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.
Key environmental issues associated with the construction and operation of the Project will be addressed through monitoring and controls specified in the EM&A Manual. Water and sediment quality, marine ecology and fisheries issues will be subject to EM&A, the details of which are outlined in Sections 3 to 9.
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. This processes by which these levels should be quantitatively defined are presented 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.
The purpose of an Event and Action Plan (EAP) 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 to be identified in the EM&A programme.
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.
All enquiries concerning the environmental effects of the Project, irrespective of how they are received, shall be reported to CEDD and directed to the ET Leader 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 CEDD 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 ET Leader shall undertake the following steps, as necessary:
· investigate and identify source of the problem;
· if considered necessary by CEDD undertake additional monitoring to verify the existence and severity of the alleged complaint;
· liaise with EPD to identify remedial measures;
· liaise with CEDD and the Contractor 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 ET Leader within a maximum of five working days and submitted to CEDD, 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 EM&A reports which shall include results of inspections undertaken by the ET Leader, 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.
Monthly, Quarterly and Annual reports submitted to CEDD, EPD and AFCD shall be prepared by the ET. The reports shall be prepared and submitted within a specified period. Additional details on reporting protocols are presented in Section 10.