Environmental Impact Assessment Ordinance

Technical Memorandum

Annex 21: CONTENTS OF AN ENVIRONMENTAL MONITORING AND AUDIT (EM&A) PROGRAMME

This Annex describes the commonly adopted approaches for carrying out an EM&A programme. The following are the key steps in an EM&A programme:

Environmental Monitoring

the systematic collection of environmental data through a series of repetitive measurements. A number of different monitoring activities are identified below:
1. Baseline Monitoring refers to the measurement of environmental parameters during a representative pre-project period for the purpose of determining the nature and ranges of natural variation and to establish, where appropriate, the nature of change;
2. Impact Monitoring involves the measurement of environmental parameters during project construction and implementation so as to detect changes in these parameters which can be attributed to the project; and
3. Compliance Monitoring unlike the previous monitoring activities, takes the form of periodic sampling and/or continuous measurement of environmental parameters, levels of waste discharge or process emissions to ensure that regulatory requirements are observed and standards met (Surveillance and inspection may also form a part of this activity but need not necessarily involve measurement of a repetitive activity).
the organization and interpretation of the environmental monitoring data to establish a record of change associated with the implementation of a project or the operation of an organization;
the process of verification that all or selected parameters measured by an environmental monitoring programme are in compliance with regulatory requirements, policies, relevant standards and criteria of this technical memorandum, and established environmental quality performance limits;
the comparison of project impact predictions with actual impacts for the purpose of assessing the accuracy of predictions;
the assessment of the effectiveness of the environmental management systems, practices and procedures;
event and action plans shall be included and linked to the environmental quality performance. The determination of the degree and scope of any necessary remedial measures in case of exceedance of compliance, for which environmental monitoring forms the basis, or the recommendation of environmental controls and operations measures in the event that the organization's environmental objectives are not achieved;
for projects which are assessed to have potential impacts on nearby fish culture zones, the part of EM&A programme to address such impacts shall be approved by Director of Agriculture, Fisheries and Conservation. A copy of the EM&A manual as well as the regular and summary reports shall be made available to Director of Agriculture, Fisheries and Conservation; and
the environmental monitoring and audit work shall be carried out by qualified personnel.

Environmental Quality Performance Limits

For the purpose of environmental monitoring and audit, environmental quality performance limits are normally in the form of a set of action/limit levels, which are defined as:

Action Levels - the levels beyond which there is an indication of a deteriorating ambient environmental quality. Appropriate remedial actions may be necessary to prevent the environmental quality from going beyond the limit levels, which would be unacceptable.
Limit Levels - the levels stipulated in relevant pollution control or environmental ordinances, this technical memorandum, or the Hong Kong Planning Standards and Guidelines, or other appropriate criteria established by the Director for a particular project, beyond which the works shall not proceed without appropriate remedial action, including a critical review of plant and work methods.

In addition to the action/limit levels, a trigger level below the action level may be set up to provide early warning of deteriorating environmental quality that may exceed the action level.

Environmental Monitoring and Audit Documentation

For the purpose of EM&A, the following documents are normally required by the Director:

EM&A Manual
The Manual shall be a stand-alone document and shall include the following:
1. project background including organisation and programme;
2. purpose of the manual;
3. an implementation schedule, summarizing all recommended environmental mitigation measures with reference to the programme for their implementation. The measures shall include those identified at detailed design, contract preparation, construction, and operation stages of the project;
4. drawings showing all environmentally sensitive receivers;
5. an EM&A programme for the construction of the project including:
  - responsibility for EM&A work;
  - EM&A organization and management structure;
  - EM&A methodology;
  - equipment to be used and calibration required;
  - locations, parameters, frequency and duration for baseline, impact and compliance monitoring;
  - environmental quality performance limits (Action and Limit levels);
  - Event-Action Plans and decision audit flow charts;
  - procedures for reviewing the monitoring results;
  - compliance audit procedures and follow-up;
6. implementation programme and impact prediction review procedures;
7. site inspection, deficiency and action reporting procedures;
8. complaint/consultation procedures; and
9. reporting format and procedures.
Baseline Monitoring Report
The report shall include at least the following:
1. drawings showing locations of the baseline monitoring stations;
2. monitoring results (in both hard and soft copies) together with the following information:
  - monitoring methodology;
  - equipment used and calibration details;
  - parameters monitored;
  - monitoring locations (and depth);
  - monitoring date, time, frequency and duration;
3. details on influencing factors, including:
  - major activities, if any, being carried out on the site during the period;
  - weather conditions during the period;
  - other factors which might affect the results;
4. determination of the action and limit levels for each monitoring parameter and statistical analysis of the baseline data;
5. revisions for inclusion in the EM&A Manual.
Regular and Summary EM&A Reports
The results and findings of each audit shall be documented in regular EM&A reports prepared by the Applicant. EM&A reports shall include at least the following :

(* Where applicable, items which have already been included in the EM&A Manual need not be repeated in each EM&A report unless there are substantial amendments.)
1. 1-2 pages executive summary;
2. * basic project information including a synopsis of the project organization, programme and management structure, and the work undertaken during the month;
3. * a brief summary of EM&A requirements including:
  - all monitoring parameters;
  - environmental quality performance limits;
  - Event-Action Plans;
  - environmental mitigation measures, as recommended in the EIA report;
  - environmental requirements in contract documents.
4. advice on the implementation status of environmental protection, mitigation and pollution control measures, as recommended in the project EIA report, summarized in the updated implementation schedule;
5. * drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;
6. monitoring results (in both hard and soft copies) together with the following information:
  - monitoring methodology;
  - equipment used and calibration details;
  - parameters monitored;
  - monitoring locations (and depth);
  - monitoring date, time, frequency, and duration;
7. graphical plots of trends of monitored parameters over the past four reporting periods for representative monitoring stations annotated against the following:
  - major activities being carried out on site during the period;
  - weather conditions during the period;
  - any other factors which might affect the monitoring results;
8. a summary of non-compliance (exceedances) of the environmental quality performance limits;
9. a review of the reasons for and the implications of noncompliance including review of pollution sources and working procedures;
10. a description of the actions taken in the event of noncompliance and deficiency reporting and any follow-up procedures related to earlier noncompliance;
11. a summary record of all complaints received (written or verbal) for each media, including locations and nature of complaints, liaison and consultation undertaken, actions and follow-up procedures taken and summary of complaints;
12. a summary record of notification of summons, successful prosecutions for breaches of environmental protection/pollution control legislation, and actions taken to rectify such breaches;
13. a forecast of the works programme, impact predictions and monitoring schedule for the next three months; and
14. comments, recommendations and conclusions for the monitoring period.