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When should we apply for the Royal Commission permit to operate?

The 60 working day deadline for the EPO, what goes with the application, and the notices before and after start-up.

Royal Commission rules. 3 min read.

Short answer

Apply for the Environmental Permit to Operate (EPO) at least 60 days before the planned start of operations or the expected completion of construction. RCER-2025 counts days as working days. The application is an updated permit application package that highlights any changes, with the previously submitted EIA and EERP. Notify the Royal Commission when process construction is 30 days from completion, and give at least 30 days’ notice of start-up. Start-up is not allowed until the EPO is issued. After that, the facility sends monthly start-up updates and a formal notice within 7 days of start-up.

Key terms used in this guide 9 terms
Day
Refers to a working day. 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
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
Process commissioning
The start-up of a plant or unit after it has been designed and installed as per the EPC conditions. It can apply to new projects and to existing units being expanded, renovated or revamped. RCER-2025 Vol. I, Glossary, page xi
Process construction
Construction in process areas. It excludes geotechnical surveys, installation of fencing and construction of non-process facilities. RCER-2025 Vol. I, Glossary, page xi
Reconstructed facility
A facility that is dismantled, damaged or destroyed and intentionally rebuilt to the original design, in the same or a different location. RCER-2025 Vol. I, Glossary, page xi

All 50 terms in the Royal Commission glossary

On this page
  1. What is the deadline?
  2. What goes with the application?
  3. What happens before the EPO is issued?
  4. What do you report after the EPO is issued?
  5. What are the fines?
  6. What can go wrong?

What is the deadline?

Apply at least 60 days before the planned date of starting operations and/or the expected date of construction completion.RCER-2025 Vol. II, 1.3.2(i), page 4

RCER-2025 defines a day as a working day, so the 60 days are working days.RCER-2025 Vol. II, Glossary, Day, page vi

On a Sunday to Thursday week, 60 working days is about 12 calendar weeks, plus any public holidays in that period. The deadline calculator in this library works out the date from your planned start.

What goes with the application?

  • An updated permit application package, highlighting the changes, if any.RCER-2025 Vol. II, 1.3.2(i), page 4
  • The previously submitted EIA and EERP.RCER-2025 Vol. II, 1.3.2(i), page 4
  • An updated EIA and EERP if the changes make the facility a modified facility.RCER-2025 Vol. II, 1.3.2(i), page 4
  • A facility is modified when production rises 10% or more above the approved value, emissions or discharges rise 10% or more, or new pollutants are emitted or discharged.RCER-2025 Vol. I, 1.3.7, page 6

What happens before the EPO is issued?

  • Notify the Royal Commission when process construction is approaching 30 days to final completion. Missing this notice attracts a fine under Volume III.RCER-2025 Vol. I, 1.2.6, page 5
  • Give the Royal Commission at least 30 days’ advance notice of the start-up of a new or modified facility.RCER-2025 Vol. I, 9.2.1, page 114
  • The Royal Commission inspects the site to confirm that construction is complete, the facility is ready and the EPC conditions are met.RCER-2025 Vol. II, 1.3.2(ii), page 4
  • For a new facility, the EPO is issued only if all EPC conditions are complied with.RCER-2025 Vol. I, 1.3.1, pages 5 and 6
  • Start-up operations are not allowed until the Royal Commission issues the EPO.RCER-2025 Vol. II, 1.3.2(iii), page 4
  • The EPC expires automatically one day before the EPO takes effect.RCER-2025 Vol. II, 1.3.1(vii), page 4

What do you report after the EPO is issued?

  • Monthly updates on the facility’s start-up, and a formal notification within 7 days of start-up.RCER-2025 Vol. I, 1.3.1, pages 5 and 6
  • Monitoring of emissions or waste streams, reported as the permit and RCER require. The Royal Commission may check the data with its own sampling.RCER-2025 Vol. II, 1.3.2(v), page 4
  • The EPO is issued for five years.RCER-2025 Vol. II, 1.3.2(vii), page 4
  • The renewal form is due six months before the EPO expires.RCER-2025 Vol. II, 1.6.1, page 5

What are the fines?

Table 3.1 of Volume III gives a range for each clause:RCER-2025 Vol. III, Table 3.1, page 5

Clause 1.2.6, notice 30 days before construction completion10,000 to 40,000 riyals
Clause 1.3.1, operating or commissioning without a valid EPO5,000 to 50,000 riyals, monthly
Clause 1.3.2, operating a modified or reconstructed facility without an amended or new EPO5,000 to 50,000 riyals, monthly

The Royal Commission assesses each fine from the range for the clause and the violation class it decides.RCER-2025 Vol. III, 3.1, page 3

Table sourceRCER-2025 Vol. III, Table 3.1, page 5

What can go wrong?

What can go wrong
  • Counting 60 calendar days instead of 60 working days.RCER-2025 Vol. II, Glossary, Day, page vi
  • Commissioning before the EPO arrives. Volume I prohibits both operation and process commissioning without a valid EPO.RCER-2025 Vol. I, 1.3.1, pages 5 and 6
  • Leaving EPC conditions open. The pre-EPO inspection checks them.RCER-2025 Vol. II, 1.3.2(ii), page 4
Planning your start-up date?

We prepare the updated PAP, the EIA and EERP updates and the start-up notices for the EPO.

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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 14 references and the 3 regulation texts
  1. RCER-2025 Vol. II, 1.3.2(i), page 4
  2. RCER-2025 Vol. II, Glossary, Day, page vi
  3. RCER-2025 Vol. I, 1.3.7, page 6
  4. RCER-2025 Vol. I, 1.2.6, page 5
  5. RCER-2025 Vol. I, 9.2.1, page 114
  6. RCER-2025 Vol. II, 1.3.2(ii), page 4
  7. RCER-2025 Vol. I, 1.3.1, pages 5 and 6
  8. RCER-2025 Vol. II, 1.3.2(iii), page 4
  9. RCER-2025 Vol. II, 1.3.1(vii), page 4
  10. RCER-2025 Vol. II, 1.3.2(v), page 4
  11. RCER-2025 Vol. II, 1.3.2(vii), page 4
  12. RCER-2025 Vol. II, 1.6.1, page 5
  13. RCER-2025 Vol. III, Table 3.1, page 5
  14. RCER-2025 Vol. III, 3.1, page 3
How to read these references 3 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.

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.