A landfill that has reached the end of its use, or was poorly managed, does not stop affecting the environment when it closes: gases form inside it, leachate can reach soil and groundwater, and the land cannot be used safely. Landfill rehabilitation therefore needs a well-studied plan approved by the National Center for Environmental Compliance (NCEC) before implementation, and monitoring that proves the site is stable afterwards. This article explains the legal framework for landfill rehabilitation, the elements of the plan and the implementation obligations.

The legal framework

  • Waste Management Law: defines waste management as including safe disposal "including after-care of waste disposal sites", and defines safe disposal as engineered storage or disposal that prevents pollution of soil, air and water, including engineered landfills. Landfills and final disposal sites are regulated by the National Center for Waste Management (MWAN) and require its license.
  • Regulation for Environmental Rehabilitation of Degraded Sites and Remediation of Contaminated Sites: applies to all degraded or contaminated sites in the Kingdom, and defines rehabilitation as any action on an environmentally degraded or damaged site to restore it to its natural environmental balance according to the standards set by the competent authority.
  • Regulation for Preventing and Treating Soil Pollution: sets soil protection standards above which a site is considered contaminated, and requires immediate notification of NCEC when soil contamination is detected.

NCEC's role

The Rehabilitation Regulation sets NCEC's tasks, including: setting the conditions for preparing and implementing rehabilitation and remediation plans, issuing a list of licensed providers to prepare and implement them, reviewing plans and issuing decisions, identifying degraded and contaminated sites and the extent of pollution and remediation requirements, maintaining a database of these sites, and coordinating with supervising authorities to oblige polluters to prepare and implement rehabilitation plans.

Common elements of a landfill rehabilitation plan

The plan depends on the site condition and the type of buried waste, and the regulation's annex sets its structure. Common elements include:

  1. Site assessment: boundaries and depth of the landfill, waste type, soil and groundwater condition and surrounding sensitive receptors.
  2. Gas management: monitoring and controlling landfill gas emissions.
  3. Leachate management: preventing it from reaching soil and groundwater, collecting and treating it.
  4. Final capping: reshaping the surface and managing stormwater drainage.
  5. Contaminated soil remediation where present, according to the soil regulation's standards.
  6. A post-rehabilitation monitoring program proving the site is stable, which is the essence of "after-care" in the Waste Management Law.
  7. Future land use compatible with its condition after rehabilitation.

Preparing and approving the plan

Rehabilitation and contaminated site remediation plans are prepared by a licensed service provider; in exceptional cases NCEC may accept plans from highly experienced bodies it approves. NCEC reviews the plan and may inspect the site to match it with reality. On approval, the submitter undertakes to implement it as specified.

Implementation obligations

  • Implement the approved plan and obtain NCEC approval for any change.
  • Submit periodic progress reports as set in the approval decision, documented with photographs, analysis results and an updated schedule.
  • Notify NCEC immediately of any incident during rehabilitation.
  • Allow NCEC to inspect the site and carry out tests and measurements.
  • Update the plan when preparing an environmental audit, after an incident or at NCEC's request.

Liability and compensation

The regulation requires anyone who caused degradation or pollution to stop its source, remove it and rehabilitate the site, and to bear compensation under the polluter-pays principle. The regulation includes a table of violations and penalties, amended by a ministerial decision published in Umm Al-Qura in 2024; violation types include starting implementation without NCEC approval, refusing to implement the plan, submitting incorrect information in it, failing to report incidents, and failing to update the plan when notified. The violator is usually required to correct the violation, repair the damage and pay compensation.

The key lesson

Do not start any rehabilitation works before NCEC approves the plan, even if the works are technically correct. Data accuracy in the plan is not a formality: submitting incorrect information is a separate violation.

Frequently Asked Questions about Landfill Rehabilitation

Who approves the landfill rehabilitation plan?

NCEC, under the Implementing Regulation for Environmental Rehabilitation of Degraded Sites and Remediation of Contaminated Sites.

Can works start before the plan is submitted?

No. Implementation follows a plan approved by NCEC, and starting without approval is one of the violations in the regulation's table.

What is MWAN's role in landfills?

MWAN regulates waste management activities, including safe disposal and after-care of disposal sites, which require its license.

Can the landfill land be used after rehabilitation?

That depends on the site's condition after rehabilitation and the monitoring results; the appropriate use is set in the plan.

How Abak Green helps

We assess the site, prepare the landfill rehabilitation or contaminated site remediation plan with accurate data, follow NCEC's approval, follow implementation and periodic reporting, and update the plan when needed. Contact us about the site.

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