1 Background

1.1 The Project

The Tuvalu Borrow Pits Remediation Project (TBPRP) is now refilling borrow pits that were created on Funafuti (on the islets of Fogafale and Tegako) during World War II for the purpose of constructing the airport runway. The project includes restoration of a breach in the islet of Tegako and other improvements associated with rehabilitating land that has been essentially unusable for the past 73 years. The goal of the project is to improve living standards for communities in Funafuti which is expected to result in the following outcomes:

• Improved water and sanitation for those living in and around the borrow pits;
• Improved climate change resilience through increased access to clean water; and
• Increased available land in Fongafale and Tegako.

Calibre Consulting Ltd (previously Spiire NZ Ltd) prepared an Options Report which recommended that the borrow pits be filled with material dredged from Funafuti lagoon. In September 2014, as part of detailed design, stakeholder consultations and the approvals process work was completed on: (i) preliminary investigations, designs and consultation with key stakeholders; (ii) surveys of the borrow pits and nearshore resources; (iii) environmental and social impact assessments in accordance with New Zealand and Tuvalu’s policies and laws; (iv) revision of preliminary designs based on stakeholder consultations and physical lagoon and borrow pit surveys; (v) preparation of environmental and social risk assessments, mitigation measures and management plan; (vi) finalisation of designs with costs and work programme; and (vii) submission of formal application to the Department of Environment for consent to proceed. These steps were part of the aims of the New Zealand Aid Programme (NZAP) of the Ministry of Foreign Affairs and Trade (MFAT) to ensure the effective management of potential adverse impacts to the environment and affected communities posed by infrastructure activities, and to ensure that, as a minimum, a ‘do-no-harm’ approach is employed.

1.2 The ESMP Requirements

An Environmental and Social Impact Assessment (ESIA), incorporating the Tuvalu Government’s requirement for a Preliminary Environmental Assessment Report (PEAR) was completed in June 2014 (Kaly and Peacock-Taylor, 2014). That report outlined the requirements for environmental management (including social considerations).

The Environmental and Social Management Plan (ESMP) for the projects was designed to cover the most important aspects of impact minimisation and mitigation without being overly-complex. Most of the ESMP measures formed part of the services provided by the Contractor, Hall Contracting Pty Ltd. The measures covered the following key areas as a series of plans:

1. Dredging & Filling Plan (D&FP);
2. Communication, Complaints & Compensation Plan (CCCP);
3. Protection of Significant Species, Features & Areas Plan (SFAP);
4. Waste Disposal & Pollution Plan (WP); and
5. Safety Plan (SP).

Most of the plans cover the period of construction, but the CCCP also has components on communication, complaints and compensation that started at the time of project approval and will persist after the project is completed until all complaints are addressed.

The Contractor’s monitoring and reporting is based on monthly reporting, most of which can be achieved using checklists during inspections, creating a register of complaints and/or recording minutes of meetings and statements used in radio announcements. The forms to be used were developed at inception. Coral monitoring is reported more frequently to be effective in reactively managing impacts on corals as there is relatively little time between stress measured as bleaching and the possible loss of the corals (perhaps a couple of weeks). Details of the Contractor’s ESMP are given in (Restall, 2015a).

1.3 Purpose of this Audit Report

The purpose of this report is to provide all project stakeholders, including the GoT, NZA, Contractor, Managing Contractor and other interested parties an independent assessment of the environmental and social management being undertaken as part of the project.

2 Methodology

Assessment of compliance with the ESMP was undertaken through a combination of review of the Contractor’s Monthly Report (Restall, 2015b), examinations of coral data and field visits at work areas, particularly the barge, at the site of dredging and in borrow pits. For the purposes of audit, the reporting provided by the Contractor was compared with the guidelines provided in the ESMP on which the Government’s Environmental Approval was based, and the Contractor’s Environmental Management Plan, which is the implementation side of the ESMP (Restall, 2015a).

Table 1: Outline of the Contractor’s ESMP in (Restall, 2015a)

ESMP Category	Control Measures	Monitoring	Responsibility
1. Dredging & Filling Management	§ Preparation of borrow pits § Dredging & filling § Coral monitoring § Land management	§ Coral Monitoring Data D § Steering Committee Minutes M § Borrow Pit Meeting Minutes AR § Incident Reports M	§ Project Engineer
2. Communication, Complaints & Compensation	§ Public disclosure § Grievance Mechanism § Social Disruptions Mitigated	§ Strategic Action Group Meeting M § Project Steering Committee M § Contract Operational Meetings W § Radio Announcements Agenda W § Bulletins W § Works Schedule M § Incident Reports M § Prestart Checks D § Borrow Pit Meeting AR	§ Calibre: Meetings & Community § Hall: Provide project information, daily prestart & environmental checks
3. Protection of Significant Species, Features, Areas	§ Borrow Pit Meetings § Significant areas identified § Coral Reactive management § Pipeline & Spuds Daily Checks	§ Project Steering Committee M § Borrow Pit Meeting minutes AR § Environmental Checklist D § Incident Reports M § Site Induction AR/D	§ Project Supervisor § Project Engineer § Dredge and Work Boat Operators § Plant Operators
4. Waste & Pollution	§ Good housekeeping § Maintenance of equipment § Management of Oil &  Chemical Waste § Bunded, Locked Storage Areas for Oil & Chemicals § Domestic Waste disposal at Official Landfill, Recycling Centre, or Composting Facility § Useable Coral Boulders recovered § Emergency Response Plan § Notification of Authorities for Incidents	§ Environmental Inspections D § Waste Dockets PC § Borrow Pit Meeting Minutes AR § Incident Reports M	§ Project Supervisor § Project Engineer
5. Health & Safety	§ STI/HIV/AIDS Awareness § Safety Gear for Workers § Excavation Permit to Locate Utilities / Services § Signage and Markers for Exclusion Zones § Presence of First Air Officer Onsite § Management of UXO Risk	§ STI/HIV/AIDS Training AR/M § Project Steering Committee M § Work Method Statement AR § PPE issue form AR § Incident Reports M	§ Project Supervisor § Project Engineer

D=Daily; W=Weekly; M=Monthly; AR=As required or prior to work in particular borrow pit; PC=Post Construction

3 Findings

3.1 Contractor’s Monthly Report

The monthly report is generally suitable for monitoring the progress of the project and outcomes of monitoring but lacks summaries of the information it encapsulates. It also lacks information on the meetings and public information being disseminated out as part of the project.

The report shows that the Contractor is responsive to project issues as they arise. This particularly concerns health and safety of employees and protection of the public. The ‘toolbox meetings’ and appendices covering dehydration, UXO safety, lifting techniques and staph infections, among other issues, are a smart way to keep the workforce updated and learning in response to issues that arise.

The report itself appears long, but much of the bulk of the report is in reproducing records. It may be worth constructing a simple pamphlet-like report for general circulation, somewhat like the Coral Monitoring Bulletins that contain an overall checklist of the numbers or presence/absence of data on compliance and reports completed during the month. This could be in the form of an overall table for easy reckoning.

The monitoring checklists included in the Monthly Report also need to be summarised at the beginning of each section, as few readers would be willing to comb through them. So in addition to a checklist of the monitoring done (mentioned above), and its extent, a more detailed table is needed for each type of monitoring showing how many in compliance, in non-compliance and without data, followed by a summary describing any issues and how they were addressed.

A record of all meetings conducted under the project is absent from this report. This includes the Borrow Pit Meetings conducted before work on a site by site basis, the Steering Committee Meetings and Public information such as radio shows. These should be included simply as numbers of each, perhaps with attendance and any significant issues. For example, a brief summary of any issued raised by communities could be included in bullet point form.

3.2 Coral Monitoring

Coral monitoring carried out by the Fisheries team is entered directly into a database that is uploaded at the end of each survey to Dropbox for access by Calibre. This is necessary because coral monitoring is reactive and if triggers are reached, action needs to be taken immediately to avoid damage to the lagoon ecosystems upon which island maintenance and fisheries depend. Results are examined daily and reported weekly by email to a list of stakeholders so that there is transparency and early warning if the condition of corals declines. Two issues have arisen:

3.2.1 Trigger Mechanism

The initial trigger mechanism for coral bleaching proposed in the Contractor’s ESMP was:

If more than 5% of the monitored corals become bleached to Level 3 of the Coral Watch Health Chart over two consecutive inspections, dredging will move outside the 100m zone and the affected corals will be monitored until the corals show evidence of recovery (back to background conditions).

During email reporting of the coral watch results the trigger levels were revised to refine their meaning, as this original definition was not clear enough to be practical. For example, It is not clear from the definition above whether actions might be triggered if 5% of the coral colonies might be bleached (equal to 4 corals across the whole study of 80); or whether all of the corals would have 5% of their surface bleached. Also, up to Level 3 of the Coral Watch Methodology is simplistic. In real terms corals can display all bleaching levels within the one colony, and the data being collected are the percentage of each coral that is Level 1, 2, 3, 4, 5 bleached, plus Level 6 unbleached, summing to 100%. A more precise trigger was defined as:

The trigger for action should bleaching threaten the condition of ecosystems includes the following criteria: Average of 50%+ of corals showing bleaching to levels 1-5 (6 is not bleached) + This occurs for 3 consecutive surveys + Occurs differentially at sites close to dredge and not at sites remote from the dredge on those days (defined by non-overlap of standard error bars).

This refers to the average % of the colony that is bleached to any level for all corals being monitored at a site. That is, it asks how much of each colony is affected.

3.2.2 Consistency of Monitoring & Frequent of Reporting

Coral monitoring has been inconsistent at times, especially in the past 1.5 weeks. Table 2 shows all coral monitoring days to date, marking missing surveys with û. The project will need to follow up this monitoring to ensure it is done consistently and reported in the same day to ensure the protective functions of the work can be relied on. It may be necessary to reschedule the monitoring so that it occurs only twice per week on Tuesdays and Thursdays to avoid on-going issues with public holidays.

Table 2: Coral monitoring dates and data returns.

Survey Date	1 North End	2 Tegako Jetty	3 Catalina Patch	4 South End	Total
21/22-Apr-15	20	20	20	û	60
24-Apr-15	û	û	û	20	20
28-Apr-15	20	20	20	20	80
29-Apr-15	20	20	20	20	80
01-May-15	20	20	20	20	80
04-May-15	20	20	20	20	80
06-May-15	20	20	20	20	80
08-May-15	20	20	û	û	40
11/12-May-15	20	20	20	20	40
13-May-15	20	20	20	20	80
15-May-15	20	20	20	20	80
18-May-15	û	û	û	û	û
20-May-15	20	20	20	20	80
22-May-15	20	20	20	20	80
25-May-15	20	20	20	20	80
27-May-15	20	20	20	20	80
29-May-15	20	20	20	20	80
01-Jun-15	20	20	20	20	80
03-Jun-15	20	20	20	20	80
05-Jun-15	20	20	20	20	80
08-Jun-15	20	20	20	20	80
10-Jun-15	û	û	û	û	û
12-Jun-15	20	20	20	20	80
15-Jun-15	û	û	û	û	û
17-Jun-15	20	20	20	20	80

All monitoring reports can be accessed at https://borrowpits.wordpress.com/, including RSS and automatic mailing of reports by email request. Note the site has been marked as ‘not to be indexed by search engines’, so will not be found by searching the web, however it is not currently protected from external access by others who are provided with a link.

3.3 Field visits

In the period since inception, several visits were undertaken to the project sites, a range of borrow pits and to coral monitoring sites to confirm environmental requirements are generally being met.

For coral monitoring, this included training of the two monitors to ensure they could appropriately identify the levels of bleaching and the species of the 20 tagged corals at each of 4 monitoring sites. Monitors were also trained in the use of the Coral Monitoring database so that data could be entered in a timely fashion and conveyed for weekly bulletins. Inspections of the corals showed a baseline condition of a low level of bleaching (natural levels) and no mucus production or sedimentation at the two northern sites (the central and southern sites have not yet been inspected). Regular inspections of the database show data is being entered properly and at least to some extent cross-checked using built in routines.

Inspections at the barge, borrow pits and dredging site revealed that all areas are tidy and free of all rubbish. A spill kit is located next to the barge which is tied up on the old wharf. There are no signs of oil spills, or any excessive damage to beach ridges or vegetation. In Borrow pit 2 drainage of the turbid dredge water appears to be occurring wholly within the borrow pit, with rapid drainage into holes in the reef rock. There is no sign of turbidity in the nearshore waters near the discharge areas. It is likely that the reef platform drain holes are depositing turbid waters nearby, but there is no sign of environmental stress at this time.

The Site Induction process is thorough, with a large emphasis on safety of the staff themselves, other staff, the public, machinery and the environment.

Discussions with the public, carried out at random demonstrated a lot of good will and good expectations for the project. People are happy to finally see something being done about filling the borrow pits. There are no obvious signs of dissatisfaction in the way the project is being delivered.

3.4 Overall Compliance with the Provisions of the ESMP

Overall, there are some items of information missing from the Contractor’s Monthly Report, although it is clear that the monitoring is being done as evidenced in separate documents. The areas missing from the report are shown in the table below.

Table 3: Summary of Compliance with Contractor’s ESMP with monitoring programmes as the focus

ü=In compliance; û=Not in compliance; NA=Not applicable; ESMP Categories: 1=Dredging & Filling Management Plan; 2=Communications, Complaints & Compensation; 3=Significant Species, Features & Areas; 4=Waste & Pollution; 5=Health & Safety.

Monitoring	ESMP Categories	May 2015 Report	Coral Monitoring	Field Visits
Coral Monitoring Data D	1	ü	ü	ü
Steering Committee Minutes M	1,2,3,5	û	NA	NA
Borrow Pit Meeting Minutes AR	1,2,3,4	û	NA	NA
Incident Reports M	1,2,3,4,5	ü	NA	ü
Strategic Action Group Meeting M	2	û	NA	NA
Contract Operational Meetings W	2	û	NA	NA
Radio Announcements Agenda W	2	û	NA	NA
Bulletins W	2	û	ü	NA
Works Schedule M	2	û	NA	NA
Prestart Checks D	2	û	NA	NA
Environmental Inspection & Checklist D	3,4	ü	NA	ü
Site Induction AR/D	3	ü	NA	ü
Waste Dockets PC	4	û	NA	NA
STI/HIV/AIDS Training AR/M	5	ü	NA	NA
Work Method Statement AR	5	ü	NA	NA
PPE issue form AR	5	ü	NA	NA

3.5 Photographs

Comparison of very heavily bleached (L1 and 2) versus unbleached corals. This photo is NOT from any sites in this study and is included here only for illustration.	The ‘bomb box’ is being deployed in the pipeline during dredging.
Dredge: No signs of floating waste or uncontrolled discharges or oil slicks.	The breach has been temporarily partially bunded. Base of BP2 has been lined with Geotextile and dewatering is occurring within the borrow pit. No sign of turbid waters washing over the reef platform.
Borrow Pit 2 in the process of being filled	The dredge in operation in BP2

4 Conclusions & Recommendations

The Contractor’s Monthly Report is not immediately mappable to the format of the Contractor’s ESMP. This makes auditing a little more difficult than it needs to be. This is because the Monthly Report covers a broader range of information than just environmental and social concerns.

The Contractor’s Monthly Report is a very long document because it incorporates records of environmental and social monitoring, but there is no summary of the monitoring for ready access to the reader. Also, not all monitoring is included (see Table 3). The following recommendations are made for the May 2015 Contractor’s ESMP Report.

1. It might be advantageous to divide the report into a section on progress of the works and a section on environmental and social management, the latter following the topics outlined in the Contractor’s ESMP, with a focus on the individual monitoring topics as shown in Table 3.
2. It may also be advantageous to provide a 2-page pamphlet style summary of each monthly report for quick access to stakeholders. This could be done in a similar vein to the Coral Monitoring Bulletins where the main message is made quickly available. One addition would be an overall checklist showing the number of meetings + attendees, number of incidents, and how many checklists etc. and a summary in bullet form of any significant issues. This would prevent important pieces of information from disappearing into a long and complicated report. This includes all meetings conducted under the project.
3. The checklists should be of two types:
   1. An overall checklist like Table 3; and
   2. Summaries for each type of monitoring showing number of measures in compliance, not in compliance, or for which there are no data. This should be followed by a bullet-point summary of any significant issues. Most readers will not comb through many pages of checklists to notice issues as they arise.
4. The Contractor’s Monthly Report should be fully indexed using the automatic bookmarks function when creating the PDF file from Microsoft Word. This would allow users of the report to navigate better through such a long document.
5. The new coral trigger definition proposed in Coral Watch Report 1 and reproduced here should be adopted as the official trigger criteria for this project.
6. Coral monitoring has to be consistent to be protective. There is a need to work more on the monitoring team’s timeliness and consistency.
7. Now that a basic dataset for corals has been collected, it would probably be sufficient to monitor just twice per week from now on. This should shift monitoring to Tuesdays and Thursdays to avoid problems with public holidays and other activities.

5 References

Kaly,U., Peacock-Taylor,C., 2014. Tuvalu Borrow Pits Project Phase II Design: Environmental & Social Impact Assessment (ESIA) and Preliminary Environmental Assessment Report (PEAR) (Volume 3).

Restall,J., 2015a. Environmental & Social Management Plan. 1-110, Hall Contracting Pty Ltd.

Restall,J., 2015b. Tuvalu Borrow Pits Remediation Project Contractor’s Monthly Report: May 2015. Rep 1, 1-109, Hall Contracting Pty Ltd.