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What goes in a Royal Commission permit application package?

The forms, the supporting plans and the signed certification the Royal Commission expects in a PAP, how to prepare it and when it is due.

Royal Commission rules. 4 min read.

Short answer

The permit application package (PAP) is form PA-G1 plus whichever of the other 23 forms in Figure 2 of RCER-2025 Volume II match the facility’s activities. It is submitted printed and in electronic form, in the order of Figure 2, with every question answered or marked “None” or “NA”, and with the Statement of Certification signed and stamped by an authorised representative. An Environmental Emergency Response Plan prepared under Appendix D goes with it. Second and Third Category facilities also prepare an EIA. First Category facilities submit an environmental management plan, and the Royal Commission may ask them for the applicable forms as needed.

Key terms used in this guide 12 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
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
Fugitive emission
Any gaseous or particulate contaminant entering the atmosphere that could not reasonably pass through a stack, chimney, vent or other functionally equivalent opening designed to direct or control its flow. RCER-2025 Vol. I, Glossary, page ix
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
Point source
An individual air emission or pollutant source originating from a specific location. RCER-2025 Vol. I, Glossary, page x
Sanitary wastewater
Water from urban use, defined as the effluent from using potable water for normal domestic purposes such as washing, cooking, cleaning, personal hygiene, sanitation and preparing food. RCER-2025 Vol. I, Glossary, page xi
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
Variance stream
A non-cooling water discharge to the seawater cooling system, meaning any water other than once-through cooling water. RCER-2025 Vol. I, Glossary, page xii

All 50 terms in the Royal Commission glossary

On this page
  1. Which forms make up the package?
  2. How must the package be prepared?
  3. What goes with the forms?
  4. What does the Statement of Certification commit you to?
  5. When is the package due?
  6. What can go wrong?

Which forms make up the package?

Figure 2 of Volume II lists the whole package. PA-G1 is the general application for industrial facilities. Each of the other forms covers one activity:RCER-2025 Vol. II, 2.1 and Figure 2, pages 8 to 10

PA-G1Permit application for industrial facilities (general)
PA-A1 to A6Air: boilers and furnaces burning fossil fuel, boilers and industrial furnaces burning hazardous materials or non-fossil fuels, hazardous or medical waste incinerators and thermal oxidizers, flares, other point sources, fugitive emissions from sources other than storage tanks
PA-W1 to W9Water: discharge to a sanitary wastewater treatment facility, treated sanitary wastewater to the Red Sea, industrial wastewater to an industrial wastewater network, treated industrial wastewater to the Red Sea, non-contact cooling water, brine and variance streams, cooling towers, storm water and surface run-off, ballast water, construction of groundwater monitoring wells
PA-H1 to H3Handling and storage of hazardous materials, waste management, transport of hazardous and non-hazardous industrial wastes and hazardous substances
PA-M1 to M4Loading and unloading, dredging, noise sources, exemptions
PA-R1EPO renewal

Each form has its own page in this library, with what it covers and the documents it asks for. The forms checker suggests which forms are likely to apply to your facility.

Table sourceRCER-2025 Vol. II, Figure 2, pages 9 and 10

How must the package be prepared?

  • Answer every question. If a question does not apply, write “None” or “NA”.RCER-2025 Vol. II, 2.1(b), page 8
  • An authorised representative of the facility signs and stamps the Statement of Certification.RCER-2025 Vol. II, 2.1(c), page 8
  • Submit the package in electronic form and in printed form. The printed copy carries the authorised representative’s signature. The regulation names a compact disc for the electronic copy.RCER-2025 Vol. II, 2.1(d), page 8
  • Put the forms in the same order as Figure 2.RCER-2025 Vol. II, 2.1(e), page 8
  • Submit drawings and related documents as A3 hard copies and as PDF soft copies only. Make each attachment clearly identifiable, and highlight the related information on the drawings.RCER-2025 Vol. II, 1.3.1, page 3
  • Provide all the relevant engineering data for the proposed technology.RCER-2025 Vol. II, 1.3.1, page 3

An electronic copy of the forms can be obtained from the Royal Commission.RCER-2025 Vol. II, 2.1(d), page 8

What goes with the forms?

  • An Environmental Emergency Response Plan (EERP) prepared under the guidelines in Appendix D. It covers hazardous material management, hazardous waste management, loading and unloading operations and other potential emergencies.RCER-2025 Vol. II, 2.1(f), page 8
  • Second and Third Category facilities: a detailed environmental impact assessment (EIA) report.RCER-2025 Vol. II, 1.3.1(i), page 3
  • First Category facilities: an environmental management plan (EMP) prepared under Appendix O.RCER-2025 Vol. II, 1.3.1(i), page 3
  • A health risk assessment, where the Royal Commission asks for one case by case.RCER-2025 Vol. II, 1.3.1(ii), page 3

First Category facilities submit the EMP with the Environmental Screening Questionnaire, and the Royal Commission may ask them to complete the applicable forms as needed.RCER-2025 Vol. II, 1.3.1, First Category (i), page 4

Appendix C asks for the EIA and the PAP to be prepared in parallel, because each depends on the other.RCER-2025 Vol. II, Appendix C, page C-3

What does the Statement of Certification commit you to?

The signatory declares familiarity with all processes and operating plans of the facility and certifies that the environmental information is accurate. The statement records that incorrect information is a highly serious issue that could lead to withdrawal of any permit issued and to penalties. It also commits the facility to notify the Royal Commission of any changes and to comply with RCER.RCER-2025 Vol. II, 2.2, page 11

When is the package due?

  • Start preparing the PAP and the screening questionnaire, and the EIA if required, immediately after signing the Conditional Site Allocation.RCER-2025 Vol. I, 1.2.4, page 5
  • Submit the PAP for the Environmental Permit to Construct (EPC) at least six months before starting any construction activity related to the process.RCER-2025 Vol. I, 1.2.4, page 5
  • For the Environmental Permit to Operate (EPO), submit an updated PAP that highlights any changes, with the previously submitted EIA and EERP, at least 60 days before operations start or construction is due to finish.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
  • Table 3.1 of Volume III gives a penalty range of 10,000 to 40,000 riyals for clause 1.2.4, the six month PAP deadline.RCER-2025 Vol. III, Table 3.1, page 5

What can go wrong?

What can go wrong
  • Changing technology or a technology supplier without telling the Royal Commission. The PAP must be updated when this happens.RCER-2025 Vol. II, 1.3.1(viii), page 4
  • Leaving fields blank. The instructions ask for every space to be completed.RCER-2025 Vol. II, 2.1(b), page 8
  • Building something the package does not describe. The EPC authorises only the facilities described in the PAP and screening questionnaire.RCER-2025 Vol. I, 1.2.5, page 5
  • Treating the package as paperwork only. Unless the Royal Commission says otherwise, everything in the PAP becomes a condition of the EPO.RCER-2025 Vol. I, 1.3.4, page 6
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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 20 references and the 3 regulation texts
  1. RCER-2025 Vol. II, 2.1 and Figure 2, pages 8 to 10
  2. RCER-2025 Vol. II, Figure 2, pages 9 and 10
  3. RCER-2025 Vol. II, 2.1(b), page 8
  4. RCER-2025 Vol. II, 2.1(c), page 8
  5. RCER-2025 Vol. II, 2.1(d), page 8
  6. RCER-2025 Vol. II, 2.1(e), page 8
  7. RCER-2025 Vol. II, 1.3.1, page 3
  8. RCER-2025 Vol. II, 2.1(f), page 8
  9. RCER-2025 Vol. II, 1.3.1(i), page 3
  10. RCER-2025 Vol. II, 1.3.1(ii), page 3
  11. RCER-2025 Vol. II, 1.3.1, First Category (i), page 4
  12. RCER-2025 Vol. II, Appendix C, page C-3
  13. RCER-2025 Vol. II, 2.2, page 11
  14. RCER-2025 Vol. I, 1.2.4, page 5
  15. RCER-2025 Vol. II, 1.3.2(i), page 4
  16. RCER-2025 Vol. II, Glossary, Day, page vi
  17. RCER-2025 Vol. III, Table 3.1, page 5
  18. RCER-2025 Vol. II, 1.3.1(viii), page 4
  19. RCER-2025 Vol. I, 1.2.5, page 5
  20. RCER-2025 Vol. I, 1.3.4, page 6
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.
  • 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.