Approved Transmission Line Const Env Mgmt Plan by Mercury

Construction Environmental Management Plan Construction Environmental Management Plan (CEMP) Turitea Transmission Line

This Construction Environmental Management Plan is the property of Electrix Limited. This document is not to be reproduced to third parties without written authority from Electrix.

Job Manager: Customer: Electrix Job No: Version No. Date of Issue:

Kevin Small Mercury NZ Ltd (Mercury) P.0242015.1.01 6.0 2nd August 2019

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Distribution Register Name

Designation

Role Peer Reviewer & Approver

Kevin Small

Project Manager

Emma ComrieThomson Chris Singleton

Environmental Consultant (Electrix) Client

Signature

Date

Approver KS CS KS CS KS CS KS CS KS CS KS CS

Peer Review Approver

Amendment Register Issue No

Issue Date

Description

Author

Reviewer

11 June 2019

Version 1

Emma Comrie-Thomson

13 June 2019

Version 2

Emma Comrie-Thomson

5 July 2019

Version 3

Emma Comrie-Thomson

18 July 2019

Version 4

Emma Comrie-Thomson

2 August 2019

Version 5

Emma Comrie-Thomson

2 August 2019

Version 6

Emma Comrie-Thomson

Environmental Management Plan Approval The undersigned acknowledge they have reviewed the Turitea Transmission Construction Environmental Management Plan (CEMP) and agree with the approach it presents. Changes to this CEMP will be coordinated with and approved by the undersigned or their designated representatives. Name

Designation

Role

Kevin Small

Job Manager

Approver

Chris Singleton

Client - Mercury

Approver

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Signature

Date

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ACRONYMS Acronyms

Defined

AAAC

All Aluminium Alloy Conductor

AEE

Assessment of Environmental Effects

AEMP

Water Quality & Aquatic Ecology Monitoring Plan

AEMRP

Adaptive Aquatic Ecology Management Response Plan

CEMP

Construction Environmental Management Plan

CLG

Community Liaison Group

CNMP

Construction Noise Management Plan

CTMP

Construction Traffic Management Plan

DEB

Decanting Earth Bund

EPT

Ephemeroptera (mayfly), Plecoptera (stonefly) and Trichoptera (caddisfly)

NMP

Noise Management Plan

OPGW

Optic Ground Wires

PNCC

Palmerston North City Council

QMCI

Quantitative Macro-invertebrate Community Index

SDS

Safety Data Sheets

SEMP

Site Environmental Management Plan

SRP

Sediment Retention Ponds

TDC

Tararua District Council

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TABLE OF CONTENTS 1.

BACKGROUND

Introduction Purpose and Application Scope of Works Project Description 1.4.1 Assessment of Environmental Effects Legislative and Other Requirements 1.5.1 National Legal Requirements and Policies 1.5.2 Project Approval Process Principal Contractor - Transmission Line Construction

7 7 9 9 14 14 14 14 14

CONSTRUCTION ACTIVITIES AND EFFECTS

Overview Construction Activities and Environmental Aspects 2.2.1 Construction Duration 2.2.2 Construction Works 2.2.3 Construction Effects 2.2.4 Environmental Risk Register 2.2.5 Review of the Register

15 15 15 15 18 25 25

SEMPS

Design for the works

IMPLEMENTATION AND OPERATION

CEMP Management structure Overview Organisation and Accountability Environmental Training and Induction 4.2.1 Training records Construction procedures inclusive of mitigation measures 4.3.1 Noise 4.3.2 Dust 4.3.3 Construction Machinery and Vehicle Emissions 4.3.4 Erosion and Sediment 4.3.5 Spill Response 4.3.6 Archaeology 4.3.7 Ecological and Landscape Management Traffic Management Emergency Contacts and Response 4.5.1 Incident/Emergency Management 4.5.2 Environmental Incidents Form 4.5.3 Environmental Incident Register 4.5.4 Hazardous Substances Spills and Spills Contingency Planning 4.5.5 Specific Environmental Emergencies Complaints Management

26 26 27 30 30 31 31 31 32 32 36 37 38 40 41 41 43 43 43 44 46

4.1.1 4.1.2

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4.6.1 4.6.2

Complaint Form Complaints Register

46 46

MONITOR AND REVIEW 5.1.1 5.1.2 5.1.3

Compliance Environmental Risk Register Environmental Monitoring Review Environmental Auditing Environmental Reporting CEMP Review

47 47 47 48 48 48 49

List of Figures Figure 1: General location of the site (Figure 1-1 of AEE)........................................................................................... 11 Figure 2: Routes for the line within the consented transmission corridorr. .............................................................. 12 Figure 3: Transmission line route and access roads to site. ....................................................................................... 13 Figure 4: Proposed Project programme. .................................................................................................................... 16 Figure 5: Laydown area for Hazardous Substances .................................................................................................... 25

List of Tables Table 1: Consent conditions relating to CEMP ............................................................................................................. 7 Table 2: Summary of key environmental issues and effects associated with construction. ...................................... 19 Table 3: Vehicle restrictions: Greens Rd and Kahuterawa Road. ............................................................................... 40 Table 4: Management of environmental incidents/emergencies. ............................................................................. 42 Table 5: Environmental Emergency Contact Details. ................................................................................................. 43

List of Appendices Appendix A - Conditions of Resource Consent Appendix B - Community Liaison Group Terms of Reference Appendix C - Environmental Risk Register Appendix D - Environmental Incident Form Appendix E - Complaints Form

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1. Background Introduction This Construction Environmental Management Plan (CEMP) details the principles, practices and procedures to be implemented to manage, remedy and mitigate potential adverse environmental effects during construction of a new 12km long 220kV transmission line to connect Transpower’s existing Linton Substation to the “Plantation Substation” at Mercury’s Turitea Wind Farm (the Project), near Palmerston North. These principles, practices and procedures meet resource consents conditions, relevant legislation and the environmental objectives of the Client, Mercury.

Purpose and Application The purpose of this CEMP is to describe the environmental management and monitoring procedures to be implemented during the Project’s construction phase. The CEMP will enable the Electrix Project team to construct the transmission line with the least adverse environmental effect. Overall, implementation of this CEMP will ensure:    

Compliance with the conditions of resource consent (Appendix A) and any relevant Management Plans required by these conditions. Compliance with environmental legislation. Adherence to Mercury’s environmental management requirements. Environmental risks associated with the Project are properly managed.

The CEMP defines details of who, what, where and when environmental management and mitigation measures are to be implemented. The CEMP covers all anticipated construction elements of the transmission line construction and presents a framework of principles, environmental policy, objectives and performance standards as well as processes for implementing good environmental management. This CEMP establishes the relationship with the related Management Plans. The CEMP sits alongside the Community Liaison Group (CLG) Terms of Reference (Appendix B). The CLG Terms of Reference identifies the key stakeholder groups and one method for community engagement throughout the construction phase of the Project. Table 1: Consent conditions relating to CEMP

CEMP Section

Number

Condition

Construction activities must not commence until written certification has been obtained. The CEMP shall be prepared with the assistance of a suitably qualified environmental management specialist, and shall include, but not be limited to, the following: 6.1

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6.2

Outline of the relevant statutory and contractual requirements

1.5

6.3

Proposed construction methodology and timetable for all construction works

6.4

A process for reviewing the CEMP, including the process for developing and advising each Council of revisions

5.4

Roles and responsibilities, including appointment of an Environmental Manager who is: a) 6.5

based on the construction site for the duration of the construction works;

b) responsible for compliance with the CEMP, SEMPs and these conditions; c) contractually authorised by the Consent Holder to issue instructions to any contractor working on site as required to ensure compliance with these conditions; and d) available to meet with the respective Councilâ&#x20AC;&#x2122;s Environmental Compliance Managers as required to review issues relating to these conditions.

4.1.2

6.6

Training to ensure all contractors are made aware of the conditions of these consents and of the need to comply with them at all times

4.2

6.7

Procedures for keeping records of public complaints and any action taken in response to such complaints in accordance with condition 19

4.6

6.8

Methodology for preparing SEMPs for each of the relevant sub-catchment areas

6.9

An outline of the key potential environmental effects and measures to be adopted to avoid or mitigate these

6.10

An Accidental Discovery Protocol in relation to archaeological sites

4.3.6

Emergency responses for managing hazardous substances and any spills, including a contingency plan for: a) 6.11

Riparian zone restoration and de-silting of the Palmerston North City Council water supply reservoirs in the event of significant erosion / washout events occurring during and caused by construction of the wind farm; b) Early notification of downstream users and monitoring of a clean-up response in the event of significant spillage of hydrocarbons / concrete products to watercourses occurring during construction of the wind farm; and c) The removal and disposal of cleared vegetation offsite in the event of significant release of nutrients / BOD from moribund vegetation bunds at turbine sites occurring during construction of the wind farm.

4.5.4

6.12

Procedures for inspections, monitoring and reporting.

Where any of the Environmental Compliance Managers advise in accordance with condition 6 that the CEMP is not consistent with these consent conditions, their written response must outline these inconsistencies to the Consent Holder. If the Consent Holder receives written notification from any of the Environmental Compliance Managers that the CEMP is not consistent with the consent conditions, the Consent Holder shall modify the CEMP as necessary and resubmit it to the Environmental Compliance Managers no later than 10 working days prior to any construction works commencing. A response should be provided within 30 working days of receipt. Construction activities must not commence until written certification has been obtained.

5.4

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Scope of Works This CEMP relates to the environmental effects associated with the construction of a new 12km long 220kV transmission line to connect Transpower’s existing Linton Substation to the “Plantation Substation” at Mercury’s Turitea Wind Farm, near Palmerston North. The principles and general approach to managing the environmental effects are set out in the main body of this document. The management of specific effects (e.g. construction noise etc.) are detailed more particularly within a suite of Management Plans that form the appendices to the CEMP. This suite of Management Plans includes:        

Construction Noise Management Plan; Site Environmental Management Plans (SEMPs) (including site specific Erosion and Sediment Control Plans); Construction Traffic Management Plan; Rehabilitation and Re-Vegetation Management Plan; Aquatic Ecology Management Response Plan; Lizard and Snail Management Plan / Accidental Discovery Procedures (as relevant); Accidental Bat Discovery procedure; and Weed Management and Monitoring Plan.

Matters that have been addressed within each of these plans are identified in the subsequent sections of this CEMP. This CEMP and the various Management Plans may require review and amendment during the life of the Project to reflect changes in activities, risks, mitigation measures, responsibilities and management of process. Modifications may also be required due to additional acquisition of authorities/consents. The ability to make changes to the CEMP is important to ensure continuous improvement. The Project team will be required to undertake all construction activities on site in accordance with the provisions of the relevant Management Plans and resource consent conditions.

Project Description The Turitea Wind Farm site is located approximately 10 kilometres south-east of Palmerston North primarily along a 14-kilometre ridge in the northern Tararua Ranges. The environment includes a number of existing wind farms to the north. The Turitea Wind Farm is located within the Turitea Reserve (owned by Palmerston North City Council (PNCC)) and on adjoining private farmland. Within the Reserve, the land predominantly supports native vegetation, with some introduced species. The Reserve also contains several access tracks, wind monitoring masts, and dam infrastructure related to the storage of water for water supply to Palmerston North. The adjoining farmland is generally pasture used for sheep and cattle grazing. There are several farm tracks, as well as public access roads in the area including Pahiatua Aokautere Road, South Range Road and Greens Road.

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The site is located within the PNCC and Tararua District Council (TDC) municipal boundaries and comes under the jurisdiction of the Manawatu-Wanganui Regional Council (Horizons). The general location of the site is shown in Figure 1 and 2. The consented Turitea Wind Farm consists of up to 60 turbine locations and includes associated substations; internal electricity reticulation (made up of underground cables and overhead transmission lines from turbines to substations, internal overhead transmission lines connecting the two proposed substations; and an external overhead transmission line connecting the Turitea Wind Farm to the national grid at Linton substation); tracking; permanent wind monitoring masts; and associated earthworks, vegetation clearance and discharges associated with construction activities. The overall Wind Farm project includes the following:  The creation of internal equipment laydown areas and a construction site office.  Alterations to existing access tracks and private roads at the site.  Construction of several new tracks within the Wind Farm to provide access to turbine locations and some transmission tower sites.  The minor upgrading of public roads providing access to the site; including upgrades to the Greens Road and the South Range Road intersection and creation of a secondary access to the site on Pahiatua Aokautere Road.  Vegetation clearance for the creation of access tracks, road widening, creation of turbine platforms and lay down areas, plantation substation, and other ancillary activities.  Land disturbance including cut and fill volumes comprising civil works for: - Upgrading and formation of roads and access tracks, - Turbine platform and foundation formations, - Substation and maintenance facility construction, - Cable trenching, and - Platforms for internal and external transmission support structures.  The construction of 33 wind turbine generators (turbines) in the northern zone of the consented Wind Farm (Note: consented turbines in the southern zone do not form part of the project at this stage).  One 33/220kV substation (Plantation Substation) within the Site in the general location of an existing pine plantation adjacent to South Range Road. The substation will include electrical equipment and operations and maintenance facilities.  An internal reticulation network of 33kV underground cables generally along internal access roads connecting turbines and the Plantation Substation.  A 220kV transmission line connecting the Wind Farm (from the Plantation Substation) to the national grid via the existing Transpower Linton Substation.  The construction of wind monitoring masts of up to 80m in height within the site.  The disposal of excess excavation material at identified disposal areas within the site.  The commissioning of wind turbines.  Ongoing maintenance activities including the monitoring, repair and replacement of turbine components; substation equipment; reticulation network; transmission lines and structures, monitoring masts and roading.  Site reinstatement, revegetation and new areas of mitigation planting within the site. This CEMP covers the Electrix component of the Project works entailing the following principal elements of construction:  Double circuit transmission line structures, including a mixture of steel tubular monopoles and steel lattice towers complete with concrete foundations, anti-climb devices and signage; Version: 6.0 DATE: 02/08/2019

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     

Two circuits to be strung with simplex Sulfur All Aluminium Alloy Conductor (AAAC), complete with all insulators, fittings, conductor hardware, and vibration dampers; Two composite fibre-optic ground wires (OPGWs), complete with fittings, junction boxes and hardware and vibration dampers; Duplicate 220kV line protection schemes for circuit 1 end to end inclusive of the required protection communications; Access tracks for construction and future maintenance of the line and structures; Vegetation removal and trimming; and Waste removal and disposal.

Figure 1: General location of the site (Figure 1-1 of AEE).

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Figure 2: Routes for the line within the consented transmission corridor (blue lines) - the exact location may still vary. Poles and towers are identified by number. Version: 6.0 DATE: 02/08/2019

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Figure 3: Transmission line route and access roads to site.

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1.4.1

Assessment of Environmental Effects

This CEMP and its Management Plans are consistent with and complement Mercury’s (formerly Mighty River Power) - Assessment of Environmental Effects (AEE) Turitea Wind Farm Redesign document dated February 2010. The AEE contains several technical assessment reports which inform the specific environmental management, monitoring and mitigation measures to be implemented by the Project team to manage actual and potential environmental effects during construction. The development shall be undertaken in general accordance with the plans and information submitted with the application (numbered 104553-104560 by Horizons, RC0068 by PNCC and 1448 by TDC).

Legislative and Other Requirements A full assessment and overview of statutory requirements of the potential effects upon the environment are contained within the AEE.

1.5.1

National Legal Requirements and Policies

Construction of the Project must comply with a range of national legislation, regulations, strategies and policies in order to provide for the management of environmental effects.

1.5.2

Project Approval Process

Mercury's resource consent application for Turitea was confirmed in September 2011 following a Board of Inquiry process. The Board limited the number of turbines to 60 in its final decision, and conditional on a range of consent conditions. The provisions within this CEMP comply with conditions of the resource consents. The finalised conditions form part of the CEMP. If required, the Electrix Project team (in consultation with Mercury) is responsible for obtaining new or altered consents required during construction. Alterations of consents will be associated with changes to construction techniques or natural environmental changes.

Principal Contractor - Transmission Line Construction Electrix recognises the serious impact environmental events can have on the community, and in turn, on Mercury’s assets, operations and reputation. This CEMP describes the specific systems the Electrix Project Manager and project team will implement to ensure effective environmental management controls relevant to the Transmission Line Construction (“the Project”). Electrix obligations regarding environmental management include compliance with the terms and conditions of any consent, outlined plans, or other approvals obtained and provided under the Resource Management Act (1991) by either Electrix or Mercury. The SEMPs will be updated as necessary during the Project to ensure that they remain current. Where relevant, significant updates will be re-submitted to the Approvers, listed in this document, for certification. Minor updates will be tracked in documentation but will not be resubmitted for approval. These are likely to include (but are not limited to):   

Minor design changes; Increase in environmental controls (e.g. Erosion and Sediment controls); and Changes as instructed by Regulatory authorities following audits.

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2. Construction Activities and Effects Overview This CEMP addresses both the actual and potential effects on the environment that may be generated by the Project. These effects have been assessed based on the activities authorised by the regional and district plans and resource consents. Section 2.2 provides a summary of the construction activities and related environmental aspects of the Project including the location of these activities. Section 2.3 details the use of an ‘Environmental Risk Register.’ A tool developed for the Project team to assess how these effects are best avoided and minimised during the construction phase of the Project. The Environmental Risk Register can be used by Mercury, PNCC, TDC, Horizons, and the Project team as a reference to activity type, location, potential effect and impact, risk rating, mitigation options and relevant Management Plans for a particular environmental aspect.

Construction Activities and Environmental Aspects 2.2.1

Construction Duration

The Project is anticipated to take approximately 1 year to construct. Many elements of the Project will be undertaken concurrently. Figure 4 shows an outline of an indicative Project programme.

2.2.2

Construction Works

There are a number of steps involved in the construction of this transmission line, those relevant to environmental considerations are. 



 



Identifying line route within the consented corridor: This will include the identification of trees that require trimming or removal; where access tracks need to be constructed or upgraded, ground stability issues will be determined, and sensitive sites will be avoided; Construction of access tracks and work sites: This includes a site survey, the creation or upgrade of both permanent and temporary tracks, clearing and levelling of the site for the poles/towers and creation of cranes pads for lifting of pole/tower sections (where required); Geotechnical investigation: Carried out to better understand the geotechnical makeup of the ground which will be used to guide the design of the pole or tower foundations; Foundations: This will include the drilling or digging of foundation holes, the placement of steel reinforcing and connecting elements between foundation and pole or tower and pouring of concrete; Construction of the pole or tower sections: These will be craned or helicoptered together with some preassembly of tower sections occurring; Wiring: Running blocks will be hung on the towers and a pulling rope will be run out between the towers by helicopter. The conductor will then be attached to the pulling rope and pulled through the towers. It is planned to do this in 3 sections. In each section there will be 8 wires pulled (two circuits each containing 3 individual conductor wires and 2 OPGW earth-wires); and Dressing: Running blocks will be removed, insulating stings hung to connect the conductor to the towers and vibration dampeners fitted.

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Figure 4: Proposed Project programme.

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2.2.3

Construction Effects

Table 2 summarises key environmental issues and effects associated with construction. Construction activities have the potential to cause dust and noise emissions that can cause a nuisance to people (and in extreme circumstances cause adverse effects to human health), traffic congestion and associated public safety hazards for road users and adversely affect the aquatic and terrestrial receiving environments.

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Table 2: Summary of key environmental issues and effects associated with construction.

Social and Environmental Issue

Noise and Air Quality

Light Pollution

Social and Environmental Assessment Effects The risk of the Project causing nuisance applies along the Project alignment. These effects include construction noise (including helicopter noise), dust generation and emission from Construction vehicles. Mitigating the risk of potential effects on nuisance from construction activities is to take place through the implementation of this CEMP and its Management Plans. During the majority of the construction period, it is unlikely to be necessary to continue construction work after sunset. However, there may be occasions when particular construction activities require work during darkness and artificial lighting may be required.

Waste Management

No domestic waste water will be discharged to ground or water within the water supply catchment.

Vehicle Movements

The overall level of truck traffic generated during construction will be highest at the start of construction when the Pahiatua Aokautere Road will carry a combined total of around 70 truck movements per day (35 in and 35 out). Greens Road access will carry around 50 truck movements per day (25 in and 25 out).

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Degree of Effect

Requirement

Sensitive receiving environments: A range of bird species have been recorded in the Turitea Reserve and surrounding area. Stock: distress from helicopter noise.

SEMP. Environmental Risk Register. NZS6803:1999 Acoustics â&#x20AC;&#x201C; Construction Noise.

Portable lighting rigs will be employed. Any use of artificial lighting during construction will only be for short periods of time and given the remote location, it is unlikely that any lighting or night-works will be noticeable beyond the boundary of the Site.

SEMP. Environmental Risk Register. District Plan Lux requirements.

All waste is to be collected and removed from site and disposed at an appropriately licensed facility.

SEMP. Environmental Risk Register.

SEMP. Environmental Risk Register. Construction Traffic Management Plan.

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Social and Environmental

Social and Environmental Assessment

Issue

Effects

Water Resources

Erosion and Sediment Discharges

Blasting

A number of freshwater aquatic receiving environments exist across the Project. These aquatic environs are potentially susceptible to adjustments in water quality from discharges of sediment, and contaminants generated by the construction activities. Mitigation of these potential effect on the aquatic receiving environment will be implemented through this CEMP and its Management Plans. Water will be required during construction for concrete production, dust suppression on gravel roads, wetting fill material, hydroseeding on exposed earth surfaces and for the construction workforceâ&#x20AC;&#x2122;s needs. During construction, there is potential for sediment laden discharges to occur from bare earth surfaces/earthworks. These discharges can have a negative impact on the receiving environment. Dust can affect human health and plant life. Mitigating the risk of sediment and dust generated by construction activities is to take place through the implementation of the CEMP and its Management Plans. The use of explosives may be required during the earthworks phase of the project. At this stage it is not proposed.

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Degree of Effect

Requirement

Sensitive receiving environments in the area include: Turitea Reserve, Turitea Steam, Kahuterawa Stream, Otangane Stream and Tainui Stream.

All areas of disturbance.

earthworks

soil

The storage, handling and use of explosives associated with blasting will be in accordance with the appropriate New Zealand Standard (NZS 4403:1976).

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SEMP. AEMRP. Environmental Risk Register.

SEMPs will contain specific erosion and sediment control methods consistent with Horizons Regional Council requirements. Environmental Risk Register.

SEMP. Environmental Risk Register. Construction Traffic Management Plan.

Social and Environmental Issue

Sedimentation of the PNCC Water Catchment - washout event

Culture and Heritage

Social and Environmental Assessment Effects

Degree of Effect

Requirement

Sediment laden discharges occurring from bare earth surfaces/earthworks. These discharges can have a negative impact on the receiving environment

Potential catastrophic siltation of the PNCC water supply reservoirs.

SEMPs will contain specific erosion and sediment control methods consistent with Horizons Regional Council requirements. Electrix will commence an immediate investigation into the incident to identify the cause and understand the severity of the event Environmental Risk Register.

During the construction activities associated with the Project it is considered unlikely that any archaeological sites will be exposed.

No archaeological sites have previously been recorded within the boundaries of the proposed Turitea Wind Farm. It is considered unlikely that any archaeological sites will be exposed during construction of turbines and associated infrastructure. The possibility that they might be, however, means that an Accidental Discovery Protocol is in place. Avoidance of sensitive sites in design and acknowledgement of tangata whenua relationship with natural resources.

SEMP. Environmental Risk Register. Accidental Discovery Protocol.

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Social and Environmental

Social and Environmental Assessment

Issue

Storage and Use of Hazardous Substances

Effects

Degree of Effect

Requirement

The majority of these substances will be stored within the dedicated laydown (see figure 4) and workshop areas on the Site and will conform to requirements for the storage and use of such substances.

Some of the hazardous substances potentially required during the construction of the Wind Farm and associated works include: Diesel oil for fuel (up to 1,000 ltrs) Petrol. Petrol vehicles may carry a 20ltr container which stays with the vehicle (most vehicles are diesel) Oil (up to 5Ltrs in a vehicle) Mineral oil for lubrication (up to 5ltr stored on site. But mostly stays with vehicle/plant) Hydraulic fluid (will not be stored on site) Mineral oils to prevent formwork sticking to concrete (10 ltrs) Welding gasses (brought in when required then removed) Paint (10 Ltrs) Bitumen based paint (10 Ltrs (if any)) All stored fuel will be protected by a bund for an appropriate volume to prevent spillage of fuel during normal use or by accidental rupture. A fuel bowser will then be used to transfer smaller quantities of fuel to plant employed around the Site. All fuel storage facilities will be constructed outside the Turitea water supply catchment.

SEMP. Environmental Risk Register.

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Social and Environmental Issue

Social and Environmental Assessment Effects

Degree of Effect -

Ecological Impacts

Removal of vegetation Construction noise impacts. Dust.

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Vegetation removal will be required for the creation and upgrading of access ways and transmission line structures. Terrestrial ecology effects from construction:  Vegetation clearance,  Adverse impact on threatened plant species,  Sediment run-off,  Potential loss of fauna habitat, and  Adverse effect on snail population.

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Requirement -

Preparation and adherence to an approved SEMP. Rehabilitation and Re-Vegetation Management Plan; Adaptive Aquatic Ecology Management Response Plan; Lizard and Snail Management Plan / Accidental Discovery Procedures (as relevant); Accidental Bat Discovery procedure; and Weed Management and Monitoring Plan

Social and Environmental Issue

Earthworks

Social and Environmental Assessment Effects

Degree of Effect

Requirement

The key earthwork activities at the Site include the following:  Formation and upgrading of access roads,  Disposal of excess excavated material within the site, and  Construction of foundations and other land disturbance associated with overhead transmission lines.

Earthworks volumes have been assessed based on an analysis of the site contours and the concept design for access tracks and turbine platforms. In order to minimise the amount of movement of fill around the site, a number of clean-fill disposal sites have been defined. These sites generally allow for the excess fill material to be disposed on site. Clean-fill disposal sites have been identified in areas where they will not have any adverse effect on freshwater ecology or result in vegetation clearance. Wherever possible, the roads have been designed on a cut to fill basis. This approach speeds up construction, minimises the earthworks footprint, reduces the area of disturbance and vegetation removal, and reduces the length of time earthworks are exposed.

SEMP. Environmental Risk Register.

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Figure 5: Laydown area for Hazardous Substances

2.2.4

Environmental Risk Register

A preliminary Environmental Risk Register is attached as Appendix C. The Risk Register is a live document which will be used by the Project team in the preparation of work plans. As construction progresses the risk register will be reviewed and updated as required. Where there is a risk identified on site these will be outlined with the risk management strategy documented in each of the SEMP. Such risks could include slope, watercourses, water supply catchments and timing of works, duration of works, etc.

2.2.5

Review of the Register

The Environmental Manager (roles and responsibilities defined in Section 4) is required to maintain and review the Environmental Risk Register. The risk assessment results will be reviewed at regular intervals and at critical Project timeframes such as change in methodology or following a significant environmental incident. This review may trigger the CEMP (and its management) to be updated as well. Should this occur, updates will be circulated for certification.

3. SEMPs SEMPs will be prepared and submitted to Mercury for review and submission to Horizons Regional Council. SEMPs will be prepared for each of the sub-catchment areas (at a minimum). They are a sitespecific document which includes the application of the CEMP. SEMP are designed to ensure there is certainty of environmental outcomes. The SEMPs will draw upon input from specialists including (but not limited to): ď&#x201A;ˇ

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   

Designer; Ecologists; Erosion and Sediment specialist; and Environmental practitioners.

Each SEMP will contain information appropriate to the sub-catchment area. This will include:      

A location plan; Description of works to be undertaken; Contact details for the onsite Operations Manager; Work programme; Method statement covering monitoring and contingencies; and Design for the works.

Design for the works The design of the works will be covered and will include descriptions of the following:      

     

Areas to be disturbed; Vegetation clearance methods and vegetation stockpiling; Fill areas; Spoil stockpile and disposal areas; Culverts and associated works in watercourses; Step by step criteria for determining the appropriate use of erosion and sediment control measures, including cut off drains, surface water control works, sediment ponds, flocculation measures (if required), and progressive rehabilitation of earthworks areas; Stormwater management measures; including both temporary and permanent measures; Re-vegetation and rehabilitation (identification of re-vegetation to be undertaken and revegetation methods and any maintenance); Inspection and reporting schedule in particular in response to adverse weather conditions; Maintenance and monitoring activities; Storage and handling of fuels and hazardous material and contingency measures for containment of spills; and Decommissioning and re-stabilising of sediment ponds, and other erosion and sediment control measures, at the completion of construction.

Construction activities will not commence in the relevant SEMP area until written certification has been obtained from the Regulator.

4. Implementation and Operation CEMP Management structure 4.1.1

Overview

Each person involved in the Project has a responsibility to avoid, remedy or mitigate adverse environmental effects. However, there are three key groups with responsibility. These include: 1. Mercury as the Project owner and holder of consents; Version: 6.0 DATE: 02/08/2019

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2. Electrix as the party undertaking the works; and 3. PNCC, TDC and Horizons who audit the works and monitor compliance against the authorities granted. Local Iwi (Rangitaane o Manawatu and Rangitane o Tamaki nui a Rua) also have an interest in the project and may, at their discretion, be involved as observers to monitor potential cultural effects associated with construction activities. During the construction phase of the Project, an Electrix Environmental Manager will be part of the Construction Team who will give advice and ensure the CEMP and Management Plans are implemented and maintained.

4.1.2

Organisation and Accountability

The proposed structure of the Electrix Project team is as follows:

Stakeholder Manager

Project Engineers

Design Manager

Project Manager Construction Manager

Health and Safety Manager

- Site Leading Hands - Foreman

Environmental Manager

Roles and Responsibilities The key requirements/responsibilities for Electrix Project staff in relation to environmental management are set out below: All Staff   

Attending tool-box talks and environmental training including familiarisation with relevant consent conditions and the requirements of the CEMP and Management Plans; Responsible for reporting environmental incidents, complaints, defects and other problem areas to senior staff as they arise; Ensuring that processes and procedures for environmental management are followed; Version: 6.0 DATE: 02/08/2019

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  

Ensuring that environmental mitigation and protection measures are maintained and working as designed; Ensure the environment on site and surrounding the site is protected; and Ensuring the site is tidy and waste is removed.

Project Manager   

Responsible for day-to-day onsite compliance with specific resource consent conditions relevant to the Project works scope; Reviews and submits, to the Consent Holder (Mercury), SEMP; and Provides adequate resources to ensure environmental risks are managed in accordance with this CEMP and any relevant SEMPs and Management Plans.

Design Manager  

Incorporates environmental requirements into design as required by resource consents, CEMP and any relevant SEMPs and Management Plans; and Advises Environmental Manager of any design issues that may impact on the environment or compliance with authorities.

Construction Manager      

Provides leadership to the site team to achieve Project environmental objectives and targets; Responsible for ensuring environmental controls and erosion and sediment control works are installed, modified and maintained; Ensures adequate resources are provided to ensure environmental issues are appropriately managed; Reports all incidents and complaints to the Environmental Manager; Assists in the development, implementation and ground-truthing of Project environmental objectives; and Ensures that staff onsite are aware of environmental requirements at all times.

Project Engineers        

Prepare and review work packages against Project environmental objectives and targets and CEMP to ensure performance is achieved; Develop, implement and monitor construction methods ensuring compliance with consents and CEMP and Management Plans; Complies with all legislation, regulations and consent conditions in relation to the work they are undertaking; Demonstrates understanding of major environmental and community issues and environmentally sensitive areas; Implements environmental protection measures in accordance with the contract, consents, best practice and CEMP any relevant SEMPs and Management Plans; Trains all workers in relation to environmental measures; Reports all incidents and complaints to the Construction Manager; and Ensures all workers comply with environmental operating procedures and community relations protocols. Version: 6.0 DATE: 02/08/2019

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Environmental Manager and Team     

          

Project Environmental liaison for Mercury (or its agents) for environmental site inspections, SEMP audits and compliance issues; Provides leadership and training to ensure staff are motivated to achieve environmental standards and comply with all resource consent conditions; Reports on environmental performance, incidents and issues; Develops, implements and reviews environmental management systems including the CEMP and any relevant SEMPs and Management Plans for the Project; Coordinates the interface and communication with external agencies and stakeholders in relation to environmental management on the Project in conjunction with Stakeholder Manager and Mercury; Assists Mercury with the management and coordination of consents required (current and any additional); Maintains and submits to Mercury, relevant reporting that is required by Resource Consent by PNCC, TDC and Horizons; Undertakes regular site inspections and audits to ensure compliance with the CEMP and any relevant SEMPs and Management Plans and consent conditions; Provides liaison point between site staff and specialists (e.g. ecologists); Trains staff in site specific environmental procedures (e.g. Accidental Discovery protocols); Coordinates environmental emergency responses; Notifies Mercury of any significant environmental non-compliance so that the correct Regulatory Authority can be contacted; Available to meet with PNCC, TDC, Horizons, Department of Conservation and Heritage New Zealand Pouhere Taonga representatives as required; In consultation with the Consent Holder, responsible for resolving issues of environmental noncompliance or complaint; Manages maintenance and monitoring of the effectiveness of erosion and sediment controls; and Ensures spill kits are available and stocked and provides training on equipment use.

Stakeholder Manager 

 

In consultation with Mercury Property Manager, responsible for notifying landowners (and where relevant, neighbours) of works occurring within the vicinity and managing mitigation as required, in conjunction with Mercury; Subject to approval by Mercury, disseminates information to the public; and Primary contact for Project related complaints and enquires (whether directly or via Mercury’s Project- Complaints email or 0800 number).

Site Leading Hands     

Provides leadership to the site construction team to achieve Project environmental objectives and targets; Ensures that the CEMP and Management Plans are implemented appropriately; Ensures environmental controls are being protected and maintained; Leads the emergency response crew; and Reviews the need for dust suppression (e.g. water carts). Version: 6.0 DATE: 02/08/2019

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Foreman    

Manages the construction of critical erosion and sediment control devices and removal of vegetation; Coordinates daily site inspections of environmental controls including erosion and sediment controls; Monitors the site during rainfall events and trigger-based monitoring; and Ensures staff on site are aware of environmental requirements at all times.

Environmental Training and Induction All Project staff will undergo general environmental awareness training and training about their responsibilities under the CEMP and Management Plans. The training will ensure that all personnel understand their obligations to exercise due diligence for environmental matters. Suitable induction training and on-going programmes of environmental training will, at a minimum include:             

The significant actual or potential environmental impacts and the importance of mitigation; Location of sensitive receptors and area of high environmental value; Cultural awareness; Importance and relevance of the CEMP and Management Plans; Consent requirements; Roles and responsibilities in relation to compliance with consents and operating procedures; Familiarisation with site environmental controls; Spill response and emergency procedures; Hazard and risk management to ensure personnel understand the potential impacts and proposed mitigation measures (contained within CEMP Environmental Risk Register); Mercury’s PreQual training; Accident, incident, spill reporting and methods for environmental prevention; Complaints management procedures; and Environmental monitoring.

The induction will include information on the surrounding natural environment and its sensitivity. Information will be provided on environmental controls such as sediment control, noise and dust mitigation measures, spill contingency and waste management. Project Engineers responsible for writing plans and undertaking site specific safety and environmental risk assessments will also be given guidance on how to assess and plan for environmental issues using the CEMP and Environmental Risk Register. Environmental issues will form a regular part of “tool-box meetings” to ensure all workers are aware of the key issues. Site staff will be made aware of the operational restrictions when working near sites of archaeological and/or cultural significance, sensitive aquatic receiving environments, areas of retained/protected vegetation and other sensitive receptors.

4.2.1

Training records

Training records regarding environmental matters will be maintained by the Environmental Manager. Records will include: Version: 6.0 DATE: 02/08/2019

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   

Who was trained; When training occurred; General description of training; and Trainer details.

Construction procedures inclusive of mitigation measures The sections below describe the environmental aspects associated with the construction phase of the Project and mitigation measures. Management Plans containing detailed controls and measures are cross-referenced.

4.3.1

Noise

An assessment of the existing noise environment has been undertaken for the Project and is provided in the Assessment of Noise Effects (Appendix M of AEE). This outlines that the potential noise effects of the proposed Project works include: 



noise from the construction of the roading network within the wind farm, the erection of the wind turbine generators and noise from construction traffic on the internal site roads and the public roading network (including traffic for construction of the Transmission Line); and noise from temporary support works, which include a possible extraction works.

A full assessment of the proposed construction works has been undertaken and the noise levels at the closest dwellings completed for each phase of the wind farm construction. The existing noise environment has been measured over a ten-day period at representative sites around the proposed wind farm in terms of the requirements of NZS6803:1999 Acoustics - Construction Noise at all times. The assessment concluded that:  

construction traffic noise will be heard but will be well within a reasonable level at all times; and construction will only be undertaken infrequently at night (e.g. during particularly lengthy concrete pours). These night time construction activities will comply with the lower noise time noise requirements of the Construction Standard of (Leq) 45dBA for any activity at the closest construction site so ensuring there will not be a sleep disturbance for the residential neighbours.

As access to the area between towers 9, 10, 26-30, 33-35 (illustrated in figure 2) is difficult, it is proposed to transport the towers to the sites using a helicopter. The analysis has been undertaken based on an AS355 helicopter operation during the daytime period. The helipad will be located a minimum of 1km from any dwelling and the towers are a minimum of 2km from the closest house. Based on these distances and assuming the helicopter is flying constantly, the noise from the helicopter is unlikely to exceed 40dBA as a 1-hour Leq. This is well within an acceptable limit for both an ongoing sound and a construction activity. Noise from all construction work shall be measured and assessed in accordance with NZS6803 and shall comply with the noise limits for long-term duration set out in that Standard.

4.3.2

Dust

Due to the exposed, windy conditions along the ridgelines there is the potential for fine sediment to enter watercourses as windblown dust from earthwork areas. Limiting exposed areas and controlling the generation of windblown sediment via dust control will minimise the amount of airborne sediment generated during earthworks. Version: 6.0 DATE: 02/08/2019

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As a result of the adoption of best industry practices for construction and given the location of works on the wind turbines pads and the majority of access ways are on ridgelines and spurs that are separated from perennial reaches of surface receiving waters, the effects of constructing the Turitea Wind Farm on aquatic ecology will be minor. Erosion and sediment control measures will be used across the Project and will be in line with the Greater Wellington Regional Council’s ‘Erosion and Sediment Control Guidelines’ and also best practicable options that can be used in conjunction with those guidelines. The potential for nuisance dust to arise during the construction process will be mitigated by appropriate dust suppression methods (watering) where possible. Should any nuisance dust emissions occur, a written report will be prepared by the Environmental Manager (within 5 working days of being made aware of emission) which will include:    

A description of the severity of the event; The cause or likely cause and any factors which may have contributed to its severity; The nature and timing of any measure implement to avoid, remedy or mitigate any of the adverse effects; and The steps to be taken to prevent recurrence of similar events.

Dust reduction measures must be implemented to suppress dust caused by the movement of construction vehicles on Greens Road and Pahiatua-Aokautere Road during the construction period. This will be illustrated in the SEMP relevant to these areas.

4.3.3

Construction Machinery and Vehicle Emissions

Excessive smoke and odour from diesel-fuelled trucks, generators and other machinery is primarily cause by poor engine maintenance. Failure to maintain air filters, fuel filters and fuel injectors in accordance with manufactures recommendations may cause excessive black smoke and objectionable odour. Excessive smoke and odour discharges from trucks, earth moving machinery and generators could cause complaints from neighbours, if vehicles and machinery are not well maintained. The Project team will utilise late model vehicles where possible and will maintain all machinery and vehicles regularly to prevent excessive smoke and odour discharges.

4.3.4

Erosion and Sediment

During construction, erosion and sediment control measures will be put in place to minimise potential adverse effects by utilising measures which meet (or exceed) industry best practice and guidelines such as the Greater Wellington Regional Council’s ‘Erosion and Sediment Control Guidelines’. Site and activity specific erosion and sediment controls will be developed within each of the SEMP. These will include specific methodologies and management techniques that will be applied to each zone. These methodologies will follow the hierarchy within schedule 2 Condition 2. However, it is worth noting that the consent does not address the reduced risk of the Transmission line works. Schedule 2 of the consent document (specifically conditions 6-26) is very prescriptive and would result in aspects of works actually departing from current best practice. Where this is the case, details will be outlined in the site based SEMPS to illustrate best practice and the reasons why deviation from consented methodologies would be required. As part of the erosion and sediment control methodology, ongoing site monitoring by the Project team will occur to ensure that the proposed erosion and sediment control measure have been installed correctly, methodologies are being followed and are functioning effectively throughout the duration of the works. Sediment control measures will be provided for potential silt run-off during construction and Version: 6.0 DATE: 02/08/2019

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until the stabilisation of ground is established. Mercury (or its agents) will also undertake regular inspections of sediment controls. Each of the SEMPs will set out a risk management framework and the construction and environmental management and monitoring requirements in relation to land disturbing activities. The SEMPs will include information on the following:     

The management of sediment inputs to water courses from earthworks via stormwater and / or windblown dust; The design of stream crossings (predominantly culverts) to ensure they provide for fish passage; Best management practices to minimise the chance of accidental spillage or loss of hydrocarbons and non-stabilised cement products to watercourses; A monitoring programme that provides the basis for an adaptive management response to issues that may arise during the construction phase of the proposed Wind Farm; and Adoption of best practice sediment and erosion control measures.

Each of the SEMP will contain erosion and sediment control sections which will:       

Identify areas susceptible to erosion and sediment deposition with particular emphasis on identified high risk areas; Ensure construction and maintenance activities avoid, remedy and mitigate effects of soil erosion, sediment runoff and sediment deposition on high value ecological areas; Detail procedures to ensure erosion and sediment control measures are installed prior to and during all works and procedures for decommissioning of controls; Identification of Environmental Management staff who are appropriately qualified and experienced, their roles and responsibilities and chain of command; Detail monitoring requirements and responsibilities for turbidity monitoring and triggered event monitoring as detailed in Schedule 2: Conditions 27-29; Identify the catchment area for each relevant sediment control measures (Sediment Retention Pond (SRP), Decanting Earth Bund (DEB) etc); and Identify any ‘No-go’ areas for traffic vehicles.

Structures within Waterways The majority of in-stream works will be culvert crossings of ephemeral (temporary) watercourses at the extreme headwaters of catchments (i.e. towards the top of gullies) and are also in relatively small catchments. Construction for all works within watercourses will be undertaken based on the following principles:      

Installation of suitable runoff controls including diverting runoff from disturbed areas to minimise discharge of sediment and construction materials into the stream; Minimising the area of disturbance; Staging works to minimise work in the stream bed; Undertaking works, as much as practical, in the dry; Allowing ‘offline’ construction works by temporarily diverting the stream to minimise the generation of sediments and the possibility of construction materials entering the watercourse; Selecting materials (such as pre-cast headwall & culverts etc) to minimise time of the works in the stream; Version: 6.0 DATE: 02/08/2019

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   

Removal of all construction materials on completion of works; Stabilising all exposed areas of soil against erosion by re-vegetating or other methods; No storage, refuelling or servicing of machinery in locations which could lead to a spill to the watercourse; and Regular inspections by Project Management to ensure construction materials handling and sediment mitigation measures are being adhered to.

In addition to the principles for works within the vicinity of watercourses, culvert works will also include the following:  

New culverts have been designed not to cause the upstream water depth and differential water level to exceed three metres; and Culverts have been designed to minimise impediment to fish passage.

General Erosion and Sediment Control Principles for the Site The underlying principles for the management of erosion and sediment are to undertake land disturbing activities in a manner that reduces the potential for erosion of bare soil surfaces to occur (Erosion Control) and to employ treatment devices to treat sediment laden water prior to discharging from the site (Sediment Control). The key principles which will be addressed in each of the SEMPs are:         

Minimise Disturbance - only work those areas required for the construction to take place. Stage Construction - carefully plan works to minimise the area of disturbance at any one time. Protect Steep Slopes - carefully consider activities on steep slopes and how runoff from these areas will be controlled. Protect Waterbodies - map all waterbodies and proposed drainage patterns before works commence. Stabilise Exposed Areas Rapidly. Install Perimeter Controls - divert clean water away from areas of disturbance and divert runoff from areas disturbed to sediment control measures. Employ Detention Devices - treat runoff by methods that allow sediment to settle out. Make Sure the Plan Evolves - Modify the ESCP as the project progresses. Inspect - inspect, monitor and maintain controls.

Erosion and Sediment Control Plans (within SEMPs) The Erosion and Sediment control descriptions will form part of each of the SEMPs. They will be prepared prior to works commencing and the controls designed and constructed to Erosion and Sediment Control Guidelines, Greater Wellington Regional Council, (2002). Where devices following exact Wellington guidelines are not appropriate, the best practicable option will be adopted. The Erosion and Sediment control descriptions will include (but not limited to) the following:  

Site description - soil types, vegetation, natural features, flood plains, waterbodies, climate; Site situation - the immediate, connecting and ultimate receiving environment; Version: 6.0 DATE: 02/08/2019

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

   

Description of proposed development - the nature and scale of works being undertaken including the total earthworks area on site, total length of exposed roads, trenches and tracks and volume of proposed earthworks; Detailed map - a detailed location map of the site with a north point and bar scale as well as a ratio scale, showing roads, boundaries, location of surface water bodies, any existing stormwater reticulation and outfalls; Limits of Disturbance - the map is to include all the “limits of disturbance” bounding protected areas. On site the limits of disturbance will be shown using fences, signs and flags; Erosion and sediment controls - a detailed map showing the erosion and sediment controls proposed; Monitoring - details of proposed monitoring to assess the effectiveness of the control measures; and Provide as-built certification sheets for Sediment Retention Ponds (SRP).

General Site Controls Stabilised Construction Entranceway A stabilised pad of aggregate on a geotextile cloth base will be located at the point of the site where traffic will be entering and leaving. This will prevent site access points from becoming sediment sources and assist in minimising dust generation and tracking of soil onto the adjacent environments. Details around the entranceways is illustrated and contained with the Construction Traffic Management Plan (CTMP). Runoff diversion Channel / Bund A non-erodible channel or bund may be used on site to intercept clean water from non-worked areas and direct it around the work site (clean water diversion). They may also be used to convey sediment-laden runoff from the site to an appropriate sediment retention structure. Stabilised Channel Protection The purpose of stabilising the channels of steep graded road side drains, diversion bunds and diversion drains is to provide suitable erosion protection. Stabilisation measures such as geotextile, vegetation stabilisation, or rock check dams may be used to line the channels of the diversion bunds and minimise erosion. Sediment Traps A sediment trap is an excavation that acts as a collection point for sediment suspended in stormwater. It is proposed that these collect flows from the roadside drains (turn out areas) and are the primary control for the access tracks where they are to be positioned. The discharge point will either be a pipe or spillway formed in in-situ materials. Depending on the topography, the sediment traps may need to be stabilised with geotextile to minimise erosion. The spacing of the sediment traps will depend on the vertical grade of the road they are servicing. Sediment traps will be built in accordance with Schedule 2: condition 10 and 13. Silt Fences Silt fences are a temporary barrier of woven geotextile fabric used to intercept runoff, reduce its velocity and trap sediment suspended in the runoff. Silt fences will be erected as a perimeter control and may also be used to limit disturbance of sensitive areas where diversion and earth bunds are not practical to

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construct. Silt fences will be utilised in the low wind areas where the topography is appropriate. Silt fences will be built in accordance with Schedule 2: condition 12. Super Silt Fences A super silt fence is a temporary barrier of woven geotextile fabric over chain link fence used to intercept sediment-laden runoff from soil disturbance. Some of the areas may require super silt fences due to site topography and/or the sensitivity of the receiving environment. Super silt fences are more effective than a regular silt fence as the barrier is stronger and will more likely cope with the exposed windy conditions. Super Silt fences will be built in accordance with Schedule 2: condition 11. Sediment Retention Pond Sediment retention ponds are temporary ponds incorporating a decanting device to dewater the pond at a rate that will allow suspended sediment to settle out. Sediment retention ponds may be used where earthworks areas of approximately 0.3 ha to 3 ha will remain exposed for a reasonable period of time i.e. at Browns Flat. Ponds are generally sized according to the catchment that is feeding them. Earthwork areas with slopes of less than 10Â°, or 200 m in length require a pond with a minimum volume of 2 % of the catchment area. For earthwork areas with slopes greater than 10Â° or longer than 200 m the minimum volume required is 3% of the catchment area. Any ponds will be monitored regularly, and sediment cleaned and disposed to fill to ensure the efficacy of sediment settlement. Site stabilisation The project will be staged so as to minimise the amount of exposed earth at any time. This will be achieved through staging of the works and progressive site stabilisation. Access roads will be stabilised as soon as their base course is down. Roads that have a slope of over 14 % will be stabilised with lime/cement or chip seal, the remaining access roads will be stabilised with metal. In some sections of the track, particularly along South Range Road and Water Catchment Access Road, it may be necessary to lay geotextile out over the worked site at the end of each working day to temporarily stabilise it, until metal is placed. Other parts of the site will be vegetated in a way that achieves a good level of vegetative cover (>80%) as quickly as possible to minimise erosion. Re-vegetation will be through hydroseeding and spreading of topsoil and grassing (mulching may be required in some areas). Hydroseeding will primarily be used on cut slopes and spoil sites. Where appropriate direct transfer of native vegetation from adjacent parts of the site will be used. Once the construction phase of the Project is complete, and it is practical to do so, on approval from Mercury (after taking advice from Council) the erosion and sediment control methods described above will be removed from site and the area reinstated.

4.3.5

Spill Response

The construction of the Wind Farm will involve the storage and use of substances, some of which are potentially hazardous if discharged to the environment. Best management practices will be adopted to minimise the chance of accidental spillage or loss of hydrocarbons and non-stabilised cement products to watercourses. A monitoring programme will provide the basis for an adaptive management response to issues that may arise during the construction phase of the Wind Farm. Impacts on freshwater ecology from construction activities can be minimised through the management of contaminated land, groundwater, spills and hazardous substances. These environmental aspects have the potential to contaminate runoff and enter waterways. Version: 6.0 DATE: 02/08/2019

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Emergency response and spill contingency plans will be implemented on site to minimise risks. The risk of accidental spillages of hydrocarbons and other potentially harmful substances during construction will be minimised by the adoption of best management practices such as refuelling in bunded sites out of sensitive sub-catchments and regular servicing / maintenance of hydraulic hoses on heavy machinery. All stored fuel will be protected by a bund for an appropriate volume to prevent spillage of fuel during normal use or by accidental rupture. A fuel bowser will then be used to transfer smaller quantities of fuel to plant employed around the Site. All fuel storage facilities will be constructed outside the Turitea water supply catchment. A Safety Data Sheet (SDS) is required for all hazardous substances stored/used on the Project. The SDS will be provided by the supplier and with delivery. The SDS must be available and understood by all personnel handling (or with access to) the substance. A location plan will be prepared for each of the SEMPs which will include the locations of:    

Stored hazardous substances; Firefighting equipment; First Aid kits; and Spill kits.

All heavy plant will carry their own spill kits with storage containers and additional spill kits carried in each of the vehicles. Hazardous materials will be stored in a container which will be bunded. Storage containers will be at the laydown yard (illustrated in figure 4).

4.3.6

Archaeology

The existing historic and archaeological values of the area have been evaluated in the Archaeological Assessment (Appendix E of the AEE). No pre-European archaeological sites have been recorded in the general vicinity of the site. During the preparation of the AEE, Iwi have confirmed that the Tararua Ranges are culturally, spiritually and historically significant to tangata whenua. Four sites of cultural significance have been identified within the vicinity of the Turitea Wind Farm. The works proposed within the Turitea Reserve have been designed so as to minimise earthworks and vegetation clearance. The fact that existing access tracks will be utilised wherever possible will also further reduce the likelihood of existing cultural or heritage sites being disturbed. It is considered unlikely that any archaeological sites will be exposed during construction of turbines and associated infrastructure. The possibility that they might be, however, means that an Accidental Discovery Protocol is in place. Accidental Discovery Protocol If Taonga (treasured or prized possessions, including Maori artefacts) or archaeological sites are discovered in any area being earth-worked, works shall cease immediately, within a 100m radius of the discovery. The Electrix Project Manager shall contact Mercury Project Manager as soon as possible. Mercury will facilitate the contacting of: 

local iwi; Version: 6.0 DATE: 02/08/2019

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 

the Heritage New Zealand Pouhere Taonga; and the relevant Council Environmental Compliance Manager(s).

Works shall not recommence in that area until a site inspection is carried out by iwi representatives, relevant Council staff and staff of the Heritage New Zealand Pouhere Taonga (if they consider it necessary); the appropriate action has been carried out to remove the Taonga and record the site, or alternative action has been taken; and approval to continue work is given by the relevant Environmental Compliance Manager(s). If during construction activities, any Koiwi (skeletal remains) or similar material are uncovered, works will cease within a 100m radius of the discovery immediately. The Electrix Project Manager shall contact Mercury Project Manager as soon as possible. Mercury will facilitate the contacting of:    

NZ Police; Local iwi; Heritage New Zealand Pouhere Taonga; and Relevant Council Environmental Compliance Manager(s).

Works shall not recommence in that area until a site inspection is carried out by iwi representatives, relevant Council staff, and staff from the Heritage New Zealand Pouhere Taonga and the New Zealand Police (if they consider it necessary). This will likely include a blessing/appropriate ceremony conducted by iwi. The Koiwi or similar material discovered will likely be removed by the iwi responsible for the tikanga appropriate to their removal and preservation or re-interment, or alternative action (e.g. works are relocated). Approval to continue work will be given by the relevant Council Environmental Compliance Manager(s) in associated with the above parties.

4.3.7

Ecological and Landscape Management

Vegetation The degree of vegetation impact of each of the proposed turbine pad sites is related to the character of existing vegetation, steepness of terrain, and the extent of new roading infrastructure required to reach a turbine site. Thus, there are many turbine sites in the Reserve and on private land where, subject to road placement in relation to streams and related sediment control measures, effects have been classed as being ‘very minor’. The private land turbine sites are all pasture or require only minor clearance of indigenous shrubland to reach the proposed turbine sites. Care will need to be taken when crossing steeper gullies to minimise clearance of riparian vegetation, and final roading alignments will address this issue. Dust and Sediment Management The large-scale earthworks may generate dust. Although a nuisance, this is very unlikely to result in adverse ecological effects as most construction works will be confined to ridges in horopito-dominant vegetation, and dust will simply wash off vegetation during rain. The construction of roading may cause sediment and run-off effects, which may affect the quality of the waterways within the Turitea site. Construction of roading also has the potential to alter drainage courses or to require culverts. However, these effects will be mitigated by the implementation of sediment runoff controls to prevent sediment inputs into waterways. Version: 6.0 DATE: 02/08/2019

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Further details of the proposed measures to be undertaken to avoid, remedy, or mitigate the effects of sediment run-off are set out in Section 3.3.4 of this CEMP. Birds Indigenous bird species may be affected by the loss of habitat during the construction of the associated infrastructure (e.g. roads and building platforms). Habitat loss is required to be mitigated by Mercury in accordance with the Rehabilitation and Revegetation Management Plan. However, with construction being confined to ridge top vegetation, effects on mobile bird species are likely to be minimal. Effect on Bats Mercury’s pre-construction bat monitoring activity recorded no bats at the site. Construction activities will, therefore, be undertaken in accordance with an accidental bat / bat roost discovery procedure to be supplied by Mercury. Effect on Lizards Mercury’s lizard searching effort has shown that herpetafauna within the Turitea reserve is at very low densities, with only three green gecko (barking gecko) found in horopito scrub vegetation. No other species of skink, gecko or lizard have been found on site. The Department of Conservation is yet to confirm preferred lizard management methodology for this project in light of these lizard search results. Removal of potentially high value lizard habitat may still require some form of pre-clearance lizard search and salvage (e.g. tower locations in the Reserve). In any event, construction activities will be undertaken in accordance with final Lizard Protection Plans. Effect on Powelliphanta Snail Population Powelliphanta traversi tararuaensis may be present in the area. If found, populations will be translocated to safe sites, which will be carried out in consultation with the Department of Conservation. Controlled Blasting At present it is not proposed to use controlled blasting. However, should this change updates to the CEMP will be drafted. Helicopter Use Individual pylons away from access roads will be constructed using helicopters - Poles 9, 10, 26-30, 33-35 (illustrated in figure 2). The noise disturbance effects will be limited to a relatively small timeframe and effects will be minor. Effects and controls will be outlined in the CNMP. Aquatic Tonkin & Taylor Ltd undertook the baseline monitoring work over an eight-month period between June 2018 and January 2019. It was concluded that the most likely cause of instream effects associated with the Project would be:   

increased sediment loading to watercourses from vegetation clearance, construction/earthworks activities, the accidental spillage of hydrocarbons into watercourses from machinery; and the accidental spillage of concrete products entering watercourses.

and

Each of the effects listed above has the potential to adversely affect instream communities downstream of construction activities.

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Given the Project will be adopting and implementing best industry practices and given the location of works and that the majority of accessways are on ridgelines are separated from perennial reaches of surface receiving waters, it is considered that the effects of constructing the Wind Farm on aquatic ecology have a high probability of being less than minor. The desired outcome will be achieved by following the following steps:     

Adoption of best practice and relevant measures detailed in Greater Wellington Regional Council’s Erosion and Sediment Control Guidelines (Denton and Robson, 2002); Adoption of Best Management Practices for instream works; Adherence to Tonkin & Taylors approved Water Quality & Aquatic Ecology Monitoring Plan (AEMP); Adherence to Tonkin & Taylors Aquatic Ecology Baseline Monitoring Report; and The implementation of the recommendations contained within Tonkin & Taylors Adaptive Aquatic Ecology Management Response Plan (AEMRP) (once submitted and approved).

Lizards Lizard surveys within the Turitea Reserve have indicated the presence of good habitat for barking gecko (Naultinus punctatus) at proposed turbine sites, as well as at proposed pylons and potential associated access tracks. The Transmission line works will be carried out in accordance with the recommendations contained within Wildlands Lizard Management Plan (once submitted and approved).

Traffic Management Traffic management is detailed within the CTMP required by Schedule 3: condition 70. Traffic will be monitored with the recording of:    

All vehicles travelling in and out of the site during construction; Any record where truck access was required outside of the prescribed limits for the purpose of carrying out emergency maintenance works or responding to a health and safety matter. Pavement surfaces on Greens Road shall be inspected by a suitably qualified engineer as required and reported as per Schedule 3: Condition 75; and Records will be kept by Mercury regarding calls received on the 0800-phone number about driver behaviour.

In total, no more than 5,800 truck* movements shall occur through the Greens Road access during construction. * N.B: A truck is defined by the Board of Inquiry decision as “a vehicle with a gross vehicle mass exceeding 3,500kg which requires a 2,3,4, or 5 drivers licence to operate.” Vehicles entering or exiting the site shall travel on Greens Road or Kahuterawa Road (following their upgrae) at the following times: Table 3: Vehicle restrictions: Greens Rd and Kahuterawa Road.

Time Period

Light Vehicles

Trucks 6.30am to 7.30am; 8.15am to 3.15pm; and

Weekdays

No restrictions

4.30pm to 6.00pm; Except that trucks shall not use the road when particular events, notified through

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community consultation, are held, and which involve a peak in the presence of vulnerable road users, such as equestrian or cycling events. In addition, the prohibition on access from 7.30am to 8.15am and 3.15pm to 4.30pm only applies on school days. 6.30am to 7.30am; and Weekends and statutory holidays*

5.00pm to 6.00pm; Except that up to 10 other light vehicle movements may occur outside of these times each day.

No truck access, except that up to 6 truck movements per day may occur on weekends and statutory holidays between the hours of 8am and 6pm.

*In addition to the traffic permitted above, light vehicle access is allowed at any time for the purposes of site security and site supervisors (associated with the monitoring of health and safety and environmental effects). Additionally, light vehicle and truck access is allowed at any time for the purpose of maintenance / emergency response, to carry out emergency maintenance works or to respond to a health and safety matter that cannot reasonable wait until a weekday.

Emergency Contacts and Response There is the potential for unforeseen events to occur that may impact on the environment and will require emergency response. The following sections detail how environmental incidents or emergencies are to be managed by the Project team.

4.5.1

Incident/Emergency Management

An environmental incident is an occurrence which has (or potentially could have had) a negative or ‘adverse’ effect on the environment. An adverse effect is something that causes (or could have caused) environmental harm. An environmental incident can also be a deviation from this CEMP. This means there has been a failure to follow the established process or procedures that help the Project achieve best practice (e.g. failure to report a spill). Environmental incidents include but are not restricted to:    

Spills; Unforeseen impact on areas of high environmental value such as protected flora or fauna, archaeology; Council non-compliances (e.g. relating to erosion and sediment control); Other consent non-compliances.

An environmental emergency is an event which has a detrimental effect on the surrounding environment. A detrimental environmental effect is something that causes significant harm to the environment, which is not legally allowed and requires immediate response or a failure to follow the established process or procedures that helps achieve best practice. In the event of an environmental incident/emergency, the following procedures, Table 4 will be followed. Environmental emergency contact details are included in Table 4.

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Table 4: Management of environmental incidents/emergencies.

Environmental Incident Management Performance objectives

To ensure rapid and appropriate response is made to environmental incidents/emergencies.

Statutory and Legislative

Resource Management Act and resource consent conditions. All incidents to be formally registered.

Performance Criteria

All incidents responded to in a timely manner and investigated by the Environmental Manager. Environmental incident and emergencies to be reported to the Client within four (4) hours of the event. Eliminate potential for environmental complaints.

Response Person

The Environmental Manager is responsible for receiving, documenting and investigating all incidents. All members of staff are responsible for their actions which could impact or result an environmental incident. The details of all incidents will be registered on an Environmental Incident Form and supplied to the Environmental Manager.

Mitigation

Upon receipt the Environmental Manager will commence an inquiry. Steps to mitigate, isolate or eliminate the reoccurrence will be implemented. The environmental incident/emergency will be reported to the Client within four (4) hours of the event.

Monitoring

Ongoing monitoring will occur to ensure compliance and best practice is observed.

Review

In the event CEMP / regulatory guidelines or permitted criteria have not been breached, the Environmental Manager, Construction Manager and the Project Manager are to investigate how work practices may be modified to lesson perceived or actual environmental impact. The environmental incident/emergency will be reported to the Client within four (4) hours of the event.

Reporting

The Environmental Manager will summarise all incidents received throughout the sites to on-site staff members through weekly Tool Box sessions. The Environmental Manager shall include monitoring inspection records in the Weekly Environmental Compliance Report and a summary in the Monthly Environmental Compliance Report.

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Table 5: Environmental Emergency Contact Details.

Position

Name

Organisation

Phone

Environmental Manager

Emma ComrieThomson

Electrix

Ph: 021 755 509

emmac@4sight.co.nz

Construction Manager

Jon Edwards

Electrix

Ph: 021 953 336

jon.edwards@electrix.co.nz

Project Manager

Kevin Small

Electrix

Ph: 021 312796

kevin.small@electrix.co.nz

HSEQ Assessor

Alison Gardiner

Electrix

Ph: 021 822 900

alison.gardiner@electrix.co.nz

Environmental Resources Manager

Mark Henry

Mercury

Ph: 027 479 7592

mark.henry@mercury.co.nz

Consents Compliance Manager

Mason Jackson

Mercury

Ph: 027 230 8567

mason.jackson@mercury.co.nz

Hamish Sutherland

ManawatuWanganui Regional Council (Horizons)

Ph: 021829607

hamish.sutherland@horizons.govt.nz

Ph: 0508 800 800

and

Monitoring Officer * Horizons to act on behalf of PNCC and TDC Horizonâ&#x20AC;&#x2122;s Regional Council Pollution response

4.5.2

Environmental Incidents Form

A standard Environmental Incident Form template will be used for all site-specific activities throughout the construction of the Project. A copy of the Environmental Incident Form is included in Appendix D.

4.5.3

Environmental Incident Register

A standard Environmental Incident Register will be controlled by the Environmental Manager. It will contain all environmental incidents occurring on sites within the Project. The Environmental Manager will input all data from completed Environmental Incident Forms as soon as possible. The Register will be discussed regularly at the Project Team meetings and reported in the Monthly reports to Mercury. These meetings/reports will discuss the corrective actions taken, and the preventative measures that have been put in place.

4.5.4

Hazardous Substances Spills and Spills Contingency Planning

Loss of containment of hazardous substances can potentially affect human health and the environment. The primary control for the management of hazardous substances will be to keep the handling and storage of hazardous substances (type and volume) to a minimum. Version: 6.0 DATE: 02/08/2019

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The Project will manage hazardous substances to minimise the likelihood of a spill. This will be done by:  



Preventative measures: Implement and maintain the required preventive measures for handling, transferring and storing of oil, fuel and chemicals; Action in the Event of Spill: o Assess personal safety and explosion risk; o Stop operating machinery; o Isolate source of spill; o Take whatever action is necessary to contain the spill and prevent it from spreading or discharging into a stormwater drain or cesspit, natural waterway (e.g. create a temporary earth bund); o Notify Foreman/Supervisor; o Locate nearest spill kit; o Use absorbent booms, mats or ‘kitty litter’ to soak up the contamination; and o If external assistance is necessary, call the local provider of spill equipment or the Regional Council spill response unit. Reporting Spills: Report spills using the Environmental Incident Report form (Appendix D). Submit Incident Report to Project Manager and copy to Environmental Manager. The Environmental Manager will then log incident Report on Register. The Project Manager will as soon as practicable inform Mercury who will notify the Councils of any significant spill to land, stormwater system or natural watercourse. Investigation: An investigation report for spills having significant environmental impact will be prepared. This will be conducted by way of investigation and preparation of the report. The Environmental Manager will obtain witness statements where appropriate.

4.5.5

Specific Environmental Emergencies

As required by condition 6.11 of Schedule 1, details on our proposed contingency plan in relation to specific environmental emergencies are as follows. These are detailed further in the respective SEMPs for potentially affected areas: Riparian zone restoration Electrix is not proposing to remove large areas of vegetation within the Turitea Reserve, therefore reducing the risk of significant erosion / washout events. Electrix will be employing narrower and shorter tracks which will mean the bulk of disturbance works are minimised, with the use of helicopters lowering equipment into place. As part of contingency planning, should an event occur and once the site is safe to examine, an investigation to identify the cause and extent of the damage to the riparian zone would be undertaken, as well as identifying what erosion and sediment controls would need to be deployed to stabilise the site. A full report of this investigation would then be promptly be submitted to Mercury and Council’s Environmental Manager/s for assessment.

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Once the site has been stabilised using erosion and sediment controls identified in the SEMP, the site would then be monitored and maintained until it was appropriate to undertake replanting activities. When able, the site will then be replanted in accordance with the Wildlands Rehabilitation and Revegetation Plan for the Turitea Wind Farm. De-silting of PNCC Water Supply Should a siltation event occur, once the work site was stabilised using erosion and sediment controls identified in the SEMP, Electrix will commence an immediate investigation into the incident to identify the cause and understand the severity of the event and of any resulting impacts on the PNCC water supply. Subject to the volume of sediment and the magnitude of the incident, options such as pumping contaminated water from the reservoir could be utilised, or in the case of a catastrophic failure caused by Electrix activities, an excavator could be deployed to clear deposited sediment from upstream tributaries or shallow waters and/or additional sediment treatment of the PNCC water supply could be implemented at the pollutersâ&#x20AC;&#x2122; cost. All remedial options will first be discussed with Mercury and Palmerston North City Councils Environmental Managers for approval prior to conducting the activity. Notification to downstream users of a clean-up response in the event of significant spillage of hydrocarbons / concrete products to watercourses occurring during construction Notice of either incident, including details of the clean-up response, will be given to Mercury who will then contact Council via the pollution hotline (24hr freephone: (+64) 0508 800 800) and in the first instance notify any owners of downstream water takes potentially affected. All crews will be equipped and trained in an on the ground response. Once the source has been contained, a team will deploy appropriately sized absorbent booms at the downstream most extent of the spill as soon as practicable. Noting no large quantities of hydrocarbons or concrete products will be onsite in the Reserve area. To eliminate / minimise the risk of a significant hydrocarbon spill, all bulk storage of hydrocarbons and chemicals not be stored in PNCC Water Supply Catchment or where in event of failure can enter any waterways. Refuelling and servicing of equipment will not be undertaken where there is a risk of spills into waterways. In the event of a significant concrete spill, immediate containment and removal of spilt concrete products from the affected area will commence. As there is little that can be done once the concrete products enter a waterway, the main focus will be on containing the spill to prevent further contamination. Downstream monitoring will then commence to determine the extent of the effects of the spill and what, if any decontamination, mitigation or compensation might be appropriate. Earth berms may also be implemented to prevent spills into waterways, reserves and farmlands in the event of a catastrophic failure during construction. Specific concrete and grout wash-down areas will also be provided and will incorporate the same controls as above. All spent/redundant concrete/grout wastes will be reused or removed from Project.

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Removal and disposal of cleared vegetation Electrix is not proposing to remove large areas of vegetation within the Turitea Reserve, additionally we will not be using moribund vegetation bunds. Narrower and shorter tracks will be used with the bulk of disturbance works minimised with the use of helicopters lowering equipment into place.

Complaints Management Procedure for keeping records of public complaints and any action taken in response in accordance with be carried out in accordance with Consent conditions Schedule 1: Condition 19-21. In this regard Mercury has set up a phone number (0800 201 520) and an email address (turiteawindfarm@mercury.co.nz) for members of the public to register inquiries or complaints. When an environmental complaint is received directly by Electrix, it will be communicated to Mercury, and vice versa if received through Mercury’s 0800 number or website. Upon receipt of the complaint, the Environmental Manager will then complete the following forms:

4.6.1

Complaint Form

A standard Complaint Form (Appendix E) will be used for all site-specific activities throughout the Project. The Environmental Manager will ensure that the details of the investigations and any follow up actions are completed and recorded for each complaint. The form will contain but not be limited to;       

Name and address of complainant (if provided); Identification of the nature of the complaint; Date and time of the complaint and alleged event; Wind and weather at the time; Activity occurring on the site at the time; Details of whether the compliant was or was not able to be verified; and Any remedial actions undertaken.

The Environmental Manager will commence an inquiry within 1 hour of receiving the complaint. Contact will be made with the complainant (if details have been provided) within the same working day an interim response advising that investigations are continuing is acceptable. A formal written response will be provided to the complainant and appropriate regulatory authorities within 10 days of complaint receipt.

4.6.2

Complaints Register

A Complaints Register will be controlled by the Mercury. It will contain all complaints received for the Project. The Environmental Manager will submit all data from completed environmental Complaints Forms as soon as possible. The Environmental Manager will summarise all complaints received throughout the site to on-site staff members during weekly Tool Box sessions. The Complaints Register will be discussed at regular meetings held between the Environmental Manager, Construction Manager, Mercury and Electrix Project Manager. Version: 6.0 DATE: 02/08/2019

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5. Monitor and Review Compliance The following section describes procedures for monitoring activities to evaluate compliance with legal requirements, the Mercury objectives and relevant policies, standards and guidelines.

5.1.1

Environmental Risk Register

The Environmental Risk Register, to be populated and maintained by the Project team is a tool for identifying, prioritising and management of activities that have the potential to impact on the environment. As described in Section 2.3, the risk assessment process adopted defines a process of managing significant risks with comprehensive Management Plans. The Risk Register will be regularly updated and reassessed to allow all significant aspects to be identified. The Risk Register will allow the Project team 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.

5.1.2

Environmental Monitoring

Scheduled environmental monitoring of environmental performance and compliance with resource consents is required throughout the construction phase of the Project. This enables the overall effectiveness of the environmental controls to be determined and allows areas of non-compliance to be identified so corrective actions can be taken. Environmental monitoring has already begun to ensure baseline data has been collected. Some of this monitoring will continue during construction to assess the impact of the construction on the environment, and after construction to assess the impact of the completed Project. Environmental monitoring is required at various stages of construction for each environmental aspect as developed in specific Management Plans and this CEMP. The monitoring schedule will be a working document and will be amended and updated to reflect resource consent and management review changes. General Site Monitoring In addition to environmental monitoring, general site monitoring will also be undertaken: ď&#x201A;ˇ

ď&#x201A;ˇ

Daily - Electrix Delivery team and/or the Health Safety and Environmental Team will conduct inspection and issues will be noted. These inspections are informal visual inspection in order to check compliance with the CEMP. Weekly - Formal site inspections are to be completed by the Health Safety and Environmental Team. Site specific checklists will be developed to check compliance against the SEMP (including resource consent conditions). Issues will be noted if they present significant environmental risks (e.g. works near watercourses). Monthly - The Electrix Project Management Team and the Construction Manager will undertake a monthly site with the Environmental Manager to confirm the environmental monitoring programmes and work procedures containing environmental controls are being implemented in accordance with the SEMP and resource consents.

The Environmental Manager shall submit environmental performance reports monthly to the Project Manager for inclusion into reporting to Mercury. This report will include but not be limited to: Version: 6.0 DATE: 02/08/2019

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   

A summary of environmental issues and actions during the month; Complaints received; Incidents - associated and corrective actions; and Environmental inductions and awareness training provided.

5.1.3

Review

The Environmental Manager and Construction Manager will review the daily inspection forms on a weekly basis to confirm that the checks and subsequent required works are being carried out. A regular meeting will be held on site between the Project Manager, Construction Manager and the Environmental Manager to discuss the results of the weekly and monthly site monitoring. On a monthly basis the Environmental Manager will review the monitoring schedule and compliance results from the required Environmental Monitoring as per this CEMP. Should inspections indicate that the environmental controls are not functioning as intended, the Environmental Manager and Construction Manager will instigate a review of the CEMP or relevant Management Plans as required. The Project Team will be available for quarterly meetings with the Regulators and Iwi representatives at the Strategic Management Oversight Unit meetings.

Environmental Auditing Periodic environmental audits are required to:   

Determine conformance with the Projects Environmental Commitments; Ensure that environmental controls are properly implemented and maintained; and Determine the extent to which the requirements defined in project resource consents, Management Plans and environmental procedures have been met.

The frequency of these audits will be determined by past performance and environmental risk. Internal audits will be undertaken by the Environmental Team and by Mercury on a regular basis. These audits will focus on site and task specific activities such as erosion and sediment controls, concrete works, refuelling procedures and high-risk construction activities to ensure all controls and methodologies are being implemented as required. External audits will predominantly be undertaken by regulatory authorities such as PNCC, TDC and Horizons to confirm compliance with resource consent conditions. The Environmental Team with input from the Construction Team will host these audits. The Environmental Manager will be responsible for ensuring that all non-conformances identified in an audit are closed out in a timely fashion as per the auditor’s recommendations. Results of the audits will be reported back to the Project team through a variety of mechanisms including site toolbox meetings, construction meetings and Management Team meetings.

Environmental Reporting The following reports will provide a record of compliance with the resource consents:  

The Environmental Manager will report weekly to the Project Manager on the status of site environmental matters. Should any member of the Project team become aware of an environmental incident or hazard that is causing - or has the potential to cause environmental harm - that person must advise their immediate supervisor who will notify the Environmental Manager, and an incident report will be completed. Version: 6.0 DATE: 02/08/2019

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

The Environmental Manager will be responsible for ensuring that all statutory reporting required by the consents is undertaken.

CEMP Review The CEMP and the Management Plans will be updated, with the necessary approvals, throughout the course of the Project to reflect material changes associated with changes to construction techniques or the natural environment. Approval from PNCC, TDC and Horizons will be required for any relevant revisions of a material nature to the CEMP or Management Plans, for which these authorities have jurisdiction. A management review of the CEMP will be undertaken at the 6-month anniversary of the Project starting by the Project Management team. The management review will be organised by the Environmental Manager. The review will take into consideration:           

Input from Mercury; Site personnel comments; Audit findings and recommendations; Environmental monitoring records; Site conditions (e.g. weather, archaeology, ecology); Environmental complaints, incidents and emergencies; Details of corrective and preventative actions; Environmental non-compliances; Changes to organisational structure; Ongoing compliance with objectives, conditions and targets; and 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 CEMP will be documented. A copy of the original CEMP document and subsequent versions will be kept for the Project records and marked as obsolete. Each new/updated version of the CEMP documentation will be issued with a version number and date to eliminate obsolete CEMP documentation being used.

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Appendix A - Conditions of Resource Consent (specific to CEMP)

Mighty River Power Generation

Turitea Wind Farm

Resource Consent Conditions

Turitea Project Manager 5 August 2011

1.5

Revision: 1.4

Any other documentation submitted by Mighty River Power relevant to the applications;

1.6 document dated February 2010; and 1.7 2.

For the purposes of section 125(1) of the Act, these consents shall lapse if not given effect to within 10 years after the date of commencement of the consents.

The terms for land use consents (under section 13 of the Act) and discharge permits shall be for a period of 35 years from the date of commencement of the consents.

The Consent Holder shall provide a copy of these conditions to any operator or contractor undertaking works authorised by these consents, prior to the works commencing.

The consents are granted by each Council subject to its officers or agents being permitted access to the property at all reasonable times for the purpose of carrying out inspections, surveys, investigations, tests, measurements or taking samples.

Management Plans

At least 40 working days prior to the commencement of any construction works, the Consent Holder shall submit a detailed CEMP to the Environmental Compliance Manager at each respective Council, for review acting in a technical certification capacity. A response should be provided within 30 working days of receipt. Construction activities must not commence until written certification has been obtained. The CEMP shall be prepared with the assistance of a suitably qualified environmental management specialist, and shall include, but not be limited to, the following:

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Mighty River Power Generation

Turitea Wind Farm

Resource Consent Conditions

Turitea Project Manager 5 August 2011

Revision: 1.4

6.1

Objectives of the environmental management process;

6.2

Outline of the relevant statutory and contractual requirements;

6.3

Proposed construction methodology and timetable for all construction works;

6.4

A process for reviewing the CEMP, including the process for developing and advising each Council of revisions;

6.5

Roles and responsibilities, including appointment of an Environmental Manager who is: a.

based on the construction site for the duration of the construction works;

responsible for compliance with the CEMP, SEMPs and these conditions;

contractually authorised by the Consent Holder to issue instructions to any contractor working on site as required to ensure compliance with these conditions; and

d. Compliance Managers as required to review issues relating to these conditions. 6.6

Training to ensure all contractors are made aware of the conditions of these consents and of the need to comply with them at all times;

6.7

Procedures for keeping records of public complaints and any action taken in response to such complaints in accordance with condition 19;

6.8

Methodology for preparing SEMPs for each of the relevant sub-catchment areas;

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Mighty River Power Generation

Turitea Wind Farm

Resource Consent Conditions

Turitea Project Manager 5 August 2011

6.9

Revision: 1.4

An outline of the key potential environmental effects and measures to be adopted to avoid or mitigate these;

6.10

An Accidental Discovery Protocol in relation to archaeological sites;

6.11

Emergency responses for managing hazardous substances and any spills, including a contingency plan for: a.

Early notification of downstream users and monitoring of a cleanup response in the event of significant spillage of hydrocarbons / concrete products to watercourses occurring during construction of the wind farm; and

The removal and disposal of cleared vegetation offsite in the event of significant release of nutrients / BOD from moribund vegetation bunds at turbine sites occurring during construction of the wind farm; and

6.12 7.

Procedures for inspections, monitoring and reporting.

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Appendix B - Community Liaison Group Terms of Reference

Turitea Wind Farm Community Liaison Group – Terms of Reference

1. Introduction In accordance with Condition 17 of Mercury’s resource consents for the Turitea Wind Farm, Terms of Reference for a Community Liaison Group (CLG) are required to be developed by Mercury and the Manawatu-Wanganui Regional, Palmerston North City and Tararua District Councils. Conditions 14 and 15 of the consents provide details on which organisations and interested parties Mercury shall invite to participate in the CLG, while Condition 16 provides detail on the specific function of the CLG. Accordingly, the requirements prescribed in conditions 14 through 17 of the consents have been used by Mercury and Manawatu-Wanganui Regional, Palmerston North City and Tararua District Councils to develop these Terms of Reference.

2. Membership As far as practicable, the membership for the CLG will be invited from parties that include;              

Manawatu-Wanganui Regional Council (1 representative, 1 alternate) Palmerston North City Council (1 representative, 1 alternate) Tararua District Council (1 representative, 1 alternate) Rangitane o Manawatu (1 representative, 1 alternate) Rangitane o Tamaki Nui a Rua (1 representative, 1 alternate) The Tararua Aokautere Guardians Inc (1 representative, 1 alternate) The Friends of Turitea Reserve Inc (1 representative, 1 alternate) Owners of private land containing turbines (1 representative, 1 alternate) Residents in the Kahuterawa Valley (Kahuterawa Road and feeders including Green Road) (2 representatives, 1 alternate) Residents in the Turitea Valley (Turitea Road and feeders, including Ngahere Park Road) (2 representatives, 1 alternate) Residents on Pahiatua Track (Pahiatua-Aokautere Road and feeders) (2 representatives, 1 alternate) Residents on Makomako Road (1 representative, 1 alternate) Mercury (1 representative, 1 alternate) Manawatu Mountain Bikers (1 representative, 1 alternate)

Notes:    

The list of organisations and interested parties above has a wider range and a greater breakdown of community sectors than the list prescribed in Condition 14 of the Consents. The membership list is not intended to be exclusive or final. It is not mandatory for the CLG to have representatives for each of the groups listed above. Representation on the CLG by each of the groups listed (and any others that may come forward in future) is up to the wishes of each individual group. Although the CLG shall strive to secure an official membership base, other members of the community who are not CLG members will be free to attend CLG meetings in

accordance with the meeting protocols the CLG has set for itself outlined in Section 7 of these Terms of Reference. An independent Chair (convenor) will be appointed to ensure adherence to the CLG agenda, and these Terms of Reference and to run CLG meetings in a fair and independent way.

3. General Functions of the CLG Construction Phase ‐ ‐

To enable two-way flow of relevant project related information between the local community and Mercury; To share, clarify and understand the various project construction activities so that: o Community members:  remain informed about what’s happening with construction and how associated activities might impact them; and  have an opportunity to consider how they might avoid any construction related impacts; and  have an opportunity to suggest alternatives or changes to Mercury, that might avoid or minimise disruption or impact. o Mercury:  has an opportunity to hear any community concerns and understand any potential disruption or adverse impact its construction related activities may have on the community; and  can consider alternative methods or timings to avoid or minimise construction related disruption or impact. o The CLG:  can discuss practicable ways to avoid or minimise disruption or adverse construction related impacts on people’s daily lives; and  communicate such changes to the community.

Operations Phase ‐ ‐

To enable two-way flow of relevant wind farm-related information between the local community and Mercury; To share, clarify and understand the wind farm operational activities so that: o Community members:  remain informed about what’s happening with wind farm operations and how associated activities might impact them. o Mercury:  has an opportunity to hear any community concerns and understand any potential disruption arising from wind farm operations. o The CLG:  can discuss practicable ways to avoid or minimise disruption arising from wind farm operations.

4. Specific Functions of the CLG (as required by Condition 16 of the Consents) 3.1

Discuss Mercury’s performance in terms of:

a. Noise control and compliance; and b. Construction traffic impact. 3.2

Consider the results of all ecological monitoring and research required in accordance with the consent conditions.

3.3

Make recommendations to and receive feedback from Mercury, in respect of the above matters where considered necessary and appropriate.

3.4

Have input, as appropriate, via consultation with Mercury with regards to the implementation of the: a. Noise Management Plan; b. Construction Environmental Management Plan; and c. Construction Traffic Management Plan.

5. What is not the function of the CLG? It is not the CLG’s function to;   

propose or discuss any changes to the activities authorised by the Turitea Wind Farm Consents (for example, size and layout of turbines etc); or challenge or discuss the validity of the consents; certify or approve management plans or procedures required by the consents.

6. Variations to CLG’s Functions The CLG may vary its functions as it thinks fit from time to time to enable it to liaise more effectively with the community and Mercury, provided this is done in consultation with the Principal Planners at each respective Council, and the variation is accepted in writing by Mercury.

7. CLG Meeting Protocols Unless otherwise agreed by Mercury and the Manawatu-Wanganui Regional, Palmerston North City and Tararua District Councils, the CLG will meet at least; o o o

Monthly during the period prior to the commencement of construction; Quarterly during the period of construction; 6-monthly during the period of wind farm operation for the duration of the consents;

OR o

At such other frequency as the CLG decides.

Appendix C - Environmental Risk Register

Environmental Risk Register Risk Rating Likelihood

Consequence

Probable

Minor

Possible

Improbable

Medium

Low

Minor: low environmental impact. Short term and can typically be remedied.

Moderate

High

Medium

Low

Moderate: Environmental effect/s which can be remediated. Discharge off site occurs.

Major

High

Medium

CEMP = Construction Environmental Management Plan CLG = Community Liaison Group SEMP = Site Environmental Management Plan Electrix Environmental Manager = EEM Electrix Project Manager = EPM Electrix Project Ecologist = PE

Major: Significant environmental effect resulting in costly restoration under Resource Management Act.

Electrix Construction Manager = CM Construction Noise Management Plan = CNMP Assessment of Environmental Effects = AEE Electrix Environmental Management Team = EEMT Electrix Site Supervisor = SS

Appendix C: Environmental Risk Register pg. 1

Issue Sediment tracking onto roads

Likelihood

Consequence

Risk

Mitigation

Reference

Possible

Minor

Low

All entrances and exits from site are to be stabilised entrance ways. These are to be maintained and may have wheel washes associated with them.

CEMP. SEMP.

Road sweeping if required. Erosion and sediment controls to be in place. Inspect controls regularly. Public complaints

Possible

Moderate

Medium

Keep Community Liaison Group (CLG) informed of works and progress.

CLGâ&#x20AC;&#x2122;s Terms of Reference.

Record complaint using the Complaints Form.

CEMP section 3.5. CEMP Appendix I.

Advise EEM. Waste management

Possible

Moderate

Medium

All waste is to be collected and removed from site and disposed at an CEMP. appropriately licensed SEMP. facility. No domestic waste water will be discharged to ground or water within the water supply catchment.

Waterway contamination due to sediment discharge

Possible

Moderate

Medium

Refer to the CEMP and the SEMP for site specific sediment controls. Methodologies within these documents need to be carefully followed.

Sedimentation of the PNCC Water Catchment washout event

EEMT will be responsible for regular inspection and maintenance of all erosion and sediment controls and audits.

CEMP section 3.3.4 and section 4.5. SEMP. AEE: Appendix J section 5.2.

Weather dependant checks will also be required from the EPM, CM and SS. Waterway contamination due to washing of vehicles and equipment

Improbable

Moderate

Low

No vehicle/equipment washing is to occur near waterways or stormwater cesspits. Designated areas will be utilised for washing vehicle/equipment.

CEMP.

Damaging protected vegetation

Improbable

Moderate

Low

SEMP identifies works affecting vegetation. All materials, plant and vehicles to be stored outside the dripline of all trees.

CEMP section 3.3.7. SEMP. AEE: Appendix D section 7.1.

Disturbance of sensitive areas due to storage of construction materials

Improbable

Moderate

Low

All materials, plant and vehicles to be stored outside the dripline of all trees. Locate all stockpiles away from waterways and overland flow-paths.

CEMP. SEMP.

Erosion and sediment controls to be in place. Inspect controls regularly.

Appendix C: Environmental Risk Register

pg. 2

Issue Lack of environmental awareness

Spill during refuelling of plant equipment to land or water

Spill of hazardous substances to land or water

Likelihood

Consequence

Risk

Mitigation

Reference

Possible

Moderate

Medium

Project environmental induction, SEMP induction and toolbox meetings.

CEMP.

Refuelling and servicing to occur in approved locations only.

CEMP.

All fuel storage facilities will be constructed outside the Turitea water supply catchment.

SEMP.

Possible

Moderate

Medium

SEMP.

Spill kits to be within easy reach and appropriately sized.

AEE: Appendix J section 5.2.

Spill kits to be within easy reach and appropriately sized.

CEMP section 3.4.4.

Appropriate training given to staff.

CEMP Appendix H.

Identify contaminant, stop source, protect receiving environment, contact EEM, clean up.

SEMP.

Review and report using Environmental Incident Form.

AEE: Appendix J section 5.2.

Store hazardous substances in bunded area or appropriately sized container. All storage containers to be labelled. Safety Data Sheet (SDS) to be stored with substances. Sediment discharge during dewatering

Possible

Moderate

Medium

Install perimeter controls to divert clean water away from areas of disturbance. Detention devices to be utilised - treating runoff by methods that allow sediment to settle out. Controls to be inspected before use and maintained during use.

CEMP. SEMP. AEE: Appendix J section 5.2.

Water quality in detention devices to be checked for hydrocarbons and other contaminates before discharge. No earthworks are proposed within 1.5km of the edge of the water reservoirs. Contamination of surrounding area during insitu concreting and grouting

Possible

Major

Medium

Isolation of work area away from waterways.

CEMP section 3.3.4.

Collect and dispose of excess concrete.

SEMP.

Spill kits to be within easy reach and appropriately sized.

AEE: Appendix J section 5.2.

Appropriate training given to staff. Culverts and temporary stream diversions preventing fish passage

Appendix C: Environmental Risk Register

Possible

Major

Medium

Ensure the design of culverts do not impede fish passage.

CEMP section 3.3.4.

As far a is reasonably possible, retain existing aquatic habitat and connectivity.

SEMP. AEE: Appendix J section 6.2.

pg. 3

Issue Damage to instream biota

Likelihood

Consequence

Risk

Mitigation

Reference

Possible

Major

Medium

As far a is reasonably possible, retain existing aquatic habitat and connectivity.

CEMP section 3.3.4. SEMP. AEE: Appendix J section 6.2.

Construction noise

Possible

Major

Medium

Plan and carry out works in accordance with Construction Noise Management Plan (CNMP). Ensure any high-risk noise methodologies are communicated to CLG. Helicopterâ&#x20AC;&#x2122;s to be used in accordance with hours of work provisions outlined in CEMP and SEMP.

CEMP section 3.3.1. CNMP. New Zealand Standard (NZS 4403:1976)

Blasting (should it be required) will be carried out in accordance with New Zealand Standard (NZS 4403:1976) Dust

Possible

Major

Medium

Controls to be inspected before use and maintained during use.

CEMP section 3.3.2.

Wetting down of any area of concern.

SEMP.

Limiting speed of traffic.

AEE: Appendix J section 6.0.

Surfaces and structures to be kept clean. Stabilisation of haul roads. All entrances and exits from site are to be stabilised entrance ways. These are to be maintained and may have wheel washes associated with them. Road sweeping if required. Archaeological disturbance

Possible

Major

High

Avoidance of sensitive sites in design and acknowledgement of tangata whenua relationship with natural resources. Accidental Discovery Protocol to be followed and form part of the Project Environmental Induction.

Contamination due to works around waterways

Possible

Major

High

CEMP section 3.3.6. Accidental Discovery Protocol (EM282).

Slurry to be captured and disposed to pit, bin or off-site.

CEMP section 3.3.4.

Use of a wet-vac to capture contaminated slurry (e.g. concrete).

SEMP.

Do not allow discharges to enter waterways or stormwater drains.

AEE: Appendix J section 6.0.

Culvert replacement and works within waterways to follow specific methodologies within SEMPs. Ensure timing of these works is appropriately managed with weather monitoring etc.

Appendix C: Environmental Risk Register

pg. 4

Appendix D - Environmental Incident Form

Environmental Incident Form Name of site area: Nature of incident: (circle)

Critical

(significant effects beyond boundary)

Serious

(significant effects within the site)

Minor

Person involved/witness: Describe incident:

Describe actions taken post incident: (Including any photos taken)

APPENDIX D: ENVIRONMENTAL INCIDENT FORM

pg. 1

Project Environmental Controls: Verify that the following actions or procedures were followed: Environmental information discussed (and documented) in works plans; Environmental Risk Register read and understood prior to starting works; Toolbox talks included site specific environmental topics/risks; Project induction included a description on project environmental procedures and controls; Training on environmental aspects was provided; and Regular site inspections are carried out and recorded. Prevention: (what actions will be taken to prevent recurrence) Action

By Whom

When

Have the environmental hazards been controlled (avoided, remedied or mitigated) and sent on to the Environmental Manager to update the environmental risk register?

Yes

Additional Information:

Incident Form completed by:

Date:

Project Manager signature:

Date:

Copy sent to: (circle)

Electrix Project Manager Electrix Project Leadership Team Electrix Project Coordinator Electrix Environmental Manager Mercury Project Manager

APPENDIX D: ENVIRONMENTAL INCIDENT FORM

Electrix Construction Manager Electrix Project Engineer Mercuryâ&#x20AC;&#x2122;s Environmental Team Mercury Project Co-ordinator

pg. 2

Appendix E - Complaints Form

Complaint Form Name of site area: Complaint source: (circle)

Client

Electrix Project Team member

Resident

Regulatory Authority

Complainant’s name: Complainant’s address:

Complainant’s email and phone number:

Complaint received by:

Nature of complaint:

Wind and weather at the time:

Activity occurring on the site at the time:

Describe any remedial actions undertaken:

Details of whether the compliant was or was not able to be verified:

APPENDIX E: COMPLAINT FORM pg. 1

Prevention: (what actions will be taken to prevent recurrence) Action

By Whom

When

Have the environmental hazards been controlled (avoided, remedied or mitigated) and sent on to the Environmental Manager to update the environmental risk register?

Yes

Additional Information:

Complaint form completed by:

Date:

Project Manager signature:

Date:

Copy sent to: (circle)

Electrix Project Manager Electrix Project Leadership Team Electrix Project Coordinator Electrix Environmental Manager

Electrix Construction Manager Electrix Project Engineer Mercuryâ&#x20AC;&#x2122;s Environmental Team Mercury Project Co-ordinator

Mercury Project Manager

APPENDIX E: COMPLAINT FORM pg. 2