1                                  Introduction

1.1                            Purpose of The Manual

This Environmental Monitoring and Audit (EM&A) Manual (“the Manual”) has been prepared by ERM-Hong Kong, Limited (ERM) on behalf of Castle Peak Power Company Limited (CAPCO).  The Manual is a supplementary document of the EIA Study of the project entitled “A Commercial Scale Wind Turbine Pilot Demonstration at Hei Ling Chau” (hereafter referred to as the Project).

The Manual has been prepared with reference to the EIA Study Brief (No. ESB-145/2006) and the Technical Memorandum of the Environmental Impact Assessment Process (EIAO TM).  The purpose of the Manual is to provide information, guidance and instruction to personnel charged with environmental duties and those responsible for undertaking EM&A work during construction and operation of the wind turbine.  It provides systematic procedures for monitoring and auditing of potential environmental impacts that may arise from the works.

1.2                            Project Description

1.2.1                      Background to the Study

CAPCO recognises the Government of the Hong Kong Special Administrative Region (HKSARG)’s efforts in exploring alternative power sources, including renewable energy, and in promoting public awareness of these alternatives.  To this end, CAPCO has launched a commercial scale wind turbine pilot demonstration (hereafter referred to as wind turbine) to collect engineering and environmental information required, to investigate the economic, environmental and technical feasibility and practicality of wind energy application and to educate and raise the community’s awareness of the issues, costs, constraints, benefits, etc of wind energy generation in Hong Kong.  

A rigorous site selection process has been conducted to identify suitable areas for the development of the wind turbine considering factors such as wind resource, environmental, physical, social and engineering considerations.  The Hei Ling Chau site was identified as the preferred site for the wind turbine pilot demonstration.

The construction and operation of a wind turbine with capacity between 800kW and 1.3MW with design lifetime of 20 years in Hong Kong is classified as a Designated Project by virtue of Item D.1 of Part I of Schedule 2 under the Environmental Impact Assessment Ordinance (Cap. 499) (EIAO) and will therefore require an Environmental Permit (EP).

1.2.2                      The Project

The works that are the subject of the EIA Study include the construction and operation of a 800kW to 1.3MW commercial scale wind turbine at the Project site at Hei Ling Chau (see Figure 1.2a).  The key components of the Project include the following:

·           site clearance and formation;

·           pre-bored H-piling and construction of reinforced concrete foundation (about 9m x 9m x 2m) for the wind turbine;

·           erection of wind turbine tower (up to 60m height, hub height about +130mPD, and tip blade height about 160mPD) by assembling pre-fabricated steel tower sections (in 3 sections, vary from about 17m to 23m each);

·           installation of nacelle (up to 12m(l) x 4.5 m (h) x 3.6m (w)) and rotor blades (3-bladed with diameter of 30m) using the cranes;

·           installation of step up transformer and substation;

·           installation of transmission cables between the substation and the 11 kV supply grid; and

·           testing and commissioning of the wind turbine system; and

·           operation and maintenance of the wind turbine system.

In addition, minor enabling works are required to upgrade some sections of existing roads and creation of temporary access for the delivery of construction materials and equipment. 

No marine works will be required for the construction and operation of the wind turbine.   

1.2.3                      Construction Programme

Once the EIA has been formally approved by Government, CAPCO will obtain an EP for construction and operation of the Project.  It is scheduled to commence the construction works in 2007 and anticipated that the wind turbine will start operation in 2008.

1.3                            Objectives of the EM&A Programme

The construction and operational impacts resulting from the implementation of the Project are specified in the EIA Report.  The EIA Report also specifies mitigation measures that need to be implemented to ensure compliance with the required environmental criteria.  These mitigation measures and their implementation requirements are presented in the Implementation Schedule (see Annex A).  The EIA recommends that an environmental monitoring and audit programme be implemented to assess the effectiveness of measures and to confirm that there will be no adverse environmental impacts during both construction and operation of the Project (particularly related to noise and ecology).  It is also recommended that regular site audits be undertaken during construction phase to check whether the good construction site practices to prevent adverse waste and water quality impacts are properly implemented.  Any activities which have a potential to cause adverse environmental impacts are identified before the adverse impacts occurred.  Ad-hoc visits to the impacted sites will also be undertaken in response to any complaints or reported non-compliance on environmental standards in order to enable prompt actions to rectify any malpractice. 

This Manual provides the EM&A requirements that have been recommended in the EIA Report in order to ensure compliance with the specified mitigation measures.  The main objectives of the EM&A programme are to:

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

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

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

·         verify the environmental impacts predicted in the EIA Report;

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

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

·         provide data against which environmental audits may be undertaken.

1.4                            Scope of The EM&A Programme

The scope of the EM&A programme is to:

·         implement monitoring and site audit requirements for noise monitoring programme;

·         implement monitoring and site audit requirements for ecology monitoring programme;

·         implement inspection requirements for mitigation measures;

·           liaise with, and provide environmental advice (as requested or when otherwise necessary) to construction site staff on the comprehension and consequences of the environmental audit;

·         identify and resolve environmental issues and other functions as they may arise from the construction works;

·           check and quantify the Contractor's overall environmental performance, and remedial actions taken to mitigate adverse environmental effects as they may arise from the works;

·           conduct monthly reviews of monitored impact data as the basis for assessing compliance with the defined criteria and to ensure that necessary mitigation measures are identified and implemented, and to undertake additional ad hoc monitoring and auditing as required by special circumstances;

·           evaluate and interpret all environmental monitoring data to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards, and to verify the environmental impacts predicted in the EIA Report;

·         manage and liaise with other individuals or parties concerning other environmental issues deemed to be relevant to the construction process;

·         conduct regular site audits/inspections of a formal or informal nature to assess:

-       the level of the Contractor's general environmental awareness;

-       the Contractor's implementation of the recommendations in the EIA Report;

-       the Contractor's performance as measured by the EM&A;

-       the need for specific mitigation measures to be implemented or the continued usage of those previously agreed;

-       to advise the site staff of any identified potential environmental issues; and

-       submit monthly EM&A reports which summarise project monitoring and auditing data, with full interpretation illustrating the acceptability or otherwise of any environmental impacts and identification or assessment of the implementation status of agreed mitigation measures.

1.5                            Organisation and Structure of the EM&A

1.5.1                      General

The Proponent (CAPCO) will appoint an Environmental Team (ET) to conduct monitoring and auditing works and to provide specialist advice on undertaking and implementation of environmental responsibilities.

The ET will have previous relevant experience with managing similarly sized EM&A programmes, particularly concerning noise and ecological impacts, and the Environmental Team Leader (ET Leader) will be a recognized environmental professional, preferably with a minimum of seven years relevant experience in impact assessments and impact monitoring programmes.

With the consideration of the reasons listed below, as well as the small-scale nature of the Project and low magnitude of expected impacts, it is not considered necessary to appoint an Independent Environmental Consultant to act as an “Independent Environmental Checker” (IEC) to verify and validate the environmental performance of the Contractor and the Environmental Team appointed by the Proponent:

·           Low complexity, reliability and implementation experience of proposed mitigation measures;

·           Low significance, short duration and reversibility of the impacts due to the Project; and

·           No complicated monitoring and auditing exercise and results to validate.

1.5.2                      Project Organisation

The roles and responsibilities of the various parties involved in the EM&A process are further expanded in the following sections.  The ET Leader will be responsible for, and in charge of, the Environmental Team; and will be the person responsible for executing the EM&A requirements.

CAPCO

CAPCO will:

·           appoint an ET, as necessary, to undertake monitoring, audit works and reporting of the EM&A requirements outlined in this Manual;

·           provide assistance to the ET in conducting the required environmental monitoring;

·           participate in the site inspections undertaken by the ET, as required, and undertake any necessary corrective actions;

·           provide information/advice to the ET regarding works activities which may contribute, or be contributing to the generation of adverse environmental conditions;

·           implement measures to reduce impact where any applicable Action and Limit levels are exceeded; and

·           take responsibility and strictly adhere to the guidelines of the EM&A programme and complementary protocols developed by their project staff.

The Contractor(s)

The Contractor(s) will:

·           work within the scope of the construction contract and other tender conditions;

·           provide assistance to the ET in carrying out monitoring;

·           submit proposals on mitigation measures in case of exceedances of Action and Limit levels in accordance with the Event and Action Plans;

·           implement measures to reduce impact where Action and Limit levels are exceeded;

·           implement measures to reduce impact where Action and Limit levels are exceeded;

·           implement the corrective actions instructed by CAPCO and the ET;

·           participate in the site inspections undertaken by the ET and undertake any corrective actions instructed by CAPCO and the ET Leader; and

·           adhere to the procedures for carrying out complaint investigation.

Environmental Team

The duties of the ET are to:

·           monitor the various environmental parameters as required by this or subsequent revisions to the Manual;

·           assess the EM&A data and 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;

·           conduct site inspections to investigate and inspect the construction equipment and work methodologies with respect to pollution control and environmental mitigation, monitor compliance with environmental protection specifications, and to anticipate environmental issues that may require mitigation before the problem arises;

·           audit the environmental monitoring data and report the status of the general site environmental conditions and the implementation of mitigation measures resulting from site inspections;

·           review working programme and methodology, and comment as necessary;

·           investigate and evaluate complaints, and identify corrective measures;

·           advice to the on environmental improvement, awareness, enhancement matters, etc, on site;

·           report on the environmental monitoring and audit results and the wider environmental issues and conditions to the Contractor(s), CAPCO and the EPD;

·           adhere to the agreed protocols or those in the Contract Specifications in the event of exceedances or complaints; and

·           the ET Leader will keep a contemporaneous log-book and record each and every instance or circumstance or change of circumstances which may affect the environmental impact assessment and every non-conformance with the recommendations of the EIA Reports or the EPs.

The ET will be led and managed by the ET Leader.  The ET Leader will have relevant education, training, knowledge, experience and professional qualifications.  Suitable qualified staff will be included in the ET, and the ET should not be in any way an associated body of the Contractor(s).

1.6                            Structure of the EM&A Manual

The remainder of the Manual is set out as follows:

·           Section 2 sets out the EM&A general requirements;

·           Section 3 details the requirements for noise monitoring;

·           Section 4 details the requirements for ecology impact monitoring, and lists relevant monitoring methodologies, submissions, compliance and Event and Action Plans (EAPs);

·           Section 5 details the requirements for landscape and visual impacts mitigation measures;

·           Section 6 details the requirements for controlling water quality impacts;

·           Section 7 details the requirements for waste management;

·           Section 8 describes the scope and frequency of site auditing; and

·           Section 9 details the EM&A reporting requirements.

The Manual is an evolving document that should be updated to maintain its relevance as the Project progresses.  The primary focus for these updates will be to ensure the impacts predicted and the recommended mitigation measures remain consistent and appropriate to the manner in which the works are to be carried out.