12 Environmental Monitoring and Audit requirements

12.1 Introduction

This section describes the requirements for environmental monitoring and audit (EM&A) during the construction and operation of the Project. The objectives of carrying out EM&A include the following:

· to provide a database against which any short or long term environmental impacts of the Project can be determined;

· to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards;

· to monitor the performance of the Project and the effectiveness of mitigation measures;

· to verify the environmental impacts predicted in the EIA Study;

· to determine Project compliance with regulatory requirements, standards and government policies;

· to take remedial action if unexpected problems or unacceptable impacts arise; and

· to provide data to enable an environmental audit.

The implementation schedule, containing the recommended mitigation measures, monitoring and audit requirements, and implementation agent of the mitigation measures for the Project, is presented in Annex I. Details of the EM&A requirements are provided in a stand-alone EM&A Manual.

12.2 Organisation and Personnel of the EM&A

The proposed organisation of all personnel involved in the EM&A process is illustrated in Figure 12.1. The roles and responsibilities of the various parties involved in the EM&A process are detailed in the EM&A Manual, and summarised in Section 12.3.

Figure 12.1 Project Organisation Chart

12.3 Role and Responsibilities

12.3.1 Project Proponent

The Project Proponent (PP), Sha Lo Tung Development Co. (SLTDC), Ltd, should supervise the Contractor’s activities and ensure that the requirements in the EM&A Manual and the Contract Document are fully complied with. They should develop appropriate contract clauses to ensure that the Contractor will have qualified professionals to interface with the Environmental Representative (ER) to fulfil the environmental requirements.

They should participate in join site inspections undertaken by the Conservation Specialist (CS) and the Contractor, whenever requested.

They should inform the Contractor when action is required to reduce impacts in accordance with the Event and Action Plans.

They should adhere to the procedures for carrying out investigation of complaints.

12.3.2 Contractor

The Contractor (C) employed by the Project Proponent should work within the scope of the construction contract and other tender conditions that are related to the environmental requirements.

They should provide assistance to the Environmental Team (ET) and CS in carrying out monitoring.

They should submit proposals on mitigation measures in case of exceedances of Action and Limit levels in accordance with the Event and Action Plans. They should also implement measures to reduce impact where the Action and Limit levels are exceeded and take the corrective actions instructed by the PP, CS, ER or ET.

They should participate in joint site inspections undertaken by the ET, CS and Independent Environmental Checker, whenever requested.

12.3.3 Environmental Representative

During the construction phase of the project, Green Power will act as Environmental Representative (ER). The ER should ensure the Contractor’s compliance with the project’s environmental performance requirements during construction of the Project. The ER should be independent and should not be in any way connected to the Contractor’s company.

They should compile an EM&A Manual and submit to the PP, IEC, EPD and C one month before the commencement of construction works.

They should report to the PP, IEC, EPD and C on a regular basis the progress of the monitoring work and the findings.

12.3.4 Environmental Team

The ET will be responsible for implementing all environmental measures and EM&A requirements recommended in the EIA Report throughout the construction and operation of the Project. The ET will contain suitably qualified support staff to carry out the EM&A programme and the ET leader should possess at least 7 years experience in EM&A and/or environmental management. Members of the ET should be independent and should not be in any way connected to the Contractor’s company. Due to the specialist nature of some of the EM&A works required for this Project, the ET should comprise professionals qualified to undertake the tasks involved. Thus, the ET should include personnel experienced in noise monitoring, water quality monitoring and ecology monitoring.

They should monitor various environmental parameters as required in the EM&A Manual. They should assess the EM&A data and prepare reports on the findings. They should also review the success of the EM&A programme, determining the adequacy of the mitigation measures implemented and the validity of the EIA predictions, as well as identify any adverse environmental impacts before they arise. The monitoring reports should be provided to the PP, IEC, EPD and C for review.

They should provide advice (if required) to the PP for the development of environmental contract clauses for Contractor’s contract.

They should review the Contractor’s working programme and methodology and comment as necessary and also recommend suitable mitigation measures to the C in the case of exceedance of Action and Limit levels in accordance with the Event and Action Plans.

They should adhere to the procedures for carrying out investigation of complaints.

They should also audit the trip tickets recorded by the waste disposal stations for all dumping activities. This ensures that the waste is properly disposed of at the designated locations.

12.3.5 Conservation Specialist

Green Power will provide a CS for the ET to stay on-site to conduct environmental audits during the construction phase. The CS should be a person who has at least 5 years experience in environmental monitoring and auditing (EM&A) or environmental management.

The CS should:

· inspect the site daily to check the implementation and effectiveness of proposed mitigation measures, in particular the temporary drainage system and runoff control measures. The person will have the authority to stop the construction works should the implementation and effectiveness of the proposed mitigation measures not be satisfied. The site audits should cover seven key environmental aspects, where appropriate, including air quality, noise, water quality, sewerage and sewage treatment, waste management, ecology, landscape and visual, cultural heritage, environmental complaints and housekeeping; and

· report on a daily basis the environmental site audit observations to the ER, IEC and EPD (copy to the PP and the C).

12.3.6 Independent Environmental Checker

The IEC will be appointed by the PP as the independent checker to verify the overall environmental performance of the Project and to assess the effectiveness of the ET in their duties. The IEC should be responsible to certify all environmental submissions to EPD. The IEC should advise PP and EPD on environmental issues related to the project. The IEC should possess at least 7 years experience in EM&A and/or environmental management. The IEC should carry out random sample check and audit the monitoring activities and results at least monthly; review the proposed measures and results submitted by ET or C and adhere to the procedures for carrying out complaints investigation.

12.3.7 EPD

As the Authority under the EIAO, the EPD will be the authority to approve all submissions under the EIAO.

12.4 Monitoring Requirements

Monitoring of noise levels, stream water quality, stream hydrology, ecology (species composition and relative abundance of riparian vegetation, adult odonate and fish communities) and cultural heritage are required during the construction phase. Baseline monitoring will also be required prior to construction commencement to establish the baseline conditions for ecology, stream water quality and hydrology. Post project (or construction) or operation monitoring for stream water quality and ecology will also be required. The details of the monitoring requirements are summarized in Table 12.1 and the monitoring locations are shown in Figure 12.2.

Table 12.1 Summary of Monitoring Requirements

Environmental Aspect	Location	Frequency	Parameters	Pre- Construction Phase	Construction Phase	Post Construction	Operation Phase
Noise	Two representative NSRs (N1 and N5) as shown in Figure 5.3 in Section 5.	Weekly	LAeq 30 min		ü
Water Quality	Sha Lo Tung SSSI Stream (R1-U, R1-UM, R1-M, R1-D)	Baseline monitoring: once every two days for at least 4 weeks Impact monitoring: For the in-situ parameters and SS: 3 days per week; For oil and grease, ammonia nitrogen, total reactive phosphorus, BOD5 and E. coli: once a month Post-project monitoring: 3 days per week after construction completion Operation monitoring: Once a month for 12 months. Two of the monitoring events should be scheduled on the day just after the Ching Ming Festival Day and Chung Yeung Festival Day.	In situ measure: pH, water temperature, turbidity, dissolved oxygen (DO), dissolved oxygen (DO, saturation), salinity and water flow rate. Laboratory measure: suspended solids (SS), oil and grease, ammonia nitrogen, total reactive phosphorus, 5-day biochemical oxygen demand (BOD5), Chemical Oxygen Demand (COD), Escherichia coli (E.coli)	ü	ü	ü	ü
Ecology – Stream Monitoring	Along Sha Lo Tung Stream next to the Development Site as shown in Figure 12.2	Baseline monitoring: 3 days per week and commence no more than 3 weeks prior to the commencement of the construction phase and the impact monitoring. Impact monitoring: Daily Post-project monitoring: 3 days per week within a week after completion of the construction works	Stream monitoring to identify the signs of the abiotic impact as presented in Table 9.20 in Section 9.	ü	ü	ü
Ecology – Stream Hydrology Monitoring	Stations R1-U, R1-M and R1-D as shown in Figure 12.2	Baseline monitoring: 5 days in wet season and 5 days in dry season prior to the commencement of the construction phase and the impact monitoring. Impact stream hydrology monitoring should be conducted quarterly (3 monitoring days per quarter) during construction phase Operational monitoring should be conducted quarterly within the first three years after the completion of construction works (a total twelve occasions).	Stream water level, stream wet width and flow rate.	ü	ü		ü
Ecology – Biological Monitoring	Along Sha Lo Tung Stream next to the Development Site as shown in Figure 12.2 The wet abandoned agricultural land to the east of the Development Site	Baseline monitoring: Once during the wet season (at least 5 days) and once during the dry season (at least 5 days) prior to the commencement of any construction works. Impact monitoring: Biweekly Operational monitoring should be conducted quarterly within the first three years after the completion of construction works (a total twelve occasions).	Biological monitoring to record the species diversity, relative abundance and community structure of the riparian vegetation, adult odonate and fishes in the aquatic habitat	ü	ü		ü
Cultural Heritage	Southern section of the Sha Lo Tung Road Improvement	During construction of the southern section of the proposed Sha Lo Tung Road Improvement alignment as shown in Figure 11.13 in Section 11. The need and scope of archaeological monitoring is subject to the detailed design of construction works.	Archaeological monitoring	ü	ü
	LF01 at the southern section of the Sha Lo Tung Road	During construction of the southern section of the proposed Sha Lo Tung Road Improvement as shown in Plan 6 in Annex H2 and Figure 11.5 under Section 11. Frequency to be agreed with AMO.	To be defined after the pre-condition survey is completed which recommendation of vibration monitoring will be provided.	ü	ü

12.5 Audit Requirements

12.5.1 Construction Phase

The CS will conduct daily site audit and weekly site audits will be undertaken jointly by the Contractor, the IEC, CS and the ET during the during the construction phase of the Project to ensure that the proposed mitigation measures and good site practices are implemented.

The audit will cover the aspects on management of air quality, noise, water quality, sewerage and sewage treatment, waste, ecology, landscape and visual and cultural heritage for the Project.

During the preparation of the detailed landscape design plan, the design submission will be audited against the recommendation proposed in this EIA Report by the landscape architect from the IEC.

12.5.2 Operation Phase

Regular site audits will be undertaken to ensure the proposed environmental mitigation measures are implemented. The audit will cover the aspects on the management of air quality, noise, water quality, sewerage and sewage treatment, waste, ecology, landscape and visual and cultural heritage. The audits will be undertaken jointly by the Contractor, the IEC, CS and ET.