Construction and sustainable commercial buildings

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This article provides information, guidance and resources on sustainable construction process.

Summary

Construction is a critical phase in the process of delivering sustainable buildings. It involves the activities of project managers, site supervisors, contractors, tradespeople, building professionals, advisors and clients, as well as any organisations involved in the supply chain for the building project. Construction can have a significant environmental impact, both directly and indirectly, if not managed correctly.

To minimise the environmental impact of construction, sustainability needs to be embedded in the project culture and documentation from the very beginning of the delivery process.

Adding sustainability after design will invariably add to the project cost and may be resented by the project team as an 'imposed requirement' that may not fit with commercial imperatives at that point in the process. For example, in the past clients have tended to isolate sustainability as a non-commercial requirement and have asked for a design that proves the project commercially first, and 'then we'll consider adding sustainability, but only if it is cost effective'(actual statement made in 1999 to the author by a Board member of an association, in response to a proposal for sustainability initiatives to be included in the design brief for a building retrofit). Such an approach may deliver a commercially viable project, but will definitely exclude any sustainability outcomes.

Sustainable design will not of itself enable or facilitate sustainable construction. While many design features will impact on construction methods and consequently affect the sustainability of the construction process, sustainable construction requires that sustainability be a contract requirement that is monitored and measured throughout the construction process. Because construction responds to the requirements specified in the design phase, there needs to be continuous communication at all stages of the building process to ensure a sustainable outcome and sustainable construction practices. This is especially important on site, where variations can sometimes be made without consultation, thus affecting the environmental impacts of the end facility.

Traditional construction practices do not generally lead to sustainable operational outcomes. Thus, to ensure construction has a minimal environmental impact, training of site personnel is required and there needs to be a focus on a new construction paradigm where sustainability is at the fore. This article will help building designers, project managers, contractors and site personnel approach the construction process in a more sustainable manner by providing guidance and resources useful in planning and implementing sustainable construction.

This article also aims to make it easier to comply with existing and future energy performance mandates, and with sustainability requirements that are increasingly being sought for projects by building owners and tenants.

Definitions

• Construction
• Management processes for sustainable construction
• Activities in sustainable construction
• Embodied energy
• Sustainable construction
• Net positive impact
• Direct and indirect construction impacts
• Commissioning
• Best practice
• Environmental management plan

There are a number of key definitions in this article. These are not formal definitions in a dictionary sense, but more explanations of how the terms are used in, and relate to, this article.

Construction

Construction is defined as the activities and processes needed to convert design specifications into finished buildings ready for commissioning and operation. The package includes information and resources covering:

• the supply of construction materials, products and building services to the site
• site preparation and construction of the facility
• on-site and off-site fabrication
• the consumption of energy and water to facilitate the construction (embodied energy and water)
• the management of waste, pollution, and other environmental and social disturbances during construction.
  
  

Management processes for sustainable construction

There are a number of management processes that require particular attention if sustainable outcomes are to be realised during construction and in the later operation of commercial buildings. First and foremost is the need for integration. Delivering sustainability requires a whole-of-system approach to ensure optimal outcomes. This means all participants working together with common and consistent aims throughout the whole delivery process. Focusing on sustainability in design only and then handing construction, commissioning and operation over to traditional ways and means will inevitably undo the sustainability intent and will result in performance that is far less than intended at the design stage. Integration is not just coordination. It is about management commitment and the building of teams with common objectives and a shared ownership of project outcomes, including financial outcomes.

Activities in sustainable construction

The traditional activities of project delivery under a design and construct arrangement are depicted in the figure titled Managing project environmental outcomes later in this article. This article provides guidance with respect to those activities of the construction phase, where the sustainability impact is greatest. These include:

• management and administration
• materials use and substitution
• energy and water use
• erosion and sediment control
• transport on site, and to and from the site
• fabrication
• waste management.
  

Embodied energy

Embodied energy refers to the energy required to produce a product, including extraction of raw materials, processing and transport.

Sustainable construction

Sustainable construction refers to construction where the impacts of building activity on resources, biodiversity and eco-system services are accounted for as part of the whole-of-life of the project. An outcome of sustainable construction is no net negative impact on financial, natural and social capital over the lifetime of the project.

Net positive impact

Net positive impact refers to a project outcome where whole-of-life considerations of the project result in an increase in natural and social capital, in addition to favourable economic returns to all concerned in the inception, delivery, operation and disposal of the facility.

Direct and indirect construction impacts

Direct construction impacts refer to the immediate impacts of construction activity on the natural and/or social environment.

Indirect construction impacts refer to whole-of-life outcomes that result from construction activities that vary design features and/or impact on sustainable design intent.

Commissioning

Commissioning is a systematic process of assuring (by verification and documentation) that all facility systems perform interactively in accordance with the design documentation and intent, and in accordance with the owner's operational needs, including preparation of operation personnel (An official definition established by The National Conference on Building Commissioning). Commissioning takes place from the design stage to a minimum of one year after construction.

Best practice

Best practice in construction refers to construction that goes beyond compliance in terms of sustainability and actively attempts to have a positive environmental impact during the construction process, rather than simply a minimised negative impact.

Environmental management plan

An environmental management plan (EMP) is a tool that is used to manage environmental risks and issues on a project. The effectiveness of the plan is dependent on the commitment of management to follow the plan, and on how well it is written and understood by construction personnel.

The importance of construction

• Relationship to other building activities
• Drivers for change
  • Sustainability
  • Quality
  • Technology
• Barriers to change

Buildings have a significant negative impact on the environment. Based on whole-of-life considerations, they consume 32% of the world's resources, including 12% of the water used and up to 40% of the energy used. Buildings also produce 40% of waste going to landfill and 40% of air emissions (OECD, 2003). In Australia, commercial buildings produce 8.8% of the national greenhouse emissions and therefore have a major part to play in meeting Australia's international greenhouse targets (DEH, 2001). Of this, office buildings and hospitals are the two largest emitters by building type, causing around 40% of total sectoral emissions (Engineers Australia Building and Construction Taskforce, 2000).

Sensitive, capable and informed design can greatly minimise these negative construction impacts and may even, at the leading edge of sustainable design, have a positive overall impact by increasing natural and built capital, and contributing to increases in occupant productivity. However, project planning and the design brief must stipulate particular energy and ESD outcomes, including those for construction, if the project is to minimise adverse impacts or achieve any positive ones.

Building designers carry a great responsibility in determining the environmental and social outcomes shaped by our built environment. Within wider planning and development constraints, the way in which sustainability is conceptualised and integrated into base building design will strongly influence the environmental and social outcomes of a project, both during the construction stage and over the operational life of the building. (See 'Design and sustainable commercial buildings' for more information)

Construction can have a significant environmental impact, both directly and indirectly. The direct impact of construction comes from construction activities themselves, whereas indirect impacts are a result of decisions made on site by construction participants that compromise design intent.

Direct construction impacts include:

• energy, water and resource use
• waste, pollution and disturbances to the community, the site and surrounds.

Construction consumables and pollutants also become part of the embodied impact of the building. Indirect construction impacts include (but are not limited to):

• on-site variations and substitutions leading to poor environmental performance
• poor documentation leading to on-site decisions that alter intended operational outcomes
• the use of environmentally undesirable consumables that persist in the finished facility
• traditional trade practices and poor construction supervision.

Relationship to other building activities

Because construction is only one activity in the delivery of commercial buildings, it is important to understand the impacts of these other activities on construction and to consider construction issues as part of those other activities.

Some of the ways in which construction is related to other building activities are outlined below.

• Design and specifications will determine construction methods (e.g. specifying non-standard dimensions, unusual features, imported materials etc. may increase energy use and site waste).
• The sustainability ideals of the client or building owner will be reflected in construction contracts and will influence construction methods and on-site behaviour.
• Commissioning is critical for checking that construction was true to design and that the building actually works the way it was designed.
• Post-occupancy evaluations (POEs) and annual reviews will discover construction and design omissions or defects, and can prove that the 'as built' facility is achieving desired long-term outcomes.
• Facility managers can gather data on construction issues that have led to shortcomings in the finished building and its operation, providing valuable feedback to designers and contractors for continuous improvement.

The construction of a building includes many different activities. All of these activities need to be integrated to ensure sustainable outcomes. Construction issues need to be addressed at the very beginning, when the sustainability goals of the project are established, as well as throughout all phases of building design. Commissioning, post-occupancy evaluation and facilities management activities will expose construction deficiencies and determine whether a building is performing as intended.

Drivers for change

Bryon Price (B.Eng. M.AIRAH FIEAust CPEng), a mechanical engineer and Business Development Director for the A.G. Coombs group of companies, identifies three main drivers that are forcing change in the building delivery chain. These drivers are sustainability, quality and technology (Price, 2006).

Sustainability

Sustainability is the current catch-cry and arguably the biggest issue influencing the building industry at the present time. There is now a greater understanding of the effects that buildings have on the environment and the need to minimise these over the long term. There is also an increasing understanding of the importance of ongoing performance outcomes, particularly with respect to energy and water consumption, and that these outcomes are effectively set by commissioning.

As a result of this growing understanding, a number of energy and environmental building rating systems have been developed, such as the Australian Building Greenhouse Rating system (ABGR) and the Green Building Council of Australia 'Green Star' suite of environmental rating tools. While ABGR has no direct impact on commissioning, it is likely that a building will receive a low ABGR if it is not properly commissioned. The Green Star rating tool also has very specific requirements in this area, and offers credits where:
*it is demonstrated that comprehensive pre-commissioning, commissioning and quality monitoring are contractually required to be performed by the appropriate contractors and trades on site (in accordance with the American Society of Heating, Refrigeration and Air-conditioning Engineers (ASHRAE) Guideline 1 and the Chartered Institute of Building Services Engineers (CIBSE) Commissioning Codes)

• the credit above is achieved and the design team and contractor are required to transfer information and documentation to the building owner/manager
• it is demonstrated that a commitment is made to a firm 12-month commissioning building tuning period after handover. This requires minimum quarterly reviews and a final recommissioning after 12 months of operation
• it can be demonstrated that an independent commissioning agent has been appointed to provide commissioning advice to the client and the design team and to monitor and verify the commissioning of HVAC and building control systems.

Comprehensive evidence is required for audit by an independent assessor in order to achieve these credits; therefore, the independent commissioning agent has the opportunity to become a powerful agent of change.

Quality

Quality is making a comeback to building services after a substantial downgrading during the late 1980s and 1990s. There is now a significant concentration of building ownership in the hands of institutional-type investors with a long-term focus on the performance of their assets. This translates to a new appreciation of life cycle issues, as well as an improved understanding of the correlation between well-performing building services and tenant satisfaction and retention. This is particularly true with air-conditioning and the developing empirical connection between the quality of the indoor air environment and occupant health and productivity.

The broader market is also being influenced by institutional demand for increased quality, with higher expectations of installed services and much higher expectations for their performance over time. Again, it is becoming recognised that this relates strongly back to the commissioning of the building and its systems.

Technology

Technology plays a central role in the quest for better performing buildings and building services. Building services systems have become very sophisticated and are increasingly integrated and interdependent. This has made the design process and installation more complicated, and has significantly increased the complexity of the challenge that faces building services commissioners in delivering the performance promised by the system's design and the technology itself. On the other hand, the sophistication of building management systems (BMS) has made building monitoring, management and maintenance far more responsive to tenant needs and has improved the delivery of more sustainable performance outcomes.

These drivers are challenging the design and construction process to deliver a much improved product. A close integration of the design, construction and commissioning processes is required to deliver a high performance, operationally energy-efficient, and environmentally conscious building. In order to deliver more sustainable outcomes, significant changes are required to the way that we traditionally go about the building delivery process.

Barriers to change

The main barrier to the construction of sustainable commercial buildings directly relates to the different incentives that drive developers, investors and tenants. Developers want to build a commercial facility that will attract tenants and quickly sell to the investment market at a good profit. Meanwhile, investors want to own a building that will attract and keep tenants, while tenants want low-cost leasing arrangements. Therefore, a developer may have little interest in design and construction initiatives that can't be immediately valued by tenants and investors. Likewise, investors may resist paying for sustainability initiatives that tenants cannot immediately identify and value as part of their decision to lease.

Other barriers to sustainable construction include:

• a lack of contractor knowledge about construction impacts and sustainability, which is exacerbated by a lack of sustainability performance guidelines, too few case studies, and few benchmarks and existing standards.
• a persistent preconception that sustainability will increase construction costs 
• sustainability being considered by developers, owners and contractors as too difficult, or too much extra work
• the developers and/or building owners not considering sustainability to be important to them
• contractors not considering sustainability as part of their responsibility in the delivery process
• the limited availability of sustainable products and materials, with the market not yet supporting the manufacture of sustainable building products
• a lack of understanding of the embodied energy and water in materials substituted by contractors
• the absence of uniform environmental rating systems for products and construction materials
• a lack of reproducible evidence that sustainable construction can deliver proven financial returns.

Overcoming these barriers requires awareness, commitment, education, an integration of project teams, and the monitoring of construction performance.

Sources of major impact in construction

• Materials and fittings selection
• Variations
• Energy use
• Water use
• Stormwater
  • Pollution from site activities
• Waste
• Transport
• Biodiversity
• Soil degradation
• Other sources of impact in construction

During the construction phase of a project there are many activities where management decisions, administrative processes, and construction methods impact on the sustainability outcomes of both the construction phase itself and of the final operational building. 
This section highlights how these activities impact on outcomes, and links these impacts to management issues and the opportunities for better outcomes discussed in later sections.

Materials and fittings selection

The selection of different building materials can influence the degree to which the project results in the depletion of natural resources, environmental degradation during raw material extraction and manufacture, and adverse health impacts due to off-gassing of pollutants during production, in construction, and in use.

Best-practice construction specifies building materials that seek to minimise energy consumption, pollution, and workplace hazards during the manufacturing and construction processes, in order to meet ESD outcomes. Therefore, it is important to ensure that these are not substituted with poorer quality materials, which are often cheaper but may have higher environmental impacts, either during construction or in operation.

Good sustainable design will specify building materials that have low embodied energy; noting that total energy over the projected life of the component also needs to be assessed (i.e. durability versus embodied energy).

On-site substitution of materials and fittings can change sustainable design intent. For example, any of the following could significantly affect the sustainability rating of a building and could also impact on pollution and occupant health:

• replacing FSC-certified timber with non-FSC certified timber, which may have been sourced from illegal operations in areas of high environmental risk
• substituting specified recycled steel with steel having no recycled content, which depletes resources faster
• substituting low VOC finishes with finishes above sustainable limits
• using glues, fillers, additives, paints, and cleaning agents that have high VOCs, which may degrade the environment through water run-off.

A vast number of materials are used in the construction of a building. Different materials can have very different environmental impacts. Care needs to be taken in the specification of construction materials, in order to minimise their impact. Furthermore, a strict substitution submittal process must be embedded in the contract process to ensure that environmentally benign materials are not replaced on site by more harmful materials.

Variations

On occasion, it is discovered on the construction site that an issue has not been adequately addressed by contract documentation. This means that contracts need to be varied, which usually costs money. In addition, variations can impact on the thermal mass, the energy or water performance, and the environmental impact of a building. They may also increase the likelihood of sick building syndrome. Therefore, variations need to be avoided through thorough, clear and encompassing contract specifications prior to construction and backed up by sound supervision and submittal processes, to ensure that variations likely to impact on sustainability targets are reviewed by the design authority.

Energy use

Greenhouse gas emissions attributable to the construction and operation of buildings account for more than 40% of total greenhouse gas emissions (OECD, 2003). This is almost entirely due to fossil fuel-sourced stationary energy consumed during the manufacture of building components, the building construction phase, and the operation of completed buildings. Good sustainable design needs to consider energy use in the construction phase, in order to minimise environmental impacts. (See 'Design and sustainable commercial buildings' for more information)

The major impacts of energy use in construction are:

• greenhouse gas and other environment polluting emissions, either directly from fuel use on site, and from delivery to the site, or from fossil fuel-sourced electricity consumed during construction
• electromagnetic radiation and interference to supply services (voltage spikes, overload, power factor anomalies), resulting from insufficient supply and/or poor energy management – Electricity consumption on a construction site is usually not smooth. The nature of construction activities can cause high fluctuations in demand, frequent interruptions and sparking, all of which may create localised radio frequency disturbances and electromagnetic frequencies (EMF) that may interfere with radio, television, and other local broadcasts.

While energy used during construction is only a small component of the whole-of-life energy considerations of a commercial building, its impacts derive from:

• the manufacture of building materials and products (energy eventually embodied in the building shell, the installed equipment, and fit-out) used and wasted on the construction site
• the transport of temporary structures, scaffolding, formwork, consumables and building products to the construction site
• fuels consumed on site during construction (site transport, cranes, pumps, generators, and other motor-driven construction equipment)
• grid-connected electricity for site tools, elevators, lighting etc.
• the transport of construction waste, temporary structures etc. from the site
• the running of equipment and services for testing and commissioning prior to occupation.

Energy is one of the key environmental considerations in building developments and is an area in which life cycle cost considerations can result in significant savings (for more discussion of this issue, see the Planning for improved performance section of this article).

Water use

In Australia, water efficiency and conservation are becoming key issues for commercial building design and construction, due to the increasingly water-scarce environment. (See 'Design and sustainable commercial buildings' for more information)

While water-efficient design is critical for water-efficient building operation, much can also be achieved during the construction and commissioning phases (See 'Commissioning of sustainable commercial buildings' for more information). The main impact of water use during construction is in the depletion of increasingly scarce water supplies.

The main areas of water use in the construction and commissioning phases include:

• the manufacture of building materials and products (water use eventually embodied in the building shell, the installed equipment, and fit-out)
• water consumed on site during construction (on-site concrete/mortar mixing, cooling for cutting, wash down, cleaning etc.)
• the running of equipment and services for testing and commissioning prior to occupation.

Water can be conserved through water-efficient design and also through the careful management of water use on the construction site. This is critical in Australia, where drought and water shortages are now major environmental issues.

Stormwater

Erosion rates associated with uncontrolled construction sites are much higher than normal – often a thousand or more times that of undeveloped land. Erosion rates increase during construction due to the removal of soil cover, alteration of soil characteristics, and changes in site topography. These vastly accelerated erosion rates, together with the higher rates typical of urbanised areas, result in excessive deposition of sediment in water resources and drainage facilities.

This excessive erosion and consequent sediment deposition can result in severe impacts to surface waters, such as smothering of fish spawning beds, algal blooms in lakes, and flooding due to obstruction of drainage ways. These effects also have an impact on local communities, as they affect water quality, beaches, fishing, marine life and landscape aesthetics (Keep Australia Beautiful website).

Pollution from site activities

The construction process can also result in other forms of pollution: noise pollution, light pollution, air pollution from chemicals, interference from spurious electro-magnetic field (EMF) radiation, and power factor anomalies in the immediate electricity supply network. These are briefly explained below.

• Noise is inevitable on construction sites and can be very disturbing to neighbouring businesses and the community.
• Any light falling outside the immediate area where it is not required can be considered wasted energy. Not only does unwanted light disturb nearby communities and wildlife, but it also affects the enjoyment of the night sky and can severely disrupt astronomical observations.
• Volatile organic compounds (VOCs) from paints, sealants, adhesives, medium-density fibreboard (MDF), vinyl floor coverings and other construction materials are at their highest during construction and can decrease local air quality (for more discussion of this issue, see the Implementing and operating for improved performance section of this article).
• Construction equipment that uses grid-connected electricity can create significant EMF radiation, causing radio and other electrical interference within neighbouring communities. High current-drawing equipment can also introduce current surges, back voltage spikes and voltage drops from overload if not operated to specifications.
• The use of high-inductive loads (motors, transformers etc.) on construction sites can cause electricity supply current and voltage to shift out of phase, resulting in higher network loads in the immediate vicinity of the site, and possibly resulting in higher electricity charges than needed.

Care needs to be taken in the construction process to ensure that pollution from noise, light, emissions and electrical interference are within regulatory compliance limits, or preferably eliminated.

Waste

In 2002-2003, Australia generated more than 32 million tonnes of waste. Of this, 42% was waste from construction and demolition – 13.7 million tonnes in a year (ABS, 2007).

This waste is usually sent to landfill and therefore has a significant impact on sustainability by using large quantities of energy during transportation and disposal, and by taking up valuable land area.

Figures from the UK show that 17% of the waste from construction and demolition that is sent to landfill is actually unused materials – materials delivered to the construction site that are not used and are then sent away for disposal. It is highly likely that a similar situation exists in Australia, as construction practices are similar. This situation means that energy is wasted during the production of the materials, and in the transport of the materials to and from the construction site. In addition, extra space is taken at the landfill site. All of this wasted energy adds to the economic and environmental costs of the project.

Transport

Design considerations can impact significantly on transport activity during construction. The transport sector is responsible for around the same amount of greenhouse gas emissions and environmental impacts as the commercial building sector. While decisions about the location of a building, the number and cost of car parking spaces, and access to change rooms and other associated infrastructure can have significant long-term, transport-related environmental impacts, care is also needed to reduce construction-related transport activity. For instance, specifying a material that can only be sourced overseas or interstate will add greatly to construction fuel consumption and to the embodied energy of the building.

Biodiversity

The construction process can negatively affect the biodiversity of a site. If suitable care is not taken, habitats can be destroyed and threaten the lives of local species. The removal of vegetation, hollow tree trunks, water bodies and other habitat types are considered a threat to biodiversity.

Soil degradation

Construction cannot occur without disturbing the natural surface and soil profiles. However, topsoil is a valuable and diminishing resource in Australia. In little over 200 years of European land use, more than 70% of land has become seriously degraded (Flannery, 1994). Despite efforts to implement best practice in soil conservation, the situation continues to deteriorate (GBCA, 2005). The careful management of topsoil on construction sites is a significant sustainability consideration.

Other sources of impact in construction

While difficult to quantify in a volumetric or financial sense, construction activities can have quite significant impacts upon society. As communities become more concerned about the future and increasingly educated about issues such as climate change and biodiversity degradation, they are demanding better care and responsibility from construction companies, particularly where cultural, heritage and site amenity are concerned. Increasingly, construction companies are recognising the importance of managing social and other issues. Some of these issues are outlined below.

• Destruction of cultural and heritage objects: Cultural and heritage objects on a construction site can be damaged or destroyed if care is not taken to protect them.
• Removal of adequate community access to areas: Construction activities can block community access to areas that are considered socially important.
• Vehicle nuisance: The use of construction vehicles can be a social nuisance if they are noisy, emit fumes and block local traffic. Construction vehicles also often carry construction materials (soil, mud, wet concrete and dust) into nearby streets, causing nuisance and degrading amenity.
• Reduced visual amenity: If not managed correctly, construction sites can be messy and may reduce the visual amenity of the area.
• Petty site crime: Construction sites are common victims of petty site crime such as vandalism. By their nature, construction sites can attract undesirable activity, particularly after hours (drug exchange and use, theft from sites, gang activity etc.).
• Fraud and corruption: The construction industry is notorious for its corruption — surveys repeatedly reveal corruption to be greater in the construction industry than in any other sector of the economy (Transparency International, 2005).
• Poor occupational health and safety (OH&S): Recent statistics (ABS, 2006) show that 8.6% of employees in the construction industry were injured in 2004-2005; the third highest rate of all industries in Australia.

Care needs to be taken to ensure that these social impacts do not occur, or are appropriately managed in consultation with local communities.

Policies, regulations and standards

While there are national and local standards and regulations governing such issues as occupational health and safety, the use of hazardous chemicals, site noise, and run-off pollution, there is very little by way of regulation or standards for sustainable construction.

However, leading companies are increasingly adopting policies designed to achieve more sustainable outcomes during construction. These policies are modelled on voluntary initiatives, such as the Australian Procurement and Construction Council's National Code of Practice or the UK Considerate Constructors scheme.

Developers and contractors should be aware of, and adopt as a minimum benchmark, the principles set out in the Australian Procurement and Construction Council's National Code of Practice for the Construction Industry. In relation to environmental performance, the Code states:

'The community's demand for ecologically sustainable development (ESD) puts the performance of the construction industry under a sharp light. In the past, economic development, social programs and environment protection occurred largely in isolation from each other. Today, however, there is a growing understanding that these systems are interlinked and that social, economic and ecological objectives are interdependent.

Governments will encourage ecologically sustainable development by working with industry to:

• define ecologically sustainable development in a way which is meaningful for participants in the construction industry
• establish environmental best practice on projects
• showcase projects with outstanding environmental innovation and management
• pilot recycling and re-use of material on construction projects
• support effective use of scarce resources.

Service providers should also be encouraged to have in place sound environmental practices above and beyond mere compliance with regulatory requirements. This may include the development and implementation of a systematic approach to environmental management to ensure that environmental planning and management become an integral part of organisational culture and day-to-day work practices. In this way, service providers can be recognised for their environmental performance and contribution to ESD.' (APCC, 1999)

Another way of demonstrating commitment to stakeholders could be through adopting policies based on the UK Considerate Constructors scheme. This is a national initiative to improve the image of construction through better management and presentation. The scheme is a voluntary code of practice and is driven by the industry.

In the UK, members of the scheme must commit to a seven-point Code of Considerate Practice, as follows:

1. Be considerate — think of those affected by the construction process. Consider the needs of traders, businesses, site personnel and visitors, pedestrians, shoppers, the general public and the environment in general. Consider the needs of those with sight, hearing or mobility difficulties.
2. Be environmentally aware — keep noise to a minimum. Select and use resources carefully — local resources should be used where possible. Manage your waste and avoid pollution — recycle surplus materials. Use materials with low embodied energy, or those that were produced with renewable resources and processes that minimised harm to the environment.
3. Be clean — keep the site clean and in good order. Temporary barriers, lights and warnings must be kept clean and in safe condition. Do not allow waste and surplus material to build up or spill into the neighbouring environment. Mud, dust, spillages and debris should be kept to a minimum.
4. Be a good neighbour — consult with local people, including adjacent traders and businesses regarding programming and site activities. Keep in contact throughout the project. Provide site information and viewing facilities where practical.
5. Be respectful — rude behaviour should not be tolerated. Pride in management and the appearance of the site and the surrounding environment is to be shown at all times. 
6. Be safe — all operations and vehicle movements are to be carried out with care for the safety of passers-by, neighbours and site personnel. No building activity should be a security risk to others.
7. Be responsible — all site personnel, specialist sub-contractors, drivers and any other persons working on the site must understand and implement the obligations of the Considerate Constructors Code. Monitor compliance with it.

Source: Building Sustainability website

The project design brief should clearly outline relevant policies and legislation, as well as any standards to be met and adhered to in the construction phase. Alteration to standard construction contract forms to include references to sustainability processes in construction, or to RAIA-type practice notes should be considered. Clauses in contract preliminaries may be a suitable location for such control mechanisms.

Measures and assessment

• Green Star -- 'office as built'
• Energy and water audits
• Waste audits

As yet, there are no assessment or measurement tools for the whole of the construction phase. However, there are a few individual measures and assessment tools that can be used in conjunction to get an overall idea of the site performance. These include the Green Star — 'office as built' tool, waste audits, energy audits and water audits, as well as on-site reporting and measurement of other significant aspects as necessary (see the Implementing and operating for improved performance section of this article for more information).

Green Star – 'office as built'

The use of the Green Star – 'office as built' tool is a good way of ensuring that sustainability design measures required to achieve a Green Star – office design rating have not been compromised during construction.

The Green Star – 'office as built' tool uses the same credit criteria as the design rating, but assesses whether the design intent has been implemented as required to achieve the Green Star – office design rating. As the rating is retrospective, it will highlight where the building contractor may have failed to implement a design feature or has made changes that compromise sustainability.

During construction, the achievement of the available points for topsoil preservation, EMPs, and waste management, and the potential loss of points due to failure to achieve an 'as built' true to design can be tracked via simple spreadsheet analysis. The left figure shows how one contractor was tracking during construction of a commercial building.

Energy and water audits

Traditional energy and water audits using standard methodologies are not really appropriate for construction sites, as they have been developed for static operational environments where technical control solutions can be implemented and behaviour modified to achieve long-term lower energy and water outcomes. This means that completing energy and water audits on construction sites can be problematic.

However, the monitoring, measurement and publicising of water and energy usage will encourage better performance on construction sites and is an essential tool for energy and water efficiency. While construction sites are constantly changing, with every day bringing new activities on site, ongoing water consumption can be measured and totals monitored in order to ensure that contractors are using water efficiently and to examine better ways of doing a task on future similar jobs. Energy consumption can be measured in much the same way.

Waste audits

Waste audits are useful for determining both the nature and quantity of waste leaving a site. This is vital information for managers, as it informs targets and strategies for waste minimisation.

Opportunities for improving performance

• Management initiatives
  • Contract types
  • How do construction leaders deliver sustainable construction?
• Substitution and variations
• Construction consumables and impacts
  • Energy use
  • Water use
  • Stormwater and run-off management
  • Pollution from site activities
  • Waste
  • Biodiversity
  • Soil preservation
  • Social responsibility

There are many opportunities for improving sustainability in the way that buildings are delivered, and in the construction activity itself. However, unless the project developer and the senior managers of all involved in the project are seriously committed to sustainable outcomes, these opportunities will be lost. This section looks at management issues, at the opportunities that exist in different contract arrangements, and at what can be done during construction activity to improve sustainability.

Management initiatives

Although developers and pre-committed tenants have less influence over design issues during the construction phase, they still need to be vigilant in checking that what is being constructed is what they asked for. There is a risk that sustainability design intent may be compromised, especially if traditional construction methods are considered by contractors to be cheaper or easier to implement without discovery.

Developers, pre-committed tenants and designers should meet with the construction team before construction commences to demonstrate and communicate their commitment to energy efficiency and ESD outcomes. They should also consider training selected construction supervisors in sustainability principles and the specific sustainability initiatives of the project, in order to ensure that the design intent is understood and that correct methods are used during construction.

Contracts should include a written requirement that the pre-committed tenants participate in regular project management meetings with the construction team leaders. Communication should be maintained between stakeholders throughout the construction phase to ensure a focus on the design goals when addressing problems and proposed variations.

Developers, pre-committed tenants and the project manager should carefully assess variations proposed by contractors to ensure that they do not have an adverse impact on the original design intent in terms of energy and other sustainability outcomes. Where necessary, they should seek advice from the design consultant or independent experts.

Contract types

Traditional building-delivery mechanisms are, by their nature, a series of independent events. For example, the ideal outcome of the design and specification phase is a set of documents that can be passed to a contractor without further need for the design professions to be involved. While there is scope for sustainability to be included in the traditional project delivery process, a comprehensive delivery of sustainability outcomes really requires a paradigm change in project delivery (see the Drivers for change section of this article for more information).

There are a number of new project delivery mechanisms growing in acceptance that offer significant opportunities to better realise the value for sustainability investments. Public Private Partnerships (PPP), Project Team Partnering (PTP) and Long Term Alliancing (LTA) present opportunities for delivering sustainability. Energy Performance Contracting (EPC) and Delivered Energy Services (DES) are contract mechanisms focusing specifically on energy and building engineering services, and can also be introduced to enhance sustainability outcomes. Selecting an appropriate mechanism must occur early in the project planning stages (see the Planning for improved performance section of this article for more information).

Each of these mechanisms has implications for design, construction, and commissioning (see the Selecting the right delivery mechanism or contract arrangement section of this article for more information).

How do construction leaders deliver sustainable construction?

The greatest opportunity for ensuring sustainability outcomes from all phases of the project exists at project inception. While the developer may initiate the sustainability agenda, it must be reflected throughout the contract chain. Unless there is an unequivocal commitment at the highest level (Chairman, Board, CEO) to a sustainability objective, the project will simply be a repetitive example of past standard commercial construction.

Substitution and variations

The opportunity to tightly control variations and contractor-initiated substitutions should be identified early in the design phase by listing materials and design initiatives that are critical to meeting the building's desired operational performance. The opportunity to lock this control into contracts should be exercised through clauses that identify critical sustainability design initiatives, construction processes and materials, and that specify submittal of any site substitution for approval by the design authority.

The contracts should require that any proposed substitutes have been tested by an accredited measurement laboratory as meeting the required sustainability performance parameters of the originally specified material or equipment, and that the material or equipment is substantially equivalent in all other respects.

Variations can be minimised through thorough documentation. In Australia, it is well-established that poor documentation leads to costly variations on site. The need for on-site design decisions can be minimised by planning for, and facilitating, better project documentation.

Construction consumables and impacts

The use of consumables during the construction process has a significant environmental impact. Energy use results in greenhouse gas emissions; water use decreases supply levels; sediment transport in stormwater run-off affects natural waterways; and materials use results in waste generation and pollution.

Opportunities for improving construction sustainability in these areas are discussed below.

Energy use

Opportunities for decreasing the amount of energy used in construction include:

• ensuring that building materials and products have low embodied energy
• minimising the transport of temporary structures, scaffolding, formwork, consumables and building products to the construction site
• minimising overall waste, and the transport of waste from the site
• considering environmentally friendly fuels for use on site during construction (site transport, cranes, pumps, generators, and other motor driven construction equipment)
• minimising grid-connected electricity for site tools, elevators, lighting etc.
• minimising the transport of construction waste, temporary structures etc. from the site
• minimising the running of equipment and services for testing and commissioning prior to occupation
• considering off-site or consolidated fabrication, which may also reduce energy and water consumption through more efficient processing and a lesser transport task.

Water use

Opportunities to decrease the amount of water used on a construction site include:

• using water-efficient cleaning appliances
• monitoring the contractor's water use, setting limits, or placing the water bills in the contractor's name to encourage conservation
• using low-flow fixtures for water siphons installed for construction
• using rainwater or greywater from the construction site.

Stormwater and run-off management

Applying erosion and sediment controls to construction sites can greatly reduce the delivery of sediment to surface waters.

Pollution from site activities

Some opportunities to reduce the noise, air and light pollution, as well as EMF radiation, include:

• minimising the use of materials that emit volatile organic compounds
• minimising the use of noisy equipment in the early morning and late afternoon
• ensuring that trucks are switched off once they have parked on site
• ensuring that all security lights hit a surface and/or are motion-activated
• ensuring the use of appropriate line filters to reduce EMF radiation.

Waste

Waste can be problematic on construction sites, but there are a number of opportunities for reducing this environmental impact, such as:

• setting up a recycling system for all recyclable materials
• educating site staff about recycling and recycling protocols
• ensuring waste is treated properly and disposed of properly to maximise resource recovery.

Biodiversity

Projects should attempt to preserve or enhance the local biodiversity of the site. Particular attention needs to be given to the protection of natural environments during construction activities. A local indigenous plant propagator should be used to source local species. Consultation with community groups can often provide very good information on local plant species and the vegetation history of the region.

Topsoil protection and site permeability are also important biodiversity considerations during construction (see the Implementing and operating for improved performance section of this article for more information).

Bushland and garden elements have the ability to support a wide range of microbiological, insect and arboreal species. It is important that construction activities do not destroy these important elements of biodiversity.

There are many opportunities for the conservation of biodiversity on construction sites. These include:

• ensuring that site managers have adequate knowledge of all biodiversity on site
• ensuring that areas of significant biodiversity are protected from site operations
• monitoring the impact of site activities on species and habitat.

Soil preservation

Green Star awards a credit point where it can be demonstrated that cut and fill are balanced within the construction site, and that no soil has been removed from the site.

Social responsibility

Construction activities create situations and local environments that have quite significant impacts on the immediate community and the construction workforce. Some of the opportunities that exist for improving social responsibility include:

• improving the management of health and safety issues
• keeping site personnel informed of cultural and heritage issues on site
• addressing oversighting of neighbours
• minimising site impacts on community access and general well-being
• controlling construction vehicle nuisance and amenity impacts
• managing traffic mix and safety on site
• controlling undesirable activities
• minimising opportunities for petty site crime
• eliminating fraud and corruption.

This article shows that there are many different ways in which the environmental impact of a construction site can be minimised. While addressing these opportunities may require some additional work in the planning and implementing phases, doing so will ensure that sustainability outcomes can be achieved.

More details and guidance on planning and implementing for sustainable outcomes are included in the Planning for improved performance and the Implementing and operating for improved performance sections of this article.

Planning for improved performance

• Management initiatives
  • Selecting the right delivery mechanism or contract arrangement
  • Participants and their motivations
  • Training
• Environmental management planning
• EMPs alone will not deliver sustainability
• Eliminating fraud and corruption

Sustainability cannot be achieved without good planning. Having identified the opportunities for sustainability, management must commit early to addressing the best ways of achieving better outcomes. This section looks at planning for sustainable outcomes in construction.

Management initiatives

Developers and contractors should be aware of, and plan to adopt as a minimum benchmark, the principles set out in the Australian Procurement and Construction Council's National Code of Practice for the Construction Industry. With regards to environmental performance, the Code states:

A systematic approach to environmental management will ensure that the organisation's environmental issues are identified and managed and includes:

• explicit management commitment and environmental policy
• acceptance by the organisation that its activities, products or service have an impact on the environment
• development and implementation of planning processes and procedures that assist in identifying possible environmental impacts and measures to mitigate or minimise these impacts
• establishing organisational responsibility, systems and procedures to review the implementation process, and
• establishing management processes for the review of these systems and procedures which support the organisation's commitment and environmental policy and which lead to continually improving performance.

It is essential that roles, duties and responsibilities are clearly defined, documented and communicated to people in an organisation so that everyone knows what they have to do, why, when and in what circumstances.' (APCC, 1999)

The quality of the declared design intent and the ESD targets set for a project will determine the extent to which the design influences the energy efficiency, environmental and social outcomes of the finished building, during both its construction and lifetime of operation. Contractors should familiarise themselves with the design intent and construction sustainability targets, and ensure that these are reflected in their business processes and site instructions. (See 'Design and sustainable commercial buildings' and 'Project management and sustainable commercial buildings' for more information)

To minimise the environmental impact of construction, project planning needs to include:

• the embedding of sustainability design and construction features in project documentation from the very beginning through the briefing, design and documentation phases
• consideration of sustainability in all tenders, or other project delivery processes
• sustainable practices as a construction contract requirement
• metering consumables, monitoring activities and reporting during the construction process
• adequate communication within and between project teams
• focus on whole-of life considerations
• practical guidance to help contractors to achieve and maintain targets
• adequate training of construction and project managers, trades and construction personnel, and facility and asset managers in sustainable construction techniques
• removal of traditional construction techniques that negate good sustainable design and construction intent.

Appointing an environmental or sustainability facilitator with responsibility over the whole of the project delivery is a necessary prerequisite to ensuring that all project personnel have a clear understanding of the environmental constraints and requirements of the project. The sustainability facilitator should be required to develop a 'project sustainability check-list' that includes all sustainability design and construction initiatives, as well as all environmental compliance requirements.

In the construction phase, tender documents for all construction packages should include the requirement to submit a construction phase EMP that meets project sustainability requirements, prior to commencement of any work on site. Contractors need to ensure that all sub-contracts also include this requirement.

The construction EMPs must be supported with a sustainability component that highlights EMP requirements in all contractor induction sessions, and must be enforced through regular environmental audits by the sustainability facilitator. Retaining an external auditor and including the client in audits will assist in audit objectivity and avoid potential conflicts of interest.

The left figure shows the roadmap used by one construction company for managing the environmental activities on their projects. It lists the activities and linkages from project identification, right through to post-occupancy operations.

Selecting the right delivery mechanism or contract arrangement

Source: AGO, 2007

Newer project delivery mechanisms have the significant advantage over traditional (design, bid, construct) methods of a more integrated approach to planning, design, construction and commissioning of a facility. An integrated approach will invariably result in lower whole-of-life costs (RAIA). As noted on some projects, these newer mechanisms can sometimes blur the decision-making processes between the planning, design and construction phases (Walker, Jaunzemis & Cavendish, 2003).

Careful planning is required. Poor understanding of the project delivery process can hinder the consideration of sustainability on a project. The mechanisms and features of these project delivery approaches are described below.

Public/Private/Partnerships (PPP)
The important element in PPP involves a shift in the role of the public sector from that of supplying its own buildings to one of partnering with the private sector to provide financing, and to design, construct, operate and maintain the required facility. The client ensures its requirements are met, and then occupies the building under a long-term lease arrangement, which forms part of the PPP mechanism.

PPPs can take many forms including Project Team Partnering; Long-term Alliancing; Design, Construct and Maintain (DCM); Design, Build and Operate (DBO); Build, Own, and Operate (BOO); and Build, Own, Operate Transfer (BOOT). The choice depends on factors such as the client objectives, the type of building, and the availability of finance.

Project Team Partnering (PTP) or Project Alliance
PTP requires all parties in the process of delivering a building to enter into an agreement that gives them all a share in defined outcomes of the project. The primary aim of partnering is to avoid an adversarial environment where parties seek to blame and gain through contract variations and litigation. Partnering usually applies to short-term arrangements for design and construction (D&C), or design, construction and maintenance (DCM), with outcomes related to construction savings (under-budget, under-time, fewer OH&S occurrences, construction energy and water use reductions, waste minimisation etc.). Those responsible for initiating, project managing, designing, contracting and construction of a project would normally partner to achieve a better outcome.

Long-term Alliancing (LTA)
LTA avoids the cost of tendering for team formation on every new project. For instance, once a project team has delivered a successful project under a partnering arrangement, that team stays together for other similar projects, further enhancing their skills and their ability to be innovative.  Following a review into the construction industry in the United Kingdom, the UK Government has directed that departments may use successful team alliances repeatedly for public sector projects.

Energy Performance Contracts (EPC)
EPCs require an up-front investment in additional professional services during design — for coordination between disciplines, computer modelling and energy analysis, compliance checking during building commissioning, and operational measurement and verification — as well as potentially additional capital on plant and equipment. The cost of the additional services is recovered through future energy savings.  Whether these are treated as performance rewards for the designers or as repayment of the additional costs is a matter for negotiation on a case by case basis.

EPCs usually focus on lighting, water use, heating, air-conditioning and related services on the operational-demand side.

Performance contracts can be included as part of the general agreement between owner/developers and designers/contractors. Having performance targets available from the start allows designers to effect meaningful changes in fundamental building characteristics, such as building form and siting. For more information about EPC, see http://www.aepca.asn.au.

Delivered Energy Services (DES)
DES involves the purchase of services that consume energy, such as light and climate/conditioned air (including specified indoor air quality), from a third party. For example, rather than the traditional process of a building owner purchasing and owning the mechanical and electrical equipment necessary to deliver conditioned air, a service contract is entered into between the tenant and an air service or climate provider. The tenant specifies standards and certain performance requirements that must be achieved by the service provider, who charges a monthly fee for that service.

Participants and their motivations

This section looks at the responsibilities of project participants in a commercial building project prior to construction, discusses their motivations, and highlights how their actions in planning for the construction phase can impact on both the sustainability of the construction process itself and the eventual sustainable performance of the building in operation.

Participants and their role in planning for construction

Participant (and motivation)	Usual role/responsibilities	Planning for enhanced construction sustainability	Planning to ensure sustainable design integrity
Developer (to conceive and deliver to market a facility that will sell and/or attract and keep tenants for a profitable outcome)	Sets the broad design requirements and targets for the building project Engages design, project management consultants (may be internal) and construction contractors	Commit early to sustainability targets for the construction process	Commit early to a design intent embracing sustainability, and set sustainability targets for the operational performance of the finished facility
Pre-committed tenant/s (achieving accommodation that meets functional requirements and minimises future rental risk)	Sets accommodation standards and space functional requirements Monitors project progress, watching for scope changes that may impact on accommodation fit-out requirements and for time blowouts	Require that the project be delivered using sustainable construction practices	Influence design by specifying 'green lease' conditions for tenancy agreement Require third-party commissioning of facility to ensure sustainability requirements are delivered
Design consultants/building design professions (to achieve recognition by injecting individuality and style to the project while meeting developer's brief)	Designs the facility, specifies materials and services and documents the project for construction Design consultants may be retained/novated to the project manager to ensure design intent is maintained during construction	Include and facilitate design charrettes that include project manager and construction personnel (and contractors if pre-determined) Design the facility with a comprehension of constructability that minimises energy, water, and resource use, and site waste dimensions) Include requirements for ISO 14000 certification, and a construction Environmental Management Plan (EMP) in contracts	Monitor project construction to ensure that design intent is not partly undone by on-site construction decisions Ensure that contracts specify submittal for approval of all material substitution including specified consumables Be involved in site start-up meetings to ensure contractors understand sustainability imperatives in the design
Project manager (to manage contracts and the construction of the project to completion on time, within budget, and to design specification)	Manages the construction delivery process particularly contract timing, materials ordering, variations, payments and cumulative project cost, and reports progress	Appoint a Construction Sustainability Officer (Environmental and Sustainability Officer) Create a sustainability awareness culture on the project site Include site-specific sustainability induction training for all contractors Carry out energy, water and environmental audits of on-site work to check compliance with EMP	Appoint a Construction Sustainability Officer Create a sustainability awareness culture on the project site Include site-specific sustainability induction training for all contractors Monitor construction to ensure only specified materials and consumables are used Ensure that 'as built' documentation is accurately compiled and transferred for operational use

Training

Formal education programs for the building professions are now beginning to address sustainability, enabling the setting of competency requirements for practice. However, the influence of building professionals may not impact on the construction process for a number of years after graduation, as most cannot make independent decisions until they have achieved professional practice competencies as assessed by their professional body, or have achieved senior positions in the management of development, design and construction processes.

On the other hand, as a tradesperson is 'hands on' during and immediately after their training, their actions on construction sites can have a significant impact on the sustainable design intent of a project.

Construction companies need to ensure that all people who will work on the construction project understand the basic principles of sustainability and are adequately trained in sustainable construction practices. This includes both their own staff and sub-contractors.

Particularly pertinent for sustainability in the building and construction industries is training for employees that enables them to:

• cope with novel situations
• analyse the requirements of a situation
• identify what they and others can bring to the situation
• engage in the task or problem (Graham, Coutts & Hes, 2003).

Employees need to have capabilities as well as knowledge-based training. They need to be able to make 'green' decisions and manage a green building and green construction process in order for the building to achieve the design outcomes.

As part of the construction process, tradespeople need to be provided with relevant information on sustainable site management and sustainable construction strategies.

In an article on the construction of the Moreland Civic Centre, it was noted that improving the communication between the project manager and the tradespeople and sub-contractors was a key to enabling sustainability on the project.

Environmental management planning

An environmental management plan (EMP) is a tool that is used to manage environmental risks and issues on a project. The effectiveness of the plan is dependent on the commitment of management to follow the plan, and on how well it is written and understood by construction personnel. EMPs are often used to ensure compliance with environmental regulations and to manage environmental risk. However, if written with sustainability objectives in mind, the EMP can assist in driving better sustainable outcomes from the construction process that go beyond compliance (see the EMPs alone will not deliver sustainability section of this article for more information).

EMPs should comply with ISO14001 2004, the international environmental management standard. ISO14001 2004 specifies a set of environmental management requirements for environmental management systems, including EMPs. The purpose of the standard is to help all types of organisations to protect the environment, to prevent pollution, and to improve their overall environmental performance.

Key aspects of an EMP are the identification of issues that need to be addressed and the development of a means of managing these issues. As with any system, monitoring the effectiveness of an EMP is also important.

A good site-specific construction EMP will be short and simple. Many construction EMPs are full of generic requirements that are the same for every project (such as 'diesel will be stored in a bunded compound which is 110% capacity of the largest tank'). Such requirements are covered by standards and all contractor's employees should be trained to manage these kind of generic issues – they don't need to be repeated in site-specific EMPs.Information that is not site-specific can be left out and included in a company environmental management plan.

The shorter the plan, the more likely employees are to know what is in it; and if they know what is in it, the more likely they are to actually implement it. Types of things to be included in site-specific construction EMPs are:

• plans that show exactly where sediment control devices are to be put in place; not generic statements stating that sediment control will be put in place — this should be left in the company management plan
• plans showing the location of the diesel storage and associated bunding
• the location of any trees that are to be retained and protected, including (if applicable) areas around the root zone where heavy vehicles should not park to prevent compaction of the soils, which could impact on the health of the trees
• site-specific check-lists, which include all the issues on site that need to be checked on a regular basis, including who is responsible for completing the check-lists
• a reporting structure for the project, specifically naming the appointed Environment Officer
• site-specific noise mitigation measures and hours of operation.

It is important to keep the content of the site-specific construction EMPs as simple and clear as possible.

However, the construction EMP will achieve little unless it is supported by a management regime that addresses the following:

• a means of managing the potential impacts identified in the EMP — what happens if it goes wrong?
• the availability of relevant legislation and industry standards for the potential issues identified — why do we have to do it?
• management of EMP monitoring, reporting and performance evaluation — how do we check we are doing what we said we would? Reporting should comply with the international environmental performance evaluation standard ISO14031
• training and induction of employees and contractors on environmental matters — knowing what is in the plan
• A complaints/incident register and reporting procedures for complaints and incidences (this can be done as part of the Quality Management System) — what went wrong, how do we fix it and how do we prevent it from happening again?
• an environmental auditing program (this can be done as part of the Quality Management System) — an independent check that the plan is working
• a number of issue-specific management plans for issues identified as needing management.

The issue-specific management plans include information such as that shown in the table below. This table is flexible and could be modified depending on the needs of the specific site.

Issue-specific management plan outline

Background	Background information on the specific issue
Objectives	The objective of the issue-specific management plan (i.e. what the plan is trying to achieve)
Management strategies	Outlines the management strategies that will be implemented for the protection of the environment during construction, operation, maintenance and decommissioning of the project
Action	Steps taken to implement the nominated strategy, including necessary approval applications, con