ENVIRONMENTAL PROCEDURES

ENVIRONMENTAL MANAGEMENT OF CHANGE

NEOM-NEV-PRC-702 Rev 01.00, November 2021

©NEOM [2021]. All rights reserved.

Document history

Revision code Description of changes Purpose of issue Date

Issued for
Rev 01.00 First Issue 14.11.2021
implementation

Document approval

Prepared by Reviewed by Approved by

Name Noel Woods Bevan Van Bloomestein Damien Trinder

Job Title Senior Manager Senior Assurance Specialist (Acting) Chief Environmental
Environmental Officer
Assurance

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Contents
1. INTRODUCTION ................................................................................................................... 4
2. PURPOSE ............................................................................................................................. 4
3. SCOPE .................................................................................................................................. 4
4. DEFINITIONS AND ABBREVIATIONS ................................................................................ 4
5. ROLES AND RESPONSIBILITIES ...................................................................................... 6
6. PROCEDURE ....................................................................................................................... 6
6.1 Events triggering Changes .................................................................................................... 6
6.2 Change Process .................................................................................................................... 6
Communication of Changes .................................................................................................. 6
Change Event Evaluation...................................................................................................... 7
Revision of Control Measures ............................................................................................... 7
Implementation ...................................................................................................................... 7
7. RELATED DOCUMENTS ..................................................................................................... 8
APPENDIX A: MANAGEMENT OF CHANGE PROCEDURE FLOWCHART ...................................... 9
APPENDIX B: MANAGEMENT OF CHANGE (MOC) REQUEST FORM ........................................... 11

List of Tables
Table 6.1-1: Abbreviations ...................................................................................................................... 4
Table 6.1-2: Definitions .......................................................................................................................... 5

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1 Introduction
Contractors, over the course of a project, may need to change some aspect of project delivery.
Changes to project delivery may result in environmental impacts that are unforeseen and/or were not
included in the initial assessment. Such changes may affect compliance obligations, controls and
conditions detailed in the relevant Environmental Accord and Management Plans for the project. This
procedure describes:

• the process by which project changes are triggered of change are identified
• The processes by which change is communicated to NEV for assessment
• the mechanism by which proposed project changes are assessed.

2 Purpose
The purpose of this procedure is to describe the means by which Contractors and other Project
Entities ensure that changes to project execution plans are assessed.
The objectives of this procedure are:
1. To describe the types of events that may trigger a change that may affect the management of
environmental risks;
2. To describe how these changes are notified to Employer and NEV; and
3. To describe the actions that may be taken by Employer and subsequent requirements to be
implemented by Contractor.

3 Scope
This procedure applies to all site activities, facilities and construction methodologies that deviate from
those originally presented at the ENVID Workshop and detailed in the relevant Environmental Accord
/ Permit.

4 Definitions and Abbreviations

Table 6.1-1: Abbreviations

Abbreviation Explanation

CESMP Construction Environment & Social Management Plan

ENVID Environmental [& Social] Hazard Identification

ESIA Environmental & Social Impact Assessment

ESMP Environmental and Social Management Plan

PEC / PMC Project Environmental Consultants / Project Management Consultant

NEV NEOM Environment Department

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Table 6.1-2: Definitions

Term Definition

Change Material difference in activity on a Project / Contract site that may cause
stressors to have negative impacts on environmental receptors
Environment NEOM regulatory agency tasked with the delivery of environmental protection
Department and sustainable land use and development.

Event Circumstances that lead to a change such as change orders or contract

amendments that result in changes to scope of works, or changes to the
construction method for example use of difference plant or machinery
Identifier The individual who first identifies a project, contract, or environmental change
event
Project Specialized Environmental Consultant selected from NEOM’s Environmental
Environmental Services Framework and engaged by the Proponent to independently review
Consultants and advise the development process and develop and implement
environmental and social risk management documentation and programs
through to the end of Construction

Project Engineering contractor who oversees the Contractors works to ensure

Management compliance with NEOM scope of works.
Consultants
Employer The Employer is a NEOM entity or a Project Management Consultant (PMC)
designated by NEOM to be responsible for the planning, designing,
constructing, or managing and operating a particular asset or a group of assets.
Receptor A component of the natural or built environment (such as a human being, water,
air, a building, or a species) affected by an impact of the construction and/or
operation of a proposed development.
Stressor A factor that causes stress to the Environment in the following four categories,
with examples shown below: Resource Consumption; Interaction with the
Environment; Pollution; and Elements with Toxifying properties.

Consumption Interaction Pollution Toxifying

Human
Mineral Presence Greenhouse GasesChemical
(Consumption) (Interaction) (Pollution) (Toxifying)
Biological Invasive species Plastics Pathogenic
(Consumption) (Interaction) (Pollution) (Toxifying)
Groundwater Mechanical Dust/Particulates Radioelement
(Consumption) (Interaction) (Pollution) (Toxifying)
Supplied water Soil Erosion Nutrient
(Consumption) (Interaction) Noise (Pollution) (Toxifying)
Seawater Sedimentation Vibration
(Consumption) (Interaction) (Pollution)
Suspended
Land Sediment Light/Shade
(Consumption) (Interaction) (Pollution)
Hydrocarbons Structures Heat/Cool
(Consumption) (Interaction) (Pollution)
Supplied power
(Consumption) Odour (Pollution)

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5 Roles and Responsibilities
1. Contractor
a. Contractor shall ensure that all site activities, facilities, and construction methodologies that
deviate from those originally presented at the ENVID Workshop and detailed in the
Environmental Accord is brought to the attention of the Proponent and PEC/PMC.
2. Employer
a. Employer shall ensure that all changes are assessed for feasibility.
b. Employer shall ensure that NEV is informed of proposed changes to project execution that
deviate from those originally presented at the ENVID Workshop and detailed in the
Environmental Accord.
3. NEOM Environment
a. NEOM Environment shall review the proposed changes and, where acceptable, apply to
update the applicable Environmental Accords / Permits.

6 Procedure

6.1 Events triggering Changes

The following are non-exhaustive examples of events that may trigger changes in project delivery.

1. Construction method change - Alternative construction method to be implemented (e.g., blasting

instead of tunnelling) – such change events may present different risks that require risk
management measures to be amended, decreased, or increased.
2. Change in location / temporary facilities / access roads – changes in planning of construction
temporary support facilities or service may present different risks to local receptors as the increased
intensity of operation or new routing /siting may impact previously unaffected or marginally affected
receptors.
3. Contractual change orders – Scope changes may present new / additional environmental risks
which has not been previously considered during the environmental assessment / approval process
which includes relevant change in law, regulation, or standards. In such cases, change orders may
trigger a re-assessment by NEV to see if any extra controls measures are required due to new
activities or locations.
4. Contract extensions – these may affect the duration of environmental impacts or may affect the
schedule or scope of any environmental rehabilitation schemes.
5. Introduction of a new neighbouring receptor – if a new sensitive receptor such as Wildlife Reserve
or a school is newly placed or designated within a significant distance of a Project, the Proponent
may need to assess the risks to the environment and potentially require amended or expanded
Control Measures.
6. Introduction of a new neighbouring stressor – if a new stressor is introduced next to a project, an
assessment may be necessary to protect environmental assets within a project boundary, which in
turn may require amended control measures.

6.2 Change Process

Communication of Changes

Although it is the responsibility of the Contractor to recognize changes and to ensure that they are
communicated, the ultimate responsibility remains with the Employer to ensure NEV is informed about
all Project changes. The following table details required communication alert mechanisms.

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1. Upon recognizing a change, the Contractor shall complete a Management of Change (MOC)
notification form using NEOM-NEV-PRC-702_FRM01 NEOM Environment Management of Change
(MOC) Request Form.
2. The Initiator should be the person most familiar with the proposed change (i.e., Expert on the
change). The initiator communicates a proposed change by completing Part A of the MOC Request
Form which shall include the following details:
a. Change Description
b. Change Reason
c. Change Category
d. Proposed Action
3. Contractor shall ensure that, attached to the MOC Request Form, are supporting documentation
which may include but are not limited to the following:
a. Photographs
b. Engineering Drawings / Sketches which depict proposed change
c. Reports
d. LUP / boundary coordinates of proposed change
e. Method Statements
f. Correspondence supporting the MOC request (e.g., Employer or authority correspondence)
4. Contractor shall formally submit the completed MOC Request Form with supporting documentation
to NEV for evaluation.

Change Event Evaluation

1. NEV shall assign a MOC Reviewer according to the scope of the change. The reviewer shall review
the proposed MOC request and associated supporting documentation and determine if the
proposed change is either acceptable, rejected or triggers a risk assessment process.
2. NEV shall formally communicate to Contractor the outcome of the MOC Review process.
3. If further risk assessment is required by the change event, NEV shall carry out collaborative Risk
Assessment with the Employer and Contractor to an appropriate level of complexity depending on
the level of risk presented by the Change, this could comprise a targeted Environmental Risk
Identification (ENVID) Workshop if deemed necessary.

Revision of Control Measures

1. The output of the targeted Risk Assessment may include the need for revised, reduced, enhanced
environmental control measures & environmental monitoring requirements.
2. NEV shall provide a formal notification of the review outcome of the targeted Risk Assessment
process.
3. The outcomes of the targeted Risk Assessment process may lead to:
a. Requirement for a revised Environmental Accord.
b. Requirement for a revised CESMP incorporating any additional Control Measures and
monitoring measures from the targeted Risk Assessment process.
c. Issuance of an addendum to the existing Environmental Accord; or
d. No change letter which shall be issued by NEOM Environment Assessment.

Implementation

1. Following approval of the MOC request the Contractor shall implement the proposed change.
2. If the change request triggered a targeted Risk Assessment process, the Contractor shall
implement any revised / additional risk management measures and controls recommended through
the risk assessment process.
3. To ensure ongoing compliance with the new control measures:
a. The Contractor must circulate the revised approval documentation (e.g., CESMP, revised
Accord, Accord Addendums, etc.) highlighting any new control measures.
b. The Contractor must implement the control measures and carry out any related required
environmental monitoring.
4. Employer shall monitor the effectiveness of the implementation of control measures and report on
and manage the environmental performance of the Project.

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7 Related Documents
1. Contractor ENVID
2. Contractor Environmental Accord

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 Appendix A: Management of Change Procedure Flowchart

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 Appendix B: Management of Change (MOC) Request Form

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 NEOM Environment
Management of Change (MOC) Request Form
PART A: To be completed by CONTRACTOR
SECTION 1 - PROJECT DETAILS (To be completed by Initiator)
Project Name MOC Number

Contractor Name: MOC Initiator

NEOM Region MOC Intiaton Date

Environmental Permit no.

SECTION 2 - MOC DESCRIPTION AND CLASSIFICATION (To be completed by Initiator)

Change Description:

Change Reason:

Construction Method Change Contract Change Order New Receptor Other Change Event or Trigger (Specify):
Change Category (Mark all that
apply): Change in Location, Facilities or
Contract Extension New Stressor
Access

Proposed Action:

SECTION 3 - MOC SUPPORTING DOCUMENTS (To be completed by Initiator)

Photographs Reports Method Statements Other (Specify):

Supporting Documents Attached
(Check all that apply):
Engineering Drawings /
LUP (coordinates) Correspondence (Proponent, Authorities, etc.)
Sketches

PART B: To be completed by NEV

SECTION 4 - MOC APPROVAL STATUS (To be completed by NEV)

Change Reviewed: Yes No Review Completion Date:

Approval Satus: Approved Rejected Approved with comments Assessment Required

Comments:

MOC Reviewer Name: MOC Approver Name:

Signature Signature:

Date Date

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