14                                        environmental Monitoring and audit Measures

14.1                                  Introduction

This EIA Study has focused on the assessment and mitigation of the potential impacts associated with the construction and operation of the Project at the Southwest Lamma site.  One of the key outputs has been the identification of mitigation measures to be undertaken in order to ensure that residual impacts comply with regulatory requirements plus the requirements of the EIAO TM.  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 14A and B) may be tracked and its effectiveness assessed.

14.1.1                            Implementation of EIA Findings and Recommendations

Sections 6 to 12 have, where appropriate, identified and recommended the implementation of mitigation measures to reduce the potential construction and operational impacts of the Project.  These findings and recommendations form the primary deliverable from the whole EIA process and will form an agreement between HK Electric 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 and operation.

The required format for the Implementation Schedule (Annex 14A and B) 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.

14.1.2                            Statutory Requirements

As the Project constitutes a Designated Project under the EIAO, an Environmental Permit must be obtained before construction or operation of the proposed wind farm and associated facilities. 

Upon approval of the EIA Report, HK Electric can apply for an Environmental Permit.  If the application is successful, the Environmental Permit may, have conditions attached to it, which must be complied with.  In addition, HK Electric and its appointed Contractor(s) must also comply with other controlling environmental legislation and guidelines, which are discussed within the specific technical chapters of this report. 

14.2                                  Environmental Management Plan

HK Electric’s construction Contractors will be contractually bound to produce and implement an Environmental Management Plan (EMP).  EMPs 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.  The primary reason for making the EMP a contractual requirement is to ensure that the Contractor is fully aware of his environmental responsibilities and to ensure his commitment to achieving the specified standards.

To evaluate a contractor’s commitment, each contract bidder shall be required to produce a preliminary EMP as part of the tendering process.  The skeletal EMP will indicate the determination and commitment of the contractor and indicate how the contractor intends to meet the environmental performance requirements laid out in the EIA.  Upon Contract Award, the successful bidder(s) will be required to submit a draft and final version of the EMP for approval by HK Electric prior to the commencement of the work.

14.3                                  EM&A Manual

The EM&A Manual defines 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.  It 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 during the construction phase.  The EM&A team, the Contractor(s) team and the HK Electric’s representatives are included;

·           A broad construction programme indicating those activities for which specific mitigation is required 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 (typically, 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 reduced 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 will undergo a series of revisions, as needed, to accommodate the progression of the construction programme.

14.3.1                            Objectives of EM&A

The objectives of carrying out EM&A for the Project include:

·            Providing baseline information against which any short or long term environmental impacts of the projects can be determined;

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

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

·            Verifying the environmental impacts identified in the EIA;

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

·            Taking remedial action if unexpected results or unacceptable impacts arise; and

·            Providing data to enable an environmental audit to be undertaken at regular intervals.

The following sections summarise the recommended EM&A requirements and further details are provided in the EM&A Manual.

14.4                                  Water Quality

14.4.1                            Construction Phase

The EIA indicated that water quality monitoring will be required during the construction phase for the following activities:

·         Dredging works in the nearshore cable landing area; and,

·         Jetting for the cable installation.

Water quality monitoring results will be compared to Action and Limit levels to determine whether impacts associated with the works are acceptable.  An Event and Action Plan provides procedures to be undertaken when monitoring results exceed Action or Limit levels.  The procedures are designed to ensure that if any significant exceedances occur (either accidentally or through inadequate implementation of mitigation measures on the part of the Contractor(s)), the cause is quickly identified and remedied, and that the risk of a similar event re-occurring is reduced.

Action and Limit levels will be used to determine whether modifications to the operations are required.  Action and Limit levels are environmental quality standards chosen such that their exceedance indicates potential deterioration of the environment.  Exceedance of Action levels can result in an increase in the frequency of environmental monitoring, modification of operations and implementation of the proposed mitigation measures.  Exceedance of Limit Levels indicates a greater potential deterioration in environmental conditions and may require the cessation of works unless appropriate remedial actions, including a critical review of plant, working methods and mitigation measures, are undertaken.  Before construction work commences four consecutive weeks of baseline monitoring will be undertaken at stations identified as detailed in the EM&A Manual.

In order to minimise the water quality impacts to the isolated coral colonies at the cable landing site, a silt curtain will be provided around the grab dredging works.

The full details of the EM&A programme for water quality is presented in the EM&A Manual for this Project.

14.4.2                            Operation Phase

As no unacceptable impacts have been predicted to occur during the operation of the proposed wind farm, monitoring of impacts to marine water quality during the operational phase is not considered necessary. 

14.5                                  Waste Management

In order to ensure that the construction Contractor(s) has implemented the recommendations of the EIA Report, regular site audits will be conducted of the waste streams, to determine if wastes are being managed in accordance with the approved procedures and the site Waste Management Plan.  The audits will look at all aspects of waste management including waste generation, storage, recycling, transport and disposal.  An appropriate audit programme will be undertaken with the first audit conducted at the commencement of the construction works. 

14.6                                  Terrestrial Ecology

The implementation of the ecological mitigation measures stated in Section 8.11.2 should be checked as part of the environmental monitoring and audit procedures during the construction and operation period.

Although no adverse residual impacts are envisaged based on the results of impact assessment, monitoring for bird abundance and distribution for one year of pre-construction phase, one year of the construction phase ([1]) and the first year of operation phase is recommended. 

The purpose of the construction and operation monitoring is to investigate the temporal variation in species occurrence, abundance and distribution of birds before and after the commencement of the wind farm.  Particular focus will be made on species of conservation interest (especially the Birds of Prey including White-bellied Sea Eagle and Black Kite) and migratory birds (eg White-winged Tern, Heuglin’s Gull),

Traditional vessel-based survey will be applied for pre-construction, construction and operation monitoring, which will be undertaken at once per week during migratory season (March to May) and at once/twice per month for the rest of the year.  Line transects survey method will be used at designated sampling locations within the Project Site.  Locations of sampling transects will be finalised during the detailed design stage (after confirmation of the types and siting of the turbines).

The results will be reviewed and analysed after the operation monitoring period.  Should bird abundance be significantly different (taking into account naturally occurring alterations to distribution patterns such as due to seasonal change) to the pre-construction activity (following the operation monitoring), recommendations for a further operation monitoring survey will be made.  Data should then be re-assessed and the need for any further monitoring established.  Significance levels will be quantitatively determined following the operation monitoring which will review up-to-date publicly available information on bird distribution to allow for typical variance levels. 

If, after the first-year operation monitoring period, insignificant variation in bird abundance have been reported then the monitoring will be ceased, as it will have been confirmed that the wind turbine is not having an adverse impact on bird species.

The EM&A Manual provides details of the operational bird monitoring programme.

14.7                                  Marine Ecology

The following presents a summary of the Environmental Monitoring and Audit (EM&A) measures focussed on ecology during the construction and operation phases of the offshore wind farm.  Full details are presented in the separate EM&A Manual.

During the construction phase, the following EM&A measures will be undertaken to verify the predictions in the EIA and ensure the environmental acceptability of the construction works:

·            Water quality impacts will be monitored and checked through the implementation of a Water Quality EM&A programme (refer Section 6 for details).  The monitoring and control of water quality impacts will also serve to avoid unacceptable impacts to marine ecological resources.

·            Marine piling works will be undertaken using hydraulic hammers, which typically have lower sound output than traditional diesel hammers;

·            Marine piling works will take place in daylight hours, sunrise to sunset;

·            Marine piling works for the wind turbines will avoid peak seasons of marine mammals (December to May);

·            Marine piling works will employ ‘soft-starts’ using ramp-up piling procedures;

·            Pre-, during and post-installation monitoring of marine mammal abundance, behaviour and distribution will be undertaken.  Prior to the  commencement of monitoring, methods may include the following to be agreed with the AFCD:

·            Vessel based surveys

·            Passive acoustic monitoring

·           Land-based theodolite tracking A marine mammal/sea turtle exclusion zone will also be implemented and monitored by qualified observers ([2]) for the presence of marine mammals/sea turtles in waters surrounding any marine percussive piling works and dredging works during construction of the wind farm structures and cable route; and,

·           As a total of four octocoral species and one black coral species were recorded during the baseline surveys on the dumped material in the vicinity of the cable route, prior to the commencement of jetting works for the cable route, a pre-construction survey will be undertaken at these sites to confirm the coral existence.  Should these corals be present, mitigation will be applied to be agreed with the AFCD at that time.  Potential mitigation may include relocation of these corals to a location away from the proposed area of works.

Details of the marine mammal/sea turtle exclusion zone monitoring components are presented in full in the EM&A Manual. 

The assessment presented above as indicated that operational phase impacts are not expected to occur to marine ecological resources.  No other marine ecology specific operational phase monitoring is considered necessary.

14.8                                  Fisheries

As no unacceptable impacts have been predicted to occur during the construction and operation of the wind farm, monitoring of fisheries resources during the construction phase is not considered necessary.  The Fisheries Impact Assessment of the EIA recommended a series of mitigation measures for the construction and operation phase of the project.  Details of all the recommended mitigation measures are included within the Implementation Schedule provided in Annex 14A and B.

The water quality monitoring programme will provide management actions and supplemental mitigation measures to be employed should impacts arise, thereby ensuring the environmental acceptability of the Project. 

There will be a need to ensure that the seabed affected by the cable installation works has restored to its original configuration to prevent impacts from occurring to fishing operations.  Consequently, a geophysical survey will be conducted following completion of cable installation works.

A Fisheries Review and Consultation Programme will also be implemented prior to the operation of the wind farm.  The general intention of the FRCP will be to outline, in consultation with the fishery sector, whether there is scope for fishing operations to be conducted within the development area.   If deemed acceptable, a Fisheries Management Plan (FMP) will be developed for the wind farm area. 

14.9                                  Landscape Visual

The Landscape and Visual Assessment of the EIA recommended a series of mitigation measures for the construction phase, including site selection, array layout, colour selection and blade rotation direction, to ameliorate the landscape and visual impacts of the project.  Details of all the recommended mitigation measures are included within the Implementation Schedule provided in Annex 14A and B.

Implementation of the mitigation measures for landscape and visual resources recommended by the EIA will be monitored through the site audit programme. 

During the operational phase, adverse impacts are not expected to occur.  Therefore, no landscape and visual monitoring will be required for the operational phase.

14.10                              Cultural Heritage

No impact to terrestrial and marine archaeology is predicted.  The avoidance of direct impacts to the shipwreck identified during the geophysical survey will be verified by the Environmental Team and the Independent Environmental Checker through review of the final design prior to the installation of turbines and submarine cable.  Designs and subsequent construction works will be checked to ensure that no works will occur within 50 m of the shipwreck.



([1])     Construction phase refers to the one year period including wind turbine construction and pre-commissiong phase, which is the fourth year of the construction programme as stated in Section 5.

([2])     A qualified person with a degree in biology or equivalent shall be employed to carry out monitoring and visual inspection of marine mammals / sea turtles.  The qualification and experience of qualified person shall have a degree in marine or environmental sciences and experience in marine mammal observation techniques.