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Second and Third Category facilities prepare a detailed environmental impact assessment (EIA) to obtain the Environmental Permit to Construct. First Category facilities prepare an environmental management plan (EMP) under Appendix O of Volume II. The EIA must be prepared by a consultant the Royal Commission has approved for that category, and its scope of work goes to the Royal Commission for approval before the study starts. For a major expansion after the EPO, Second and Third Category facilities submit an EIA, and First Category facilities do so case by case or if MEWA requires it.
Key terms used in this guide 12 terms
- EIA third party classes
- RC approves EIA consultants in three classes. Class A may conduct EIA studies for First, Second and Third Category facilities. Class B for First and Second Category facilities. Class C for First Category facilities only. RCER-2025 Vol. I, Glossary, page ix
- Environmental Emergency Response Plan (EERP)
- The general operational emergency response plan every facility prepares and submits, covering the issues in section 4.3 of Volume I, particularly clause 4.3.19, and following the guidelines in Volume II, Appendix D. RCER-2025 Vol. I, 1.1.10, page 3
- Environmental Permit to Construct (EPC)
- The Royal Commission permit an operator must obtain before starting any construction activity related to the process of a new facility. An existing facility also needs an EPC, decided case by case, for reconstruction, modification or expansion. RCER-2025 Vol. I, 1.2.1 and 1.2.2, page 5
- Environmental Permit to Operate (EPO)
- The Royal Commission permit without which a facility may not operate or carry out process commissioning. It is valid for five years from the date of issue. RCER-2025 Vol. I, 1.3.1 and 1.3.6, pages 5 and 6
- Environmental Screening Questionnaire (ESQ)
- The questionnaire every facility submits as part of the RC Industrial Site Allocation Request. RC reviews it to determine the category of the facility. RCER-2025 Vol. II, 1.3, page 3
- First Category facility
- A facility with negligible or no impact on public health or the environment during construction or operation. Typically support industries and commercial establishments. RCER-2025 Vol. I, Glossary, page xii
- Modification
- Any physical change to an existing facility, or change in its method of operation, that increases unit capacity or the pollution emitted to the atmosphere, or causes an impact on the environment that did not occur before. RCER-2025 Vol. I, Glossary, page x
- Modified facility
- A facility subject to a modification with production increases greater than 10 percent, a 10 percent increase in emissions or discharges, or new pollutants emitted or discharged. Clause 1.3.7 of Volume I words the production and emissions tests as 10 percent or more. RCER-2025 Vol. I, Glossary, page x
- Permit Application Package (PAP)
- The package of application forms facilities submit, with the ESQ, to obtain the EPC and EPO. Unless RC says otherwise, everything submitted in it is a condition of the EPO. RCER-2025 Vol. I, 1.1.7 and 1.3.4, pages 2 and 6
- Second Category facility
- A facility with potential for moderate impacts on public health or the environment during construction or operation. Typically secondary industries and some larger support industries. RCER-2025 Vol. I, Glossary, page xii
- Third Category facility
- A facility with significant potential for environmental harm, including permanent or irreversible damage to public health or the environment, during construction or operation. Typically primary industries and some larger secondary industries. RCER-2025 Vol. I, Glossary, page xii
- Third party
- A contractor selected on the basis of ability and absence of any conflict of interest. All environmental studies and field tests in RC cities, including EIA studies, stack and fugitive emission tests and baseline sampling, must be done by an RC approved independent third party. RCER-2025 Vol. I, Glossary, page xi, and 1.1.27, page 4
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How is the study decided?
Every facility submits the Environmental Screening Questionnaire (ESQ), which is part of the Royal Commission’s Industrial Site Allocation Request. The Royal Commission reviews it and sets the category of the facility.RCER-2025 Vol. II, 1.3, page 3
| First Category | Negligible or no impact on the environment at any time. Prepares an EMP under Appendix O. |
|---|---|
| Second Category | Potentially moderate impacts. Prepares an EIA report. |
| Third Category | The greatest potential for significant adverse impacts, including permanent and irreversible damage. Prepares an EIA report. |
Volume I says the same: Second and Third Category facilities prepare and submit an EIA, in addition to the PAP forms, to obtain an EPC.RCER-2025 Vol. I, 1.1.8, page 2
A health risk assessment may also be required case by case.RCER-2025 Vol. II, 1.3.1(ii), page 3
Table sourceRCER-2025 Vol. II, 1.2 and 1.3.1(i), pages 2 and 3
What does a Royal Commission EIA cover?
Appendix C of Volume II sets out a typical EIA format in 22 chapters. They run from the project description, air quality and modelling, groundwater, noise, waste, water quality and the marine environment to traffic, utilities, health and safety, alternatives, cumulative impacts, mitigation and an environmental management and monitoring plan.RCER-2025 Vol. II, Appendix C, pages C-4 to C-13
- The study area covers the community area and its surroundings, at least 30 km for a Second Category facility and 75 km for a Third Category facility.RCER-2025 Vol. II, Appendix C, page C-3
- Baseline weather and ambient air data for the parameters the Royal Commission monitors come from the Royal Commission only. At least five years of data are used where possible.RCER-2025 Vol. II, Appendix C, page C-5
- Appendix C recommends the latest AERMOD for domains under 50 km and the latest CALPUFF for longer ranges.RCER-2025 Vol. II, Appendix C, page C-5
- The increase from a new facility or major modification must stay below 25% of the available increment, which is the gap between the background level and the ambient air quality standard.RCER-2025 Vol. II, Appendix C, page C-7
- Ecology, socio-economic aspects and archaeology are required case by case. The marine chapter applies near the coast, with a direct discharge to sea, or where impacts are likely to be significant.RCER-2025 Vol. II, Appendix C, pages C-8 to C-10
- Considering alternative sites, layouts, processes and phasing of construction is mandatory. The “do nothing” option should also be assessed.RCER-2025 Vol. II, Appendix C, page C-11
What does a First Category EMP contain?
Appendix O is a short template. It asks for:RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
- A brief introduction to the project, such as the process and location.RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
- A site layout naming each area or unit.RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
- A table of construction activities with potential environmental impacts, the risk of each and the controls. The worked example is dust from site grading, controlled by regular water spraying.RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
- The same table for operational activities. The worked example is spillage onto the ground from a liquid chemical storage tank, controlled by secondary containment or a dip tray.RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
The EMP is submitted with the screening questionnaire, and the Royal Commission may ask for the applicable permit application forms as needed.RCER-2025 Vol. II, 1.3.1, First Category (i), page 4
Who may prepare the EIA?
The EIA is prepared by a “Third Party” consultant approved by the Royal Commission. A Third Party has no known conflict of interest and a team that has carried out several similar EIAs. For significant developments such as petrochemical complexes and refineries, the consultant needs significant experience with that type of facility.RCER-2025 Vol. I, 1.1.9, page 3
The facility appoints the consultant from the Royal Commission’s list of approved consultants. The approval has three classes:RCER-2025 Vol. II, Appendix C, page C-2
| Class A | EIA studies for First, Second and Third Category facilities |
|---|---|
| Class B | EIA studies for First and Second Category facilities |
| Class C | EIA studies for First Category facilities only |
Table sourceRCER-2025 Vol. II, Glossary, EIA 3rd Party, page vi
In what order does the work happen?
- Submit the EIA scope of work to the Royal Commission for approval before starting the EIA.RCER-2025 Vol. II, Appendix C, page C-3
- Consult the Royal Commission’s environmental department (RC-EPCD) on the scope before the EIA and modelling, and prepare the EIA and the PAP in parallel.RCER-2025 Vol. II, Appendix C, page C-3
- Submit the EIA and the PAP in hard and soft copy to obtain the EPC.RCER-2025 Vol. II, Appendix C, page C-3
- Build the EIA recommendations into the plant design, and carry any design changes into the final design.RCER-2025 Vol. II, 1.3.1, page 3
- For the EPO, submit the updated PAP with the previously submitted EIA and EERP. Update the EIA and EERP if the changes make the facility a modified facility under Volume I clause 1.3.7.RCER-2025 Vol. II, 1.3.2(i), page 4
What about an expansion after the EPO?
For a major expansion or significant change, Second and Third Category facilities submit an EIA. First Category facilities submit one case by case or if MEWA requires it. After the applications and EIA are approved, an EPC is issued for the modification work.RCER-2025 Vol. II, 1.7.1 and 1.7.2, page 5
What can go wrong?
- Starting the EIA before the Royal Commission approves the scope of work.RCER-2025 Vol. II, Appendix C, page C-3
- Fixing the design before the EIA results are in. Appendix C says the final design is determined once impacts and mitigation are assessed, not before.RCER-2025 Vol. II, Appendix C, page C-3
- Appointing a consultant whose approval class does not cover the facility’s category.RCER-2025 Vol. II, Glossary, EIA 3rd Party, page vi
We are approved by the Royal Commission for EIA, groundwater and noise studies, and prepare First Category EMPs.
References
Each small number in this guide shows the article or section that point comes from. Hover over or tap a number to see it, or open the full list below.
Show all 18 references and the 3 regulation texts
- RCER-2025 Vol. II, 1.3, page 3
- RCER-2025 Vol. II, 1.2 and 1.3.1(i), pages 2 and 3
- RCER-2025 Vol. I, 1.1.8, page 2
- RCER-2025 Vol. II, 1.3.1(ii), page 3
- RCER-2025 Vol. II, Appendix C, pages C-4 to C-13
- RCER-2025 Vol. II, Appendix C, page C-3
- RCER-2025 Vol. II, Appendix C, page C-5
- RCER-2025 Vol. II, Appendix C, page C-7
- RCER-2025 Vol. II, Appendix C, pages C-8 to C-10
- RCER-2025 Vol. II, Appendix C, page C-11
- RCER-2025 Vol. II, Appendix O, pages O-2 and O-3
- RCER-2025 Vol. II, 1.3.1, First Category (i), page 4
- RCER-2025 Vol. I, 1.1.9, page 3
- RCER-2025 Vol. II, Appendix C, page C-2
- RCER-2025 Vol. II, Glossary, EIA 3rd Party, page vi
- RCER-2025 Vol. II, 1.3.1, page 3
- RCER-2025 Vol. II, 1.3.2(i), page 4
- RCER-2025 Vol. II, 1.7.1 and 1.7.2, page 5
How to read these references 2 texts cited
- RCER-2025 Vol. I, 1.3.6, page 6 means Volume I, clause 1.3.6, on printed page 6. All three volumes define a day as a working day.
- First, Second and Third are the numbered parts some articles are divided into. The Arabic texts write them أولاً، ثانياً، ثالثاً (meaning first, second, third).
The three RCER-2025 volumes are listed in the Royal Commission library.
Regulation texts this guide is written from
- Royal Commission Environmental Regulations 2025, Volume I, Regulations and Standards
- Royal Commission Environmental Regulations 2025, Volume II, Environmental Permits and Licenses Program
- Royal Commission Environmental Regulations 2025, Volume III, Penalty System and Service Charges
This guide is general information written from the regulation texts listed above. It is not legal advice. Regulations change, and the official text always prevails. Spotted something out of date? Request a change.