2                                  EM&A General Requirements

2.1                            Introduction

In this section, the general requirements of the EM&A programme are presented with reference to the findings and recommendations of the EIA Report 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 Manual and Contract Specification.  Noise and ecology will be subject to EM&A, the details of which are outlined in Sections 3 and 5, respectively. 

The monitoring of the effectiveness of the mitigation measures will be achieved through site inspections/audits.  The inspections will include within their scope, mechanisms to review and assess the Contractor’s 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 and operational monitoring will be carried out by the Environmental Team.  Monitoring work is focussed on construction and operational noise impact to identified noise sensitive receivers and on ecology, specifically construction phase impacts to the Common Rat Snake and Bodagek’s Burrowing Lizard and operation phase impacts to birds.  These are discussed in Sections 3 and 4 of this Manual.

2.2.2                      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.

2.2.3                      Site Inspections/Audits

In addition to monitoring ecology and noise as a means of assessing the ongoing performance of the construction works, the ET will undertake 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 construction team(s) and the implementation of the environmental mitigation measures recommended in the EIA Report.

The findings of site inspections and audits will 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 8 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.

2.2.4                      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. 

All enquiries concerning the environmental effects of the works, irrespective of how they are received, will be reported to CAPCO and directed to the ET who will set up procedures for handling, investigation and storage of such information.  The following steps will then be followed:

1)        The ET Leader will notify CAPCO of the nature of the enquiry.

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

3)        The Contractor(s) will undertake the following steps, as necessary:

·           investigate and identify source of the problem;

·           if considered necessary by CAPCO, undertake additional monitoring to verify the existence and severity of the alleged complaint;

·           identify necessary remedial measures and implement as soon as possible;

·           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 will be documented on a complaint proforma (see Annex B).  A formal response to each complaint received will be prepared by the Contracto(s) within a maximum of five working days and submitted to CAPCO, in order to notify the concerned person(s) that action has been taken.

5)        All enquiries which trigger this process will 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 will be notified of the findings, and audit procedures shall be put in place to ensure that the problem does not recur.

2.2.5                      Reporting

With respect to the identified potential impacts and the nature (including general site audits at monthly intervals during construction phase, noise monitoring for both construction and operation phases, and bird collision monitoring during the operation phase, see below) and frequency (weekly, biweekly or monthly) of the monitoring and audit to be undertaken, it is considered that real-time reporting of the monitoring data is not applicable. 

Monthly reports submitted to the Contractor(s), CAPCO, EPD and AFCD will be prepared by the ET and verified by the ET Leader.  The monthly reports will be prepared and submitted within 10 working days of the end of each reporting month.  Additional details on reporting protocols are presented in Section 9.

2.2.6                      Cessation of EM&A

The ET will continue to carry out environmental monitoring and site inspection/audit until completion of the construction works and the specified operation phase monitoring period.