11 Reporting

11 REPORTING

11.1.1.1 The types of reports that the ET should prepare and submit include the Baseline Monitoring Report, Monthly EM&A Reports and Final EM&A Review Report. In accordance with Annex 21 of the EIAO-TM, a copy of the monthly and final review EM&A reports should be made available to the Director of Environmental Protection (DEP). All the monitoring data (baseline and impact) should be submitted in an electronic medium.

11.2 Baseline Monitoring Report

11.2.1.1 The ET should prepare and submit a Baseline Monitoring Report within 10 working days of the completion of the baseline monitoring. Copies of the Baseline Monitoring Report should be submitted to the Contractor, IEC, Engineer and EPD. The ET should liaise with the relevant parties on the exact number of copies required.

11.2.1.2 The Baseline Monitoring Report should include at least the following information:

(i) An Executive Summary of up to half a page;

(ii) A brief description of the project background;

(iii) Drawings showing locations of the baseline monitoring stations;

(iv) Monitoring results (in both hard and diskette copies) together with the following information:

· Monitoring methodology;

· Name of laboratory and types of equipment used and calibration details;

· Monitoring parameters;

· Monitoring locations;

· Monitoring date, time, frequency and duration; and

· QA/QC results and detection limits.

(v) Details of the influencing factors, including:

· Major activities, if any, being carried out on-site during the period;

· Weather conditions during the period; and

· Other factors which might affect the monitoring results.

(vi) Determination of the Action and Limit Levels for each monitoring parameter and statistical analysis of the baseline data. The analysis should conclude if there is any significant difference between the control and impact stations for the parameters monitored, where appropriate;

(vii) Revisions for inclusion in the EM&A Manual; and

(viii) Comments and conclusions.

11.3 Monthly EM&A Reports

11.3.1 Background

11.3.1.1 The results and findings of the EM&A programme required in this EM&A Manual should be recorded in the monthly EM&A reports prepared by the ET and endorsed by IEC. The EM&A reports should be prepared and submitted within 10 working days of the end of each reporting month, with the First Monthly EM&A Report due in the month after the major construction works commences. Copies of each monthly EM&A report should be submitted to the Contractor, Engineer, IEC and EPD. Before the submission of the First Monthly EM&A Report, the ET should liaise with the relevant parties on the exact number of copies and format of the reports in both hard and electronic copies.

11.3.1.2 The ET should review the number and location of the monitoring stations and parameters every six months, or on as-needed basis, in order to cater for any changes in the surrounding environment and the nature of works in progress.

11.3.2 First Monthly EM&A Report

11.3.2.1 The First Monthly EM&A Report should include at least but not limited to the following information:

(a) Executive summary (1-2 pages):

· Breaches of the Action and Limit levels;

· Complaint log;

· Notification of any summons and successful prosecutions;

· Reporting changes; and

· Future key issues.

(b) Basic project information:

· The project organisation including key personnel contact names and telephone numbers;

· The construction programme;

· The management structure; and

· Works undertaken during the reporting month.

· Advice on the status of the statutory environmental compliance, e.g. EP conditions under the EIAO, submission status under the EP and implementation status of mitigation measures, etc;

· Works undertaken during the reporting month with illustrations (e.g. location of works, etc); and

· Drawings showing the project area, environmental sensitive receivers and locations of the monitoring and control stations.

(d) Summary of EM&A requirements:

· All monitoring parameters;

· Environmental quality performance limits (Action and Limit levels);

· Event and Action Plans;

· Environmental mitigation measures, as recommended in the EIA report; and

· Environmental requirements in contract documents.

(e) Implementation status:

· Advice on the implementation status of environmental protection and pollution control/mitigation measures as recommended in the EIA report, summarised in the updated implementation schedule.

(f) Monitoring results (in both hard and diskette copies) together with the following information:

· Monitoring methodology;

· Name of laboratory and types of equipment used and calibration details;

· Monitoring parameters;

· Monitoring locations;

· Monitoring date, time, frequency and duration;

· Graphical plots of the monitoring parameters in the reporting month annotated against the following information;

- Major activities being carried out on site during the reporting period;

- Weather conditions during the reporting period;

- Any other factors which might affect the monitoring results; and

- QA/QC results and detection limits.

(g) The report on the non-compliances, complaints, notifications of summons and status of prosecutions:

· Records of all non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

· Records of all complaints received (written or verbal), including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

· Records of all notification of summons and successful prosecutions for breaches of current environmental protection / pollution control legislation, including locations and nature of the breaches, investigation, follow-up actions taken, results and summary;

· The review of the reasons for and implications of non-compliances, complaints, summons and prosecutions including the review of pollution sources and working procedures; and

· Descriptions of the actions taken in the event of non-compliances and deficiency reporting and any follow-up procedures related to the earlier non-compliances.

(h) Others:

· A forecast of the works programme, impact predictions and monitoring schedule for the next three months;

· An account of the future key issues as reviewed from the works programme and work method statements;

· Advice on the solid and liquid waste management status;

· Comparisons of the EM&A data in the reporting month with the EIA predictions and annotate with explanation for any discrepancies; and

· Comments (e.g. the effectiveness and efficiency of mitigation measures), recommendations (e.g. any improvement in the EM&A programme) and conclusions.

11.3.3 Subsequent Monthly EM&A Reports

11.3.3.1 The subsequent monthly EM&A reports during the construction phase should include the following information:

(i) Executive summary (1-2 pages):

· Breaches of the Action and Limit levels;

· Complaint log;

· Notifications of any summons and successful prosecutions;

· Reporting changes; and

· Future key issues.

(ii) Basic project information:

· The project organisation including key personnel contact names and telephone numbers;

· The construction programme;

· The management structure; and

· Works undertaken during the reporting month.

(iii) Environmental status:

· Advice on the status of statutory environmental compliance, status of compliance with EP conditions under the EIAO, submission status under the EP and implementation status of mitigation measures;

· Works undertaken during the reporting month with illustrations (such as location of works, etc); and

· Drawing showing the project area, environmental sensitive receivers and locations of the monitoring and control stations.

(iv) Implementation status:

· Advice on the implementation status of environmental protection and pollution control / mitigation measures as recommended in the EIA report, summarised in the updated implementation schedule.

(v) Monitoring results (in both hard and diskette copies) together with the following information:

· Monitoring methodology;

· Name of laboratory and types of equipment used and calibration details;

· Parameters monitored;

· Monitoring locations (and depth);

· Monitoring date, time, frequency and duration;

· Graphical plots of the monitoring parameters in the month annotated against the following information;

- Major activities being carried out on site during the reporting period;

- Weather conditions during the reporting period;

- Any other factors which might affect the monitoring results; and

- QA/QC results and detection limits.

(vi) The report on non-compliances, complaints, notifications of summons and status of prosecutions:

· Records of all non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

· Records of all complaints received (written or verbal), including the locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

· Records of all notification of summons and successful prosecutions for breaches of current environmental protection/pollution control legislation, including locations and nature of the breaches, investigation, follow-up actions taken, results and summary;

· The review of the reasons for and implications of non-compliances, complaints, summons and prosecutions including review of pollution sources and working procedures; and

· Descriptions of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to the earlier non-compliances.

(vii) Others:

· A forecast of the works programme, impact predictions and monitoring schedule for the next three months;

· An account of the future key issues as reviewed from the works programme and work method statements;

· Advice on the solid and liquid waste management status;

· Comparisons of the EM&A data in the reporting month with the EIA predictions and annotate with explanation for any discrepancies; and

· Comments (e.g. the effectiveness and efficiency of the mitigation measures), recommendations (e.g. any improvement in the EM&A programme) and conclusions.

(viii) Appendices:

· Action and Limit levels;

· Graphical plots of trends of the monitored parameters at key stations over the past four reporting periods for the representative monitoring stations annotated against the following information:

- Major activities being carried out on site during the reporting period;

- Weather conditions during the reporting period; and

- Any other factors that might affect the monitoring results.

· The monitoring schedule for the present and next reporting period;

· Cumulative statistics on complaints, notifications of summons and successful prosecutions; and

· Outstanding issues and deficiencies.

11.3.4 Annual/Final EM&A Review Report – Construction Phase

11.3.4.1 The EM&A programme should be terminated upon the completion of the construction activities that have the potential to cause significant environmental impacts.

11.3.4.2 Prior to the proposed termination, it may be advisable to consult the relevant local communities. The proposed termination should only be implemented after the proposal has been endorsed by the IEC, Engineer and Project Proponent, followed by the approval from the Director of Environmental Protection. The following factors also need to be considered before the termination of the EM&A Programme:

(a) Completion of construction activities and insignificant environmental impacts of the remaining outstanding construction works;

(b) Trends analysis to demonstrate the narrow down of monitoring exceedances due to construction activities and, return of ambient environmental conditions in comparison with baseline data; and

11.3.4.3 The ET should prepare and submit the Final EM&A Report within 14 working days after the completion of the construction activities that have the potential to cause significant environmental impacts. The Final EM&A Report should contain at least the following information:

(a) Executive summary (1 - 2 pages);

(b) Drawings showing the project area, environmental sensitive receivers and locations of the monitoring and control stations;

(c) The basic project information including a synopsis of the project organisation, contacts of key management, and a synopsis of works undertaken during the course of the project or past twelve months;

(d) A brief summary of EM&A requirements including:

· Environmental mitigation measures implemented as recommended in the EIA report;

· Environmental impact hypotheses tested;

· Environmental quality performance limits (Action and Limit levels);

· Monitoring parameters; and

· Event and Action Plans.

(e) A summary of the implementation status of environmental protection and pollution control / mitigation measures, as recommended in the EIA report, summarised in the updated environmental mitigation implementation schedule;

(f) Graphical plots and statistical analysis of the trends of the monitored parameters over the course of the project, including the post-project monitoring for all monitoring stations annotated against:

· Major activities being carried out on site during the reporting period;

· Weather conditions during the reporting period; and

· Any other factors which might affect the monitoring results;

(g) A summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

(h) A review of the reasons for and implications of non-compliances including the review of pollution sources and working procedures as appropriate;

(i) A description of the action taken in the event of non-compliances;

(j) A summary record of all complaints received (written or verbal), liaison and consultation undertaken, action and follow-up procedures taken;

(k) A summary record of the notifications of summons and successful prosecutions for breaches of the current environmental protection / pollution control legislation, locations and nature of the breaches, follow-up investigation taken and results;

(l) A review of the validity of EIA predictions and identification of shortcomings in the recommendations of the EIA study;

(m) Comments (e.g. a review of the effectiveness and efficiency of the mitigation measures and of the performance of the environmental management system, i.e., of the overall EM&A programme); and

(n) Recommendations and conclusions (e.g. a review of the success of the overall EM&A programme to cost-effectively identify deterioration and to initiate prompt effective mitigation action when necessary).

11.3.5 Data Keeping

11.3.5.1 No site-based documents (e.g. the monitoring field records, laboratory analysis records, site inspection forms, etc.) are required to be included in the EM&A reporting documents. However, any such documents should be properly maintained by the ET and be ready for inspection upon request. All relevant information should be clearly and systematically recorded in the document. The monitoring data should also be recorded in magnetic media form, and the electronic copy must be available upon request. All documents and data should be kept for at least one year following the completion of the construction phase EM&A for each construction contract.

11.3.6 Interim Notifications of Environmental Exceedances

11.3.6.1 With reference to the Event and Action Plans, when the environmental quality performance limits are exceeded and if they were proven to be valid, the ET should immediately notify the IEC and EPD, as appropriate. The notification should be followed up with advice to the IEC and EPD on the results of the investigation, proposed action and success of the action taken, with any necessary follow-up proposals. A sample template for the interim notification is presented in Appendix D.