Environmental and Social Management Plan for Capital Works

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1 Environmental and Social Management Plan for Capital Works Northern Arterial For resource consent - July 2014 DRAFT

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3 Page iii [This is a template to be used to prepare an Environmental and Social Management Plan for Capital Works. All notes in square brackets should be deleted or edited and should not form part of the plan without modification. Further information on preparing and implementing an Environmental and Social Management Plan for Capital Works is provided in the NZTA Guideline for Preparing an Environmental and Social Management Plan, which is available from Template version 1.2, April 2014] Record of amendment Amendment number Description of change Effective date Updated by

4 Page iv Contents 1. Background Scope and Purpose Description Location Environmental Policy Environmental Objectives/Key Performance Indicators Roles and Responsibility 6 3. Environmental and Social Management Environmental and Social Impacts Environmental Risk Register Legislative Requirements National Legal Requirements Project Approvals NZTA Consent Compliance Management System Implementation and Operation Environmental Aspect Management Plans or Maps Operating Procedures Communications Procedures Communications Register Transition Phase Emergency Contacts and Response Training Monitoring and Review Compliance Monitoring Audits Corrective and Preventive Action Incident / Accident Investigation Preventative Action Management Review Appendix A. Requirements Checklist 19

5 Page 1 1. Background This Environmental and Social Management Plan (ESMP) is provided in draft form to demonstrate the content and outlines structure of the final ESMP regarding details, principles, practices and procedures to be implemented by the Northern Arterial (NArt) Contractor. These details, principles, practices and procedures are intended to meet the conditions of resource consents, designations, other relevant legislation and the environmental objectives of the NZ Transport Agency (NZTA). The final ESMP will be completed prior to the start of the construction of the NArt by the appointed Contractor. It should be noted that the final ESMP will be a working document, updated by the Main Contractor on a regular basis to reflect changes in construction methodology and to ensure the ESMP remains fit for purpose. Details of the actual and potential environmental effects arising from construction and how these will be mitigated are detailed in the Assessment of Effects on the Environment (AEE) and specialist mitigation plans developed by thematic specialists. 1.1 Scope and Purpose This ESMP is the umbrella document for environmental management of the construction phase of the NArt Project. This ESMP will be reviewed after confirmation of the resource consent and designation conditions, and the document revised in accordance with these conditions. The ESMP should be updated, throughout the course of the Project to reflect material changes associated with changes to construction techniques or the physical environment. While all sections should be reviewed prior to implementation, sections to be completed or significantly updated prior to works commencement by the Main Contractor, are clearly labelled throughout this Draft ESMP. The purpose of this ESMP is to ensure the project meets the conditions and requirements of the resource consents and designations, relevant legislation and the NZTA s environmental objectives. The ESMP establishes the framework of management plans and protocols for implementation during construction. The final ESMP to be submitted by the Contractor will outline all details required to enable the NZTA and the Contractor to undertake construction works whilst ensuring these works meet the appropriate environmental standards. Overall, the implementation of the ESMP will manage: Compliance with the conditions of resource consents and designations Compliance with appropriate legislation The requirements of Section 176A of the RMA (outline plan) for construction of the Project Adherence to the NZTA s environmental objectives Environmental risks associated with the Project. One of NZTA's prime objectives during the construction and operation of the NArt is to ensure that adverse effects on the environment are adequately avoided, remedied or mitigated. To achieve this NZTA will: make environmental management a core consideration in the management process ensure a partnership approach between NZTA, the Contractor and local authority monitoring staff

6 Page 2 ensure adequate resourcing of environmental management activities require the Contractor to appoint staff responsible for environmental management aspects undertake monitoring and auditing of the project works to:- o o determine the effectiveness of the environmental management activities being undertaken document and report on the outcomes. The ESMP defines details of who, what, where, when and how environmental management and mitigation measures should be implemented. This ESMP will require review and amendment during the construction phase of the Project to reflect changes to activities, risks, mitigation measures, responsibilities and management processes. The ability to make changes to the ESMP is an important aspect of continually improving its effectiveness. Modification will be required once the consents and designations are obtained and detailed design and construction methods finalised. In preparing this ESMP, the following considerations have been factored into the development process for mitigation measures: the identified significant environmental issues within the main Assessment of Environmental Effects Report (AEE) the extent and duration of the activities (e.g. multiple year construction project) the location, and in particular the vicinity to sensitive receiving environments the principle that environmental management needs to be incorporated into day-to-day operations. Description Project name and State highway number: Council(s) who have jurisdiction: Construction period: Nature of works being undertaken: SH74 Northern Arterial Christchurch City Council, Waimakariri District Council and Environment Canterbury 3 years Capital project The NZ Transport Agency (the NZTA) proposes to construct, use and maintain a new 4-lane median divided arterial road directly linking the Christchurch Northern Motorway (SH1) with Queen Elizabeth II Drive (QEII Drive) and Winters Road (the Northern Arterial). Where the new Northern Arterial ties into the Christchurch Northern Motorway (SH1), additional laning up to and over the Waimakariri River Bridge will be required. The NZTA also proposes to widen, use and maintain QEII Drive to four lanes between Main North Road and just beyond Innes Road (QEII 4Laning). The key aspects of the project are summarised as: A new lane will be added to the Waimakariri River SH1 Bridge The Northern Arterial will be a four lane motorway; Access onto the motorway will be limited; QEII Drive widening will be on the northern side; A pedestrian/cycle way will be provided along the general line of the route from Belfast Road to QEII Drive, and on the south side of QEII Drive;

7 Page 3 The end sections of Ford Road and Factory Road will be closed; Prestons Road will be realigned and will go over the motorway on a bridge (with the motorway being an underpass ); Guthries Road will remain open but will be realigned; Belfast Road and Radcliffe Road will go over the motorway on bridges (with the motorway being an underpass ). Provision will be made for the future possibility of access in a southerly direction on and off the motorway from Belfast Road; A bridge across the Styx River and three crossings of Kaputone Creek will be required; The motorway s southern connection with QEII Drive (the Southern Interchange) will go over QEII Drive as a flyover (or motorway overpass ) with a north-south priority; and A link will be provided between the Southern Interchange and Winters Road west of the Northern Arterial which will make it possible to access Winters Road from all directions via the Southern Interchange. Location Insert here Figure 1: Location plan Insert here Figure 2: Route plan 1.2 Environmental Policy To ensure that environmental management on this Project aligns with the NZTA s policy framework for environmental management, the Project will be undertaken in accordance with the NZTA Environmental Policy, objectives and key performance indicators. The NZTA has a number of policies governing its operations in accordance with s96 of the Land Transport Management Act 2003 that defines the Agency s operating principles particularly the need to exhibit a sense of social and environmental responsibility (s96(1)(a)).

8 Page Environmental Objectives/Key Performance Indicators The NZTA adopted the Transit New Zealand (TNZ) Environmental Plan 2008, which outlines key social and environmental impacts that are relevant to the NZTA s activities. The relevant objectives associated with construction are: Noise: N2 Determine reasonable noise requirements when seeking or altering existing designations

9 Page 5 including when designating existing local roads by using RMA procedures. N3 Manage construction and maintenance noise to acceptable levels. Air Quality: A1 A2 Understand the contribution of vehicle traffic to air quality. Ensure new State highway projects do not directly cause national environment standards for ambient air quality to be exceeded. Water Resources: W1 W2 W3 Ensure run-off from State highways complies with RMA requirements. Limit the adverse effects of run-off from State highways on sensitive receiving environments. Ensure stormwater treatment devices on the network are effective. Erosion and Sediment Control: ES1 ES2 ES3 Ensure construction and maintenance activities avoid, remedy or mitigate effects of soil erosion, sediment run-off and sediment deposition. Identify areas susceptible to erosion and sediment deposition and implement erosion and sediment control measures appropriate to each situation with particular emphasis on high-risk areas. Use bio-engineering and low-impact design practices where practicable. Social Responsibility: SR1 Enhance and contribute to community cohesion. Culture and Heritage: H1 Proactively limit the disturbance of significant cultural and heritage features along State highways. Ecological Resources: E1 E2 E3 Promote biodiversity on the State highway network. No net loss of native vegetation, wetlands, critical habitat or endangered species. Limit the spread of plant pests. Spill Response and Contamination: S1 S2 Design stormwater control and retention devices that can accommodate spills in areas of high environmental risk. Ensure the removal, placement and disposal of contaminated soils is achieved in accordance with best practices. Resource Efficiency: RE1 Manage energy consumption and waste associated with NZTA s business in a cost effective and sustainable manner.

10 Page 6 Climate Change: Adaptation and Mitigation C3 Mitigate activities associated with the construction, operation and maintenance of State highways to effect a net reduction of GHG from transport. Visual Quality: VQ1 Incorporate multi-purpose landscaping as an integral part of all new State highway construction projects. Vibration: V1 V2 V3 Plan and design new State highways to avoid or reduce adverse vibration effects. Mitigate vibration where levels are unreasonable and exceed relevant criteria set in New Zealand or internationally accepted thresholds. Avoid or reduce, as far as practicable, the disturbance to communities from vibration during construction and maintenance. 2. Roles and Responsibility The final management roles for the construction of the Project will be based around the following roles: Project Manager Construction Manager Environmental Manager and/or Planning Manager Stakeholder Relationship/Communications Manager Site supervisor/project Engineer. These roles will be confirmed once the contract documents are confirmed. Depending on the Contractor s proposed team structure, a combination of these roles may be able to be combined, so long as the following principles are able to be maintained: Accountability for all environmental management responsibilities ultimately rests with the Project Manager The Environmental and/or Planning Manager s roles provide a clear management structure for monitoring consents. If required, the roles can be merged into one, and delegation of responsibilities can be passed to other roles if appropriate. For example, the Contractor may choose to employ an Erosion and Sediment Control Manager who may have responsibility for implementing and monitoring the conditions of consent around sediment control. The key management roles from each organisation in relation to environmental management during the construction of the Project are outlined below:[insert ORGANISATION CHART HERE]

11 Page 7 Table 1: Accountabilities in the ESMP Role Whom Responsibilities NZTA Environment Canterbury Christchurch City Council Main Physical Works Contractor Consent Holder and Asset Owner Environmental Representative Project Manager Environmental and/or Planning Manager Construction Manager Stakeholder relationship/ Communications Manager Compliance with the RMA and with any condition of the designations and resource consents Review of Contractors site specific environmental management plans, and relevant Management Plans. Note: Waimakariri District Council role relates to the Outline Plan only Overall responsibility for site environmental management Reviewing and reporting on environmental performance Inspections, auditing and checking of environmental management practices and procedures Report to the NZTA changes to construction techniques or natural environmental changes which require alterations to the consents/ designations or new resource consents and designations Facilitate and oversee environmental monitoring Prepare, review and update of specific Management Plans Inspection of works to assess compliance with the ESMP and Management Plans Training of all staff including sub-contractors Maintain Complaints, Incidents and Non Compliance forms Sub-Contractors Construction Manager Adherence to the Management Plans Preparation/variation of specific Management Plans as required MSQA Alliance On-site compliance with resource consent and designation conditions and other requirements and tracking compliance information on CS-VUE. Outline Plan of Works Local Authorities Consent Manager Commenting on specific Management Plans. Auditing to assess whether the resource consent and 3. Environmental and Social Management 3.1 Environmental and Social Impacts designation conditions are being complied with As part of the management of significant risks and opportunities associated with the Project, an Environmental Risk Register will be developed by the Contractor. The register will identify potential significant environmental benefits that may be able to be created and managed during construction. The register will also identify significant risks. The register will develop from information contained within the AEE prepared for the Project.

12 Page 8 Environmental Risk Register An Environmental Risk Register shall be prepared and should be periodically updated by the appointed Main Contractor and Construction Environmental Manager. As a starting point for the Risk Register the AEE development process and the conditions attached to consents and approvals shall be utilised. The Environmental Risk Register, to be populated and maintained by the Main Contractor, is a tool for the identification, prioritisation and management of activities that have the potential to impact on the environment. As part of this update process the Main Contractor is expected to use a recognised Risk Assessment methodology for consensus agreement with the NZTA. The risk assessment process shall define a process of identifying significant risks. These risks are then entered into the Risk Register. The Environmental Risk Register will allow the Main Contractor to search and sort on activities, locations, environmental aspects, and risk ratings, and provide a quick reference to the mitigation measures and controls that are in place to manage the significant impacts. The Construction Environmental Manager will also be required to maintain the Environmental Risk Register. The risk assessment results will need to be reviewed at regular intervals and repeated at critical times within the Project. Triggers for this review and update include: On instruction from NZTA Before commencement of construction (once detailed programme and methodologies are understood) When there is a new or changed activity, equipment or location of activities When there is a change to legislative or consent and designation requirements As a result of a significant environmental incident or non-compliance. The Register will be reviewed and updated on a quarterly basis in the event that none of the preceding activities have already triggered a review. 3.2 Legislative Requirements This ESMP has been produced to outline the framework for how the Project will manage environmental effects during construction and give effect to the relevant policies, plans and resource consent and designations conditions that must be addressed in the construction and operation of this project. National Legal Requirements Construction of the Project must comply with a range of national legislation, regulations, strategies and policies in order to effectively provide for the management of environmental effects. Key documents, national environmental legislation and regulations relevant to the NZTA and the Project are provided below: Resource Management Act 1991 Land Transport Management Act 2003 Hazardous Substances and New Organisms Act 1996 Historic Places Act, 1993 Government Policy Statement on Land Transport Funding 2012/ /22 (GPS) National Environmental Standard Air Quality 2004 (NES: AQ) Reserves Act 1977

13 Page 9 Public Works Act 1981 Wildlife Act 1953 Freshwater Fisheries Regulations 1997 National Environmental Standards for Assessing and Managing Contaminants in Soil to Protect Human Health National Policy Statement for Freshwater Management Project Approvals Other than under the RMA, approvals under other legislation are also required. Approvals are required under the following legislation: Historic Places Act 1993 section 12 authorisations NZTA Consent Compliance Management System CS-VUE is a legal compliance system adopted by the NZTA to manage environmental statutory requirements. It is the NZTA s contractual requirement that CS-VUE is used to track and record the compliance of the following legal obligations: Resource consents Designation conditions Department of Conservation concessions Historic Places Act authorities Any other agreements or obligations which have compliance conditions. CS-VUE is a secure database which matches each consent and condition (or other legal obligation) with a consent manager and condition manger and automatically sends an notifying them of compliance requirements. The Consent Manager is the NZTA Project Manager who is responsible for overseeing consent compliance management, and the condition manager is the consultant who is responsible for ensuring dayto-day compliance. Evidence to demonstrate compliance is entered in CS-VUE with all entries/changes annotated with the person s name and date who undertook the changes. Post-construction, the responsibility of any conditions which have on-going maintenance and operational requirements will be transferred to the NZTA Asset Manager.

14 Page Implementation and Operation 4.1 Environmental Aspect Management Plans or Maps The Management Plans are the next tier of plans to manage environmental effects. They set out the environmental management approach and provide principles that are applied site-wide, setting out how design criteria and performance standards will be met. The Management Plans bring together the principles of the ESMP and focus on specific effects, for example the management of construction noise and vibration. The suite of Management Plans comprises: Draft Erosion, Sediment and Dust Control Plan Draft Dewatering Management Plan Construction Noise and Vibration Management Plan Draft Waterway Management Plan Draft Hazardous Substances and Spill Contingency Plan. These plans will all be live documents and will be updated and revised as the construction methodology, regulatory environment and requirements for managing the various effects change over time and will reflect changes to activities, risks, mitigation measures, responsibilities and management processes. This reflects the fact that the construction methodology cannot be fully confirmed until the detailed design is completed, a Contractor appointed and detailed construction planning commences. The ability to make changes to the ESMP and Management Plans is an important aspect of continually improving the effectiveness of the ESMP making sure it remains fit for purpose. The Contractor will be required to undertake all construction activities on site in accordance with the provisions of the ESMP, relevant Management Plans and resource consent and designation conditions. 4.2 Operating Procedures Operating procedures will be established within the ESMP to ensure the Project stays within the environmental and social objectives and requirements as set out within the ESMP. Communication procedures will be key in ensuring the ESMP is implemented and the environmental and social objectives and requirements are meet. Communications Procedures A dedicated Stakeholder Relationship/Communications Manager will be appointed for the construction phase of the Project, who will manage all public consultation, engagement, enquiries and complaints. The following procedures will be developed for engaging with the public: All enquires/complaints received by telephone will be forwarded directly to the Stakeholder Relationship/Communications Manager who will determine the appropriate person to respond to the request All enquires/complaints will be managed through an online complaints register, which can be regularly updated All enquires/complaints addressing issues that form part of Management Plans will also be housed in the register. Enquires/complaints details will include:

15 Page 11 Full name of the caller (if they are willing to provide it) Time/date of call Detailed outline of the call Timeframe required to close out the complaint/enquiry. Communications Register A Communications Register will be kept for the Project, electronically. All enquiries and complaints will be logged. Responses to the questions will be tracked and closed out within an agreed timeframe between the respondent and the NZTA. Consultation During construction, consultation with affected parties may be required for: Construction Noise and Vibration - targeted consultation with individual property owners located within close proximity to the site. It is noted that this is a requirement of the Construction Noise and Vibration Management Plan when noisy works are proposed close to people. A revised construction methodology due to unforeseen physical constraints. Communications The impacts of the Project, especially from construction, will be noticeable for the local communities which the Project will interface. Open, two-way communication will be provided to keep the community informed about what is happening in their neighbourhood. A general communications strategy will be developed and will include the following mechanisms to communicate with the general public: Website 24hr 0800 number Mail Drops Brochures and Billboards Newsletters Information on the project will be available on the NZTA NArt Project website. The website will be updated frequently by the Stakeholder Relationship/Communications Manager and will provide details on construction, contact details, consultation processes, and frequently asked questions. A 0800 contact number will be set up prior to construction to field any calls relating to the Project. This is an important avenue for stakeholders and members of the public to communicate with the NZTA and contractor. All calls will be recorded, identifying all feedback (both positive and negative), issues that need to be addressed and other enquiries. During and prior to key stages of construction, targeted mail drops will outline and forewarn the public of construction activity within their area, and provide information on the progress of the Project. The contact details of the Stakeholder Relationship/Communications Manager s will be included. Brochures and flyers on the Project will be readily accessible to the public. There will also be billboards positioned around the site, which will include the name, telephone number, and address for service of the Site and Project Manager as well as the Stakeholder Relationship/Communications Manager. The Project Team will provide a regular bulletin, advising stakeholders and interested parties on Project updates and news. This may take the form of an e-newsletter, to which anyone can subscribe.

16 Page 12 Media coverage In addition to advertising in the local press, in selected publications and through other media, the Stakeholder Relationship/Communications Manager will provide regular updates to the media and encourage regular editorial updates through print, television and radio channels Transition Phase The transition phase is the crossover period between the construction and operational phases of the Project whereby the responsibility for the management of the environment is transferred from the construction contractor to the network operators. During this phase the construction contractor(s) will be required to work with the NZTA, ECan and CCC in finalising the construction and meeting any post-construction resource consent and designation conditions. The transition phase also provides for the transfer of information in relation to consent and designation conditions which remain operative (such as long term monitoring), and historical results of environmental management and monitoring that are pertinent to effective ongoing management of the environment. Consents and designation conditions still operative are to be entered into the OMC s CS-VUE permit file and managed by the OMC. NZTA environmental information transferred to the OMC includes: Landscape design and as-builts Agreements between key stakeholders (e.g., landowners) Information on environmentally sensitive areas Monitoring requirements Historical monitoring results Results of audits and inspections in relation to environmental risks that were identified as significant in the risk assessment process A report on consent and designation conditions that have been closed out on CS-VUE. This information is to be collated following the completion of construction works. In addition, this information will be included in the asset owner s manual (prepared in accordance with the NZTA s Standard Professional Services Guideline PSG/15) and operations and maintenance manuals prepared by the Contractor and handed to the relevant OMC. 4.3 Emergency Contacts and Response In the event of a non-compliance with a resource consent or designation condition, other statutory approval or other regulatory requirements, and if an incident occurs that results in a significant adverse environmental effect, the following shall occur: 1. Immediate action will be taken to stabilise the situation (i.e. cease work, turn off or move machinery, deploy spill equipment). All spills shall be contained, recovered and disposed of appropriately 2. The Contractor shall contact the relevant Council within 24 hours, or sooner if appropriate to the situation (for example, a significant oil spill) 3. Any affected parties shall be contacted as soon as possible if an incident occurs that may affect any land outside of the Project area 4. All steps necessary to mitigate the incident shall be taken. Other external agencies shall be contacted where appropriate

17 Page An incident report shall be prepared that shall include, as a minimum: o o o o o o A Description and location of the incident/ non-compliance The likely cause of the incident/ non-compliance Potential or actual effects of the incident/ non-compliance Mitigation and remedial action taken Preventive action / changes to prevent a re-occurrence of the incident/ non-compliance Monitoring results. Table 2: Internal Environmental Emergency Contact Details Role Name Organisation Phone e.g. Environmental Manager J Smith Smith and Co jsmith@smith.co.nz Table 3: External Environmental Emergency Contact Details Role Organisation Phone e.g. Emergency Services Fire, Police, Ambulance Training All personnel will be required to be appropriately qualified and/or trained for their particular role. The training is to be relevant to their different roles to ensure that they are aware of: The importance of conformance with the environmental policy and procedures and with the requirements of this ESMP The actual and potential environmental impacts of their work activities and the environmental benefits of improved personal performance Their roles and responsibilities in achieving conformance with the environmental policy and this ESMP The potential consequences of departure from specified operating procedures. The Project specific site environmental induction will include an overview of resource consent conditions, designation conditions, permitted activity standards, environmental control procedures and the Management Plans. Specific individuals with environmental responsibilities may require training in: Emergency response; Spill kits; Environmental auditing; and Sampling and Monitoring. All environmental training records are to be held at the Project Construction Office. The Construction Environmental Manager will have responsibility for maintaining and updating these records.

18 Page 14 Table 4: Training Log Type of Training Purpose Convenor Attendees Date completed e.g. Erosion and Sediment Control Course To train the teams awareness of erosion and sediment control on site R Mitchell D Greig R Hannaby J Bell

19 Page Monitoring and Review 5.1 Compliance Monitoring Environmental monitoring of the Project will primarily be based around the monitoring of: Erosion and sediment controls Water quality Dust / air quality Noise and vibration Hazardous substances General construction management. Monitoring of these effects (both positive and adverse) will provide an immediate picture to all parties of the progress of the Project, scale of potential effects, and mitigation employed. Monitoring will be based on two levels depending on the Management Plans and will align with conditions: Construction monitoring Level 1: Scheduled Operational Monitoring Regular periodic monitoring to be undertaken prior to and during the construction period. Construction monitoring Level 2: Triggered monitoring Monitoring to be undertaken when certain environmental conditions or incidents are encountered. Monitoring will be carried out principally by the Contractor. All consent and designation conditions for the NZTA will be managed through CS-VUE. CS-VUE is an online monitoring system, which houses all of the NZTA s consents and designations for the State Highway network. For construction associated with the Project all consents and designations will be managed through the CS-VUE compliance management system. 5.2 Audits The Environmental Manager will undertake monthly audits of compliance with the ESMP. These will include a review of site documentation, records and an inspection of site activities. Based upon the findings of these audits the Environmental Manager will develop a report identifying non-compliances, improvements and opportunities for enhancements and specifying agreed corrective actions. Review The Environmental Manager will, as a minimum, undertake a quarterly review of the ESMP in order to identify any required amendments. A review will also be undertaken in the event of significant changes to activities on site or in response to certain incidents. The findings of the review and proposals for amendments to the ESMP will be circulated to key team members (e.g. Project Manager, Construction Manager, Environmental/Planning Manager). If appropriate, findings relating to compliance with consent and designation conditions will be communicated to regulatory authorities.

20 Page 16 Compliance The Environmental Manager will undertake system audits on a monthly basis and will report back to the Project Manager on performance. In addition, periodic audits of the management of the Project will be undertaken in order to assess compliance with NZTA SM030 Z/4 Contractor s Social and Environmental Management Plan specification requirements. Mechanism for Revision There are two main reasons for changing the ESMP after it has been made final. These are: As a result of regular reviews made during the life cycle of the project which will ensure the ESMP remains fit for purpose and continues to meet social, environmental and regulatory requirements. If there has been a significant change in the construction methodology or activities undertaken on the site. Any change made to the ESMP will need to comply with all of the necessary social and environmental requirements of the Project, including the conditions of the consent and designations granted in respect to this Project. The NZTA anticipate that the altered ESMP will be submitted to the relevant regulatory authorities for their record. Reporting Records will take a number of forms including: Monitoring Data Data collated from monitoring activities will be stored in a document management system for the Project and will be available online and in hard copy on the Project website. Inspection Records As set above, a number of activities will be regularly inspected. For each inspection a checklist or form will be completed to provide a written report of findings. These will be reviewed during site meetings and project audits. Reviews Audit activities will provide a review of overall ESMP performance. Communications All internal and external communications relating to environmental performance, including any complaints, will be collated and maintained. Training Records In order to demonstrate that all site personnel have received appropriate training, records will be made available. These records will be regularly reviewed to identify further training requirements. Finally, a ESMP review report will be generated and submitted to inform relevant parties of environmental performance on the Project. This report shall be completed by the Environmental Manager, who will produce a monthly Management Review Report, based on the findings of the ESMP Audit, to be submitted to the Project Manager. This report will contribute to a regular management review of the effectiveness of the ESMP.

21 Page 17 NZTA Monitoring and Review Following construction of the route, all monitoring of conditions of consents and designations for the NZTA will be managed through the CS-VUE compliance management system. Handover of responsibilities for enforcing compliance with operational consents and designations conditions will be given to the NZTA Area Engineer and will be managed by the NZTA Network Management Consultant. 5.3 Corrective and Preventive Action The identification, reporting and rectification of environmental effects will be promoted at site inductions. System deficiencies identified during audits will be documented and rectified within agreed timeframes. Work practice deficiencies or non-compliance with site rules identified at any time during the works will be recorded in Hazard Identification books, which will be carried by all personnel in Occupational Health and Safety and Environmental roles. Generally, the person identifying the unsafe condition will, if possible, rectify the situation immediately. All unsafe conditions or acts identified during inspections or audits will be recorded in a Hazard Register / Incident Database to monitor recommended actions and close out. Incident / Accident Investigation Incidents, accidents and non-conformances with the ESMP or with legal requirements and near miss events will be reported and recorded in an on-site register. The incident/accident will be investigated to identify how the incident/accident occurred and to review and rectify the process so the incident/accident does not happen again. This will be recorded on the Opportunity for Improvement (OFI) register. Actions identified through the OFI to improve the process or system shall be developed by the construction management team and signed off by the Environmental Manager. All information will be recorded into the Occupational Health and Safety systems for the on-site Environmental Team. The Environmental Manager will review all environmental OFIs raised on a weekly basis to close out in the timescales specified. Preventative Action To proactively manage potential environmental issues, a safety and environment committee will be responsible to review the following: OFI registers Environmental alerts from other projects Changes to legislation. After reviewing all relevant information, any opportunities to improve site procedures will be incorporated into environmental education provided on the Project. 5.4 Management Review This document will be reviewed after confirmation of the resource consent and designation conditions and will be revised in accordance with those conditions. The ESMP and the Management Plans will be updated, with any necessary approval, throughout the course of the Project to reflect material changes associated with changes to construction techniques or the natural environment. Any changes to the Erosion Sediment and Dust Control, Waterway and Dewatering Plans will be submitted to ECan.

22 Page 18 A management review of the ESMP will be undertaken at least annually by the Project Management team and the Project Manager. This is independent of the monthly audits but will take the findings of these audits into account. The management review will be organised by the Environmental Manager. The review will take into consideration: Input from the NZTA Site personnel comments Audit findings and recommendations Environmental monitoring records Environmental complaints, incidents and emergencies Details of corrective and preventative actions Environmental non-compliances Changes to organisational structure On-going compliance with objectives, conditions and targets Possible changes in legislation and standards. The review process will include looking at the environmental controls and procedures to make sure they are still applicable to the activities being carried out. Reasons for making changes to the ESMP will be documented. A copy of the original ESMP document and subsequent versions will be kept for the Project records, and marked as obsolete. Each new/updated version of the ESMP documentation will be issued with a version number and date to eliminate obsolete ESMP documentation being used.

23 Page Appendix A. Requirements Checklist [This checklist is to be filled in, which will allow the reviewer of the Environmental and Social Management Plan to clearly establish if the minimum requirements have been complied with] 1. Background ESMP Scope Description Location Management Plan Framework Included Yes No Comment Environmental and Social Responsibility Policy Environmental Objectives Roles and Responsibility 2. Environmental and Social Management Environmental and Social Impacts Legislative Requirements 3. Implementation and Operation Environmental Aspect Management Plans or Maps Operating Procedures Emergency Contracts Training 4. Monitor and Review Monitoring Audits Corrective and Preventive Action Management Review

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