling of 1,200 wells for residential and investment projects.” He added: “The depth of wells in general in 2000 did not exceed 250 meters, but today, reaching water requires digging 650 meters deep.” Regarding the damage caused by residential complexes and projects and their impact on the decline in water quantities, Rashad says: “The projects completed during the past decade had a significant impact on the decline in groundwater by about 100% and 50% of the water produced.”
To prevent environmental violations and address part of the environmental degradation resulting from housing projects that encroach on agricultural and green areas, the head of the Environmental Sciences Department at the College of Environmental Sciences at the University of Sulaymaniyah, Dr. Zeino Khalid Mohammed, calls for the appointment of an environmental monitor from the graduates of the Environmental Sciences Colleges, in the projects that are being implemented. She says that the specialized environmental monitor “will work to evaluate the project periodically through scientific reports that determine the extent of its impact on environmental resources and whether these projects conform to the required specifications or not.” The university academy criticizes the current Kurdish society’s lack of sufficient environmental awareness and culture regarding the need to protect the environment and preserve it from pollutants, and sees the importance of doing serious work to spread this culture within society, especially with the expansion of urban, investment and industrial projects.
A former member of the Kurdistan Parliament from Sulaymaniyah, Ahmad Daban, who is one of the residents of vertical housing complexes, acknowledges the significant and unplanned expansion in the construction of concrete vertical blocks, “with their locations being determined randomly, which affects the city’s environment and aesthetics.”
He points out that these complexes use large private generators to provide electricity to residents around the clock, which leads to “air pollution and harm to citizens’ health in one way or another.” The former deputy warns against the continuation of random construction in Sulaymaniyah and the surrounding mountains, as this will strip the area of its vegetation cover, harming the soil. He adds that “dust storms do not stop in Sulaymaniyah, which is about 3,000 meters above sea level, all due to the greed of corrupt individuals who destroy trees and green spaces.”
The private generators, which number more than 6,000 within residential neighborhoods in the region, are among the largest sources of pollution there, operating at least 12 hours a day, especially during the winter and summer seasons when authorities fail to provide national electricity for long hours.
With a single generator consuming more than 150 liters of fuel for each hour of operation, there arises a need for over 11 million liters of diesel daily to meet its requirements, not including the needs of factories and other facilities.
This quantity is generally produced by informal refineries that operate with primitive technologies and do not adhere to environmental standards, causing ongoing pollution of the air, soil, and environment at varying levels.
According to Dr. Abdul-Muttalib Raf’at Sarhat, an environmental science expert and lecturer at Garmian University, there are hundreds of medium and small oil refineries in Kurdistan, alongside more than 200 large refineries. Most of these refineries operate without official legal licenses and do not meet public health and safety standards, neither in terms of geographical location nor in terms of operational techniques.
With the decline of vegetation due to concrete expansion, air pollution, according to the expert, is causing an increase in the incidence of chronic respiratory diseases as well as cancer, which “has started to double in recorded cases year after year” in Kurdistan, where the population is estimated to be 6 million.
Statistics from the Ministry of Health in the region indicate that over 8,000 cancer cases were recorded in 2021, more than 9,000 cases in 2022, while the number of cases approached 10,000 in 2023.
In the Kurdistan Region, Law No. (8) of 2008 regarding environmental protection and improvement was enacted. It includes many provisions that legal experts describe as positive for the environment, but some refer to them as “ink on paper” when it comes to influential figures and those in power.
The law requires every natural or legal person, whether public, private, mixed, or any entity engaged in activities affecting the environment, to prepare an environmental impact assessment study for the activities and projects they undertake, and submit it to the ministry for appropriate decision-making. The study must include an assessment of the positive and negative impacts of the project, establishment, or factory on the environment, as well as proposed measures to prevent and address pollution causes, ensuring compliance with environmental regulations and standards, while minimizing waste and promoting recycling or reuse, and estimating the costs of environmental benefits and damages caused by the project.
The law also stipulates the prohibition of any activity that results in the cutting, uprooting, or removal of trees, shrubs, plants, and wild or aquatic grasses in public properties, and bans any action, conduct, or activity that harms or affects the natural, aesthetic, or heritage aspects of natural reserves or public parks and gardens.
The law holds accountable anyone who causes harm to the environment, requiring them to compensate and remove the damage and restore the situation to what it was before the harm occurred, within the specified time and under the established conditions.
The law imposes penalties, including imprisonment for no less than one month or a fine of no less than 150,000 dinars (114 dollars) and no more than 200 million dinars (252,000 dollars), or both penalties, with the punishment doubling each time the violation is repeated.
Attorney Younis Mohammed notes that simple imprisonment or financial fines do not constitute the necessary deterrent: “The punishment should be at least severe imprisonment or even incarceration if the damage is significant.” He then pointed out that the damage may not be immediate, saying, “The results of deforestation and reduction of vegetation cover may not appear in the same place, but they clearly show up in hospitals!” referring to the rising rates of various diseases due to pollution and changes in air quality.
The head of the Kurdistan Environment Protection and Improvement Authority, Abdul Rahman Sadiq, stated in a press conference that the green spaces in the region “are not at a global level, as the cities of Kurdistan are expanding horizontally rather than vertically. Our engineering and culture are horizontal, not vertical, which increases the areas of concrete materials and asphalt-paved roads.” He describes the struggle the region is facing for its environment as “very difficult” and different from other countries. He clarifies, “We do not have green space at the global level, but we essentially have 12.4% for forests and 19.5% for greenery in the city.” Over the past years, the authority has granted the necessary licenses for about eight thousand projects, and rejected 450 projects due to a lack of environmental conditions. Additionally, the authority conducted inspections over the past three years for more than 14 thousand projects.
Environmental activist Salam Adel mentioned that population growth inevitably necessitates urban expansion: “This should be accompanied by continuous campaigns to preserve or expand the vegetation cover,” especially since the Kurdistan region is characterized by mountainous areas that accumulate snow and have high rainfall rates. Therefore, the continuous cultivation of trees will be successful and beneficial for the environment of Kurdistan and for the development of its tourism sector.
He also believes in the necessity of raising environmental awareness among citizens in general throughout the region, as they are, in one way or another, contributors to pollution, whether through the daily amounts of waste produced or the emissions from gasoline cars, which are estimated by the Kurdistan Traffic Directorate to number over two million vehicles in 2022.
Additionally, he suggests setting specific seasons during which citizens are allowed to light fires in recreational areas for barbecuing and other activities, such as in winter and part of spring, due to “the repeated incidents of burning green spaces, which result in the annual loss of vast areas of land that include forests and ancient trees.”
A security source in Sulaymaniyah confirmed Salam Adel’s statement, saying that about five thousand dunams of forests and pastures burned in Sulaymaniyah over the past few months, and 10 suspects were arrested for causing those fires.
This investigation was conducted under the supervision of the “Nirij” network and supported by the Internews organization as part of an environmental journalism project.
Investigative Reports
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