2.2. Communications and Reporting

  1. Regular progress meetings will be held before and during construction and operation and maintenance activities, between the Applicant Environmental Manager (and the Applicant ECoW as required) and relevant Contractors/Subcontractors. During these progress meetings, the Applicant Environmental Manager and/or Contractor’s Environmental Manager will present a section on environmental management and consents compliance.
  2. Contractor/Subcontractor RAMS will be reviewed, and copies of the relevant consents will be provided to the Contractors and/or Subcontractors and they will be made aware of the consent obligations associated with a particular activity.
  3. All Applicant personnel, Contractors and Subcontractors should report any environmental concerns or issues immediately. A Safety and Environmental Awareness Report (SEAR) will be completed for all potential (near miss) or actual environmental incidents or emergencies which occur on-site. All environmental incidents should be reported to the Applicant’s emergency number within 30 minutes or when safe to do so.

2.3. External Communications

  1. External communications, notifications and reporting including any environmental incidents in relation to the Array activities will be carried out in accordance with the commitments included in the Array EIA Report and the requirements of the consent conditions.

2.3.1. Incident Reporting

  1. The procedures to report spill or pollution events are provided in the MPCP.
  2. The procedures to carry out following an environmental incident (excluding marine pollution incidents) will be provided in the Environmental Incident Reporting Procedure which will be produced, approved and annexed to this EMP prior to the start of the construction activities.

2.3.2. Dropped Objects

  1. All dropped objects deemed to be a hazard to safe navigation by the Applicant, Contractors or Subcontractors will need to be recorded and reported to MD-LOT via the Marine Directorate – DROPOB1 - Offshore Wind and Marine Renewables Dropped Objects Form.

2.4. Training, Auditing and Change Management

2.4.1. Training and Competence

  1. Contractors and Subcontractors will ensure that they have adequate environmental management resources and procedures in place for the duration of the Array’s scope of works that they are contracted to undertake. To ensure adherence to the EMP and environmental and consents requirements all Contractors documentation will be reviewed by the Applicant.
  2. The Contractor’s Environmental Manager will be responsible to provide environmental training and promoting awareness regarding environmental management using various means such as:
  • inductions;
  • toolbox talks; and
  • awareness materials.
  1. Further information on these means is included in Table 2.1.

Table 2.1:
Methods of Environmental Training and Promoting Environmental Awareness

Table 2.1: Methods of Environmental Training and Promoting Environmental Awareness

 

  1. The Contractor’s Environmental Manager will ensure that environment and consents issues, highlighting the key environmental sensitivities and considerations, are covered in a dedicated section within wider Contractor inductions for the Array. All the Applicant staff, Contractors and Subcontractors will receive an Array induction.
  2. Specific training on the purpose, requirements and procedures of the EMP and its related annexes will be delivered in toolbox talks by the Contractor’s Environmental Manager. Toolbox talks will be prepared to communicate clearly and concisely the key points to the Array staff (as advised by IEMA, 2008). Toolbox talks prior to specific activities taking place during the construction, operation and maintenance phases (e.g. pilling activities) to identify specific control measures and mitigation requirements, will also be undertaken.
  3. The Contractor’s Environmental Manager will provide awareness materials in various forms, likely to include among others, training packs, posters, signs and newsletters.
  4. In order to update relevant personnel (including new staff) with any revisions in the requirements or procedures, training will be carried out regularly for the duration of the Array and the Contractor’s Environmental Manager will keep a record of the training provided.
  5. The Applicant Environmental Manager will be responsible, directly or by contractually requiring a Contractor, for the promotion of awareness and environmental training to the relevant personnel during the operation and maintenance phase of the Array.

2.4.2. Monitoring and Audits

  1. The Commitments Register will be the principal tool available for ensuring compliance with consent conditions and mitigation commitments. The Commitments Register will contain all the commitments (e.g. mitigation measures and monitoring measures) included in the Array EIA Report and the phase/duration over which they apply.
  2. The Commitments Register will also provide a track and audit trail of compliance throughout the construction and operation and maintenance phases of the Array.
  3. The Commitments Register will be prepared and approved in advance of the construction phase. The Commitments Register will be maintained throughout the construction phase of the Array. Similarly, prior and during the operation and maintenance phase, the Commitments Register will be updated, reviewed and maintained.
  4. Compliance with the EMP will be monitored through a series of audits during the construction and operation and maintenance phases of the Array. Following a toolbox talk, an audit will be scheduled to ensure the requirements and procedures have been understood by, for instance, undertaking site visits and conversation with relevant personnel to monitor awareness. Checklists, informed by review of the EMP and Contractor RAMS, will be prepared. These will be used to facilitate the audit process.
  5. The following environmental audits may be completed:
  • at least one per quarter, to be confirmed by the Applicant. The Applicant may choose to undertake audits more frequently;
  • on a monthly basis during construction. These will be undertaken by the Contractor’s Environmental Manager and a record of all completed audit forms, and records of corrective action and close outs will be maintained and provided to the Applicant Environmental Manager;
  • audits of Subcontractors on a quarterly basis to be undertaken by the Contractor’s Environmental Manager. Audit reports will be provided to both the Contractor and the Applicant within two weeks of the audit being undertaken;
  • environmental inspections will be undertaken weekly during construction by the Contractor’s Environmental Manager and all relevant records will be delivered to the Applicant when and as requested.
  1. A record of all the details and findings arising from monitoring and audit activities will be maintained and any observation or corrective actions will be addressed, with procedures revised in the EMP as required. These will be submitted to the Applicant for approval prior to implementation.

2.4.3. Review and Change Management

  1. The EMP will be reviewed at regular intervals throughout the construction and operation and maintenance phases of the Array. The Applicant will contractually require Contractors’ and Subcontractors’ Environmental Managers to comply with the EMP. All updates to the EMP made by the Contractor require the review and approval of the Applicant.
  2. The EMP will be reviewed at regular intervals or when any important new information, methods, procedures or good environmental practice become available. The schedule for reviews will be agreed with MD-LOT post-Application. The EMP will also be revised following any findings or lessons learned during the construction and/or the operation and maintenance phases.
  3. In the event of a new environmental sensitivity being identified during works, change management procedure will be followed by the Contractor’s Environmental Manager (as recommended in IEMA, 2008). An assessment of potential impacts will be initiated by the Contractor’s Environmental Manager following the notification of a change and if necessary, the EMP will be updated and submitted to MD-LOT for approval. Every change to the EMP will be recorded as part of the EMP review audit trail, and this will include details of the review undertaken.