In this section, the general requirements of the EM&A programme are presented with reference to the EIA Study findings that have formed the basis of the scope and content of the programme.

2.2 EM&A

Key environmental issues associated with the construction of the Project will be addressed through monitoring and controls specified in the EM&A Manual and construction contract.  Water quality, marine ecology and landfill gas issues will be subject to EM&A, the details of which are outlined in Sections 3 to 5. 

The monitoring of the effectiveness of the mitigation measures will be achieved through environmental monitoring programme as well as through site inspections.  The inspections will include within their scope, mechanisms to review and assess Towngas' environmental performance, ensuring that the recommended mitigation measures have been properly implemented, and that timely resolution of received complaints are managed and controlled in a manner consistent with the recommendations of the EIA Report.

2.2.1 Environmental Monitoring

Impact monitoring will be carried out by the Contractor's Environmental Team.  Monitoring work will comprise quantitative assessment of water quality, marine ecology and landfill gas impacts at representative sensitive receivers in the vicinity of the works.  This is discussed in Sections 3 to 5 of this Manual.

2.2.2 Action and Limit Levels

Action and Limit (A/L) Levels are defined levels of impact recorded by the environmental monitoring activities which represent levels at which a prescribed response is required.  These levels are quantitatively defined later in the relevant sections of this manual and described in principle below:

* Action Limits: beyond which there is a clear indication of a deteriorating ambient environment for which appropriate remedial actions are likely to be necessary to prevent environmental quality from falling outside the Limit Levels, which would be unacceptable; and

* Limit Levels: statutory and/or agreed contract limits stipulated in the relevant pollution control ordinances, HKPSG or Environmental Quality Objectives established by the EPD.  If these are exceeded, works should not proceed without appropriate remedial action, including a critical review of plant and working methods.

2.2.3 Event and Action Plans

The purpose of the Event and Action Plans (EAPs) is to provide, in association with the monitoring and audit activities, procedures for ensuring that if any significant environmental incident (either accidental or through inadequate implementation of mitigation measures on the part of the Contractor) does occur, the cause will be quickly identified and remediated, and the risk of a similar event recurring is reduced.  This also applies to the exceedances of A/L criteria identified in the EM&A programme.

2.2.4 Site Inspections

In addition to monitoring water quality, marine ecology and landfill gas monitoring as a means of assessing the ongoing performance of the Contractor(s), the ET Leader shall undertake weekly site inspections and audits of on-site practices and procedures.  The primary objective of the inspection and audit programme will be to assess the effectiveness of the environmental controls established by the Contractor(s) and the implementation of the environmental mitigation measures recommended in the EIA Report.

The findings of site inspections and audits shall be made known to the Contractor at the time of the inspection to enable the rapid resolution of identified non-compliances.  Non-compliances, and the corrective actions undertaken, shall also be reported in the monthly EM&A Reports.

Section 6 of this Manual presents details of the scope and frequency of on-site inspections and defines the range of issues that the audit protocols should be designed to address.

2.2.5 Enquiries, Complaints and Requests for Information

Enquiries, complaints and requests for information can be expected from a wide range of individuals and organisations including members of the public, Government departments, the press and television media and community groups.  During construction of the Project, the vast majority of such correspondence is likely to be received directly by Towngas.

All enquiries concerning the environmental effects of the works, irrespective of how they are received, shall be reported to Towngas and directed to the Contractor(s) who shall set up procedures for handling, investigation and storage of such information (Figure 2.2a).  The following steps shall then be followed:

1) The ET Leader shall notify Towngas of the nature of the enquiry.

2) An investigation shall be initiated to determine the validity of the complaint and to identify the source of the problem.

3) The Contractor shall undertake the following steps, as necessary:

* investigate and identify source of the problem;

* if considered necessary by Towngas following consultation with the IC(E), undertake additional monitoring to verify the existence and severity of the alleged complaint;

* liaise with EPD to identify remedial measures;

* liaise with the IC(E) to identify remedial measures;

* implement the agreed mitigation measures;

* repeat the monitoring to verify effectiveness of mitigation measures; and

* repeat review procedures to identify further possible areas of improvement if the repeat monitoring results continue to substantiate the complaint.

4) The outcome of the investigation and the action taken shall be documented on a complaint proforma (Annex B).  A formal response to each complaint received shall be prepared by the Contractor(s) within a maximum of five working days and submitted to Towngas, in order to notify the concerned person(s) that action has been taken.

5) All enquiries which trigger this process shall be reported in the monthly reports which shall include results of inspections undertaken by the contractor, and details of the measures taken, and additional monitoring results (if deemed necessary).  It should be noted that the receipt of complaint or enquiry will not be, in itself, a sufficient reason to introduce additional mitigation measures. 

In all cases the complainant shall be notified of the findings, and audit procedures shall be put in place to ensure that the problem does not recur.

2.2.6 Reporting

Monthly, bi-annual and annual reports submitted to Towngas, EPD and AFCD shall be prepared by the ET.  The monthly reports shall be prepared and submitted within 10 working days of the end of each calendar month.  Additional details on reporting protocols are presented in Section 7.

2.2.7 Cessation of EM&A

The ET and the IC(E) shall continue to carry out environmental monitoring and site inspections until completion of the construction works and confirmation from EPD.