This EIA Study has focused on the
assessment and mitigation of the potential impacts associated with the
construction and operation of the Project.
One of the key outputs has been the identification of mitigation
measures to be undertaken in order to ensure that residual impacts comply with regulatory
requirements plus the requirements of the EIAO TM. To ensure effective and timely
implementation of the mitigation measures, it is considered necessary to
develop Environmental Monitoring and Audit (EM&A) procedures and mechanisms
by which the Implementation Schedule (Annex
17) may be tracked and its effectiveness assessed.
17.1.1
Implementation of EIA Findings and
Recommendations
Sections
4 to
14 have, where appropriate,
identified and recommended the implementation of mitigation measures to reduce
the potential construction and operational impacts of the Project. These findings and recommendations form
the primary deliverable from the whole EIA process. Once endorsed by the EPD, they will form
an agreement between CAPCO and the Government as to the measures and standards
that are to be achieved. It is
therefore essential that mechanisms are put in place to ensure that the
mitigation measures prescribed in the Implementation Schedule are fully and
effectively implemented during construction.
The required format for the Implementation
Schedule (Annex 17) is specified in
the EIA Study Brief. The format
requires the specification of implementation agent(s), timing, duration and
location for each of the recommended mitigation measures. Apart from the mitigation measures
identified in the EIA, there are also procedures for other requirements to be
included within the finalised Implementation Schedule. Prior to the issue of an Environmental
Permit, there is an EIA Determination Period. During this period the EIA Report is
reviewed and commented upon by both the public and professional bodies. Where recommendations are made and accepted
by either the Advisory Council on the Environment (ACE) or its EIA
subcommittee, these measures will be included within the Implementation
Schedule, where appropriate.
17.1.2
Statutory Requirements
As the Project constitutes a Designated
Project under the EIAO, an
Environmental Permit must be obtained before construction or operation of the LNG
terminal and associated facilities.
Upon approval of the EIA Report, CAPCO can
apply for an Environmental Permit.
If the application is successful, the Environmental Permit may, have
conditions attached to it, which must be complied with. In addition, CAPCO and its appointed
Contractor(s) must also comply with other controlling environmental legislation
and guidelines, which are discussed within the specific technical chapters of
this report.
17.2
Environmental
Management Plan
CAPCO’s construction Contractors will be
contractually bound to produce and implement an Environmental Management Plan
(EMP). EMP’s
are similar in nature to safety or quality plans and provide details of the
means by which the Contractor (and all subcontractors working for the Contractor)
will implement the recommended mitigation measures and achieve the
environmental performance standards defined both in
To evaluate a contractor’s commitment,
each contract bidder shall be required to produce a preliminary EMP as part of
the tendering process. The skeletal
EMP will indicate the determination and commitment of the contractor and
indicate how the contractor intends to meet the environmental performance requirements
laid out in the EIA. Upon Contract
Award, the successful bidder(s) will be required to submit a draft and final
version of the EMP for approval by CAPCO prior to the commencement of the work.
The EPD requires the submittal for
approval of an EM&A Manual prior to the commencement of construction. The EM&A Manual defines the
mechanisms for implementing the EM&A requirements specific to each phase of
the work. The EM&A Manual provides
a description of the organisational arrangements and resources required for the
EM&A programme based on the conclusions and recommendations of this
EIA. The EM&A Manual stipulates
details of the construction monitoring required and actions that shall be taken
in the event of exceedances of the environmental
criteria. In effect, the EM&A
Manual forms a handbook for the on-going environmental management during
construction.
The EM&A Manual comprises descriptions
of the key elements of the EM&A programme including:
·
Appropriate
background information on the construction of the Project with reference to
relevant technical reports;
·
Organisational
arrangements, hierarchy and responsibilities with regard to the management of
environmental performance during the construction phase. The EM&A team, the
Contractor(s) team and the CAPCO’s representatives
are included;
·
A
broad construction programme indicating those activities for which specific
mitigation is required and providing a schedule for their timely
implementation;
·
Descriptions
of the parameters to be monitored and criteria through which performance will
be assessed including: monitoring frequency and methodology, monitoring
locations (typically, the location of sensitive receivers as listed in the
EIA), monitoring equipment lists, event contingency plans for exceedances of established criteria and schedule of
mitigation and best practice methods for reduced adverse environmental impacts;
·
Procedures
for undertaking on-site environmental performance audits as a means of ensuring
compliance with environmental criteria; and
·
Reporting
procedures.
The EM&A Manual will be a dynamic
document which will undergo a series of revisions, as needed, to accommodate
the progression of the construction programme.
17.3.1
Objectives of EM&A
The objectives of carrying out EM&A
for the Project include:
·
Providing
baseline information against which any short or long term environmental impacts
of the projects can be determined;
·
Providing
an early indication should any of the environmental control measures or
practices fail to achieve the acceptable standards;
·
Monitoring
the performance of the Project and the effectiveness of mitigation measures;
·
Verifying
the environmental impacts identified in the EIA;
·
Determining
Project compliance with regulatory requirements, standards and government
policies;
·
Taking
remedial action if unexpected results or unacceptable impacts arise; and
·
Providing
data to enable an environmental audit to be undertaken at regular intervals.
The following sections summarise the
recommended EM&A requirements and further details are provided in the EM&A
Manual.
The EIA study concluded that no air
sensitive receivers (ASRs) will be affected by construction dust through the
implementation of mitigation measures to reduce dust levels. During the operational phase, emissions
will be controlled by integrated measures, regular inspections and relevant
emissions licenses. Emissions from
construction or operation phase are not predicted to yield concentrations that
would lead to significant air quality impacts at the ASRs. Therefore, no air quality monitoring
will be required for either, aside from that required by specific emissions
licenses.
Regular site inspections will be carried
out during the construction phase in order to ensure that the mitigation
measures are implemented and are working effectively.
The EIA study of the Project concluded
that no sensitive receivers will be affected by construction noise. Based upon this, no noise monitoring is
necessary during the construction phase.
However, audit of the construction noise is planned. Regular site inspections will be carried
out to audit the compliance of the Contractor with regard to noise control,
contract conditions, and to recommend further mitigation measures if found to
be necessary.
No operational phase noise impacts were
predicted at sensitive receiver locations and hence no operational phase
monitoring is required.
Regular site inspections will be carried
out during the construction phase in order to ensure conformity with the
regulatory requirements.
17.6.1
Construction Phase
The EIA indicated that water quality
monitoring will be required during the construction phase for the following
activities:
·
Dredging
works for the seawall construction and backfilling works at the reclamation
area at
·
Dredging
works for the approach channel and turning basin;
·
Dredging
works for the submarine gas pipeline; and
·
Jetting
and dredging works for the submarine cable and watermain.
Water quality monitoring results will be
compared to Action and Limit levels to determine whether impacts associated
with the works are acceptable. An
Event and Action Plan provides procedures to be undertaken when monitoring
results exceed Action or Limit levels.
The procedures are designed to ensure that if any significant exceedances occur (either accidentally or through
inadequate implementation of mitigation measures on the part of the
Contractor(s)), the cause is quickly identified and remedied, and that the risk
of a similar event re-occurring is reduced.
Action and Limit levels will be used to
determine whether modifications to the operations are required. Action and Limit levels are
environmental quality standards chosen such that their exceedance
indicates potential deterioration of the environment. Exceedance of
Action levels can result in an increase in the frequency of environmental
monitoring, modification of operations and implementation of the proposed
mitigation measures. Exceedance of Limit Levels indicates a greater potential
deterioration in environmental conditions and may require the cessation of
works unless appropriate remedial actions, including a critical review of
plant, working methods and mitigation measures, are undertaken. Before construction work commences four
consecutive weeks of baseline monitoring will be undertaken at stations along
the pipeline/cable alignment as well as next to the dredging areas.
In order to minimise the water quality
impacts to the False Pillow Coral, silt curtain (stand type) will be provided
at the south of
The full details of the EM&A programme
for water quality is presented in the EM&A Manual for this Project.
17.6.2
Operation
Phase
As
no unacceptable impacts have been predicted to occur during the operation of
the LNG terminal at
In order to ensure that the construction
Contractor(s) has implemented the recommendations of the EIA Report, regular
site audits will be conducted of the waste streams, to determine if wastes are
being managed in accordance with the approved procedures and the site Waste
Management Plan. The audits will
look at all aspects of waste management including waste generation, storage,
recycling, transport and disposal.
An appropriate audit programme will be undertaken with the first audit
conducted at the commencement of the construction works. Routine weekly site inspections will
also include waste management.
The EIA study concluded that the impact on
the natural habitats is considered to be low to moderate and no adverse
residual impact is expected after the implementation of the mitigation
measures. However, transplantation
will be conducted for Golden Eulophia prior to the
commencement of construction works.
Regular site inspections will be carried out during the construction
phase in order to ensure that the mitigation measures are implemented and are
working effectively.
During the operational phase, adverse
impacts are not expected to occur.
Therefore, no terrestrial ecology monitoring will be required for either
the construction or operational phase.
The jetting and dredging operations have
been shown to proceed at rates that maintain environmental impacts to within
acceptable levels following application of mitigation measures.
Marine Mammal exclusion zones will be
implemented during the piling works at South Soko and
the grab dredging works in
In order to monitor that the False Pillow
Corals are in healthy conditions during the dredging works at the approaching
channel/turning circle at
A water quality monitoring programme will
provide management actions and supplemental mitigation measures to be employed
should impacts arise, thereby ensuring the environmental acceptability of the
project.
The EM&A Manual provides complete
details of the marine ecology monitoring programme.
During the operational phase, adverse
impacts are not expected to occur.
Therefore, no marine ecology monitoring will be required for the
operational phase.
The water quality monitoring programme will
provide management actions and supplemental mitigation measures to be employed
should impacts arise, thereby ensuring the environmental acceptability of the
Project. Since the impacts to
fisheries resources and fishing operations are small and of short duration, the
development and implementation of a monitoring and audit programme specifically
designed to assess the effects on commercial fisheries resources is not deemed
necessary. To ensure the seabed
affected by the pipeline works has restored to its original configuration, a
geophysical survey will be conducted in the post-construction phase of the
pipeline works
The Landscape and Visual
Assessment of the EIA recommended a series of mitigation measures for the
construction phase to ameliorate the landscape and visual impacts of the
project. Details of all the
recommended mitigation measures are included within the Implementation Schedule
provided in Annex
17.
Implementation of the mitigation measures
for landscape and visual resources recommended by the EIA will be monitored
through the site audit programme.
During the operational phase, adverse
impacts are not expected to occur.
Therefore, no landscape and visual monitoring will be required for the
operational phase.
Marine Archaeology:
No
impact to marine archaeology is predicted and hence no EM&A is required.
Land
Based Archaeology:
The EIA identified areas (identified as Sites B to E) of archaeological
potential at South Soko and recommendations have been
put forward for the rescue of the artefacts in specified locations prior to
commencement of construction works as part of an Archaeological Action Plan (AAP) .
There are also two other archaeological
areas (identified as Site A and Site G) where works may take place in close
proximity. For these areas
archaeological monitoring is required, which will be included in the AAP. The archaeological monitoring (watching
brief) is a form of mitigation measure and is a formal programme of observation
and investigation when construction work takes place in areas that have been
assessed as having archaeological potential.
During relocation of the Tai A Chau Tin Hau Temple, an
archaeological survey will conducted at the site and appropriate mitigation will
be provided prior to the relocation, if there are significant archaeological
finds. Similarly, proper records of
affected earth shrines will prepared prior to their relocation.
The details of the watching brief are
presented in the EM&A Manual.
17.13
Hazard to Life,
Land Contamination Prevention
Appropriate measures to reduce land
contamination, hazard to life and environmental risk have been
recommended. A design phase audit
is recommended to ensure that the design of the Project, including the spill response
plan, comprise the necessary elements to control, detect, contain, clean up,
handle and dispose any material that could lead to contaminated land or pose a
risk to life or the environment.
Full details of the EM&A requirements
are presented in the EM&A Manual.