This EIA Study has focused on the prediction and mitigation of the potential impacts associated with the construction and operation of the Project. One of the key outputs has been recommendations on the mitigation measures to be undertaken in order to ensure that residual impacts comply with regulatory requirements plus the requirements of the EIAO TM. The findings and recommendations of this EIA will form the basis on which HEC’s environmental performance will be judged during the detailed design and construction of the Project. To ensure effective and timely implementation of the mitigation measures, it is considered necessary to develop Environmental Monitoring and Audit (EM&A) procedures and mechanisms by which the Implementation Schedule (Annex D) may be tracked and its effectiveness assessed.
Sections 4 to 8 have, where appropriate, identified and recommended the implementation of mitigation measures in order to minimise the potential construction and operational impacts of the Project. These findings and recommendations form the primary deliverable of the whole EIA process. Once endorsed by the EPD, they will form an agreement between HEC and the Government as to the measures and standards that are to be achieved. It is therefore, essential that mechanisms are put in place to ensure that the mitigation measures prescribed in the Implementation Schedule are fully and effectively implemented during construction.
The required format for the Implementation Schedule (Annex D) is specified in the EIA Study Brief. The format requires the specification of implementation agent(s), timing, duration and location for each of the recommended mitigation measures.
Apart from the mitigation measures defined in the EIA, there is also scope for other requirements to be included within the finalised Implementation Schedule. Prior to the issue of an Environmental Permit, there is an EIA Determination Period. During this period the EIA Report is reviewed and commented upon by both the public and professional bodies. Where recommendations are made and accepted by either the Advisory Council on the Environment (ACE) or its EIA subcommittee, these measures will be included within the Implementation Schedule, where appropriate.
As the Project constitutes a Designated Project under the EIAO by virtue of Item D.1 of Part I of Schedule 2, an Environmental Permit must be obtained before construction or operation of the proposed wind turbine can commence.
Upon approval of the EIA Report, HEC can apply for an Environmental Permit. If the application is successful, the Environmental Permit will, in most circumstances, have conditions attached to it, which must be complied with. In addition, HEC and its appointed Contractors must also comply with all other controlling environmental legislation and guidelines, which are discussed within the specific technical chapters of this report. Failing to comply with these legislative requirements could lead to prosecution under the various Pollution Control Ordinances.
For construction of the Project, it is envisaged that the contractual documentation will require HEC’s Contractors to define mechanisms for achieving the environmental requirements. This will most likely be achieved by requiring the Contractor to produce and implement an Environmental Management Plan (EMP).
EMP’s are similar in nature to safety or quality plans and provide details of the means by which the Contractor (and all subcontractors working for the Contractor) will implement the recommended mitigation measures and achieve the environmental performance standards defined both in Hong Kong environmental legislation and in the Implementation Schedule. A primary reason for adopting the EMP approach is to make sure that the Contractor is fully aware of his environmental responsibilities and to ensure that his commitment to achieving the specified standards.
The EMP approach is grounded on the principle that the Contractor shall define the means by which the environmental requirements of the EIA process, and the contractual documentation shall be met. In the first instance, each Tenderer shall be required to produce a preliminary EMP for submission as part of the tendering process; the skeletal EMP will demonstrate the determination and commitment of the organisation and indicate how the environmental performance requirements laid out in the available EIA documentation will be met. It is recommended that this aspect be included as a specific criterion in the assessment of tender documents; this will act as a clear indication to all Tenderers of HEC’s commitment to the minimisation and management of environmental impacts. Upon Contract Award, the successful Tenderer shall be required to submit a draft and final version of the EMP for the approval of HEC prior to the commencement of the works.
The EPD requires the submittal for approval of an EM&A Manual prior to the commencement of construction. The EM&A Manual has the purpose of defining the mechanisms for implementing the EM&A requirements specific to each phase of the work.
The EM&A Manual provides a description of the organisational arrangements and resources required for the EM&A programme based on the conclusions and recommendations of this EIA. The EM&A Manual stipulates details of the construction monitoring required, and actions that shall be taken in the event of exceedances of the environmental criteria. In effect, the EM&A Manual forms a handbook for the on-going environmental management during construction.
The EM&A Manual comprises descriptions of the key elements of the EM&A programme including:
· appropriate background information on the construction of the Project with reference to relevant technical reports;
· organisational arrangements, hierarchy and responsibilities with regard to the management of environmental performance functions during the construction phase to include the EM&A team, the Contractor’s team and the Corporation’s representatives;
· a broad construction programme indicating those activities for which specific mitigation is required, as recommended in the EIA, and providing a schedule for their timely implementation;
· descriptions of the parameters to be monitored and criteria through which performance will be assessed including: monitoring frequency and methodology, monitoring locations (in the first instance, the location of sensitive receivers as listed in the EIA), monitoring equipment lists, event contingency plans for exceedances of established criteria and schedule of mitigation and best practice methods for minimising adverse environmental impacts;
· procedures for undertaking on-site environmental performance audits as a means of ensuring compliance with environmental criteria; and
· reporting procedures.
The EM&A Manual will be a dynamic document which may undergo a series of revisions to accommodate the progression of the construction programme.
The objectives of carrying out EM&A for the Project include:
· to provide baseline information against which any short or long term environmental impacts of the projects 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 to be undertaken at regular intervals.
The following sections summarise the recommended EM&A requirements, further details are provided in the EM&A Manual.
Given the compliance with the stipulated noise criterion, noise monitoring is not required during the construction stage. Though site audit will be conducted to ensure that the plant inventory used on site are consistent with the assumptions used in the EIA report.
During the operational phase, noise monitoring is recommended to ensure the compliance with the stipulated noise criterion at the nearby NSRs. A noise monitoring location is proposed at No. 1 Tai Ling Tsuen (N1). Details of the monitoring schedule and plan are presented in the separate EM&A Manual. To ensure the operational noise level complies with the noise standard, the supplier shall guarantee the wind turbine with allowable maximum noise level of 100 dB(A) and pure tone free, by providing certificate of measurement and verify the overall noise level during commissioning and testing in accordance to international standard procedures such as IEC 61400-11.
The implementation of the ecological mitigation measures stated in Section 5.7 should be checked as part of the environmental monitoring and audit procedures during the construction period as presented in the separate EM&A Manual.
Monitoring for bird collision during operation is required. The purpose of the monitoring of wind turbines is to assess the impact (via collisions) of the wind farm on birds, with a particular focus on species of conservation interest (ie Black Kite). During the operation of the wind turbine, monitoring will be undertaken at monthly intervals for a period of 12 months. An area of 50 m radius will be searched around the base of the turbine. After this 12-month period, the monitoring results will be reviewed. Should any bird mortality or injury be confirmed to be due to the wind turbine, relevant government departments (ie Environmental Protection Department (EPD) and Agriculture, Fisheries and Conservation Department (AFCD)) would be notified. If the bird collision event persists more than 3 times, HEC will discuss to propose for remedial action with government and implement any agreed actions to solve the event such as adjustment of wind turbine lighting and the colour of the wind turbine. The effectiveness of the proposed remedial action will be verified and evaluated with discussion with EPD/AFCD.
If, after the 12-months
monitoring, insignificant number of bird collisions have been reported then
monitoring will cease as it will have been demonstrated that the wind turbine
is not having an adverse impact on bird species.
The implementation and
operational maintenance of proposed landscape and visual mitigation measures should be checked as part of the environmental monitoring and audit
procedures during the construction period as presented in the separate EM&A
Manual. The
detailed landscape designs shall be audited during the design stage. Construction and operational stage
EM&A will comprise audit of the compensatory planting and planting
establishment in the form of site inspection. Further details of the specific EM&A requirements are
presented in the separate EM&A Manual.
During the construction phase, regular site auditing is recommended to ensure the recommended mitigation measures are properly implemented.
As no adverse air quality impact is expected, air quality
EM&A is not considered necessary.
During the construction phase, regular site auditing is recommended to ensure the recommended mitigation measures are properly implemented.
As no water quality impact is expected, EM&A for water quality is not considered necessary.
During the construction phase, regular site auditing is recommended to ensure good construction practice as well as good waste management and disposal measures are properly implemented.
No waste generation is expected since the turbine will be unmanned during operation.