InformalsettlementsinSyria: ageneralframeworkforunderstanding andconfrontingthephenomenon EdesioFernandes LegalConsultant

Tableofcontents 1Generalremarks ...............................................................................................1 2ReasonsofrapidurbandevelopmentinSyria ...............................................3 3Causesofinformaldevelopment ....................................................................7 4Implicationsofinformalsettlementsforresidentsandcities......................15 5Typesofinformaldevelopmentinurbanareas............................................18 6Regularisationprogrammes..........................................................................21 6.1Preventivepolicies ..................................................................................21 6.2Regularisationpolicies............................................................................24 7Recommendations..........................................................................................28 8References ......................................................................................................30
th Damascus,September4 2008

This paper has been produced with the assistance of the European Union. The contentof thepaper isthesoleresponsibility ofthe author andcaninnowaybetakentoreflecttheviewsoftheEuropeanUnion (northoseoftheGovernmentofSyria) 1Generalremarks

Thisbriefreporthasanumberofinterrelatedobjectives: to explore the legal dimensions of the process of informal land developmentandhousingconstructioninurbanareasinSyria to establish how the countrys overall legal planning system has relatedto/determined tosome extent the mainfactors thathave been identifiedascausesofthephenomenonofinformaldevelopment to provide a general analysis of the main legal implications of informaldevelopmentfortheresidentsofinformalzonesandlast,but notleast to provide general ideas on how to confront the phenomenon of informal development through both preventive land, urban and housingpoliciesaswellasremedialregularisationpolicies. My main goal is to offer a general conceptual framework for research, policymakingandactioninthefieldofinformalsettlements,whichcouldbe usefultoguidefuturediscussionsanddecisionmakinginSyria. Byplacingemphasisonthelegaldimensionsofthesubject,Iwillbearguing thatinformaldevelopmentistoalargeextenttheresultofthelegalplanning systeminforce,andthatitisinthereformofthislegalsystemthatsolutions have to be found to both regularise consolidated situations and prevent futureinformaldevelopment. Ifinditnecessarytostressthatmyanalysishasbeenconstrainedbythelack of precise and organised data on the phenomenon of informal land development in Syria the fact that there are few indepth analyses and publications available and also by my linguistic limitations. As well as conducting a general bibliographical research, I spoke with a number of people notably Ms. Wafaa Daghistani, Director of Urban Planning Mr. HoussamSufudi,LegalExpertandtheteamfromDeirEzzourestablished ashortcorrespondencewithProfessorMonaSerageldinandbrieflyvisited theinformalsettlementsofQassioun,DouwellaandTabbalahinDamascus. IgreatlybenefitedfromreadingProfessorPatrickMcAuslansreportonthe Syrian legalplanning system, as well as ProfessorPatrick Wakelys report on the informal settlements in Aleppo. A fundamental source of reference th wasthechapteronSyriashousingsectorinthe10 FiveYearPlan(2006
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2010). Specialthanks aredue to Mr. Kanaan AlMasesfrom MAMfor his comments,supportandattention. Moreover, I would like to mention that I am drawing from my own professionalexperienceleadingwiththesubjectofinformaldevelopmentin many countries for the last 25 years. Given all due respect to the several specific historical, political and legalcharacteristics of the Syrian case, the fact is that there are also many similarities with informal development processescurrentlytakingplaceindevelopingandtransitionalcountries,and valuablelessonscanbelearnedfromallsuchinternationalexperiences. 2ReasonsofrapidurbandevelopmentinSyria Syriahasexperiencedaprocessofrapidurbandevelopmentsincethe1980s, whentheannualgrowthrateswereashighas5%thecurrentrateof3%is lower,butstillconsiderablyhigh.About55%ofthetotalpopulationlivesin urbanareas,andthisnumberisexpectedtoriseto75%by2050.Some45% of the total population is concentrated in Damascus and Aleppo (Lavinal, 2008). There are some important demographic factors underlying this process of rapidurbandevelopment,whichdeservespecialmention: populationgrowth:accordingtomostsources,thecurrentpopulation is approximately 19 million, growing at an annual rate of over 1 2.30% ruraltourban migration within the borders of the provinces and increasingly towardsDamascus, Aleppo, Homsand other maincities (Winckler,2000),aswellas growing migrationforotherurbanareas towards Damascus, given the concentration of opportunities in the capitalcity internal population displacement resulting from conflicts, especially affectingthe SyrianArabsdisplacedfromtheGolanHeights in1967
1

The State Planning Commission estimates that the current population is 21.660.000 people accordingto civil registration records, with the estimatedgrowthbetween2006 20010being 2.37% http://www.planning.gov.sy/index.php?page_id=50

(there are currently still about 305,000 people displaced from that 2 conflict,includingdescendants ),andthosedisplacedduringthe1973 SyrianIsraelconflict international migration and influx of refugees, mostly Palestinian (mainly between 19481967), Lebanese (mainly between 1984 and 2006) and Iraqi (mainly between 19902008) Syria has reportedly received between 1.5 and 2 million Iraqi refugees in recent years (Lavinal, 2008), being one of the countries that received the most refugeesin2007:

Source: Forcedmigration Seekingrefuge, TheEconomist,Jun19th2008

Rapidurbanisationhascorrespondedto,andsupported,aremarkablegrowth oftheeconomy,estimatedas6.6%in2007,whichhasbeenincreasinglyled bytheexpandingprivatesector.Nationalandinternationalinvestmentshave

2

SeethedatacollectedbytheInternalDisplacementMonitoringCentre http://www.internaldisplacement.org/8025708F004CE90B/(httpCountries)/9F19CC0028 0C471C802570A7004CE12F?OpenDocument 4

brought about the expansion of the industrial sector and the appearance of neweconomicactivities,someofthemrelatedtothegrowthofinternational 3 tourism. Mostsuchsocioeconomicchangeshavebeen madepossiblebythe gradual politicalandinstitutionalchangesthathavebeenpromotedinthecountryin recent years, which have also been translated into legal changes aimed at introducing elements of the market economy and empowering the private sector. The devolution of powers and strengthening of local administrations has altogetherbeenlessstraightforward,butthelocaladministrationsseemtobe widelyexpectedtomaterialisetheplanningorderstilllargelydefinedatthe nationallevel. Despite the recent efforts made towards the upgrading of infrastructure by both the state and the private sector, urbanisation has entailed a growing crisisinthe provision of publicservices and implementation of equipment, facilitiesandgeneral infrastructure. Theenvironmentalimpactsresultingfromrapidurbandevelopmentarealso escalating: air pollution water contamination, energy shortage, etc. The number of vehicles has increased from 400,000 to 1.5 million since 2003, leadingtofurtherpollution,roadcongestionandaccidents.4 Of special importance in this context is the growing demand for access to serviced urban landandadequatehousing. OneshouldnotunderestimatetheenormousburdenSyriahasshoulderedfor thelast40yearswithrespecttohousingpeople,especiallyfollowingthewar with Israel and more recently the extraordinary influx of refugees. The
3

See2008WorldBankreportonSyrianeconomy http://web.worldbank.org/WBSITE/EXTERNAL/COUNTRIES/MENAEXT/SYRIANA RABEXTN/0,,menuPK:310553~pagePK:141159~piPK:141110~theSitePK:310548,00.ht ml Seealsothe2007BanqueAudireport http://www.banqueaudi.com/geteconomy/syria/SyriaEconomicReport.pdf 4 SeerecentreportinSyriaToday www.syriatoday.com/pkg05/index.php?page=view_article&dir=articles&ex=2&id=759& First=0...

governmental action, the legal support of which has been largely provided by Law no. 9/74, has been largely responsible for the satisfaction of this growing housing demand over the decades more recently, also the private sectorhasplayedagrowingrole. Infact, the abovementioned recenteconomic investment has brought about increasinglandandpropertyinvestments,generatingakindofconstruction boom in 2006 and 2007, especially with new groups of executives demanding highend housing. The recent political and legal changes have included a more favourable legislation on the organisation of the property sector(Lawno.15/08), thusreinforcingtheexpansionoftheprivatesector 5 inSyria. However,itisclearthatthereisaseriouslandandhousingsupplyproblem inSyria.
th As fully acknowledged by the State Planning Commission in the 10 Five YearPlanFYP,thecurrenthousingdeficitisestimatedas687,000units.6

The lack of suitable and sufficient mechanisms to release both public and private land for urban development has led to a considerable bottleneck in the land and housing market, thus generating escalating land and property prices. In fact, although studies should be urgently promoted to explain the formationanddynamicsoflandandpropertypricesinurbanareasinSyria, therearealready manyelementsattestingtotheremarkablegrowthinland andpropertyprices. Thecombinedquestionsofavailabilityandaffordabilityofland,housing, infrastructure, and transport are by all accounts crucial, especially consideringthatabout40%ofthetotalSyrianpopulation isunder15years of age, and soon these young people will be looking for mechanisms and opportunitiestohaveaccesstourbanlandandhousing.Moreover,thereturn
5

Seethe2007reportbyBanqueAudi http://www.banqueaudi.com/geteconomy/syria/SyriaEconomicReport.pdf 6 th Seethe10 FiveYearPlandocumentattheStatePlanningCommissionswebsite www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf

of refugees to their original countries seems to be an unlikely scenario in manycases. Theongoingprocessesofurbansprawlanddeteriorationofhistoriccentres aredirectreflectionsofthecountryscurrentlandandhousingcrisis:urban developmenthasincreasinglybeentakingplaceinformally. Indeed,informallanddevelopmenthasbeenhappeningsincethe1960s,but it certainly is escalating: informality accounts for 50% of urban growth in the outskirts of conurbations and houses 40% of the population (Lavinal, 2008). The rate of informal development has been estimated as between 40% and 50% in Damascus. In Aleppo,almosthalfthe population lives in 22 underserviced informal settlements, which are estimated to be growing by some 8,000 households per year creating 160 new dwellings per week (Wakely,2008). Morethanever,informalaccesstourbanlandandhousingisnolongerthe exception,butithasbecometherule. Thephenomenonseemstobegrowing,boththroughtherecentformationof newsettlementsandthefurtherexpansionanddensificationofconsolidated ones which growth is certainly firm evidence of a structural flaw in the officiallandandhousingdeliverysysteminSyria. 3Causesofinformaldevelopment One shouldnot mistakethe causesof informal development inurbanareas for the same causes of rapid urban development, referring to the social, political and economic factors mentioned above as the causes of informal development. These are of course interrelated processes, but they are by no means the same: not all urban development is, or needs to be, informal. Population growth and economic changes are not per se the reason why urban land development has been promoted informally. If half the urban population onlyhasaccesstolandandhousingthroughinformalprocesses,thenthereis somethingseriouslywrongwiththeoverallsystemputinplacetorespondto suchfundamentalneeds.

Inthiscontext,specialemphasisneedstobeplacedontheunderstandingof the several causes of informal development. The multilayered and intertwined reasons of the gap between the growing land and housing demandandthelimitedsupplyneedtobeconfrontedsothatthecurrentland supplybottleneckcanberemoved.Itiscrucialthateffectsarenottakenfor causes. The structural difficulties facing the government to provide sufficient, adequateandaccessibleoptionsofaccesstolandandhousinginurbanareas hastwomaindimensions. On the one hand, informal development has resulted from the lack of sufficientandaffordableofficialmarketoptionsofaccesstourbanlandand housing especially serviced land thus leading to increasing land and propertypricesandexcludingintheprocessagrowingpartofsociety. Although itseemslogicaltorefertothelackoflandasbeingaproblem, the fact is that land itself is widely available, what is not fully and easily availableisservicedlandreleasedintothemarketthroughlegalprocesses. On the other hand, informal development has resulted from the nature of stateaction,inseveralways. To begin with, the lack of a consistent social housing policy has certainly accounted for the fact that the urban poor live in informal settlements. PovertyinSyriahasaffectedbetween2and5.3millionpeopledependingon themeasurementcriteriaused,with38.8%ofthepoorlivinginurbanareas (El Laithy & AbuIsmail, 2005). There are serious regional variations, but this number may rise as a result of the fact that recent economic development has not been fundamentally propoor. The urbanisation of poverty is a trend, particularly in the NorthEastern region, especially consideringthegrowinglevelsofunemploymentincities. The analysis of the housing sector in the FYP indicates that the actions of thePublicEstablishmentforHousing,createdin1961inordertosecureand sell land for housing development, were limited to directives, procedures and plans, and have never been developed into strategies with goals. Even clear directives have not been accompanied with specific implementation requirements.() Inspite of thesuccessofafewhousing projects, it was obvious that the implementation policies were inefficient, which had many
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implications,theworstofwhichwastheeverexpandinginformalsettlement areas.Moreover,thedocumentstatesthatthelegislationsandregulations issuedtillmid1970sclearlyreflectedavisionfocusingonthesocialroleof the state in this sector. This was manifested in providing facilities and exemptiontosecuresuitablehousingforlowincomegroups,withminimum possiblecostand collect thesecosts in longterm instalments that suit their income. This vision haschanged. By year 2000, the Government gradually reduced this intervention by issuing several businessoriented legislations, 7 withoutconsideringthesocialaspects. Also the lack of a social rental policy needs to be mentioned 12% of the urban poor rent houses, given the impossibility of their acquiring property evenintheinformalmarket (ElLaithy&AbuIsmail,2005). Again according to the analysis of the housing sector in the FYP, the previous rent law led to a nonbalanced relationship between owner and tenant,andcausedcompletedisappearanceoftheleasingapproachfromthe housing market in Syria, leaving tens of thousands of flats empty, which adversely affected the sector. It is estimated that there are 500,000 empty houses in Syria, and the enactment of Law no. 6/01 was an attempt at 8 addressingthisseriousproblem. That said, informal development in Syria is by no means a phenomenon limited to the urban poor, on the contrary, there are many informal settlements occupied by middleclass groups, which means that there are many other factors at stake to be discussed other than the recourse to povertyasbeingthesole,oreventhemain,causeofinformaldevelopment. The definition of informal settlements is always a difficult one, because several different situations are encompassed in this umbrella expression, including situations which at first sight do not seem to be related to each other in any logical way. For example, in terms of urban form and living conditions, it may be difficult to refer to both a precarious settlement on public land occupied by refugees and a more established middleclass

Thisaverbatim quotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf 8 Verbatim quotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf 9

neighbourhood developed on occupied private land as being equally informalsettlements. AccordingtotheFYP,theterminformalsettlementareasinSyriarefers tohousesbuiltcontrarytourbanplanningorbuildingregulations.However, these areas have basic services (drinking water, electricity, telephone, sanitation..) at reasonable levels and a fair number of the buildings have sound structure, a far cry from the tin cities found in other countries.9 Interestingly,thereisnomentionwhatsoeverinthisofficialdefinitiontothe landtenuresituation. As discussed below in more detail, I would argue that, whatever their differences may be in terms of their urban and environmental conditions, and however contrasting their socioeconomic profiles may be, all forms of informal land development imply some form of noncompliance with the legal order, and as such they are expressions of intrinsic problems in this legal order. Naturally, different situations should be treated differently, not least withinthecontextofpublicpolicies, butoneshouldnotnaturalisethe problem, thus making some situations more socially acceptable. The fact that people have violated the legal order and live informally however legitimatetheirjustificationsmaybeisnotinoffensive,onthecontrary,it producesseveralharmful consequences,legalandotherwise. In this context, rather than dismissing the importance of the law in this process, I would argue that the lack of sufficient, adequate and affordable urbanlandandhousinginSyriaisdue,toalargeextent,totheoveralllegal planningframeworkinforce. Tobeginwith,thelegalorderhasfailedtoprovidespecificmechanismsfor thenecessaryreleaseoftheverysignificantstockofpubliclandintothe marketforhousingpurposesinurbanareas,beitthroughlanddevelopment bythepublicsectoritselfordevelopmentbytheprivatesector,throughsale, leasing,publicprivatepartnerships, and/orsocialrental policies. Moreover,evengivenduerespecttotheverysignificantamountofhousing builtinSyriaovertheyearsundertheaegisofLawno.9/74,ithastobesaid thatthe legalorder has also affectedthe necessaryreleaseof vacantand/or
9

VerbatimquotefromtheEnglishtranslationofthedocument

www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf

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underutilised private land into the urban housing market and its development by land developers and promoters, by imposing anachronistic and inflexible rural/urban boundaries establishing obsolete urban and environmental planning directives and requirements imposing unrealistic building regulations in short, by failing to consider the current 10 socioeconomicconditionsofaccesstourbanlandandhousing. The provisions governing the subdivision of land for the sale of plots for construction need to be revisited and updated in the light of contemporary needs, including the indication of the obligations land developers have to fulfilsoastoprovideinfrastructuretothenewresidentialareas.Thenotion of compulsory distribution of land by landowners (Law no. 9/74), followingthelocalmasterplansorfreelyifnosuchdirectivesexist,needsto be expanded so as to become a properly functioning land release mechanism. Isitamerecoincidencethatthegrowthofinformallanddevelopmentinthe 1980sbeginstotakeplacesoonaftertheenactmentofLawno.60,in1979, which determinedthe freezingofurbanexpansion with no compensation being effectively offered to landowners, many of whom informally subdividedtheirlandintosmallerplotsandsoldthemtothirdparties? Itisbelievedthattwothirdsofinformalsettlementshavebeendevelopedon privateland(Lavinal,2008),withmostofthemontheareastakenoutofthe marketbyLawno. 60/79. TheanalysisofthehousingsectoroftheFYPclearlystipulatesthatLawno. 60/79 faced enormous difficulties and failed to meet its objectives, the matterthatcreatedarealcrisisregardingtheprovisionofrequiredlandfor constructing.11 Furthermore, the legal order has not included sufficient mechanisms to guarantee its own enforcement. Although it is often said, in Syria and elsewhere,thatlawsaregood,theproblemistheirenforcement,thefactis that enforcement is an intrinsic condition of validity of any adequate legal
10

For a general assessment of Syrias overall legal planning system, see McAuslan (2006). 11 VerbatimquotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf

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system. If the laws are not implemented, then the legal system cannot be deemedtobegood. Bureaucratic, time consuming and costly directives and management procedures in force do not take into account the land planning and management capacity at local level, particularly the capacity of local administrationstoapplythenationalplanningprovisions,formulatemaster plans,aswellasenforcingdevelopmentandbuildingregulations.12 This picture has been aggravated further by the lack of institutional integration, conflicting directives, problems of information, land cadastre andregistration,andlackofarticulationbetweenthedifferentkindsofplans andpolicies. Popular participation in planning and management is still incipient, if not negligible,andthepossibilitiesofbothextrajudicialconflictresolutionand efficientaccesstojudicialpowerarelimited. In short, while there is undoubtedly a growing expansion of the land and private property market in Syria, both formally and informally, the corresponding overall legalinstitutional framework regulating land rights, land management, urban planning and urban management has proved wanting andneedstobecriticallyreassessedasawhole. It is not that there are no laws in force directly regulating aspects of the process of informal land development: as will be discussed below, Syria followsaratherlegalistictradition,andthereareseverallawsonpreventing unauthorised constructions, repulsion of code violations, clearance of unauthorisedconstructionsthatviolatemasterplans,aswellasonmandating the relocation of families. However, it is fair to say that these are mostly reactive, negative measures, which do not compensate for the lack of properlypreventivelandmanagementmeasures,andmanyofwhichendup not being properly enforced anyway given the abovementioned legal and institutionalobstacles. Moreover, many of these are laws mainly concerned with individual irregularconstructions,withoutaproperunderstandingthatwhatisatstake
12

For example, the high costs of the engineering fees requested for the issuing of buildingpermitsseemstobeasignificantobstacletomanypeople. 12

is a more complex, collective land development process, through which wholeneighbourhoodsareformed. Systematic capacity building, education and training are of utmost importanceatallgovernmental levelsso thatthelawsinforcecanbefully applied, with general directives translated into specific plans and the legal possibilities for intervention in the land structure being effectively materialised.However,oneshouldnotignorethefactthat,toalargeextent, the problem lies inthe legalsystem itself:once again,I wouldargue there arestructuralproblemswiththeSyrianlegalplanningsystem,whichshould beaddressed.
th Sincethe 9 FYP(20002005)the intentionoftheSyrianstatehasbeento promote a shift from the old approach of a purely social role (direct subsidiesandexemptions,whicharelossactivitiesineconomicterms)toan advanced role through creating conducive environments to spur activities andinvestmentsinthisimportantsector()tostrikeapricebalanceinthe market, hence creating better chancesforlimited income persons to own a 13 residence. However,giventhefailuretoreformthelegalplanningsystem, thisgoalhasbeenunobtainable. th Forallthesereasons,the10 FYPclearlylistsasdifficultiesfacinghousing sector,amongstothers:

weaklegislationsthathelpsecurelandsreadyfordevelopment multiple systems, legislations and parties concerned with housing process, and lack of clear structure of the housing sector which definesrolesofinvolvedpartiesatvariousstages lack of accurate connection between the housing process with the economicandsocialdevelopmentconcepts lack of connection between housing and comprehensive planning, etc.14
13

VerbatimquotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf 14 VerbatimquotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf 13

Indeed, Syria would benefit from expanding its tradition of physical urban planningsoasto,following aproper understanding of thedynamics of the land markets, better articulate planning directives and land management tools. The constitution of an articulated land governance framework is the condition for the promotion of more inclusive urban planning and management strategies in the country. In particular, housing and land policiesneedtobebetterintegrated. Syrianpolicymakerscouldcertainlylearnfromwhathasbeenhappeningin othertransitionalcountries:withtheexpansionoftheprivatesectorandthe growinginvestmentinlandandhousing,thecapitalistproductionofthecity has clearly shown the limits of traditional planning notions, which, pretending to be technical, objective and rational, do not properly consider the impact of planning principles and standards, or of the conditions of urban management, in the formation of land and property prices. By failing to interfere in the land structure, traditional physical planning decisively reinforces processes of social exclusion and territorial segregation. By failing to promote a better distribution of the onus and benefits of urban development, functionalist planning directly creates the basesoftheinformaldevelopmentprocess. The lack of supervision is also a factor commonly referred to by urban managers when asked about the causes of the phenomenon of informal development,whichseemsto indicatethe existence ofaninstitutionalvoid over the years, creating a culture of tolerance of informal development of public land, environmentallysensitive areas, green areas, risky areas, agriculturaland periurban areas,in short, areas outside ofthe officialland andpropertymarket. Ashappensinternationally,the phenomenoncanalsobeexplainedtosome extent in terms of the opportunities presented for interference in the processes, notleast through thelackoftransparency. Itseemsthatthereiscurrentlyafirmergovernmentalattempttocontrolthe formationofnewinformalzonesthanwasthecaseinthe1980sand1990s withseveralpeoplebeingarrestedasaresultofLawno.1/03,whichforbade unauthoriseddevelopmentofprivateland butinfacttheabovementioned demographic factors, especially the constant influx of immigrants, seemto

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have put serious political limits and constraints to this intention of governmental control. All in all, it should be recognised that the system of informal land and propertydevelopmentdoesworkandseemstosatisfymanyofthefinancial and political interests involved, as well as providing immediate housing opportunitiestothosewhoneedthemhalformoreofthecountrysurban population. However, this is a system that should not be condoned, as it entails prohibitivefinancial,environmental,social,legalandpoliticalcostsnotonly tothoselivingin informalareas,buttothecitiesandthe Syrianpopulation asawhole. Expressing this concern, under the patronage of Mr. Abdulla alDardari, Deputy Prime Minister for Economic Affairs, the Institutional Sector and Modernisation Facility (ISMF) promoted the important meeting "From informal to formal: Ways of reducing the underground activities in the Syrian economy" in May 2008, to discuss the causes and consequences of 15 informaldevelopmentinSyria. 4Implicationsofinformalsettlementsforresidentsandcities Although there are many significant variations, the general implications of the phenomenon of informal development in Syria for the residents in the informalareashavegraduallybeenidentified, researched,andquantified: limited access to public services: 91% of the urban population has accesstowatersysteminsomeway,butonly29.4%ofthepoorlives in houses connected to the sewer system ((El Laithy & AbuIsmail, 2005) inadequatestreetcleaningandrubbishcollectionservices

15

SeereportISMFholdsroundtableforreducinginformaleconomicactivityinSyria http://www.sebcsyria.com/web2008/art.php?art_id=1446

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 there is a profoundly unequal distribution of public equipment, collective facilities and open spaces in urban areas, with informal settlementsbeingthemostaffectedareas despite the reasonably good level of the constructions in many informalsettlements,manyofthemareunsafeandonthewholeliving conditionsareprecarious environmental pollution and safety hazards areserious, with women bearing a disproportionate burden of poor health and disability (Maziaketal,2005) there are serious vulnerabilities in many informal settlements, which usually have high population density such as the case in Damascus, wherethereare800peoplelivingperhectarein2005,some800,000 people were living in these informal settlements which were built in 16 highfrequencybufferzonesandalongtheDamascusfaultline young people have beenespeciallyaffected by theoverall conditions of social exclusion and spatial segregation, with the lack of opportunities(Kabbani,2007) communities living in informal zones are often marginalised and discriminatedagainstetc. Naturally,froma broaderperspectivesuchproblems especiallyregarding health and environmentalconditions affectnot onlythe population of the informalzones,buttheoverallurbanpopulation. Special emphasis should be placed on the financial costs of living in informalareas:contrarytopopularbelief, informalityisnotacheapoption for the residents, as they have to pay for the high economic costs of transportationfromperipheralareasandfortheinformalprovisionofwater andotherservices,as wellashavingtoputup withtheincreasinglyhigher economiccostsofhousingwithintheinformalmarketforlandandproperty acquisition,constructionand/orrental.
16

SeereportSyria:Governmentupgradesdisastermanagement http://www.irinnews.org/report.aspx?reportid=25097 16

Moreover, also from the viewpoint of the city as a whole informal development is a very expensive process. Not only are cities produced informally deeply fragmented, inefficient, polluted and difficult to administer, but also the costs of land regularisation programmes are enormous. Finally, thelegal implicationsof theprocess ofinformalsettlementfor the residentsarealsomanifold,andequallyimportant: lackofsecurityoftenureandexposureofoccupierstoforcedeviction resultingfromthelackoftitleregistration impossibilityofaccesstoofficialcredit andhousingsubsidies repeated legal problems resulting from changing family relations (marriages,separations,deaths,births) repeated legal problems resulting from changing neighbourhood relations(demarcation,access) repeated legal problems resulting from the expansion of the constructions(newunits,morefloors,etc.)etc. Not being recognised fully as subjects of rights, residents in informal settlements as prone to political manipulation and less protected against market pressuresbesidesthe growingasking prices, the informal landand property market has reportedly become more speculative, with significant areasand/orbuildingsbeingkeptvacant. For all these reasons, the phenomenon of growing informal development needstobeurgentlyconfronted:itcannotbemainformoflandandhousing policy. Perhapsthemainlessonfromtheinternationalexperienceisthattoprevent informal development is much cheaper, easier and faster than to regularise informalsettlements. Thatsaid,theconsolidatedinformal situationsneedtoberegularised.

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In principle, people should stay where they live as the implications of massiverelocationwouldbegigantic:thereisnotenoughservicedlandthe environmental footprint and high costs of resettlement would be prohibitive communities living in consolidated informal areas have developedtheirownsocialandcapitalnetworksand in manycasespeople mayhaverightstostayonthelandtheyhaveoccupied,forexamplethrough adversepossession. Resettlement is always possible, but it should be viewed as an exception, not as the main policy, and its implementation should require the formulationofacceptablealternatives. Fundamental for the purpose of designing regularisation policies is to distinguish between the different categories of informal settlements, as, although many of them may look similar in urban, environmental and architectural terms, or differ in terms of their socioeconomic profile and generalstateofacceptability,theirdifferentlegalcharacteristicsgenerate, or should generate, different legal and political implications, which should betakenintoaccountduringtheformulationofregularisationpolicies. 5Typesofinformaldevelopmentinurbanareas Informal settlements in Syria can result from the following frequently intertwinedandoverlappingcategoriesoflegalsituations: informalityresultingfromlandtenure informality resulting from noncompliance of land use/planning regulations, including the lack of consideration of urban boundaries (mainlyregarding agriculturalandperiurbanland) informalityresultingfromnoncomplianceofbuildingstandardsand informality resulting requirements. from noncompliance of registration

Mostinformalsettlementshaveafundamentalproblemoflandtenure,beit the occupation (grabbing, squatting) of public (government and/or municipal) land or the occupation of private land, in this case either land owned by the developer/builder or by someone else. Settlements on public
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land tend to be occupied by poorersocial groups.Pricestendtoreflectthe amountofinvestmentbytheinformaldevelopersinthedemarcationofplots and implementation of basic infrastructure. Once the settlement is consolidated, a growing, dynamic informal land market is formed to promotetheresaleofconstructionsontheoccupiedland. In terms of the urban form, occupations of public land tend to be less organisedthanthoseonprivateland,whichoftenhavetheappearanceofa regularlandsubdivision,withamoregenerousinternalstreetsystemanda more clearly defined articulation with the overall city whereas in the former case, thestreets tend to be too narrow, the density of occupation is higher, constructions can be unsafe and there is no clear demarcation between private and public spaces. However, also in general terms, besides the limited infrastructure and the relative quality of the constructions, in both cases one the main problem is the lack of public spacesfortheimplementationofcollectivefacilitiesandequipment,aswell as green areas. The overall quality of life in the informal zones is thus compromisedbythisseriousimbalancebetweentheprivatelyoccupiedareas andtheareasleftforcollective use. Qassioun is an example of a large settlement on public land, which has consolidated and become denser over theyears,puttingfurtherpressure on the precarious infrastructure and narrow street system. It is a particularly special part of Damascus, both geographically and visually, and it requires specialtreatmentduetoseismichazards. Douwella and Tabbalah are reportedly more typical expressions of tbe phenomenonof informal land developmentin Damascus they areboth the result of informal land subdivision by the original, apparently legitimate landowners, but the land subdivision processes were not authorised. Therefore, not only are the constructions illegal, but also the very settlementsareillegal. That said, the legal situation in Syria is even more ambiguous than that of other comparable countries, as many layers of contradictions have been created as a result of legal changes and political decisions over the years, which have had the effect of contributing towards the consolidation of the informal zones, generating a widespread sense of perception of security of tenure, as well as conferring some forms of rights onto the occupiers of informalzones.
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For example, a recommendation (198082) from the leadership of the Al BaathPartyhasdeterminedthatallinformalsettlementsshouldbeprovided withbasicservicesregardlessoftheirlegalstatusandplanningsituation.As wellaspayingfortheservicestheydoreceive,many,ifnotmost,residents in informal settlements also reportedly pay property tax, even without havingregisteredtitles.Lawno.46/04allowsforthepossibilityofbuilding permitsbeinggiventooccupiersofinformalsettlements,providedthatthey agree to pay for the collective utilities, and that the size of their plots is acceptable accordingto thetermsof anexisting or even aproposedmaster planforthearea. The case of Alothmaniah in Deir Ezzour seems to combine all such elements:asettlementdevelopedsincethe1980smostlyonprivateland,but with around 10% being on public land, on land that the local plans had excludedfromurbandevelopmentbyclassifyingtheareasasagriculturalor greenareasandtheinformaldevelopmentofwhichwaspossiblegiventhe lack of supervision. The Regional Committee has pragmatically and understandablysuggestedtheamendmentofthemasterplansothatschools, mosques and other equipment can be built, thus seemingly further compromising the objective of environmental preservation of the area still expressedbythelocal masterplaninforce. In all these cases, besides the land component there is also the need to confront the fact that building standards have not been obeyed either and constructions have not been approved, which factor has been aggravated furtherbytheprogressivehorizontalandespeciallyverticaldensificationof theareas,withnewfloorsregularlybeingaddedtoexistingconstructions. One rather complex dimension that needs to be confronted is that of land registration,notonlytosimplifycriteriaandlistofrequireddocumentsand to lower costs, but also to both generate the implementation of a truly comprehensive system and to integrate it with an equally updated, modern landcadastre. All that said, it should be briefly noted that there are certainly countless situations of informal practices involving violations of the legal order in some way such as new additions, expansions, size differences between approvedlayoutsandeffectivelybuiltareas,etc.inurbanzonesotherthan

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the informal settlements, which seems to confirm that there is a fundamental problemwiththelegalsystemasawhole. Moreover,residentialconstructionstendtocoexistwithallsortsofinformal businesses and other uses, which fact should be taken into account during theformulationofregularisationprogrammes. 6Regularisationprogrammes Itisinthiscomplexcontext,whichurgentlyneedstobebetterstudiedand understood, that policymakers should discuss how best to confront the phenomenon of informal development, as well as how to regularise the existingconsolidatedsituations. Tobeeffective,publicinterventionneedstoaddressinanarticulatedwayall the abovementioned causes of phenomenon, combining preventive and remedialpolicies. 6.1Preventivepolicies Regarding the need for preventive policies, a set of articulated land and housingpoliciesneedstobeconceived,beginningwiththeformulationofa ruralpolicysoastogeneratemorejobandincomeopportunitiesaswellas betterlivingandworkingconditionstothepeoplelivinginthecountryside thusatleastminimisingtheprocessofruraltourbanmigration. Abroadandarticulatedhousingpolicyalsoneedstobedesigned,regulating bothsocialhousingandtheconditionsofhousingfinanceasawhole. The development of a social housing sector is of utmost importance, includingtheinvestmentbythegovernment(directlyor inpartnership with the private sector) in the construction of a suitable housing stock (for example, in housing estates) for the most vulnerable social groups. Partnerships also should be formed between the public sector and the organised communities (housing associations, NGO). Housing associations foryoungpeopleshouldbeespeciallytargeted.TherecentLawno.17/07on housing cooperatives seems tobea step inthisdirection.17 Alsothe Youth
17

SeearticleinSyriaToday : 21

Housing Project launched in 2002 seems promising and should be 18 expanded. Specialattentionshouldbepaidtotheformulationofanational,articulated policy on the use of public land , especially when it has already been providedwithinfrastructureandservices.Thisisacrucial,althoughlargely neglected, question in a country like Syria, where the stock of publicly ownedlandisstillverysignificant.Theplanninglawsinforcedonotapply topublic landfor example, theabovementionedcompulsory distribution mechanismcouldnotbeimposedonpublicland.Thereisagreatdealtobe discussed regarding the social functions to be performed by public land within a broad land governance framework aimed at democratising the access to urban land and housing.The discussion on a nationalpolicy,and supporting law, providing for the utilisation of public land for residential development, environmental preservation, economic development, among othersocialfunctions,wouldbewelcome. Otherareasofinterestwouldbethedevelopmentforresidentialpurposesof vacant and already serviced, private urban land, which development could be achieved either through agreements with landowners, expropriation or compulsory development orders. The same applies to empty or under utilisedprivateproperties.19 Besides these specific policies, a preventive approach to confront informal land development in Syria will require not only a thorough revision of the existingmasterplans,butalsooftheoveralllegalplanningsysteminforce, including the technical criteria orientating the formulation of plans and licensing of urban development and construction applications the requirements for the subdivision of private land a realistic approach to existingruralandurbanboundaries,etc.

http://www.syriatoday.com/pkg05/index.php?page=view_article&dir=articles&ex=2&id =511&First=0&Last=2&CurrentPage=0&src=cat&cat_id=20 18 www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf 19 Besidestheabovementionedlargenumberofvacanthouses,thereareothersituations tobeconsideredarecentdevelopmentinDamascushasbeenthenegotiationtousethe thousandsofpropertiesstillownedbyJewishfamilieswhodonoplantoreturn http://www.syriatoday.com/pkg05/index.php?page=view_article&dir=articles&ex=2&id =428&First=0&Last=7&CurrentPage=0&src=cat&cat_id=1

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Thesameappliestothedynamicsofthelandmanagementprocess,soasto guaranteeacleardistributionofresponsibilities,bettercoordinationbetween the national and the local levels, faster decisionmaking procedures, strengthening and capacity building of the local administrations, popular participation in the planning and decisionmaking process, etc. The productionofreliabledataandthemodernisationofinformationsystemsare alsoofutmostimportanceinthisprocess. Itseemsthattherearetwoconcurrent,ongoinginitiativesinSyriaaimingto promote changes in the planning laws in force, respectively regarding the planning principles and standards, and the conditions of planning implementation,especiallyofmasterplans.Suchinitiativeswouldcurrently beinaprocessofendorsement.Beingunawareoftheircontents,Icannot pretend to comment on them. However, much as one understands the politicaldecision to favour a sequence of partial legal changes, rather than an overall revision of the legal planning system, it is hoped that the opportunity will not be missed to remove the abovementioned factors that together account for the longstanding bottleneck in the planning system, whichhascreatedtheseriousproblemoflandsupplyinSyria. Havingstressedtheneedforabroaderapproachsoastobreakthecyclethat has produced informal development, it is also necessary to confront the existingsituationsofconsolidatedinformalsettlementsinurbanareas. 6.2Regularisationpolicies Regularisation policies are of course most important public policies, although they should not be formulated in isolation or as merely sectoral policies to be effective, they should be part of a broadly defined land and housing policy, as well as of the overall set of strategic, master and local plans and zoning schemes, so as to guarantee the integration of technical concepts,institutionalactions,andfinancialresources. Regularisation policies should also be multidimensional, involving the upgrading of the informal zones and improvement of constructions the legalisation of occupied areas, constructions and also businesses and the implementation of socioeconomic programmes aiming at improving living conditions in informal zones, especially those occupied by the urban poor. Mechanisms to ensure popular participation should be conceived at all

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stages, and special emphasis should be placed on the financing of the programmes,thatis,theoverallsocialdistributionoftheircosts. Onefundamentaldimensionofaregularisationpolicynaturallyreferstothe upgrading of the zones and the improvement of constructions. This is the opportunity to address accumulated problems resulting from inadequate services and facilities, lackof collective spacesand green areas,inefficient transportation, and lack of safety. Housing improvement involves not only the safety of individual constructions, but the management of existing environmental risks. Resettlement is always a possibility when individual constructions or areas are intrinsically risky and unsafe, or when areas are necessary for widening the streets and implementing public infrastructure and facilities, but in those cases acceptable solutions should be discussed with the affected parties. Special emphasis should be given to gender and youthneeds. Legalisationpoliciesshould bedeveloped topromotetheformalisationand titlingofinformalareas,plotsandconstructionsaswellasbusinesses.Itis important to distinguish between the different categories of informal settlements, especially, and ideally, by treating those on public land with differentcriteria.Therecognitionofhousingrightstooccupiedpublic land does not, or should not, necessarily entail the privatisation of the land through the distribution of freehold titles collective titles, leasehold and other rights might be more adequate in given circumstances, especially to minimisethefuturepressurefrommarketdevelopersinterestedinacquiring thenewlyupgradedandlegalisedareas,especiallyincentrallocations.The situationsofinformaltenantsandoccupiersofnewlybuiltexpansionsofthe originalconstructionsrequirespecialattention. In fact, the promotion of security of tenure to the occupiers should be reconciled with the objective of promoting sociospatial integration of the informalzones,aimingtoguaranteethepermanenceofthecommunitiesand toensurethattheyarethefinalbeneficiariesofthecostlypublicintervention through upgrading and legalisation programmes. Internationally, these programmes have generally brought about higher land and property prices, as well as more densification of the regularised areas. In particular, the distribution of property titles in regularised areas is especially attractive to land developers and promoters, as they try to capitalise on the public investment.Iftitlingcertainlyprovidessecurityoftenuretotheoccupiers,if promoted in isolation it might expose them to a powerful form of market
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pressure,whichhasbeencalled"evictionbythemarket".Inmanycountries, the gentrification of the regularised areas and eviction of the original communitiesbythemarkethasbeenverifiedwhiletheprocessofinformal development is replicated elsewhere. In this context, it is crucial that regularisation programmes are combined with urban planning mechanisms so as to guarantee the permanence of the communities to some extent. Customary, social, cultural, and religious values should be taken into account, as for that matter the need for a gendered approach (Fernandes, 2007). Upgrading and legalisation policies should be supported by socioeconomic policies aiming to promote income and job generation microcredit mechanisms can be introduced for both commercial development and housingimprovement. Popular participation should be encouraged in the design and implementationofprogrammes,inthedefinitionofcriteriaforallocationof public resources, but also for the financing of programmes, with the communities contributing towards some of the regularisation costs. In the settlements onprivate landresultingfrom informal land subdivisionby the original owners, there is always the question of also involving them in the finaldistributionoffinancialcosts. Given the fact that regularisation programmes are intrinsically very expensive,severalsourcesoffinancingshouldbeconsidered,rangingfrom local taxes to the transfer of national resources the involvement of the privatesectorforexample,byusingthetransferofdevelopmentrightsand the concept of planning gains in a newly revised planning system the affectedcommunitiesandinternational financialorganisationsanddonors. All such dimensions should be closely integrated. For example, new legal problems and financial costs often emerge if the upgrading programme is promoted without a proper consideration of the legalisation requirements, By thesame token,if the legalisation programme fails to take into account the upgrading requirements, unsustainable situations may end up being legalised,thusgeneratingfurtherproblems. Of special importance is the need to reconcile the scale of the public intervention with the scale of the phenomenon of informal land development, so as not to create further distortions. It is not sufficient to
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invest an enormous amount of resources in sophisticated regularisation programmes dealing only with a few informal zones, with the remaining ones being left out. For that purpose, policymakers need to find a difficult balance between the technical criteria they use, the existing financial resources, andtheircapacitytoact. Incremental upgrading is more than a possibility, it is a necessity. In fact, partof the reasonwhy informaldevelopment is attractive is the fact that it canbeimplementedinphasessoitiseconomicallyreasonableandeffective. As mentioned above, internationally,oneoftheautomaticconsequencesof theformulationofregularisationprogrammeshasbeenthefactthatlandand property values significantly increase perhaps a less distorted land market would result froma decision todo less, but in more informalzones,rather thandoingmoreinonlyafewselectedzones. Atthisjuncture,andinthelightofsuchgeneralprinciples,itisimportantto examine how the laws in force in Syria respond to the matter of informal settlementsregularisation. It seems that there has been an administrative interpretation of the main applicable legal provisions (Laws no 9/74 no. 20/83 and no. 26/00) to promote a classification of informal settlements not according to legal criteriaoflandtenure,butaccordingtotheconditionsofthesettlements,that is: settlements which are generally acceptable and as such can be kept as they stand, in which only minor and/or specific interventions are necessary (Law no. 9/74 would apply) settlements which need more thorough rehabilitation(Lawno.20/83wouldapply)andsettlementswhichneedto bedemolished(Lawsno.20/83and26/00wouldapply). InHoms,forexample,all19informalsettlementswouldseemtofitintothe firstcategory.Inthecaseofnecessaryremovalsfollowingthedemolitionof individual constructions say, to build schools or to widen streets the affected persons are given land (not houses) in the same neighbourhood. Also in the case of rehabilitation policies, if land is expropriated, housing alternatives have to be offered. No cases of full removal have taken place yet.

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Inallthreecategories,amasterplanapprovedbythelocaladministrationis neededtoprovidetheminimumstandards,servicesandequipmentnecessary fortheregularisationoftheinformalzones. Regardingthelegalisationoftheplots,thecurrentinterpretationisthatinthe settlements where Law no. 9/74 would apply, the occupiers would be entitledtofullownership,freeofchargewhereLawno.20/83wouldapply, occupiers would have to pay for the title to compensate for the upgrading costs and where Law no. 26/00 would apply, a rather more complex formuladeterminesthat,followingtheoveralldevelopmentoftheareaand implementation of public infrastructure, the original occupiers would be given, collectively, 40% of the resulting land (in plots, apartments or buildingcredits),withtheremaining60%ofthelandbeinggiventohousing associationsandotherpublicbodies. Whatseemstobearationalclassificationisinfactacomplicatedsystem which is not easily transplanted to real life: more often than not, in most informal settlements, a combination of specific or even cosmetic interventions, broader rehabilitation strategies, and a dose of removals, is necessary. Given the fact that the original ownership of the land is not consideredbytheSyrianlegislation,whiletheoccupiedpubliclandistobe privatised through the legalisation schemes, landowners who have informally developed their private land and capitalised in the process will bear no responsibility for the enormous costs of upgrading these areas. Moreover, the calculation of values to be paid and compensation costs requires a more clearly established land valuation system rather than the formula established by Law no. 20/83 (with values defined by the Public Establishment for Housing), which should be used for the purposes of propertytaxation,compulsorypurchase,andpaymentofcompensation. Itseemsthat,onceagain,thereisnointegrated,articulatedlegalframework, butapiecemealapproachtolawmaking,generatingseverallegalprovisions trying toaddress all sortsofspecificcategories,formingas aresulta legal patchwork, which may seem formally logical, but which in fact does not addressmanyofthemainissuesthatneedtobeaddressed. 7Recommendations Giventheabovementioned,complexpicture,Iwouldargueandsuggest:
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 that Syria would greatly benefit from the development of a comprehensive and articulated national programme for the regularisation of informal settlements, which would provide the generalframeworkofpreventiveandremedialpoliciestobefollowed bythenationalandthe localadministrations,communities,andother stakeholders thatthisnationalprogrammeshouldcomprisedetailedlegal,financial, institutional and technical strategies to fully guarantee its implementation that a national commission should be installed to create and oversee the application of the proposed national regularisation programme, also being responsible for making recommendations to the national governmentsoastoguaranteethatthenecessaryintegrationbetween the regularisation policies and the ongoing reassessment of the overalllegalplanningsystem thatthedevelopmentoflocalprogrammesandregularisationprojects should by all means be encouraged, but ideally this should be done withinthecontextofsuchanationalframework,whichwouldalsobe usefulfortheviewpointofgeneratingbudgetaryresourcesaswellas mobilising and integrating resources from other national and internationalsources thatthe convenienceof enacting a specificlegislationtosupportand renderthenationaland localregularisationprogrammes,projectsand actionsviableshouldbeconsideredwithinthecontextoftheongoing discussion on the revision of the overall legal planning system however, if the current laws are to be kept, they could perhaps be better organised and partly improved, as well as interpreted in a broaderandmorearticulatedway thatthereareseveralexpensiveandtimeconsumingprerequirements fortheimplementationoflandregularisationprogrammes,suchasthe productionofinformation,maps,photos,andlandandsocioeconomic cadastres,whichwouldrequiresignificantinvestment

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 that of utmost importance are the clear definition of responsibilities andthe adequate institutional articulation amongallpublic agencies in fact, the effective management of the regularisation programmes requires not merely onestopshops, but a conceptual, institutional andlegalintegration that the nationalbudget should express the contents and scale of the proposedpublicintervention andlast,butnotleast that, needless to say, the effective involvement of the private sector, communities, academia, associations and NGOs, and other stakeholdersisalsocrucial. Finally, itshould benoted that mostoftheissuesraised inthisbriefreport th were well identified and addressed to some extent in the 10 FYP, which gives priority to the integration of territorial planning, housing and other policies. The FYP sets very ambitious goals so as to satisfy required housing needs and establish balance between supply and demand, qualitatively and quantitatively, to handle informal settlement areas and limittheirexpansion,aswellastoincreasethesupplyoflandassignedfor 20 buildinganddevelopment. Thedocumentclearlyconveysthenotionthat a more sustainable and comprehensive approach is urgently necessary in Syria, so that economic development policies have a sound social orientation, and so that the strengthening of the private sector and the property marketdoesnot leadto sociospatial exclusionashas happened in somanydevelopingandtransitionalcountries. Technical assessment, capacity building, institutional articulation, social mobilisation and legal reform are crucial requirements in this process, but ultimately the creation, approval and successful implementation of a solid land governance framework in Syria depends on political leadership and determination. 8References

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Verbatim quotefromtheEnglishtranslationofthedocument www.planning.gov.sy/files/file/FYPCh%2014HousinggEnglish.pdf

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ElLaithy,Heba&AbuIsmail,Khalid(2005)PovertyinSyria:19962004 DiagnosisandProPoorPolicyConsiderations,UNPDSyria. Fernandes, Edesio (2007) Urban Land Regularization Programs: State of Knowledge,inGarland,AllisonM.,Massoumi,Mejgan&Ruble,BlairA. (orgs) Global Urban Poverty: Setting the Agenda, Washington, D.C: WoodrowWilsonCenterforScholars/USAID.
th Government of Syria (2006) 10 Five Year Plan (20062010), Chapter 14, HousingSectorinSyria.

Kabbani,NaderS.,(2007)YouthExclusioninSyria:Social,Economic,and Institutional Dimensions, Middle East Youth Initiative Working Paper No. 4.(availableatSSRN: http://ssrn.com/abstract=1088037) Lavinal, Olivier (2008) The challenges of urban expansion in Syria: the issueofinformalhousing,in79Villesendeveloppement. McAuslan, Patrick (2006) On urban planning in Syria: an overview with suggestionsforreform,MAMProjectReport. Maziak,W.etal(2005)Mappingthehealthandenvironmentalsituationin informalzonesinAleppo,Syria:reportfromtheAleppohouseholdsurvey, in78Internationalarchivesofoccupationalandenvironmentalhealth. Wakely,Patrick (2008)InformalSettlementsinAleppo,GTZProject Report. Winckler,Onn(2000)DemographicDevelopmentsandPopulationPolicies inBathistSyriain32InternationalJournalofMiddleEastStudies.

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