IEE Cruise Program – MV Corinthian Multi-year Assessment

Grand Circle Corporation

Initial Environmental Evaluation for Antarctic Peninsula Ship-based Tourism Aboard MV Corinthian

Five-year Programmatic Assessment

December 2014 – March 2019

Submitted 12 September 2017 to US Environmental Protection Agency for Activities during the 2017-18 Season

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

TABLE OF CONTENTS

1. CONTACT DETAILS ...... 5

2. NON TECHNICAL SUMMARY ...... 6 2.1 Description of the Proposed Activity ...... 7 2.2 Alternatives ...... 8 2.3 Assessment of Potential Impacts ...... 8 2.4 Minimization and Mitigation ...... 9 2.5 Conclusion ...... 9

3. INTRODUCTION AND BACKGROUND ...... 11 3.1 Scope of the Evaluation ...... 11 3.2 Company Description ...... 11 3.3 Vessel Specifications ...... 13 3.4 Vessel Operations ...... 18 3.4.1 In General ...... 18 3.4.2 Relevant Laws and Regulations ...... 19 3.4.2.1 ...... 19 3.4.2.2 Applicable Marine Legislation ...... 22 3.4.2.3 Safety of Vessels ...... 23 3.4.2.4 Safe Vessel Operations ...... 23 3.4.2.5 Emergency Response Action ...... 24 3.4.2.6 Environmental Safeguards ...... 24 3.4.3 Oil and Oily Mixtures ...... 25 3.4.4 Garbage ...... 27 3.4.5 Sewage ...... 27 3.4.6 Ballast ...... 28 3.4.7 Stack Emissions ...... 28 3.4.8 Avoidance of Harmful Interference with Biota ...... 29 3.4.9 Security Plan ...... 29 3.4.10 Anchor Watch ...... 29 3.4.11 Disembarking Passengers ...... 30 3.4.12 SAR Arrangements ...... 30 3.4.13 Insurance Provisions ...... 33

4. PROPOSED ACTIVITY ...... 36 4.1 Itinerary Planning, Site Selection, Route Planning and Management ...... 36 4.2 Purpose and Value of Antarctic Tourism ...... 41 4.3 Location and Duration ...... 41 4.4 Small Boat Activities and Cruising ...... 42 4.5 Landings and Shore Activities ...... 44 4.6 Education and Training of Passengers, Crew and Expedition Team ...... 47

5. ALTERNATIVES TO PROPOSED ACTIVITY ...... 51 5.1 Changes to Itinerary ...... 51 5.2 Changes to Sites Visited ...... 51 5.3 Changes to Number of Passengers ...... 51 5.4 Changes to Vessel Used ...... 52 5.5 Changes to Zodiac Usage ...... 52 5.6 Alternative of Not Proceeding with Cruise Program ...... 52

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

6. LIKELY IMPACTS, ASSESSMENT, MINIMIZATION AND MITIGATION OF PROPOSED ACTIVITIES ...... 54 6.1 Affected Environment ...... 54 6.2 Relevant Laws and Regulations ...... 54 6.3 Standard Operating Procedures ...... 54 6.4 Assessment of Impacts ...... 57 6.5 Air ...... 59 6.5.1 Origins ...... 59 6.5.2 Assessment ...... 60 6.5.3 Minimization and Mitigation ...... 60 6.6 Water - Fuel and Oil Spills ...... 60 6.6.1 Origins ...... 60 6.6.2 Assessment ...... 61 6.6.3 Minimization and Mitigation ...... 61 6.7 Wastes Generated During the Expedition ...... 62 6.7.1 Origins ...... 62 6.7.2 Assessment ...... 62 6.7.3 Minimization and Mitigation ...... 64 6.8 Noise ...... 64 6.8.1 Origins ...... 65 6.8.2 Assessment ...... 65 6.8.3 Minimization and Mitigation ...... 65 6.9 Physical Disturbance ...... 66 6.9.1 Origins ...... 65 6.9.2 Assessment ...... 65 6.9.3 Minimization and Mitigation ...... 66 6.10 Introduction of Alien Species and Translation of Diseases ...... 67 6.10.1 Origins ...... 67 6.10.2 Assessment ...... 67 6.10.3 Minimization and Mitigation ...... 68 6.11 Dependent and Associated Ecosystems ...... 69 6.11.1 Origins ...... 69 6.11.2 Assessment ...... 70 6.11.3 Minimization and Mitigation ...... 70

7. CUMULATIVE IMPACTS ...... 72

8. MONITORING AND VERIFICATION ...... 77

9. CONCLUSION ...... 79

10. SKETCH MAP OF THE ANTARCTIC PENINSULA AREA ...... 80

11. ACKNOWLEDGMENTS ...... 81

12. ACRONYMS ...... 82

13. APPENDICES ...... 84 13.1 Advance Notification ...... 85 13.2 Background Information for Captains, Ice Pilot and Expedition Leader ...... 98 13.3 IAATO Wildlife Incident Report Form ...... 105 13.4 IAATO Whale Collision Reporting Form ...... 106 13.5 IAATO Emergency Contingency Plan ...... 107 13.6 IAATO Incident Report Form ...... 111

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

13.7 IAATO Emergency and Medical Evacuation Response Plan (EMER) ...... 114 13.8 IAATO List of South Orkneys and Antarctic Peninsula Sites ...... 117 13.9 IAATO Criteria for Assessing New Sites ...... 131 13.10 IAATO Guidelines for the Operation of Small Boats in the Vicinty of Ice ...... 132 13.11 IAATO Standard Procedures for Station Visits ...... 136 13.12 IAATO Boot, Clothing and Equipment Decontamination Guidelines for Small Boat Operations ...... 137 13.13 IAATO Antarctic Pre-arrival Biosecurity Declaration ...... 139 13.14 IAATO Guidelines for the Discovery of Non-native Species ...... 140 13.15 Table 3 Matrix of Likely Environmental Impacts ...... 142 13.16 IAATO Assessment of Potential Impacts and Mitigation Measures ...... 145

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

1. CONTACT DETAILS

As noted below, an outside consultant assessed the proposed operation and prepared this environmental impact assessment. It is the responsibility of the Expedition Organizer to ensure compliance with the activities outlined in this document.

Inquiries should be directed to:

EXPEDITION ORGANIZER:

For Grand Circle Corporation: Mr. Alastair Newton Director of Nautical and Land Planning 347 Congress Street Boston MA 02210 USA Tel: +001 (617) 346 6841 -- head office +011 44 7590 482481 -- Mobile #1 – for emergencies Emergency Tel: as noted above Fax: +001 (617) 346 6840 – head office E-mail: [email protected] / [email protected] Website: http://www.gct.com

Alternative Contact: Captain Josko Duric Port Captain -- Designated Person Ashore -- Chief Safety Officer (Safety, Security and Environmental) Email: [email protected] Mobile: +011 385 99 227 1581

~~ ~~ ~~

OUTSIDE CONSULTANT:

Victoria Wheatley Expedition Voyage Consultants, Ltd. Knox House, 16-18 Finch Road Douglas, Isle of Man, IM1 2PT, United Kingdom Tel: +001 858 699 8867 (USA) Email: [email protected] Website: www.expeditionvoyage.com

Ms. Wheatley has been active in the Antarctic tourism industry since 1986 and has traveled to Antarctica over 50 times aboard a range of vessels. She is an IAATO Accredited Expedition Leader for Antarctica (Peninsula and ) and South Georgia and has participated in numerous IAATO committees and working groups over the years, including the Executive Committee where she served for eight years. Since 2010 Ms. Wheatley has worked as a private consultant to the expedition cruise industry on a worldwide basis with a special interest in the Polar Regions. Her company is an Associate Member of IAATO. She has authored numerous Antarctic and Arctic Environmental Impact Assessments. In 1999 she was tapped by the U.S. Department of State to serve as the government’s Antarctic private sector tourism advisor. In this role, she attends the annually-held Antarctic Treaty Consultative Meetings as part of the national delegation and is responsible for providing US government agencies with informed views on industry and advice on technical matters, such as visitor regulations; legal, policy and liability matters; management plans; and potential environmental impact resulting from human visitation.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

2. NON-TECHNICAL SUMMARY

This multi-year environmental impact assessment has been compiled by Grand Circle Corporation (hereafter GCC) (ref. Section 3.2), a US-based company to evaluate and assess environmental aspects of their planned operations for five consecutive austral summer seasons, from December 2014 through March 2019, under the multi-year environmental documentation provisions under 40 CFR (Code of Federal Regulations) Part 8, Environmental Impact Assessment of Nongovernmental Activities in Antarctica; Final Rule, §8.4 Preparation of Environmental Documents, sections (d) and (e); and §8.7 Initial Environmental Evaluation (hereafter IEE) issued by the Office of Federal Activities of the EPA, effective 07 January 2002, and in accordance with the Antarctic Conservation Act of 1978 (Public Law 95-541), as amended by the Antarctic Science, Tourism and Conservation Act of 1996 (Public Law 104-227). (See below.) This documentation has been prepared for review by US Environmental Protection Agency (hereafter EPA) and other US agencies with an interest in Antarctica, most notably National Science Foundation (hereafter NSF).

During the 2017-18 austral summer season, GCC, also referred to in this evaluation as the Expedition Organizer, plans to operate eight voyages to the Antarctic Peninsula and the South Shetland Islands during the period of 12 December 2017 through 28 February 2018. Details can be found in Section 4. A snapshot follows:

Number Embark Date Embark Port Disembark Date Disembark Port CLE12DEC2017 12 Dec 2017 Ushuaia 21 Dec 2017 Ushuaia CLE21DEC2017 21 Dec 2017 Ushuaia 30 Dec 2017 Ushuaia CLE30DEC2017 30 Dec 2017 Ushuaia 8 Jan 2018 Ushuaia CLE08JAN2018 8 Jan 2018 Ushuaia 17 Jan 2018 Ushuaia CLE17JAN2018 17 Jan 2018 Ushuaia 26 Jan 2018 Ushuaia CLE26JAN2018 26 Jan 2018 Ushuaia 7 Feb 2018 Ushuaia CLE07FEB2018 7 Feb 2018 Ushuaia 19 Feb 2018 Ushuaia CLE19FEB2018 19 Feb 2018 Ushuaia 28 Feb 2018 Ushuaia

As part of the company’s standard operating procedures and per requirements under 40 CFR Part 8, annual updates in regards to proposed activities for future seasons will be submitted to EPA no fewer than ninety (90) days before the proposed departure of the first expedition for each consecutive austral summer season.

This Environmental Impact Assessment (hereafter EIA), at the level of an IEE, is being filed to comply with the general obligations contained in the Protocol on Environmental Protection to the Antarctic Treaty of 1991 (hereafter Environmental Protocol) (http://www.ats.aq/documents/recatt/Att006_e.pdf), the specific obligations under Environmental Impact Assessment (Annex I) and the general obligations set forth within the context of the other Annexes including Conservation of Antarctic Fauna and Flora (Annex II), Waste Disposal and Waste Management (Annex III), Prevention of Marine Pollution (Annex IV), Area Protection and Management (Annex V) and Liability Arising from Environmental Emergencies (Annex VI).

The proposed activity also complies with obligations under the Antarctic Treaty and also acknowledges and meets with the suite of applicable tourism-related instruments (including Measures, Resolutions and older Recommendations) as adopted by Antarctic Treaty Consultative Parties (hereafter ATCPs) at the Antarctic Treaty Consultative Meetings (hereafter ATCMs). Details can be found on the Antarctic Treaty Secretariat (hereafter ATS) website at http://www.ats.aq.

Domestic obligations under the Environmental Protocol are implemented in the US by virtue of national legislation enacted as a result of its ratification of the Environmental Protocol. The Antarctic Conservation Act of 1978 (Public Law 95-541, 16 U.S.C. §2401-2413, October 28, 1978) provides for the conservation and protection of the fauna and flora of Antarctica and the ecosystem upon which they depend. The Act, amended extensively by the Antarctic Science, Tourism and Conservation Act of 1996 (Public Law 104-227), was enacted to implement the

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

Environmental Protocol. These regulations can be found at http://www.nsf.gov/od/opp/antarct/aca/nsf01151/start.jsp.

Other national laws and regulations apply, including: • NSF Final Regulations Federal Register Aug. 13, 2001, 45 CFR Parts 670 (Conservation of Antarctic Animals and Plants), 671 (Waste Regulation), 672 (Enforcement) (http://www.nsf.gov/pubs/stis1993/opp94006/opp94006.txt), 673 (Antarctic Non-governmental Expeditions) (https://ecfr.io/Title-45/pt45.3.673) and 674 (Antarctic Meteorites) (http://www.nsf.gov/geo/plr/antarct/meteorite_regs.jsp) • NSF Final Rules -- Federal Register Jun. 29, 1993, 45 CFR Part 670, 671, 672 regarding Conservation of Antarctic Animals and Plants, Waste Regulation, and Enforcement and Hearing Procedures, respectively. (http://www.nsf.gov/pubs/stis1993/opp94006/opp94006.txt) • EPA Final Rule regulation 40 CFR Part 8 (Environmental Impact Assessment of Non-governmental Activities in Antarctica) (http://www.law.cornell.edu/cfr/text/40/part-8) • Coast Guard Direct Final Rule regulation 33 CFR Part 151 implementing Annex IV to the Protocol and Article 15 of the Protocol with respect to vessels (http://www.gpo.gov/fdsys/pkg/FR-1997-04-14/pdf/97- 9540.pdf) • Chapter Vi-- NSF Part 672--Enforcement and Hearing Procedures; Tourism Guidelines (https://www.gpo.gov/fdsys/granule/CFR-1999-title45-vol3/CFR-1999-title45-vol3-part672/content- detail.html) • Marine Mammal Protection Act (hereafter MMPA) of 1972 and subsequent amendments and 50 CFR 216 MMPA Regulation (http://www.nmfs.noaa.gov/pr/laws/mmpa/) (see also below) • Endangered Species Act of 1973 (16 U.S.C. 1531-1544, 87 Stat. 884), as amended Public Law 93-205, approved Dec. 28, 1973, repealed the Endangered Species Conservation Act of Dec. 5, 1969 (P.L. 91-135, 83 Stat. 275). (http://www.fws.gov/laws/lawsdigest/esact.html)

The planned activities will also be carried out in accordance with applicable marine legislation that apply to virtually all ships at sea, including the International Convention for the Prevention of Pollution from Ships (hereafter MARPOL) (http://www.imo.org), the International Agreement Concerning Safety of Life at Sea (hereafter SOLAS) (http://www.imo.org), the International Management Code for the Safe Operation of Ships (hereafter ISM Code) (http://www.imo.org/en/OurWork/HumanElement/SafetyManagement/Pages/ISMCode.aspx), and applicable domestic statutes and regulations, including the MMPA (http://www.nmfs.noaa.gov/pr/laws/mmpa/) and the Endangered Species Act (http://www.fws.gov/laws/lawsdigest/esacdt.html), the latter two of which are also referenced above.

Details on these and other applicable relevant laws and regulations can be found in Section 6.2, along with a list of government guidance and policies and other resources.

An integral part of the EIA process is the submission of Advance Notification as required under Article VII(5) of the Antarctic Treaty (http://www.ats.aq/documents/ats/treaty_original.pdf). Advance Notification was submitted on 25 August 2017 to the US Department of State, the Expedition Organizer’s Competent Authority. A copy of the revised submission is attached as Appendix 13.1. The submission included details on: (1) the tour/expedition operator; (2) transport and equipment to be used for the tour/expedition (including vessel used for transport to/from Antarctica and equipment to be used); and (3) contingency planning to comply with ATCM Measure 4(2004) “Insurance and Contingency Planning for Tourism and Non-governmental Activities in the Antarctic Treaty Area” and ATCM Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities in the Antarctic Treaty Area.”

GCC is full (voting) Member in good standing of the International Association of Antarctica Tour Operators (hereafter IAATO), having joined on 08 August 2014. (Ref. Section 3.2.) Members in this category are referred to as Operators. Members of the association are committed to safe and environmentally-responsible private-sector

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment travel to Antarctica. The Association’s Bylaws, which outline requirements for membership and operational procedures, can be found on the public page of the Association’s website at: http://www.iaato.org.

To provide a context for the proposed activities, the known scope of commercially organized seaborne tourism to the Antarctic Peninsula region is presented.

2.1 Description of Proposed Activity

The proposed activity, conducted aboard the MV CORINTHIAN, a small expedition ship carrying 100 passengers, includes a series of voyages operated by GCC each austral summer to the Antarctic Peninsula and South Shetland Islands. The company’s inaugural season was in 2014-15.

Activities feature a combination of on board and off ship activities with the goal being to provide a well-rounded educational experience. Activities include Antarctic-themed educational presentations, Zodiac cruising, shore landings, and, on a conditional basis, Polar Plunges – and new for the 2017-18 season – the possible landing of passengers onto the ice (from Zodiacs). Details can be found in Section 4.

A fleet of Zodiacs (ref. Section 3.3) facilitates a variety of off-ship activities, including shore landings and touring. Shore landings will be limited to not more than 100 visitors (including passengers and any crew on leisure) ashore at one time at any one landing site unless a lower number is called for in any applicable regulations, guidelines and/or site guidelines.

Expedition operations have been planned to be fully self-sufficient, with activities managed by experienced officers, crew and expedition staff and to be within the search and rescue (hereafter SAR) capability of GCC, including for medical evacuation, if required. Details are elaborated upon in Section 3.4.12. Insurance provisions are disclosed in Section 3.4.13.

This assessment has considered the range of activities as disclosed by GCC at the time document preparation. New activities will be elaborated upon as information becomes available and the details advised in updates as appropriate. Any activities not assessed are the responsibility of the Expedition Organizer.

A list of acronyms used can be found in Section 12.

2.2 Alternatives

Six alternatives have been considered: • Changes to itinerary, • Changes to sites visited, • Changes to number of passengers, • Changes to vessel used, • Changes to Zodiac usage, and • Alternative of not proceeding with cruise program.

None of these alternatives are justified and all have been rejected for environmental, logistic or commercial reasons.

2.3 Assessment of Potential Impacts

This evaluation considers various aspects of the vessels’ operations, activities of passengers on shore and activities offshore and how these activities could have potential impacts. The potential for cumulative impacts of the proposed activities is also considered.

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2.4 Minimization and Mitigation

Section 6 of this assessment includes a description of the measures to be taken to minimize and mitigate likely impacts of the proposed activity as well as minimization and mitigation procedures that will be undertaken by the Expedition Organizer.

The possibility of potential impacts will be minimized by strict adherence to applicable international and national laws and regulations, company policies and standard operating policies; careful pre-trip planning and preparation; briefings; and supervision and monitoring of activities in the field by experienced personnel.

One of the perceived activities most likely to cause such an impact is the activity of passengers ashore. Measures to minimize the potential for impact from these activities include: • Compiling an EIA (at the level of an IEE) and submitting it to the Competent Authority (US EPA) for review in advance of the season. • Ensuring strict adherence to the full suite of tourism-related ATS instruments (e.g. Measures, Resolutions and older Recommendations) and domestic regulations to implement applicable provisions under the Antarctic Treaty, the Environmental Protocol and national law. • Carrying out careful pre-season planning which includes the implementation of IAATO guidelines and standard operating procedures. • Ensuring strict adherence to company-specific standard operating procedures, including activity manuals, e.g. Zodiac Operation Manual (available upon request). • Conducting a risk assessment and having appropriate contingency plans and sufficient arrangements for health and safety, search and rescue, and medical care and evacuation in place, including an Oil Contingency Spill Plan (hereafter SOPEP), an Emergency and Medical Response Plan (hereafter EMER), Emergency Contingency Plan and adequate insurance. • Hiring a qualified and experienced team of ship’s command, bridge officers, crew and an expedition team who have sufficient and demonstrable experience appropriate for the proposed activity. This includes having adequate first-aid equipment available during the activity and having at least one person who is proficient in advanced first-aid. • Ensuring that applicable personnel take and pass the appropriate IAATO Online Assessment in order that they are certified at the appropriate level. • Ensuring that all equipment, including communication, navigational, emergency and logistic equipment is in sound working order, with sufficient back-up spares and suitable for effective operation under Antarctic conditions. • Utilizing the IAATO Field Operations Manual (hereafter FOM).1 • Scheduling detailed briefings by the Expedition Organizer and ship’s owner to the Captains, senior officers, Expedition Leaders, and home-office personnel. • Pre-scheduling landing sites in advance of the season to ensure there is only one ship at any one landing site at any one time and also so that ATCM and IAATO Site Guideline requirements are adhered to. • Scheduling on board briefings by the Captain and Expedition Leader to the ship’s crew and expedition team -- not only at the start of the season -- but later on should new crew members or expedition staff sign onto the vessel during the season. • Conducting thorough passenger briefings by the Expedition Leader in advance of arrival to the Antarctic, and before and after shore landings and activities (as applicable).

1 IAATO. IAATO Field Operations Manual (FOM) (IP 87, XXXII ATCM, Baltimore, 2009). The FOM – an 800-page, two-volume compendium – is based on the traditional Expedition Leader’s Handbook, previously created by each member operator for its own vessel or operation. The new standardized format, introduced for the 2008-09 season and used by all IAATO members, incorporates numerous information, including regulations, guidelines and operating procedures that have proven to be effective tools over the years for the management of Antarctic travel. The FOM assists in maintaining compliance with IAATO Bylaws and also provides the course material for the IAATO Online Field Staff Assessment. The goal of the FOM is to ensure that all members and their field staff know what is required, and where to find critical information and the additional resources available to them. The manual is updated prior to each operating season by the Secretariat.

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• Maintaining a minimum staff-to-passenger ratio of one qualified guide to every 20 passengers while ashore (unless a lower number is called for in any site guidelines). • Ensuring procedures are in place for the careful monitoring of visitor activities ashore. • Filing ATCM-adopted Post Visit Reporting (hereafter PVR) at the conclusion of each voyage to IAATO and the US NSF to account for activities and to note any environmental impacts observed (if applicable). • Compiling an end-of-season report for IAATO to provide details as to the Expedition Organizer’s operations during the course of the season.

2.5 Conclusion

Direct, indirect and cumulative impacts of the proposed activity have been considered, as have alternatives. Provided that minimization and mitigation measures are adhered to, it is concluded that the proposed activity will have no more than a minor or transitory impact on the environment to be visited, including associated and dependent ecosystems, and that the activity should be authorized/permitted to proceed.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

3. INTRODUCTION AND BACKGROUND

In addition to also ensuring compliance with international and national laws and regulations, this assessment has been prepared to meet with general obligations under company-specific guidelines, standard operating procedures, and shipping requirements in general.

3.1 Scope of the Evaluation

Proposed tourism activities must be assessed prior to an activity taking place as per Article 8 of the Environmental Protocol, ATCM Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Non- governmental Activities in the Antarctic,” and IAATO Bylaws (http://www.iaato.org) and membership requirements.

GCC has undertaken this IEE to document and assess their planned activities during the next five operating seasons, from the 2014-15 through the 2018-19 austral summer seasons and in the upcoming season (2017-18).

As outlined in Sections 2 and 4, the proposed activity takes into account the general obligations contained in the Environmental Protocol and its Annexes, in particular the specific obligations contained in Annex I (Environmental Impact Assessment) and the entire suite of ATCM instruments that are applicable to tourism activities in Antarctica, including Protected Areas and those mentioned below.

Specific attention has been focused on: • ATCM Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities In the Antarctic Treaty Area,” • ATCM Resolution 6(2014) “Toward a Risk-based Assessment of Tourism and Non-governmental Activities,” • ATCM Resolution 3(2011) “General Guidelines for Visitors to the Antarctic,” • ATCM Resolution 6(2011) “Non-native Species Manual,” • ATCM Resolution 7(2009) “General Principles of Antarctic Tourism,” • ATCM Measure 15(2009) “Landing Of Persons from Passenger Vessels in the Antarctic Treaty Area,” • ATCM Resolution 5(2007) “Tourism in the Antarctic Treaty Area,” • ATCM Resolution 4(2007) “Ship-based Tourism in the Antarctic Treaty Area,” • ATCM Resolution 6(2005) “Antarctic Post Visit Site Report Form for Tourism and Non-governmental Activities in Antarctica,” • ATCM Measure 4(2004) “Insurance and Contingency Planning for Tourism and Non-governmental Activities in the Antarctic Treaty Area,” and • ATCM Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Tourism and Non- governmental Activities in the Antarctic” and “Guidance for Visitors to the Antarctic.”

ATCM instruments can be found on the Antarctic Treaty Secretariat website at: http://www.ats.aq.

NOTE: In most instances, further references in this assessment to ATCM Measures, Resolutions and Recommendations do not include the name of the document since provided here and in Section 3.4.2.1, which also contains a list of relevant laws and regulations and applicable marine legislation.

In addition to also ensuring compliance with national laws and regulations, this assessment has been prepared to meet the general obligations of the Environmental Protocol and its Annexes as well as wider obligations under the ATS; IAATO membership requirements and adherence to the association’s guidelines and standard operating procedures; and international obligations on ship owners/operators.

3.2 Company Description

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

Grand Circle Corporation (GCC): GCC is the largest US provider of international vacations for Americans aged 50 and older. We’re a family of brands: Grand Circle Cruise Line (http://www.gct.com), Grand Circle Small Ships Cruises, Overseas Adventure Travel (http://www.oattravel.com/), Grand Circle Travel (http://www.gct.com) and Grand Circle Foundation (http://www.grandcirclefoundation.org). Our small group sizes, unsurpassed value and excellence, and unique itineraries position us as the industry leader in travel and discovery. GCC is full voting Member (at the level of Operator) in good standing of IAATO, having joined the Association on 08 August 2014.

Grand Circle Dubrovink d.o.o. (GCD): GCD is the largest GCT office in Europe, with ship and land operation departments, port agency, crewing agency and IT support, exclusively serving GCCL, OAT and GCT land and ship programs, currently employing 60 people. The ship operation department is the holder of Document Of Compliance for passenger ship’s operation issued by the Flag State (Malta) proving that ships are operated in accordance with International Ship Management (hereafter ISM) standards on Safety, Security and Environmental Protection.

Grand Circle Cruise Line (GCCL): GCCL, based in Boston, MA has responsibility for sales and marketing, itinerary development (in concert with GCD), marine hotel operations, guest services (e.g. preliminary and final tour documentation), and the expedition team- related issues, including the selection and hiring of the expedition team and day-to-day supervision of this team. GCCL has an affiliated office in Buenos Aires, Argentina, where sales and marketing is also done. GCCL is also the corporation’s award-winning cruise division for Grand Circle Cruise Line Small Ship Cruise Tours and River Cruise vacations. This fleet consists of 50- to 250-passenger vessels that we either own or privately charter. All vessels are operated exclusively for GCCL, and have been custom-built according to the company’s specifications.

Grand Circle Travel (GCT): GCT handles sales and marketing activities at the company’s Boston, MA headquarters. GCT offers distinctive international vacations for older Americans. Established in 1958 by Ethel Andrus, educator and foundation of the American Association of Retired Persons (AARP), we view world travel as a powerful lever for lifelong learning. We make it accessible through trips that deliver unmatched discoveries, leisurely pacing, more travel choices, and comprehensive value.

Grand Circle Small Ship Cruises (GCSSC): Grand Circle Small Ships Cruises serves both our GCT and OAT brands with an award-winning fleet known for exceptional value and high-quality experiences in Europe, Asia, Africa and South America. Custom-designed according to our traveler’s specifications, our fleet includes 50+ small river and ocean-going ships that we own or privately charter.

Overseas Adventure Travel (OAT): OAT offers unique small group adventures worldwide to Americans over 50. By land and sea, we explore on – and off – the beaten path with a resident OAT trip leader. As noted below, OAT will not be selling into the MV CORINTHIAN voyages.

Grand Circle Foundation (GCF): GCF was established in 1992 as a means to give back to the world that had already given us so much. Since its inception, our Foundation has donated or pledged more than $50 million to educational, humanitarian, and cultural organizations worldwide.

Grand Circle Travel Buenos Aires (GCTBA): GCTBA handles organization of all South American trips on site, leading teams of Program Directors and Expedition Leaders and arranging all local activities.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

The management teams at GCC, GCD, GCCL, GCSSC and GCTBA, are all highly experienced in expedition cruising having previous Antarctic experience, starting from 2001 and cooperating with different ship/tour operators. Through the 2015-16 season more than 6600 people have traveled to Antarctica with GCT/OAT. As of the 2014-15 season, OAT no longer sells into the MV CORINTHIAN voyages.

As per membership requirements, company representative Alastair Newton has taken and passed the IAATO Online Assessment for Antarctica2. Following IAATO’s recommendations, GCC requires members of their Expedition Team to be IAATO-certified at an appropriate level (e.g. Expedition Leader or Expedition Guide) based upon the position hired for. IAATO’s online assessments test the working knowledge of expedition leaders and field staff as to the content of the FOM. The intent behind this service is to provide a free-to-the-user training mechanism for new field staff to test their knowledge of matters relevant to Antarctic guiding and leading trips. The online assessment also serves as a mechanism for established expedition leaders and field staff to refresh their knowledge and ensure they are familiar with new information prior to the season commencing. While the certification program is specific to Antarctica and South Georgia, it provides a framework for operating in Polar Regions in general and provides a basis for work in other Sub-Antarctic regions (such as South Georgia, the Falkland Islands/Islas Malvinas, Macquarie Island and the New Zealand Sub-Antarctic) and also other remote destinations where environmental protection is paramount.

3.3 Vessel Specifications

The technical specifications of the vessel are as follows:

Vessel Name MV Corinthian AIS Yes Antarctic Trips Since Year 2010 (with Travel Dynamics International); since 2014-15 with GCC Anti-fouling Certificate Yes Approved SOPEP Yes Auxiliary Engine Yes Ballast Amount – Normal Operation (m. ton) 150 – 200 m3 Ballast Capacity (m. ton) 307.4 m3 Ballast Exchange Frequency – Antarctica (days) N/A Ballast Exchange Frequency – Normal Operation (days) Depending on trading area Ballast Water Management Plan Yes Bilge Water Holding Capacity (cbm) 5.66 m3 Bilge Water Holding Capacity (days) 20 Black Water Management Plan Yes (part of SMS) no direct discharge Black Water Capacity (cbm) 6.3 m3 + 55.364 m3 Black Water Capacity (hours) 240 appx Boiler 2 gas oil fired, 6 bars steam Breadth (m) 15 Call Sign 9HUT9 Category IAATO Category 1 (13 - 199 passengers) Certified Black Water Treatment Plant Yes Certified Oily Water Separator (OWS) Yes

2 IAATO. IAATO Online Field Staff Assessment & Logbook. (IP 25, XXXIII ATCM, Punta del Este, 2010).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

Certified OWS with 15ppm Alarm & Automatic Shut-Off Yes Class Notation Bureau Veritas BV Code COR Crew Capacity 66 (excluding Expedition Staff) Damage Control Equipment Yes Deadweight, Normal Operation (m. ton) 796.0 mT Description Passenger Ship Diver & Equipment for Polar Waters No Draft Max (m) 4,012m Echo Sounder 1,2,3, etc 1 Echo Sounder Transmission Power and Frequency 50 kHz Echo Sounder Type Simrad ED-161 Email Master: [email protected]

Chief Engineer: [email protected]

Expedition Leader: [email protected]

Designated Person Ashore: Captain Josko Duric [email protected] Emergency Medical Evaluation Response Plan Yes Fax 001 321 95392 93 Fresh Water Capacity (cbm) 155.6 m3 Fresh Water Consumption (cbm/24 Hrs) 35 Fresh Water Production (cbm/24 Hrs) 144 Fuel Consumption per 24 Hrs - Max (m. ton) 15 mT Fuel Consumption per 24 Hrs - Normal Cruising (m. ton) 12 kts Fuel Consumption per 24 Hrs – Penetrating Ice (m. ton) N/A Gas Oil (GO) Capacity – Normal Cruising (m. ton) 7.3 mT GMDSS Area A1 + A2 + A3 Grey Water Capacity (cbm) 62.564 m3 Grey Water Capacity (days) 2-3 Gross Tonnage 4077 Heavy Fuel Oil (HFO) Capacity - Normal Cruising (m. ton) Capacity 129.1 m3; not used or carried while in the Antarctic Treaty Area Helicopter Deck No Helicopters On Board 0 HFO Specification, Grade (IFO 380, IFO 180, >IFO, etc.) IFO 180 (Not in use) HFO Storage Tanks (Type & Location) HFO DB 11-12-16-17 & 18 (Aft port and Stbd) Hydrographic Work No

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IAPP Certificate Yes Ice Class 1D - Bureau Veritas IMO Number 8708672 Incinerator Burning Temperatures Not in use (800 – 150 Celsius) Incinerator Capacity Not in use Incinerator Frequency of Use 0 Incinerator Used in Antarctica N/A IOPP Certificate Yes Length Overall (m) 88.10 mtrs Length pp (m) 74.77 m Life Boats 4 partially-enclosed for 48 persons each Lubricating Oil Capacity – Normal Cruising (m. ton) 20.66 m3 Lubricating Oil Storage Tanks (Type & Location) LO drain (Stbd aft), Stern T. LO (Port aft), Clean & Dirty LO tanks (Port and Stbd aft) Main Engine 2 internal combustion MAN B&W Marine Diesel Oil (MDO) Capacity Normal Cruising (m. ton) 261.92 mT Member of AECO Membership pending Member of IAATO Yes (as of 08 August 2014) Member of Other No MMSI 249556000 Morgue facilities Yes Name Corinthian Net Tonnage 1223 Number of Doctors onboard 1 Number of hospital beds 1 Number of Nurses or other medical staff onboard 0 Number of Zodiacs/Landing Craft 6 Oil Record Book Yes Oil Spill Containment Equipment Yes Oil Spill Response Company Yes Operate in the Arctic No Operator Name Grand Circle Durbrovnik d.o.o. Owner Name GCCL (Malta) Fleet 4 Ltd P&I Insurance (Amount in USD) Claims are limited to a maximum aggregate amount of US$3,000,000,000 any one accident or occurrence Passenger Capacity 110 / 50 cabins Pollution Liability Insurance (Amount in USD) Claims (through P&I Insurance) are limited to a maximum aggregate amount of US$1,000,000,000 any one accident or occurrence Port/Country of Registry Valetta, Malta PSSC Total # of Persons 178 persons

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Remarks 110 Pax and 68 Crew Sel-Call 249556000 Sludge Oil Holding Capacity (cbm) 13.67 m3 Sludge Oil Holding Capacity (days) 27 Sonar Yes (only Echo-sounder) Sonar Transmission Power and Frequency Check Echo-sounder part Sonar Type Check Echo-sounder part Speed – Max 15 kts Speed - Normal Cruising 12 kts Status Telephone/Telefax/Emergency Phones Emergency phones: Mobile: +385 99 227 1581 DPA Mobile: +385 99 21 83 625 Deputy DPA

Contacts for the vessel: Telephone: +1-321-953 9 292/291 Fax: +1-321-953 9 293/294 Inmarsat: 424955611/610 Iridium: 001 321 9539292 Inmarsat-C: 00870 764870072

Iridium Satellite phones: Captain’s Fleet 77 – 00 870 764 905 610 Bridge Fleet 77 – 00 870 764 870 072 Radio Room Fleet 77 – 00 870 764 911 299

INMARSAT – 424 955 611/610 MTN 1(reception) – 00 385 20 770 130 MTN 2 – 00 385 20 770 125 MTN 3 – 00 385 20 770 134

Iridium Hand Held – 00 881 651 487 565 (to be used by the Expedition Leader in the field) Iridium Fixed – 00 881 651 489 873 Telex (Sat C.) IMN C Type Passenger/Cruise Ship Under Water Welding Facilities N/A Untreated Grey Water Discharged Directly Overboard N/A (cbm/hours) VDR Yes, Kelvin Hughes Waste Management Plan Yes X-ray equipment No Year Built 1990 Year(s) Rebuilt N/A

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Details of all life-saving equipment carried on board (i.e. number and capacity of life rafts, number of survival suits, life jackets, Emergency Position Indicating Beacons (hereafter EPIRBs), Search and Rescue Transponders (hereafter SARTs), pyrotechnics, etc., are as follows:

5 pcs. Life Rafts for 12 persons each 4 pcs. Life Boats - 48 persons each partially-enclosed 9 pcs. Immersion Suits 188 pcs. Adult Lifejackets 20 pcs. Children’s Lifejackets 0 pcs. Infant Lifejackets 2 pcs. EPIRB 3 pcs. Survival Craft Portable Radio 12 pcs. Lifebuoys (6 pcs. w/lights, 2 pcs. w/lights and smoke, 4 pcs. w/line) 1 (4 cartridges) pcs. Line Throwing Apparatus 13 pcs. + 16 pcs. Rocket Parachute Flares (Bridge) (in Lifeboats)

Information on Ship Certification under Bureau Veritas can be found at: (http://www.bureauveritas.com/wps/wcm/connect/bv_com/group/services+sheet/classification+of+ships+and+of fshore+units)

Information on the Statutory Certification of Ships under Bureau Veritas can be found at (http://www.bureauveritas.com/wps/wcm/connect/bv_com/group/services+sheet/statutory-certification-of- ships_1703?presentationtemplate=bv_master_v2/Services_sheet_full_story_presentation_v2)

Additionally, for auxiliary boat operations using the Zodiacs (see auxiliary equipment below) there are 72 pcs. Inflatable-type lifejackets available for use.

Auxiliary equipment to be used within Antarctica to support the proposed tourism activities: Type of Craft: Mark V-brand Zodiac inflatable boats Number of Craft: 6 total (for 12 persons each) Engines / Fuel Type: 6 Yamaha-brand 50 HP 4-stroke electronic outboard gasoline- powered engines plus three spare engines for back-up/spares Intended use: To facilitate shore landings and short sightseeing excursions

Safety equipment in each Zodiac includes: fire extinguisher, Personal Floatation Devices (12), thermal protective aids (12), horn, light, first aid kit, paddles, sea anchor, towing line, painter lines (2) and a lifeboat knife.

Information on Zodiac lifejackets has been noted above under life-saving equipment carried on board.

In regards to communications, further to the information above, the vessel is equipped with a GMDSS Radio Station, which is authorized to operate in areas A1, A2, and A3. The ship is also equipped with VHF radiotelephony and Air Band VHF Radio telephones.

MV CORINTHIAN is equipped with Integrated Bridge Navigation and an Electronic Chart Display System (ECDIS) to- be-certified per latest requirement during the vessel’s next annual survey (15 April); the ECDIS includes Automatic Radar Plotting Aids (ARPA) radars, Chartpilots and Multipilot at the conning stations.

The following equipment is also part of the Navigation Bridge: • 1 DGPS positioning systems • 1 GPS positioning system • 1 Automatic Identification System (AIS) • 1 Doppler Speed Logs • 1 Echosounder system with forward transducers

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• 1 Long Range Identification and Tracking (LRIT) system • Weather station consisting of wind, temperature and humidity sensors • Voyage Data Recorder • 2 Searchlights remotely operable • 1 NAVTEX • 2 ARPA radars

The pertinent details the vessel’s specifications, life-saving equipment and auxiliary equipment, have been added to the IAATO Vessel Database3, launched in 2006, which provides a single database of critical information for every IAATO member and vessel.

Weather and ice information is obtained by the ship through government and private services by means of telex, voice, internet and e-mail communications. The vessel subscribes to a private weather information service, which sends updated weather daily by e-mail providing current weather, sea conditions and forecasts for up to ten days. Additional ice information can be requested as well as a ship's routing service.

The hull on MV CORINTHIAN is ice-strengthened (see above). The expedition itineraries are limited to the traditional operating season and to areas where conditions are known to be suited to the qualifications of the vessel, the Master and Bridge Officers.

The vessel frequently operates in areas that are three to five days’ distance from land support. This is exceeded on a routine basis with the Antarctic operations. Thus, the ship is staffed and equipped to handle most medical emergencies. Details on medical equipment and a list of medications are available upon request. Stabilizing medical care can be provided until patients are safely disembarked to a land facility offering equal or superior care. Medical staff includes one doctor experienced in Emergency Medicine who is on call 24 hours a day. The doctor and ship’s command are experienced in arranging air ambulance transfers for critical patients. The vessel does not have on board helicopters or landing platforms, nor are any facilities on board to refuel aircraft. Consequently, air evacuations can only be done when the ship is close enough to land at a site where there is a landing strip so that the aircraft can reach the ship and return with its own fuel supply. Accordingly, GCC has subscribed to the air evacuation priority service offered by AeroRescate S.A. (http://www.aerorescate.cl); this service offers priority access to aircraft in the event subscribers need medical air evacuation from the Antarctic Peninsula. Additional information can be found in Section 3.4.12.

In compliance with Regulation V/7.3 of SOLAS (http://www.imo.org/blast/blastDataHelper.asp?data_id=5635&filename=1041.pdf), the vessel has on board a Plan for Cooperation with SAR services in the event of an emergency. SAR cooperation planning enables the early and efficient establishment of contact in the event of emergency between a passenger ship, its operator’s shore- based emergency response system, and shore side SAR services. Additional information can be found in Section 3.4.12.

Each of GCC’s insurers likewise has regional correspondents capable of arranging assistance in the event of a vessel emergency. Additional information on insurance provisions can be found in Section 3.4.13.

3.4 Vessel Operations

3.4.1 In General

Details of the proposed activity are outlined in Section 4.

The vessel’s technical specifications can be found in Section 3.2.

3 IAATO. IAATO Vessel Emergency Contingency Plan 2006-2007 IAATO Operational Document (ref. Appendix C – IAATO Vessel Questionnaire Used in New Vessel Database) (IP 91, XXIX ATCM, Edinburgh, 2006).

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As noted in Section 3.2, the vessel is outfitted with a fleet Zodiac inflatable boats that will be employed during short sightseeing excursions and for shuttling passengers and the expedition team to and from shore for landings and shore-based activities. An experienced mechanic is on hand for servicing the engines. Zodiac drivers are experienced individuals from the expedition team, including the majority of the lecture team, however Bridge officers and/or deck crew (rated as Able-Bodied or Ordinary Seaman) may also be utilized on occasion, e.g. for shuttling purposes. Standard operating procedures are in effect through GCC’s Zodiac Operation Manual (available upon request).

Ship’s command and members of the Expedition Team are fully aware that cruising in a potentially dangerous and sensitive environment such as in Antarctic waters, demands special care and a carefully planned and organized operation.

Utilizing the MV CORINTHIAN, a vessel with years of polar and other worldwide cruising experience, along with an experienced ship’s command, bridge team, senior officers and crew and a highly-experienced Expedition Team will enable GCC to safely conduct these voyages to the highest standard of environmental protection possible. Ship’s command, including an experienced Master, Chief Officer and Chief Engineer with prior shipboard experience including navigation in and around the areas to be visited as well as knowledge of the areas and landing sites to be visited. Background information on the Master and Expedition Leaders are included in Appendix 13.2.

3.4.2 Relevant Laws and Regulations

3.4.2.1 Antarctica

In general, Antarctic operations of the MV CORINTHIAN will comply with all applicable requirements for ensuring the preservation of wildlife and protection of the environment and to conform with any national laws or regulations applicable to tourism operations, as well as to requirements under IAATO membership.

Activities in the Antarctic are subject to the Antarctic Treaty of 1959 (http://www.ats.aq/documents/ats/treaty_original.pdf) and associated legal instruments, referred to collectively as the , which governs activities in the Antarctic. There are three other major agreements that are considered part of the ATS: 1) Agreed Measures for the Conservation of Antarctic Flora and Fauna (adopted 1964) (http://www.ats.aq/e/ep_faflo.htm) These measures, which were more or less incorporated into Annex II of the Environmental Protocol, prohibit the taking of species without a permit and the introduction of non-native species, and designate specially protected species. 2) Convention for the Conservation of Antarctic Seals (CCAS) (adopted 1972) (http://www.ats.aq/documents/recatt/Att076_e.pdf) The Convention establishes measures designed to conserve Antarctic seal populations, including the issuing of permits for the killing of seals. Although the Convention allows for the commercial hunting of seals, no commercial hunting currently takes place in the Antarctic. 3) Convention on the Conservation of Antarctic Marine Living Resources (CCAMLR) (adopted 1980) (http://www.ats.aq/documents/ats/ccamlr_e.pdf) The Convention adopts the ecosystem approach to managing the commercial exploitation of marine resources such as fish and crustaceans.

Associated legal instruments include: • Agreement on the Conservation of Albatrosses and Petrels (ACAP), 2001 (as amended 2009) (http://www.acap.aq/) The Agreement was signed in 2001 over concern for the dramatic decreases in many seabird populations, primarily albatrosses and petrels in the Southern Hemisphere.

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Advance Notification (of intent to travel to Antarctica) is required under Article VII(5) of the Antarctic Treaty (http://www.ats.aq/documents/ats/treaty_original.pdf). As a US-based company, GCC is responsible for filing their company-specific Advance Notification to the Department of State. A copy can be found in Appendix 13.1.

In 1991 the Consultative Parties to the Antarctic Treaty adopted the Protocol on Environmental Protection to the Antarctic Treaty (www.ats.aq/documents/recatt/Att006_e.pdf). The Environmental Protocol sets out environmental principles, procedures and obligations for the comprehensive protection of the Antarctic environment, and its dependent and associated ecosystems, provisions that apply to all who visit Antarctica. The Protocol seeks to ensure that human activities, including tourism, do not have adverse impacts on the Antarctic environment or on its scientific and aesthetic values. Annexes to the Protocol include: Environmental Impact Assessment (Annex I), Conservation of Antarctic Fauna and Flora (Annex II), Waste Disposal and Waste Management (Annex III), Prevention of Marine Pollution (Annex IV), Area Protection and Management (Annex V) and Liability Arising from Environmental Emergencies (Annex VI).

ATCM Management Plans for Antarctic Specially Managed Areas (hereafter ASPAs) and Antarctic Specially Managed Areas (hereafter ASMAs), a list of Historic Sites and Monuments (hereafter HSMs), and other relevant information can be found at www.ats.aq/e/ep_protected.htm. ATCM Site Guidelines for Visitors can be found at www.ats.aq/e/ats_other_siteguidelines.htm.

Section 2 of this evaluation includes information on: • International Treaties (including the Antarctic Treaty) and the suite of obligations under the ATS (including the Environmental Protocol and its Annexes), • National laws/regulations, and resolutions applicable to Antarctic operators, • Marine regulations, • US domestic legislation (to implement the Treaty and Environmental Protocol), and • Pertinent regulations concerning the operation of the vessel.

ATCM instruments (Measures, Resolutions and older Recommendations) applicable to ship-based tourism operations in Antarctica (including landings and shore activities) include the following: • Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-Governmental Activities in the Antarctic Treaty Area” • Resolution 2(2016) “Site Guidelines for Visitors” • Resolution 6(2014) “Toward a Risk-based Assessment of Tourism and Non-Governmental Activities” • Resolution 4(2014) “Site Guidelines for Visitors” • Resolution 3(2013) “Site Guidelines for Visitors” • Resolution 4(2013) “Improved Collaboration on Search and Rescue (SAR) in Antarctica” • Resolution 2(2012) “Cooperation on Questions Related to the Exercise of Jurisdiction in the Antarctic Treaty Area” • Resolution 4(2012) “Site Guidelines for Visitors” • Resolution 5(2012) “Barrientos Island – Aitcho Island Visitor Site Guidelines” (revised) • Resolution 6(2012) “Antarctic Conservation Biogeographic Regions” • Resolution 7(2012) “Vessel Safety in the Antarctic Treaty Area” • Resolution 3(2011) “General Guidelines for Visitors to the Antarctic” • Resolution 4(2011) “Site Guidelines for Visitors” • Resolution 6(2011) “Non-native Species Manual” • Resolution 1(2010) “Site Guidelines for Visitors” • Resolution 2(2010) “The Contribution of the IPY to Hydrographic Knowledge of Waters of the Antarctic Treaty Area” • Resolution 6(2010) “Improving the Co-ordination of Maritime Search and Rescue in the Antarctic Treaty Area” • Resolution 7(2010) “Enhancement of Port State Control for Passenger Vessels Bound for The Antarctic Treaty Area”

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• Measure 15(2009) “Landing of Persons from Passenger Vessels in the Antarctic Treaty Area” • Resolution 4(2009) “Site Guidelines for Visitors” • Resolution 7(2009) “General Principles of Antarctic Tourism” • Resolution 2(2008) “Site Guidelines for Visitors” • Resolution 5(2008) “Improving Hydrographic Surveying and Charting to Support Safety of Navigation and Environmental Protection in the Antarctic Region” • Resolution 6(2008) “Enhancing the Role of Maritime Rescue Coordination Centres with Search and Rescue Regions in the Antarctic Treaty Area” • Resolution 1(2007) “Resolution on Site Guidelines for Visitors” • Resolution 4(2007) “Ship-based Tourism in the Antarctic Treaty Area” • Resolution 5(2007) “Tourism in the Antarctic Treaty Area” • Resolution 2(2006) “Resolution on Site Guidelines for Visitors” • Resolution 3(2006) “Ballast Water Exchange in the Antarctic Treaty Area” • Measure 1(2005) “Annex VI to the Protocol on Environmental Protection to the Antarctic Treaty – “Liability Arising from Environmental Emergencies” • Resolution 5(2005) “Resolution on Site Guidelines for Visitors” • Resolution 6(2005) “Antarctic Post Visit Site Report Form for Tourism and Non-Governmental Activities in Antarctica” • Measure 4(2004) “Insurance and Contingency Planning for Tourism and Non-Governmental Activities in the Antarctic Treaty Area” • Resolution 3(2004) “Tourism and Non-Governmental Activities: Enhanced Co-operation Amongst Parties • Resolution 1(2003) “Advice to Mariners and Vessel Operators on the Environmental Protocol’s Obligations” • Resolution 3(2003) “Co-operations in Hydrographic Survey and Charting of Antarctic Waters” • Resolution 3(2001) “Collection of Meteorites in Antarctica” • Resolution 3(1998) “International Code of Safety for Ships in Polar Waters” • Resolution 1(1997) “Emergency Response Action and Contingency Planning” • Resolution 3(1997) “Standard Form for Advance Notification and Post-Visit Reporting on Tourism and Non-Governmental Activities in Antarctica” • Resolution 3(1995) “Reporting of Tourism and Non-Governmental Activities” • Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Tourism and Non- Governmental Activities in the Antarctic” and “Guidance for Visitors to the Antarctic” • Recommendation XVI-13(1991) “Tourism and Non-Governmental Activities in the Antarctic Treaty Area” • Recommendation XV-3(1989) “Human Impact on the Antarctic Environment: Waste Disposal” • Recommendation XV-4(1989) “Human Impact on the Antarctic Environment: Prevention, Control and Response to Marine Pollution” • Recommendation XV-13(1989) “Comprehensive Measures for the Protection of the Antarctic Environment and Dependent and Associated Ecosystems” • Recommendation X-8(1979) “Effects of Tourists and Non-Governmental Expeditions in the Antarctic Treaty Area” • Recommendation VIII-9(1975) “Effects of Tourists and Non-Governmental Expeditions in the Antarctic Treaty Area” • Recommendation VII-4(1972) “Effects of Tourists and Non-Governmental Expeditions in the Antarctic Treaty Area” • Recommendation VI-7(1970) “Effects of Tourists and Non-Governmental Expeditions in the Antarctic Treaty Area” • Recommendation VI-11(1970) “New Islands” • Recommendation IV-27(1966) “Effects of Antarctic Tourism” • Recommendation I-X(1961) “Principles of Emergency Assistance”

These instruments can be found on the ATS website at: http://www.ats.aq.

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US legislation to comply with requirements under the Antarctic Treaty and Environmental Protocol includes the Antarctic Conservation Act of 1978 (Public Law 95-541) as amended by the Antarctic Science, Tourism and Conservation Act of 1996 (Public Law 104-227) (http://nsf.gov/od/opp/antarct/aca/nsf01151/start.jsp), which enacts the Environmental Protocol and Annexes I-V. Domestic regulations to implement Annex VI (Liability Arising from Environmental Emergencies” are (as of the date of this submission) still being developed.

The Act applies to: • The area south of 60° South latitude, • US citizens in Antarctica, • Certain persons in Antarctica who participate in US government activities, • US corporations or other legal entities that organize expeditions into the Antarctic, and • US persons wherever located, or foreign persons while in the United States, who import certain Antarctic animals and plants.

Violations under the Act can result in civil penalties and imprisonment.

The following provide US government guidance and policies:

Hand Book of the Antarctic Treaty System 9th Edition, 2002 http://www.state.gov/documents/organization/15271.pdf

US Policy on Private Expeditions to Antarctica http://nsf.gov/od/opp/antarct/ngo_policy.jsp

US Regulation Governing Antarctic Meteorites http://nsf.gov/od/opp/antarct/meteorite_regs.jsp

US EPA Regulations for Non-Governmental Activities in Antarctica https://www.gpo.gov/fdsys/pkg/FR-2001-12-06/pdf/01-30268.pdf

Other resources include: • Antarctic Protected Areas Information Archive http://www.ats.aq/devPH/apa/ep_protected.aspx?lang+e • Antarctic Treaty Secretariat Website http://www.ats.aq/index_e.htm • ATS-related Information on Tourism and Non-governmental Activities in Antarctica http://www.antarctictreaty.org/e/ats_other_tourism.htm

3.4.2.2 Applicable Marine Legislation

Activities will be carried out in accordance with applicable marine legislation that applies to virtually all ships at sea, and applicable domestic statutes and regulations, including the MMPA (http://www.nmfs.noaa.gov/pr/laws/mmpa/) and Endangered Species Act (http://www.fws.gov/laws/lawsdigest/esacdt.html).

Provisions of the ATS deal with shipping-related activities are most notably Annexes IV and VI of the Environmental Protocol, which deal with marine pollution matters and liability, respectively. The International Maritime Organisation (hereafter IMO) (http://www.imo.org) and other international shipping regulation, largely deal with regulations related to shipping within the ATA as laid out in four primary categories: 1) Safety of Vessels, 2) Safe

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Vessel Operations, 3) Emergency Response Action and 4) Environmental Safeguards.4 5 Applicable Antarctic-related marine legislation is detailed below. (Additional information has been provided in Section 2.) Additional information can be found in Section 6.2.

With regard to the IMO, list of all IMO Conventions, including related protocols, can be found at http://www.imo.org/About/Conventions/ListOfConventions/Pages/Default.aspx.

3.4.2.3 Safety of Vessels

Safety of Vessels: • SOLAS, International Convention for the Safety of Life at Sea, 1974 (with frequent updates) and its Protocol of 1988 (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International- Convention-for-the-Safety-of-Life-at-Sea-(SOLAS),-1974.aspx) • International Convention on Loadlines, 1966, amended, including the Protocol of 1988 relating to the International Convention on Loadlines, 1966 IL PROT 88 (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-on-Load- Lines.aspx)

Further assurance of compliance with vessel safety standards is provided through the various classification societies (e.g. American Bureau of Shipping, Bureau Veritas, Det Norske Veritas, Germanischer Lloyd, Lloyd’s Register, Registro Italiano Navale (RINA), Russian Maritime Register of Shipping, etc.). These societies set technical standards (design, construction and periodic survey of vessels) and provide a certificate of classification to a vessel once all standards have been met. As noted in Section 3.3, MV CORINTHIAN is classified under Bureau Veritas (http://www.bureauveritas.com). Additional information can be found in Section 6.2.

3.4.2.4 Safe Vessel Operations

International marine legislation to deal with safe vessel operations includes: • International Labor Organization’s Maritime Labor Convention, 2006 (MLC, 2006) (http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:91:0::NO::P91_ILO_CODE:C186) • International Labor Organization ILO Convention 147 (http://www.admiraltylawguide.com/conven/minstandards1976.html) • International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW Convention), 1978 as amended in 1995 (http://www.imo.org/OurWork/HumanElement/TrainingCertification/Pages/STCW-Convention.aspx) • Convention on the International Regulations for Preventing Collisions at Sea, 1972 (COLREG 72) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/COLREG.aspx) • ISM Code (International Management Code for the Safe Operation of Ships) (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/ISMCode.aspx) • IACS (International Association of Class Societies) (http://www.iacs.org.uk/) • International Convention on Tonnage Measurement of Ships, 1969 (Tonnage 69) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-on- Tonnage-Measurement-of-Ships.aspx) • IMO International Ship and Port Facility Security Code (ISPS Code) (http://www.imo.org/OurWork/Security/Instruments/Pages/ISPSCode.aspx)

Since 1998, SOLAS has required companies and vessels to implement an International Safety Management system (see ISM code above). The system must encompass the following: • Adoption of a safety and environmental policy;

4 IAATO. Regulation of Antarctic Tourism – A Marine Perspective (IP 83, XXXI ATCM, Kyiv, 2008). 5 IAATO. Regulatory Mechanisms that Address Antarctic Tourism (IP 85 - Rev.1, XXV ATCM, Warsaw, 2002).

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• Instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag state legislation; • Defined levels of authority between ship personnel and shore management; • Procedures for reporting incidents; • Procedures to prepare for and respond to emergency situations; and • Procedures for internal audits and management reviews.

The system requires a formal, institutionalized system of continuing management to ensure that a high level of safety is achieved and takes accident prevention beyond mere compliance with standards and rules.

As manager of the MV CORINTHIAN’s technical services for the vessel, GCD has in place a Safety and Quality Manual to accomplish goals and objectives under the company’s Quality, Safety and Environmental Management System (hereafter QSE). The Manual describes in principle all activities related to ship management including, but not limited to, quality, safety and environmental protection. The manual addresses the requirements of the ISO 9001 (http://www.iso.org/iso/home/standards/management-standards/iso_9000.htm) and ISO 14001 (http://www.iso.org/iso/home/standards/management-standards/iso14000.htm) Standards, along with the ISM Code. Details are provided in Section 6.2.

3.4.2.5 Emergency Response Action

Despite prevention measures, emergency response procedures need to be in effect to deal with emergency situations and potential accidents. Measures include: • International Convention on Maritime Search and Rescue (SAR), 1979 (IMO) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-on- Maritime-Search-and-Rescue-(SAR).aspx) • Guidance to Recovery Techniques Using Equipment Currently Available (MSC Circular 1182) (IMO) (http://www.uscg.mil/hq/cg5/cg534/MassRescueOps/IMO%20- %20Guide%20to%20Recovery%20Techniques%20(MSC%201%20Circ%201182)%2031%20May%202006.p df) • Enhanced Planning for Passenger Ships Operating in Areas Remote from SAR Facilities (MSC Circular 1184) (IMO) (http://www.imo.org/KnowledgeCentre/PapersAndArticlesByIMOStaff/Documents/International%20requ irements%20for%20ships%20operating%20in%20polar%20waters%20-%20H.%20Deggim.pdf) • Global Maritime Distress and Safety System (GMDSS), 1988 (IMO under SOLAS), mandatory for passenger vessels as of 1999 (http://en.wikipedia.org/wiki/Global_Maritime_Distress_and_Safety_System)

The Expedition Organizer is also aware of ATCM Recommendation I-X(1961) “Principle of Emergency Assistance” which reaffirms the principle that expeditions should render all assistance feasible in the event of an emergency request for help and ATCM Resolution 6(2008) “Enhancing the Role of Maritime Rescue Coordination Centres with Search and Rescue Regions in the Antarctic Treaty Area,” which encourages operators of tourist vessels, via their National Authorities, to consider the IMO’s “Enhanced Contingency Planning Guidance for Passenger Ships Operating in Areas Remote from SAR Facilities” (http://www.imo.org/blast/blastDataHelper.asp?data_id=14711&filename=1184.pdf). Ref. also Section 3.4.12.

3.4.2.6 Environmental Safeguards

Measures designed to provide environmental safeguards include: • MARPOL 73/78 – International Convention for the Prevention of Pollution of Ships (1973, modified by the protocol of 1978) (IMO) (http://www.imo.org), frequently amended with additional updates. Current Annexes include: o Annex I: Oil Pollution o Annex II: Chemical Pollution

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o Annex III: Hazardous Materials on Packaged Form o *Annex IV: Sewage o Annex V Garbage from Ships o Annex VI: Air Pollution from Ships *Note: Sewage discharges from ocean going ships are in many instances regulated by port states, such as the United States of America. Reference 33 CFR 159. • International Convention on the Prevention of Pollution by Dumping of Wastes and Other Matter (1972) and its 1996 Protocol (in force 2006) which supplements the provisions of MARPOL 73/78 (IMO) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/Convention-on-the-Prevention-of- Marine-Pollution-by-Dumping-of-Wastes-and-Other-Matter.aspx) • International Convention on Oil Pollution Preparedness, Response and Cooperation (in force 1995) (IMO) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-on-Oil- Pollution-Preparedness,-Response-and-Co-operation-(OPRC).aspx) • Protocol on Preparedness, Response, and Co-operation to Pollution Incidents by Hazardous and Noxious Substances (in force 2007) (IMO) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/Protocol-on-Preparedness,- Response-and-Co-operation-to-pollution-Incidents-by-Hazardous-and-Noxious-Substances-(OPRC-HNS- Pr.aspx) • International Convention on the Control of Harmful Anti-fouling Systems on Ships - IMO Systems Convention (SFS/CONF/26) (http://www.imo.org/OurWork/Environment/Anti- foulingSystems/Pages/Default.aspx) • IMO Resolution MEPC.42(30) (entered into force 1992): Designation of the Antarctic Area as a “Special Area” under Annex I (Regulations for the Prevention of Pollution by Oil) and Annex V (Regulations for the Prevention of Pollution by Garbage) (http://www.imo.org/blast/blastDataHelper.asp?data_id=15616&filename=42(30).pdf) • IMO Resolution MEPC.57(33) (entered into force 1994): Designation of the Antarctic Area as a “Special Area” under Annex II (Regulations for the Prevention of Pollution by Noxious Liquid Substances) (http://www.imo.org/blast/blastDataHelper.asp?data_id=30979) • International Convention for the Control and Management of Ship’s Ballast Water and Sediments (IMO), (2004, not yet in force). In the interim, Guidelines for Ballast Water Exchange in the Antarctic Treaty Area have been adopted by the IMO (Resolution MEPC. 163(56), 2007 (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-for-the- Control-and-Management-of-Ships'-Ballast-Water-and-Sediments-(BWM).aspx) • ATCM Resolution 3(2006) adopted by ATCPs as voluntary interim rules, which provides practical guidelines recognizing the sensitive nature of Antarctic waters (www.ats.aq)

A list of all IMO Conventions, including related protocols, may be found at: http://www.imo.org/About/Conventions/ListOfConventions/Pages/Default.aspx.

3.4.3 Oil and Oily Mixtures

The vessel is in compliance with international standards required under Article 3 (Discharge of Oil) of Annex IV (Prevention of Marine Pollution) of the Environmental Protocol. In addition, the vessel carries an approved SOPEP to prevent oil pollution at sea as required under MARPOL.

No oil or oily mixtures will be discharged into the seas (except in cases permitted under Annex I of MARPOL 73/78). All sludge, dirty ballast, tank washing waters and other oily residues and mixtures will be retained on board in a special holding tank for discharge outside the Antarctic Treaty area, at reception facilities or as otherwise permitted under Annex I of MARPOL 73/78. Discharge ashore (once the vessel has return to port) is the preferred method of disposing of these wastes. Limited oil spill contingency response equipment is carried on board; officers and crew are trained in emergency response procedures.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

Operators of the vessel and its owners/managers are aware of the IMO ban on the use and carriage of Heavy Fuel Oil (hereafter HFO) in the Antarctic Treaty Area, which has included the prohibition on the use and carriage of all Intermediate Fuel Oil (hereafter IFO) and HFO since 1 August 2011.

3.4.4 Garbage

The vessel fully complies with regulations under MARPOL 73/78, Annex V, Rule 9 (http://www.imo.org/blast/blastDataHelper.asp?data_id=30760&filename=201(62).pdf), adopted on 10 July 1996. This resolution elaborates rules for garbage handling under MARPOL for solids, food waste, plastics and other garbage. Under the Polar Code, discharge of garbage into the sea permitted in accordance with regulation 6 of MARPOL Annex V, shall meet the following additional requirements:

.1 discharges under Regulation 6.1 of MARPOL Annex V shall be as far as practicable from areas of ice concentration exceeding 1/10, but in any case not less than 12 nautical miles from the nearest fast ice; and

.2 food waste shall not be discharged onto ice.

Operation in polar waters shall be taken into account, as appropriate in the Garbage Record Book, Garbage Management Plan and the placards as required by MARPOL Annex V.

The master is mandated to relay to officers, crew (including the Expedition Team) the ship’s garbage handling policy in order to ensure that MARPOL requirements and guidelines are met. These requirements and guidelines are not specific to the Antarctic, but instead general worldwide obligations.

Crewmembers, under the Captain’s responsibility, are required to separate all garbage by type in color-coded bins. Solid matter, plastic, and food garbage is separated into separate containers for disposal. When discharged, a log is kept by color code as to what was discharged and where.

MARPOL totally prohibits the discharge of plastics at sea so all plastic products will be retained for proper disposal ashore.

As per Environmental Protocol requirements under Annex II (Conservation of Antarctic Fauna and Flora), Appendix C (Precautions to Prevent Introductions of Micro-organisms), food wastes are separated into “poultry products” and “all other products.” “Poultry products” (poultry or parts not consumed) will be handled in a manner that eliminates risks to native flora and fauna; either being incinerated (outside the Antarctic Treaty area), kept refrigerated or in frozen storage for disposal upon return to port. “All other products,” predominately kitchen waste from food preparation and disposal, will be stored until these can be released. There will be no disposal of poultry products South of the Antarctic Convergence (Polar Front) or less than 12 nautical miles from land (when North of the Polar Front). No poultry products will be taken on land, introduced into the water or onto the ice to avoid the spreading of the Infectious Bursal Disease Virus.

The vessel also complies with IAATO’s Statement on Waste Management (see below) for the storage of food waste while North of the Antarctic Convergence (the Polar Front) as a further means of environmental protection and as a minimization and mitigation measure.

IAATO STATEMENT ON WASTE MANAGEMENT (adopted 2007)

The IAATO 18 Annual Meeting discussed waste management practices in marine areas adjacent to the area of the Antarctic Treaty and agreed that: 1. For IAATO Member operated vessels, the restrictions on discharge into the sea from vessels that apply in the Antarctic Treaty area, pursuant to the Protocol on Environmental Protection to the Antarctic Treaty and MARPOL 73/78,

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

should be extended northward to apply everywhere south of the Antarctic Convergence (Polar Front); 2. The location of the Antarctic Convergence shall normally be deemed to be the line defining the northern limit of the Convention on the Conservation of Antarctic Marine Living Resources (CCAMLR) set forth in Article I, paragraph 4 of the Convention [see below], unless measurement of variation in sea water temperature clearly establishes its location as further north; 3. With the long term objective of preventing any discharge of waste by IAATO Member operated vessels on Antarctic voyages, all such vessels capable of doing so are strongly urged to retain all waste on board for appropriate shore- side disposal; and 4. IAATO open lines of communication with the appropriate authorities in gateway ports aimed at promoting expansion of environmentally sound waste reception facilities.

The Antarctic Convergence shall be deemed to be a line joining the following points along parallels of latitude and meridians of longitude: 50°S, 0°; 50°S, 30°E; 45°S, 30°E; 45°S, 80°E; 55°S, 80°E; 55°S°, 150°E; 60°S, 150°E; 60°S, 50°W; 50°S, 50°W; 50°S, 0°.

Emergency food is taken ashore as part of the Emergency Shore Kit (ref. Section 3.4.12) to provide for Search and Rescue (SAR) arrangements however all unused food and any garbage/waste will be strictly controlled and returned to the ship for proper disposal. These provisions are only for emergency purposes and only used in the event of a stranding ashore or medical emergency. (These provisions do not include poultry products.)

Battery disposal boxes are kept by the Hotel Director, in the engine room, and by deck department personnel and also by the electrician for proper disposal and removal from the Antarctic Treaty Area (hereafter ATA) – the area south of 60°S latitude -- to comply with Annex III of the Environmental Protocol. Passengers, the expedition team, and crew are advised of the need to utilize the battery boxes for disposal purposes and urged to turn in any expired batteries at the Reception for collection by the Hotel Director. Should this fail, the cabin attendants sort garbage and batteries are collected prior to the other garbage being sorted by type and bin. The provision master is responsible for collecting and arranging for disposal of all batteries. In addition, all electronic devices containing special chemicals, e.g. toner cartridges, printer cartridges, etc. are also collected for proper disposal ashore.

3.4.5 Sewage

The vessel is in compliance with MARPOL 73/78, according to Appendix V, Rule 9.2 (http://www.imo.org/blast/blastDataHelper.asp?data_id=30760&filename=201(62).pdf) and MARPOL 33/38, Appendix IV, Rule 3 (http://www.imo.org/KnowledgeCentre/ReferencesAndArchives/HistoryofMARPOL/Documents/MARPOL%2073- 78%20Brief%20History%20-%20List%20of%20amendments%20and%20how%20to%20find%20them.htm). All sewage, gray water and kitchen sink water is stored in tanks until it can be processed. The treatment plant chlorinates and flocculates sewage, separating solids and liquids. All treated liquid waste will be discharged at a speed of no less than four knots when the ship is more than 12 nautical miles from the coast or ice shelves (if applicable). Sewage sludge is disposed of ashore, once the ship is back to port.

3.4.6 Ballast

The vessel operates in accordance with MARPOL Resolution A.868 (20) (adopted 27 November, 1997) (http://globallast.imo.org/868%20english.pdf). The Company will ensure that ship’s command is aware of and will comply with international guidelines for preventing the introduction of unwanted aquatic organisms and pathogens from ship’s ballast water and sediment discharges and the related Practical Guidelines adopted by the IMO.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment

The vessel also operates in accordance with the International Convention for the Control and Management of Ship’s Ballast Water and Sediments (IMO), (2004, not yet in force) (http://www.imo.org/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Control-and- Management-of-Ships'-Ballast-Water-and-Sediments-(BWM).aspx). In the interim, Guidelines for Ballast Water Exchange in the Antarctic Treaty Area have been adopted by the IMO (Resolution MEPC. 163(56) (http://globallast.imo.org/2012/Individual%20Guidelines%20for%20reference/Antarctica%20MEPC.163(56).pdf), 2007 following recommendations in ATCM Resolution 3(2006) and the related Practical Guidelines. The vessel’s owner requires the uptake and release of only clean ballast picked up in the north of 60°S latitude and will not allow tank washing, other oily residues or mixtures to be released in Antarctic waters.

3.4.7 Stack Emissions

The vessel burns marine gas oil. There are no heavy oil bunkers. There are insignificant stack emissions from the vessel into the atmosphere to cause any kind of direct or indirect impact. While burning fuel the ship will produce normal amounts of hydrocarbon, heat and trace chemical emissions. The emissions will be a function of the types and quantity of fuel burned. As noted in Section 3.3 the Expedition Organizer is not anticipating that incineration will be done while in the ATA. Impacts to air quality will be no more than minor or transitory as well as local.

3.4.8 Avoidance of Harmful Interference with Biota

To avoid harmful interference, standard operating procedures are in place. In normal circumstances the vessel will not ordinarily approach the landing sites closer than 1500 feet (500 meters), following recommendations for vessels in the wildlife watching guidelines established by IAATO:

• General Wildlife Watching Guidelines: (http://iaato.org/documents/10157/19699/5e+i+General+Wildlife+Watching+Information.pdf/29d99a22- ed79-4824-9f91-2de5dfce1d07) • Cetacean Watching Guidelines (http://iaato.org/documents/10157/19699/5e+ii%29%20IAATO+Cetacean+Watching+Guidelines.pdf/730 43f71-28df-4732-aa4c-de93bbf5bbf8) • Seal Watching Guidelines (http://iaato.org/documents/10157/19699/5e+iii%29%20IAATO+Seal+Watching+Guidelines.pdf/c0873aa 4-9d52-4ffe-a40e-c8356d62188e) • Bird Watching Guidelines (http://iaato.org/documents/10157/19699/5e+iv%29%20IAATO+Birdwatching+Guidelines.pdf/039e2b3d- fa6f-45bb-a6b5-10e7337f390a) • Leopard Seal Watching Guidelines (https://iaato.org/documents/1515077/1515521/IAATO+Leopard+Seal+Watching+Guidlines+English.pdf)

The vessel will encounter marine mammals and seabirds. Whale watching is an exciting experience and ship’s command and the Expedition Leader will actively search for marine mammals to show passengers these animals at sea, with a primary focus on large baleen whales and orcas. In these instances, the vessel is instructed to follow the applicable IAATO wildlife-watching guidelines (see above) to ensure operations do not have an impact on the animal. The aim is to allow passengers to view wildlife from the decks of the ship by reducing speed, holding a steady course (unless some course changes are necessary) and maintaining a prescribed distance from the animal (300 feet/100 meters is recommended). All efforts will be taken to avoid disturbance.

Through an initiative led by BirdLife International (www.birdlife.org), simple practical guidelines have been established to minimize the likelihood of seabirds landing on vessels and to provide guidance on handling stranded birds. Seabirds land on vessels every year. Although the seabirds usually survive the initial impact, they can become hypothermic if they become waterlogged. These incidents occur most frequently during hours of darkness and usually during nights of poor visibility (snow, fog, or rain). On most occasions, this involves one or two birds

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment landing on deck and only rarely is there mortality. Serious bird strikes (where large numbers of birds may land on deck and mortality occurs) are considerably more rare. The intention of this initiative was to promote the very simple mitigation measures, which can be taken to minimize the chance of even rare occurrences happening. Guidelines are conveyed aboard ship by means of a poster (“Seabird Landing on Ships”)6 to be displayed in passenger and crew areas and as a PowerPoint presentation given by the Expedition Leader in his/her pre-arrival briefing. Expedition Leaders and ship’s command are encouraged to log and report incidents via a Seabirds Strike report form via the FOM. Details are reported using the IAATO Wildlife Incident Report form (Appendix 13.3). If an incident occurs with a whale, IAATO’s Whale Collision Reporting Form (Appendix 13.4) is used.

Zodiacs operated by expedition staff members will be employed to transport passengers between ship and shore. As noted previously, on occasion Bridge officers and/or deck crew (rated as Able-Bodied or Ordinary Seamen) may be used to operate the boats. Should wildlife (e.g. seals, dolphins, porpoises, whales or penguins) be present, drivers are trained to reduce the speed of the boats and to not approach the animal closer than 15 feet (5 meters). Drivers are instructed to follow the provisions of the applicable IAATO Wildlife Watching Guidelines (see above) and instructions in the company’s Zodiac Operation Manual (available upon request).

Standard operating procedures minimize wildlife disturbance, protect wildlife while ensuring a high-quality wildlife watching experience by responsible observation. Operating procedures minimize harmful impacts on marine wildlife populations by ensuring that the normal patterns of daily and seasonal activity of the animals are maintained in both the short and long term.

3.4.9 Security Plan

The vessel is compliant with the International Ship and Port Facility Code (ISPS) and carries an approved ship security plan and a valid International Ship Security Certificate. The plan includes procedures to be followed while the vessel is at anchor and while disembarking passengers and include an introduction, and covers corporate policies, safety management organization, and the safety management system. As not all aspects of the plan apply when the vessel is operating in Antarctica, the plan is only being briefly summarized.

3.4.10 Anchor Watch

While the vessel is at anchor, the Master will write down his temporary instructions in the book at the bridge indicating the responsibilities of anchor watch of the vessel. According to the conditions of the anchoring point (weather, proximity of dangers, risks of safety incidents), the Master will appoint the Officer of the Watch, his substitute, or both, to provide anchor watch.

It is the duty of the Officer of the Watch to train the Substitute of the Watch. He/she will especially insist on the “responsibility of the watch man” regarding the safety of persons and goods. The Watch Officer informs his/her relief and judges his/her ability to take the watch. The persons responsible for the watch will make sure of the good behavior of the vessel at anchoring by checking the following parameters: • Soundings, • Distances, radar bearings, and • Remarkable alignments, visual cues.

The radar parameters shall not be modified in order to avoid any variation of information, which will perturb the valuation of the vessel drift. In case of chase of the vessel, they will inform the Master and the Chief Engineer to launch the propelling engine. At least, they are responsible for the lighting of the vessel and for the hold of lights, flag and anchoring marks. If the watch is only provided by the substitute, this latter in case of incident, will inform in priority the officer of the watch, who will judge the situation. Security and safety rounds will be carried out when changing the watch officer by the leaving shift.

6 IAATO. IAATO Guidelines to Minimize Seabirds Landing on Ships. (IP 24, XXXII ATCM, Punta del Este, 2010).

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3.4.11 Disembarking Passengers

The Officer of the Watch is responsible for all movements of passengers. A Deck Officer will attend each landing and embarkation. He/she informs the Master of any boat launching, stowage, and movements of passengers, expedition team members and crew.

Passengers (and any crew on leisure) will be checked prior to disembarking the ship for Zodiac operations to make certain they have donned their appropriate personal floatation device and that it is put on correctly on in order that his/her movements cannot be hindered. A check will be made to ensure they are also dressed properly, have disinfected their footwear (if appropriate) and have signed out according to the vessel’s “sign-in/sign-out” procedures. Deck crew will assist with the embarkation/disembarkation of the Zodiacs. Passengers will be transferred into / out of the boats using the method. Passengers will be instructed as to these procedures during the Expedition Leader’s pre-arrival briefing. (Ref. Section 4.6.)

A continuous communication’s link with the Master or Watch Officer on the bridge is in effect during Zodiac operations and shore landings.

According to the state of the sea and before the operation, the Master – with the consultation of the Expedition Leader – will define the number to be carried on board each Zodiac. Accounts as to the numbers on board and ashore are provided to the Officer of the Watch as per standard operating procedures.

3.4.12 SAR Arrangements

MV CORINTHIAN is a modern cruise vessel that is fully self-sufficient and meets all necessary requirements for an ocean-going ship. Activities will be managed to be within the SAR and medical evacuation capability of GCC’s resources.

Appropriate contingency plans and sufficient arrangements for health and safety, search and rescue, and medical care and evacuation have been drawn-up and are in place for these proposed Antarctic activities to be in compliance with Article 15 of the Environmental Protocol, ATCM Measure 4(2004), ATCM Measure 15(2009), and ATCM Resolution 6(2017). Such plans and arrangements are designed so as not to be reliant on support from other Expedition Organizers or national programs.

Details on SAR coverage can be found in Section 3.4.13.

Vessels are required to operate under the ISM Code and have an established Safety Management System (hereafter SMS) in place in addition to the IAATO emergency contingency plans and recommendations. Since it entered into place on 01 July 1998, the ISM Code for Safe Operating of Ships and for Pollution Prevention (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/Default.aspx), adopted by all Flag States, has had a huge impact towards drastically improving the safe operation of ships and in pollution prevention. The ISM Code describes, in broad terms, what a ship operating company’s safety management system needs to include. A summary of the points describing the ISM Code framework are included in Appendix B to the IAATO-wide “Emergency Contingency Plan” discussed below.

Details on the classification of the vessel can be found in Section 3.3.

The Expedition Organizer complies with the IAATO-wide Emergency Contingency Plan agreed to at IAATO’s 14th General Meeting (May 2003, Seattle) and updated in 2014 (ref. Appendix 13.5). An update to the plan was last presented to ATCPs at ATCM XXIX7. The Plan provides for coordination of Emergency Plans (Emergency Contingency and Search and Rescue Plans) amongst Member vessel operators. The cornerstones are to ensure that there is adequate emergency equipment available on board IAATO member-operated ships, ship schedules and

7 IAATO. IAATO Vessel Emergency Contingency Plan - An Update (IP 91, ATCM XXIX, Edinburgh, 2006).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment positions are frequently updated and exchanged, an effective communication plan using the Global Maritime Distress and Safety System (hereafter GMDSS) and a mandatory reporting schema are in place to assist in the event of a possible event and to provide for medical evacuation support. The plan – which is updated annually -- considers emergency situations, identifies currently existing plans and standard operating procedures to deal with emergencies, and recommends preventive measures. As part of the Plan, IAATO has established an “Emergency Contingency Plan Flow Chart” to provide a checklist to assist in the event of an emergency. As part of this plan, IAATO launched a vessel database in March 2006, which provides a single database of critical information for every IAATO member and vessel. General details on vessels in the database can be found at: http://iaato.org/iaato- member-vessels. Members have Member’s-only access to each vessel’s attributes and asset resources on the ships in the IAATO fleet.

IAATO’s Emergency Contingency Plan and GCC’s own established standard operating procedures provide for self- sufficiency under Antarctic Treaty Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Tourism and Non-governmental Activities in the Antarctic,” Resolution 3(2011) “General Guidelines for Visitors to the Antarctic,” obligations under the Protocol on Environmental Protection to the Antarctic Treaty including the Environmental Impact Assessment procedure mandated in Annex I of the Protocol, and Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities in the Antarctic Treaty Area.”

The vessel has a tracking device and participates in IAATO’s Vessel Tracking System, which is compulsory for member vessel operators. This system tracks all IAATO vessels on a single website using a new state-of-the-art technology. In addition to improving contingency planning, the system also provides significant management and monitoring benefits and can provide data for the assessment of cumulative environmental impact. Vessel positions are logged into the system and portrayed through a dedicated password protected website. Positions are logged on an hourly basis during the season but can be “pinged” from shore for positions every 15 minutes in the case of an emergency. By clicking on the vessel’s name, a pop-up box displays an image of the vessel and key information (e.g. vessel call sign and IMO number, position, course and speed). Maritime Rescue Coordination Centres (hereafter MRCCs) with responsibility for Antarctic waters and the Atlantic Merchant Vessel Emergency Reporting System (hereafter AMVER) (http://www.amver.com) -- have full access to the website. This information can be coupled with detailed contact information for the vessels and the IAATO database8, which details each vessel’s attributes and asset resources in the event of an incident. The tracking system has also proven useful when unidentified distress signals were received by MRCCs, who then requested IAATO vessels to deviate and verify the authenticity of the signals.

At IAATO’s 20th Annual Meeting (2009), “Actions to Enhance Marine Safety” were agreed as had been recommended by the Marine Committee following the outcomes of the “Report of Investigation in the Matter of Sinking of Passenger Vessel Explorer (O.N. 8495) 23 November 2007 in the Bransfield Strait near the South Shetland Islands.”9 A second meeting of the IAATO Marine Committee in September 2009 created additional enhancements, which were also adopted by the membership. Details were provided in IAATO’s Information Paper to ATCM XXXIII in 201010. Of particular interest to vessel operators was the suggestion of including specific damage control training for crew and the importance of getting passenger participation in regular crew emergency drills. In line with the passenger drills, the Expedition Organizer will follow the recommendation to hold the mandatory lifeboat and safety muster prior to the ship’s departure from port (day of embarkation).

GCC is also aware, by way of the FOM, of the National Chart list produced by the International Hydrographic Organisation (hereafter IHO) (http://www.iho.int) to be used as an additional source of information for vessel masters. IAATO also provides, again by way of the FOM, an updated list of weather, sea ice and iceberg website information links for use by ship’s command and Expedition Leaders.

8 IAATO. IAATO Vessel Emergency Contingency Plan 2006-2007 IAATO Operational Document (ref. Appendix C – IAATO Vessel Questionnaire Used in New Vessel Database) (IP 91, XXIX ATCM, Edinburgh, 2006). 9 http://www.cruisejunkie.com/Explorer%20-%20Final%20Report.pdf 10 IAATO. IAATO Further Recommendations to Tourism Vessel Expedition Organizers to Enhance Marine Safety and Guidelines for Small Boat Operations in the Vicinity of Ice (IP 61, XXXIII ATCM, Punta del Este, 2010).

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In the case of a significant incident related to any of the following, IAATO provides Operators with an Incident Report Form by way of the FOM (ref. Appendix 13.6).

Incidents may include but are not limited to any of the following: 1. Medevac involving several or many people, 2. Medical emergency involving serious injury or loss of life, 3. Vessel loss or incapacitation (e.g. grounding, sinking, collision, trapped in ice), 4. Aircraft loss or incapacitation (e.g. stranding, crash landing), 5. Any incident that involves the need to ask for assistance by another vessel, station or aircraft, 6. Logistical (e.g. passengers stranded ashore for an extended period of time), 7. Environmental: pollution (e.g. oil spill, accidental discharge, etc.),

Other minimization and mitigation measures include IMO guidelines, IAATO guidelines and standard operating procedures and the suite of ATCM instruments (Measures, Resolutions and older Recommendations) applicable to vessel operations.

In terms of arrangements for self-sufficiency with specific regard to medical emergencies, the vessel will be manned on all voyages with a general physician and a well-equipped ship’s infirmary stocked with emergency medical equipment, including emergency medications, a defibrillator, oxygen cylinders and an EKG, that can provide first response leading to stabilization of injured parties.

To assist with medical emergencies on shore and in the Zodiacs, members of the Expedition Team are trained in CPR and basic First Aid; two have training in Wilderness Medicine.

In the event of a serious medical injury/illness to a passenger, expedition staff member or a crewmember, circumstances could require the ship to divert and to proceed as rapidly as possible to the closest port where competent medical care is available. Emergency evacuation, if required, is coordinated by ship's command, with the appropriate assistance of land agents, port agents or evacuation assistance companies to make whatever arrangements are necessary to safely evacuate or transport the patient to the closest shore side facility where competent medical care can be provided. Evacuation may include transportation by any land, water, or air conveyance as required to transport the patient. The most suitable arrangements would be made, taking into consideration the severity of the illness or injury, the location where the evacuation or transportation must occur and the availability of shore side medical facilities. The ship's physician is to do whatever he/she possibly can to sustain the patient until evacuation or transport can be enacted.

Every effort is made to be self-sufficient and to deal with the situation on board ship or by means that do not involve National Antarctic Program bases or personnel.

To minimize this potential impact, and recognizing the need to ensure self-sufficiency, IAATO member vessel operators are required to be part of an Emergency and Medical Evacuation Response Plan (hereafter EMER). The IAATO EMER (Appendix 13.7) provides formal procedures by way of a checklist (assessment, initial action, secondary action and final action) for member operators to follow in the event of a medical emergency. Each member operator is responsible for establishing its own air rescue service through one of the service providers to assist if a medivac was required due to a life-threatening medical emergency that was unable to be dealt with on board. Accordingly, GCC has contracted with AeroRescate S.A. (http://www.aerorescate.cl) for medivac services since their inaugural season in 2014-15, subscribing to their priority service. This gives subscribers priority access to their aircraft (over non-subscribers) should a life-threatening medical emergency present itself that GCC was unable to deal with on board. AeroRescate is a Punta Arenas, Chile-based company, with more than 25 years’ experience operating small ambulance-equipped aircraft into Frei/Marsh Base on King George Island (South Shetland Islands). Their aircraft includes a King Air (10 pax) for passenger transport, manned by 2 pilots and 1 assistant, as well as a Twin Otter. AeroRescate’s pilots are highly experienced and have more than 10,000 flying hours on average. If AeroRescate is unable to assist, other medical evacuation companies would be contacted, for

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment example, Aerocardal (http://www.aerocardal.com), also based in Punta Arenas. IAATO member vessel operators have also agreed to provide mutual support in case of a medical emergency through the plan; as such, depending upon the circumstances, another IAATO vessel may be asked to assist. In the worst-case scenario, the voyage would be cancelled and the vessel would proceed back to its planned port of disembarkation.

On tours that visit areas remote from shore side medical facilities, including destinations such as the Antarctic, sub-Antarctic and Arctic, detailed medical questionnaires are forwarded to passengers in advance. Office personnel first screen completed questionnaires, then the ship’s physician contacted should a question arise over someone’s suitability to undertake the voyage. Participants are advised that they may be cancelled from a program if deemed to have a physical condition or other disability that might create a hazard or lead to an unsuitable risk medical or otherwise. Once a reservation has been placed, participants are advised it is mandatory that they take out medical and emergency evacuation insurance to cover the anticipated costs of a medical evacuation for the period of time they will be traveling.

Medical emergencies, including any evacuations, are to be reported to IAATO via a brief report to the Secretariat and also noted on the PVR form (http://www.ats.aq/documents/recatt%5Catt074_e.pdf) submitted by the Expedition Leader at the conclusion of the voyage (ref. also Section 4.5.2).

All crewmembers (including members of the Expedition Team) must undergo, as part of their induction, a First Aid Familiarization course that includes Cardiopulmonary Resuscitation (CPR) training. As mentioned previously, two of the Expedition Team members have training in Wilderness Medicine. On occasions when the doctor is ashore he/she takes with him/her a backpack with basic field supplies to tend to an injured person before return to the ship.

Safety equipment in each Zodiac includes: fire extinguisher, Personal Floatation Devices (12), thermal protective aids (12), horn, light, first aid kit, paddles, sea anchor, towing line, painter lines (2) and a lifeboat knife.

During all Zodiac and landing operations, members of the Expedition Team are equipped with portable VHF marine radios and spare batteries. A listening watch between the ship and the Expedition Team is routinely maintained throughout boat and shore operations to maintain a continuous communication’s link with the Master or Watch Officer on the bridge.

Any wastes generated ashore, including spent flares, will be returned to the vessel for disposal. All crew, staff and passengers will wear SOLAS-approved PFDs at all times while in the crafts. Zodiac drivers will wear SOLAS- approved PFDs, immersion suits or floatation coats (as preferred).

Standard operating procedures are in effect through the company’s Zodiac Operation Manual. As noted previously the manual is being finalized at the time of this submission.

During the landings, an emergency shore kit (to be provided by the Expedition Organizer) is taken ashore to provide for emergency provisions in the unlikely event passengers, the expedition team and/or crew are stranded. The kit includes minimal shelter and emergency food supply for all; additional equipment has been considered for a percentage of hypothermic patients (e.g. should a small boat load of passengers get wet).

Other than the emergency food provisions described above to provide for Search and Rescue (SAR) arrangements, no other food is taken ashore.

GCC’s emergency shore kit has been based on the following IAATO recommendations:

Equipment Quantity Storm shelter (Vango or similar) – or tents Sufficient for maximum number ashore

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Thermal protective aids / space blankets or Sufficient for maximum number ashore similar Sleeping bags Sufficient for at least a few hypothermic patients Foam sleeping mats (or similar insulating ground Sufficient for one between two cover) Shovels Two Toilet paper (sealed in zip lock bags) Sufficient for maximum number ashore for at least 24 hours Emergency food11 Sufficient for maximum number ashore for at least 24 hours Water or water purification tablets Sufficient for maximum number ashore for at least 24 hours 1 litre water containers (if using water Sufficient for maximum number ashore for at least 24 hours purification tablets) Strong plastic sacks for waste Sufficient for maximum number ashore for at least 24 hours Whistle Two Signal Mirror One

This list does not take into account medical equipment, which is the responsibility of the onshore medic, or standard emergency equipment usually carried onboard small boats (e.g. flares, throw lines, radios, etc.)

Should a stranding occur, garbage and human waste (liquid and solid) resulting from a stranding will be collected and returned to the ship for proper disposal using garbage/waste bags. If urine cannot be collected in garbage/waste bags the liquid wastes will be discharged directly into the sea in a manner that does not adversely affect the local environment. At no times would liquid waste (e.g. urine) be disposed of onto sea ice, ice shelves or grounded ice-sheet.

3.4.13 Insurance Provisions

Insurance includes:

P&I Club Class I – Protection & Indemnity Insurance Cover through Steamship Mutual Underwriting Association Limited / Aquatical House 39, Bell Lane, London E1 7LU (Association); Steamship P&I management LLP; Aquatical House 39, Bell Lane, London E1 / LU (managers). The Certificate of Entry is under GCCL (Malta) Fleet 4 Ltd. (Owner). Cover is extended from 20 February 2017 through 20 February 2018 for 1) Oil Pollution 2) Passengers and Seamen, and 3) Collision. Certificate no. 55294/1.

Hull & Machinery – Marine / War Risks – 2016/2018 through Aon Insurance (8 Devonshire Square, London, England, EC2M 4PL, UK). The Policyholder is Grand Circle Cruise Lines Holding B.V. with Grand Circle Corporation as one of the Insured. Policy number C0085728014. Cover is extended from 01 June 2016 through 01 June 2018.

Tour Operator’s General Liability Insurance, including Errors and Omissions, is in place through the producer Risk Strategies Company (160 Federal Street, Boston, MA 02110) and insured through Lloyds of London with Grand Circle Holdings, LLC as the insured. Certificate number 180/PD1431768. Cover is extended from 01 May 2017 through 01 May 2018.

11 Depending on expected operation, energy bars may be sufficient. Alternatively, hot meal kits are available. The best are those where you add a small amount of water for a chemical reaction, which warms the meals up – the remaining heat pockets can double as hot water bottles to help warm hypothermic patients.

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As noted in Section 2, the Expedition Organizer has planned their activity to be in compliance with the specific requirements under ATCM Measure 4(2004) “Insurance and Contingency Planning for Tourism and Non- governmental Activities in the Antarctic Treaty Area” and ATCM Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities in the Antarctic Treaty Area” that call for including appropriate contingency plans and sufficient arrangements for health and safety, search and rescue (SAR), and medical care and evacuation to ensure support from other operators or national programs is not required. Additionally, adequate insurance and other arrangements are in place to cover any costs associated with search and rescue and medical care and evacuation and in the highly unlikely event that liability was incurred under Annex VI (Liability Arising from Environmental Emergencies) to the Environmental Protocol.

The Expedition Organizer is also aware of the US Policy on Private Expeditions to Antarctica (http://nsf.gov/od/opp/antarct/ngo_policy.jsp) and has taken the necessary steps to be self-sufficient and carries adequate insurance coverage against the risk of incurring financial charges or material losses in the Antarctic. Further details are provided in Section 3.4.13.

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4. PROPOSED ACTIVITY

The model of expedition ship born tourism to be followed in general terms is that started by Lars-Eric Lindblad, who was the first to offer tourist cruises to Antarctica in 1966. In 1969 Mr. Lindblad, considered to be the “grandfather” of the modern expedition tourism industry, purposely built the MS Explorer, a small specially constructed vessel for cruising to the Antarctic, Sub-Antarctic and the Arctic. Rather than simply offering tourists the opportunity to “cruise,” he developed an educational program, incorporated an environmentally-conscious focus to all aspects of the on board program; introduced the use of Zodiacs for off-ship transport; and instituted a model for shore landings that is still followed to this day. This model (of an activity with an educational and environmental focus), has come to be known as the “Lindblad Model” and has led to the development of a method of determining cruise routes and ways in which Expedition Leaders determine which landing sites to use.

The proposed Antarctic voyages covered by this evaluation feature a combination of on board and off ship activities with the goal being to provide a well-rounded educational experience and to meet fully with obligations under ATCM Resolution 7(2009) and in a manner that provides for safe and environmentally-responsible tourism to Antarctica, meeting obligations under the Environmental Protocol (and its Annexes) and according to ATS regulatory instruments or guidelines and international and national laws and regulations.

Carrying a maximum of 100 passengers while in Antarctica, MV CORINTHIAN will be operated as an IAATO “Category 1” activity, defined in the IAATO Bylaws (http://iaato.org/bylaws) as being applicable to “Organizers of vessels that carry 13-200 passengers and are making landings.” This allows for landings at any site in Antarctica, dependent upon IAATO’s own Site Specific Guidelines12 or any separate restrictions in ATCM-adopted Site Guidelines for Visitors (http://www.ats.aq/e/ats_other_siteguidelines.htm).

Each voyage will be led by an experienced Expedition Leader, selected because of his/her first-hand knowledge of the region(s) to be visited; in-depth knowledge of the particular landing sites; skill at managing groups in remote and sensitive environments; and the ability to carry out the voyage to the company’s expectations and in accordance with legal obligations. An Assistant Expedition Leader and a team of naturalists and lecturers with a far-reaching range of expertise will assist the Expedition Leaders.

4.1 Itinerary Planning, Site Selection, Route Planning and Management

The Expedition Leader, while responsible for the on board program, passenger activities off of the vessel and carrying out the day-to-day itinerary as to what landing sites are to be visited, works hand-in-hand with the Master who is responsible for the safe operating and running of the ship.

Itinerary planning and management is an on-going effort – both prior to and during the season. Selecting sites for visitation is a three-stage process. The first involves developing proposed itineraries internally prior to the commencement of the activity. The second is ensuring compliance with applicable requirements by an internal review. The third is the adjustment of the itinerary – on board – responding to environmental conditions, the presence of other vessels, and opportunities encountered locally (e.g. the presence of whales which might result in a change of plans to take advantage of this unexpected event or something unexpected on shore that might want to be experienced).

In the planning process, Expedition Leaders strive to develop itineraries that will provide the most diverse, comprehensive, educational and exciting experience to the passengers, within the number of days allotted, and most importantly, while also ensuring a safe and environmentally-responsible operation.

Usually an Expedition Leader seeks to provide passengers with two landings per day, with nighttime hours spent traveling to the next morning’s landing site. On occasion, off ship activities, for example short sightseeing

12 IAATO. IAATO Site Specific Guidelines in the Antarctic Peninsula (IP 90, XXVIII ATCM, Stockholm, 2005).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment excursions, are done by means of a Zodiac cruise without a shore landing being made. Additional information can be found in Section 4.5.

Itinerary development and site selection takes into account a number of factors. For example, most expedition leaders will start a trip with the easier landings (e.g. sites featuring protected access, beach terrain that is easy to walk on, sites with limited wildlife, etc.) and then work their way up later on in the trip to the more difficult landings (e.g. sites with beach terrain that may be more difficult to maneuver, sites with more sensitive wildlife, etc.). They also take into account the nature of particular groups of passengers. For example, some groups are well mannered, listen to instructions, follow advice of the expedition team and behave properly around wildlife or in areas where flora is present. Other groups may not be so well mannered and require more supervision, which may result in the Expedition Leader selecting other sites to be visited.

Itineraries are also developed in consideration of IAATO’s Wilderness Etiquette, which is detailed below.13 Adopted in 2007, the guidelines seek to (1) reinforce the understanding that the wilderness aspect is intrinsic to visitor’s experience of Antarctica, (2) reduce the pressure on vessels to view the number of landings made per day or per trip as the key indicator of the success of a voyage and (3) underpin the informal understanding and courtesy code traditionally afforded between IAATO vessel and yacht operators.

IAATO’s Wilderness Etiquette is as follows: • Where possible, Expedition Leaders and Vessel Masters recognize the desirability to keep vessels out of sight from each other as far as is practicable. • Vessels work co-operatively to ensure that they give a ‘buffer’ time (of a recommended 30-60 minutes) between visits at landing sites. • Where appropriate, spread activities across all possible ‘experience’ platforms (e.g. ship cruising, small boat cruising, kayaking, landings, etc.) to decrease pressure on specific landing sites. • Over time, companies phase out of brochures and other marketing materials direct mention of specific sites (e.g. Deception Island, Paradise Bay) to reduce the pressure for all vessels to visit these sites on all departures.

As a member of IAATO, the Expedition Organizer coordinates their day-by-day itineraries with other member vessel operators in advance of the season via the IAATO Ship Scheduler. The Scheduler opens on a set date each year (usually in late June or early July) and remains open for a set period of time for any follow-up or changes ahead of the season. The itineraries, including specific landing sites as scheduled on the Ship Scheduler, can be found in Addendum 2 to Advance Notification (Appendix 13.1).

To date, over 367 landing sites have experienced tourist visits, however most visitations occur to 30 or so Antarctic Peninsula sites; over 70% are sites where there are ATCM-adopted Site Guidelines for Visitors (http://www.ats.aq/e/ats_other_siteguidelines.htm) in place. IAATO’s own Site Guidelines14 cover some additional sites. A list of bays, channels and landing sites (excluding research stations) as reported by IAATO member operators to IAATO and NSF since 1989 through the end of the previous austral summer season is attached as Appendix 13.7.

Expedition Leaders are responsible for ensuring adherence to limitations on the number of passengers on shore at one time. To ensure compliance with ATCM Measure 15(2009), IAATO Bylaws (http://iaato.org/bylaws) and ATCM and IAATO Site Guidelines, a limit of 100 passengers ashore at any one time along with a minimum guide-to- passenger ratio of 1:20 will be maintained at all times, unless a smaller number is called for in any Site Guidelines.

Information on landing sites that may have site guidelines affixed to them – either by the ATCPs or by IAATO – are provided on an annual basis to Expedition Leaders and Captains via the FOM. IAATO’s Site Guidelines include some sites not currently under ATCM Site Guidelines for Visitors.

13 IAATO. Update of the Antarctic Peninsula Landing Site Use and Site Guidelines (IP 82, XXXI ATCM, Kyiv, 2008). 14 IAATO. IAATO Site Specific Site Guidelines in the Antarctic Peninsula (IP 41, XXXIX ATCM, Santiago, 2016)

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Two background documents that are heavily utilized by Expedition Leaders and field staff include: • Antarctic Peninsula Compendium (Ron Naveen, 3rd ed.) (http://www.oceanites.org/visiting/2011/APC_2011_3rd.pdf) • Oceanites Site Guide to the Antarctic Peninsula (Ron Naveen) (http://www.longitudebooks.com/find/p/2064/mcms.html)

The documents provide a wealth of information compiled by Naveen and his team of Oceanites (http://www.oceanites.org) researchers through their work on the Antarctic Site Inventory Project aimed at characterizing visitor sites and collecting relevant biological data over the past 23 seasons (from November 1994 through February 2017). To date the team has made over 1819 site visits collecting data from 226 Antarctic Peninsula landing site locations15. Repetitive visits have been made to all of the visitor sites that are most heavily visited by expedition tourists, to all sites which exhibit the most species diversity and are most prone to potential environmental impact from human visitors, and to the species-diverse, environmentally-sensitive tourism sites now subject to Site Guidelines for Visitors adopted at recent ATCMs. In addition to these background documents, Expedition Leaders have landing information compiled over many years of leading trips that provide information on various landing sites.

MAPPPD (Mapping Application for Penguin Populations and Projected Dynamics), http://www.penguinmap.com, is an exciting new tool developed for Oceanites by the Lynch Lab at Stony Brook University & NASA. MAPPPD allows instant access to the latest data required to analyze changes in Antarctica and will help assist ecosystem management. Expedition Leaders will be able to utilize the MAPPPD website to search for penguin species, region and site.

Antarctic weather and ice conditions are such that a site may be unobtainable. Opportunistic landings and excursions take place at sites on offshore islands and the mainland peninsula. These sites include areas of scenic and wilderness interest, scientific stations, historic sites, and areas where a specified physical activity is possible. In general, activities are limited to supervised walks with the express purpose of appreciating wildlife and nature. No opportunistic landings will be made where passengers will be endangered or the potential impact on wildlife is perceived to be more than minor or transitory.

If landing sites not previously visited before are being considered, Expedition Leaders utilize IAATO’s “Criteria for Assessing New Sites” (Appendix 13.9), provided by way of the FOM, to elaborate the agreed-upon procedure for visiting sites that haven’t been visited before to ensure activities have no more than a minor or transitory impact. Criteria include environmental and scientific considerations, visitor management considerations and safety considerations. These are considered in conjunction with the other guidelines that manage IAATO-member shore activities, e.g. ATCM Site Guidelines for Visitors, IAATO’s own Site Specific Guidelines (discussed above) and ATCM Resolution 3(2011). IAATO also recommends Expedition Leaders consult the Oceanites Antarctic Peninsula Compendium for any site to be visited that does not have ATCM or IAATO Site Guidelines attributed to them and to follow the suggested visitor management practices outlined in the Compendium to minimize impact. Consideration is also given to sites that are known to have crevasses. (IAATO has a reporting scheme in place.)

Protected Areas are known by Expedition Leaders and ship’s command, including ASPA’s, ASMA’s, HSM’s, Seal Reserves, CCAMLR Ecosystem Monitoring Research Sites (http://www.ats.aq/documents/ats/ccamlr_e.pdf), and sites where it is deemed inappropriate to visit (e.g. sites where there has been a recognizable change in the wildlife populations for an unknown reason, etc.). The FOM contains up-to-date information in this regard, including ASPA and ASMA Management Plans, along with a list of designated HSMs. Expedition Leaders and ship’s command are aware of the ATS website where additional information on Protected Areas can be found (http://www.ats.aq/e/ep_protected.htm).

15 SCAR, Report of Oceanites, Inc. (IP 81, XL ATCM, Beijing, 2017).

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Research sites will be avoided, although from past experience many of these sites are unmarked. Advice about the location of research sites will be sought from station managers and/or field researchers in the vicinity prior to a landing being made (if in the vicinity of these sites). IAATO also includes information in the FOM when received by the National Antarctic Program Managers.

Appropriate permissions will be obtained and applicable visitation guidelines followed if future operations include visits to the Falkland Islands (Las Malvinas) and South Georgia.

IAATO members work diligently to ensure that, as a matter of policy and practice, day-by-day itineraries are coordinated with other vessels in the field to ensure that no more than one ship is at one place at any one time to comply with ATCM Measure 15(2009), IAATO Bylaws and ATCM and IAATO Site Guidelines. As mentioned previously, this is a requirement of IAATO membership – and crucial for minimizing environmental impacts and potential conflicts and a key factor in self-regulation, monitoring of activities and also a proven emergency response.

Despite pre-planning by destination experts, the Expedition Leaders and Masters will make the final itinerary decisions in the field.

Itinerary changes include alternatives to the order, date and duration in places visited (or other activities occurring if not involving shore landings) rather than the choice of specific locality (this is discussed below). Changes to the proposed itineraries might be desirable should any of the following factors be present: • Other tourist vessels and/or small sailing vessels (e.g. yachts) in the vicinity that have plans (unknown to the Expedition Leader) to visit the site at the same time. • Prior knowledge of vessel or shore-based operations in support of scientific programs taking place at particular sites where tourist activities were hoped to take place. • Specific situations involving seasonal effects, e.g., a site that would be vulnerable to human presence (e.g. damage from foot traffic in exposed moss beds at certain times during the season), or situations involving animals whereby presence at certain times of the season should be minimized (e.g. birds on eggs) so as not to disrupt phases of their breeding cycle. • Limited or restricted landing area for the proposed activity that could result in disturbance to fauna or flora (e.g. a landing area too small to accommodate the planned number of people going ashore while maintaining a safe distance from animals). • Changes in weather conditions or situations where passenger safety could be compromised (e.g. conditions expected to deteriorate or adverse enough to prevent off-ship activities). • An inexperienced or difficult group of passengers (or a passenger) to control. • A significant likelihood of disturbing birds nesting or flora that cannot be avoided close to the landing site. • Presence of seals, especially fur seals that are too abundant to land without disturbance. • Discovery of a high-mortality event. • Presence of crevasses in areas where hikes were planned to take place (e.g. on snowfields).

Factors resulting in such decisions cannot be quantified or predicted in advance and, based on these factors, changes to proposed itineraries will occur – even on a daily basis.

As a member of IAATO, GCC coordinates their day-by-day itineraries with other member vessel operators in advance of the season via the IAATO Ship Scheduler. The Scheduler opens on a set date each year (usually in late June or early July) and remains open for a set period of time for any follow-up changes ahead of the season. The Scheduler is an important mechanism to ensure that member’s operations meet with requirements under IAATO Bylaws and ATCM Measure 15(2009), ATCM Resolution 3(2011) and ATCM Recommendation XVIII-1(1994), which require, among other things, that vessel operators coordinate with each other to ensure that no more than one tourist vessel is at a landing site at any time. The Scheduler is also set up to limit the number of landed visits per day in accordance with ATCM and IAATO Site Guidelines for Visitors for sites where the ATCM may not yet have adopted Site Guidelines. Through the Scheduler, site visits are allocated on a first-come first-served basis.

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This advance ship coordination has greatly simplified the work of the Expedition Leaders on board the vessels in having to coordinate with each other on the spot and has minimized overlapping schedules and is an important minimization and mitigation tool to reduce potential environmental impact.

Once the Scheduler has been closed ahead of the season (normally in early October of each year), the official pre- season schedules of the IAATO fleet are generated by the Secretariat and circulated to all IAATO member vessel and yacht operators. These pre-season schedules, along with other selected information, are circulated to MRCCs, the Secretariat of the Council of Managers of National Antarctic Programs (hereafter COMNAP) (https://www.comnap.aq) and selected others on the basis of a Memorandum of Understanding with IAATO.

Changes after the Scheduler closes are then the responsibility of the Expedition Leader to communicate to all other IAATO vessels and yachts operating in the vicinity to ensure others are aware of the change(s) to avoid any conflict in landing (to ensure no more than one vessel is a landing site at any one time). IAATO has developed a standard operating procedure for ensuring communication in this regard.

Itinerary management includes the appropriate crewing of the vessel as well as staffing of the Expedition Team who will be carrying out the landings and off-ship activities. In general terms, unless a lower number/ratio is called for, for example in any ATCM and/or IAATO Site Guidelines, the staffing will include 1 guide to every 20 passengers (unless Site Guidelines call for a lower ratio) to ensure appropriate supervision and guidance in the field. The staffing will include the hiring of appropriate guides with expertise of the area(s) being visited.

As standard operating procedures, the Expedition Leader is responsible for completing the end-of-trip reporting, via the ATCM-adopted two-part Post Visit Report (http://www.ats.aq/documents/recatt%5Catt074.pdf), to provide information on each landing, account for the activities and numbers involved, as well as to convey any information needed by the head office, including regards to any environmental disturbances noted, and to assist in planning for future seasons.

IAATO annually submits a report on member use of Antarctic Peninsula Landing Sites and ATCM Visitor Site Guidelines to the ATCMs. The Association’s report to ATCM XL was IP 16416. This report provided details on member operator activities at the various landing sites from the 2016-17 season as well as historical data back to the 1989-90 season. Additional tourism statistics can be found on the IAATO website (http://iaato.org/home). Many statistics are included annually in IAATO’s overview report also submitted annually at the ATCMs.

IAATO has developed an operational plan to guide the exchange of information amongst vessels, assist with the coordination of itineraries and to facilitate end-of-season reporting. The Secretariat provides a number of e-mail updates – known as “Seasonal Instructions” – ahead of the season to its Expedition Organizers for reference by their Expedition Leaders and Captains. In regards to itineraries, the Seasonal Instructions offer information and updates on a wide range of issues, including such things as procedures to facilitate the exchange of itineraries, changes to itineraries (e.g. if cancellations occur), ‘rules’ on landing site priority, information on new ATCM or IAATO Site Guidelines, protocol for station visits, use of Channel 16, IAATO radio schedule, radio log-on, vessel-to- vessel communication, SOLAS passenger vessel tracking, bio-security and decontamination procedures, emergency medical and evacuation response plan, post-visit reporting and end-of-season reports, as well as updates from the ATCMs or other meetings relating to tourism not previously communicated or included in the FOM.

Communications will be maintained with other vessels operating in the area to be visited to minimize the likelihood of itinerary conflicts. IAATO provides member operators with its “Vessel, Land-based and Emergency Contact Information” each season as part of the FOM for use by expedition leaders, ship’s command and radio officers in order that they have the various means of contacting the IAATO-operated yachts and vessels. GMDSS is

16 IAATO. Report on IAATO Operator Use of Antarctic Peninsula Landing Sites and ATCM Visitor Site Guidelines, 2016-17 Season (IP 164, XL ATCM, Beijing, 2017).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment the preferred method of communication between the ships, however all methods are used to ensure the information is received, including by fax, e-mail, telex and voice, if necessary.

4.2 Purpose and Value of Antarctic Tourism

The following has been developed by IAATO as a statement on the purpose and value of Antarctic tourism17:

Unique to the world, the whole continent of Antarctica remained unexplored and uninhabited until early in the 20th century. Antarctica's physical isolation, extreme climate and remarkable wilderness values are a great part of its attraction for tourism. Antarctic visitors experience the grandeur and solitude of the polar wilderness first-hand, while learning of the human dependency on technology and sophisticated knowledge necessary for survival in a remote and hostile environment. Few places offer similar opportunities to experience the thrill of discovery, an important element of any Antarctic voyage. Antarctica has drawn visitors on annual voyages since 1966.

Shipboard tourism provides a legitimate means, within the provisions of the Antarctic Treaty System and the Protocol on Environmental Protection to the Antarctic Treaty to meet the tourism demand without the need for permanent infrastructure and with limited residence time. The availability of small, specialized vessels well suited for polar environments provides an optimal means to meet the demand for Antarctic tourism in a safe and well-managed way. Ship- based tourism is the preferred touring method for environmentally sensitive areas such as Svalbard, the Galápagos, Baja California, the Canadian Archipelago, and remote Arctic environs. This mode of travel in the Antarctic region is the best-suited way in which impacts to the environment can be minimized.

Education is an important component of any Antarctic expedition. Shipboard visitation in Antarctica provides an opportunity for visitors to experience a wide range of areas of interest, including wildlife sites, historic sites, unique vistas, and active research stations. Wildlife can be observed in its natural state. At research stations and field camps, tourists can meet scientists and learn about the research.

Antarctic tour operators coordinate with and support scientific communities, providing logistic and scientific support to national Antarctic programs and Antarctic organizations. Each season Antarctic tour vessels transport scientists and support personnel to or from their research stations or field camps. Antarctic tour operators also make direct financial contributions to scientific, environmental, and conservation efforts and the Antarctic travelers benefit from the exposure to science on board tour vessels with minimal disruption to tour schedules.

Providing a first-hand Antarctic experience to tourists educates them to the ecological sensitivity of the Antarctic environment and promotes a greater understanding of the earth’s resources and the important role of Antarctica in the global environment. Controlled visitation by well informed, well prepared travelers in small groups, led by experts in the field, helps ensure ecologically sustainable activities and the continued protection of Antarctica as well as support for science.

4.3 Location and Duration

Tourism to the Antarctic Peninsula region has an over 50-year history with regularly occurring voyages having been conducted there since 1966. The overwhelming majority of visits to the Antarctic Peninsula region have taken

17 IAATO. Initial Environmental Evaluation Antarctic Cruise Program, Ship-Based Tourism to the Antarctic Peninsula, South Shetland Islands and South Orkney Islands, November 2002 – March 2007, Multi-Year Document. (Submitted to US EPA.)

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment place by ship. To date, over 367 sites have experienced tourist visits. A list of bays, channels and landing sites (excluding research stations) as reported by IAATO member operators to IAATO and NSF since 1989 through the end of the previous austral summer season is attached as Appendix 13.8.

The proposed activity as defined by this assessment involves voyages to the Antarctic Peninsula region during the austral summer season months of December through March, which coincides when the area is predictably ice-free in its coastal zones.

For the 2017-18 season eight ten-day voyages are planned. The Itineraries may be found in Attachment 2 to Advance Notification (Appendix 13.1). Details on planned activities for subsequent seasons will be relayed via subsequent annual updates.

The voyages can be found in company marketing materials at: https://www.gct.com/trips/small-ship-cruise-tours/antarctica/antarcticas-white-wilderness/2017 https://www.gct.com/trips/small-ship-cruise-tours/antarctica/antarctic-circle-expedition-journey-through- antarctica/2018

The region to be visited includes the South Shetland Islands and Antarctic Peninsula north of 67°34'S. A sketch map of the proposed area of operation is included in Section 10.

The geographic scope of the proposed activities can be roughly divided into the following seven sub-regions18: 1. South Orkneys Region including Laurie, Coronation, and Signy Islands 2. Elephant Island Region including nearby islands 3. South Shetland Islands Region including Deception, Low and Smith Islands 4. Northeastern Region from Saxum Nunatak (63°17'S, 56°03’W) south to Snow Hill Island (64°47'S, 57°20’W) 5. Northwestern Region from Gourdin Island (63°20'S, 57°30’W) south to Lindblad Cove (63°85'S, 59°45’W) 6. Central Western Region from Mikkelsen Harbour (63°90'S, 60°78’W) south to the Berthelot Islands (65°33'S, 64°13’W) 7. Southwestern Region from Martin Islands South (65°69'S, 65°33’W) south to Red Rock Ridge (68°30'S, 67°13’W)

Shore visits tend to occur at variable intervals and frequencies, depending upon the schedules of other ships. Additional factors include management recommendations, weather, ice conditions and other factors.

Landings and shore activities (ref. Section 4.5) are conducted with no more than 100 passengers at any one time at any one site and with a minimum of one guide to every 20 passengers to meet with obligations under ATCM Measure 15(2009), ATCM and IAATO Site Guidelines and IAATO Bylaws requirements unless Site Guidelines call for a lower number.

Weather and ice permitting, GCC plans to conduct up to two landings/activities per day. Schedules remain flexible and it is not uncommon to have landings that are conducted during meal times. All landings are executed in accordance with the times allowed by the ATCM Site Guidelines for Visitors for each landing site. In general, landings are approximately four hours from start to finish, inclusive of scouting. Zodiac cruises generally never last longer than two sessions of 90 minutes (longest) or as short as two sessions of 45 minutes, depending upon the site. At some sites, it is not uncommon for the Expedition Leader to operate a landing site visit as well as a Zodiac tour at the same time.

18 Ron Naveen, The Oceanites Site Guide to the Antarctic Peninsula (Washington, DC: Alan Abrams Associates, 1997).

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Each year, IAATO submits information to the ATCPs via an Information Paper presenting details in its Overview of Antarctic Tourism. The reports include statistical information on the season just concluded as well as preliminary estimates for the upcoming season. IAATO’s paper to ATCM XL was IP 163 rev.119. The submission includes information on IAATO member activities including the scope of commercial tourist activities for seaborne, yacht, land, air/land and air operations (including over flights); tourism trends and tourism statistics. (Ref. also Section 4.2 for information on other papers presented by IAATO.)

4.4 Small Boat Activities and Cruising

The vessel carries a fleet of Zodiac auxiliary craft, the details of which were included in Section 3.3.

Off-vessel activities include touring by Zodiac to experience cruising in and around ice, in scenic areas, in places with historic significance, and in areas where marine life can be observed from a respectful distance. Off-vessel activities also include landing and shore activities (ref. Section 4.5) and if conditions permit, possibly landing passengers onto ice from the Zodiacs (details on this are noted below). Small boat activities will vary during each voyage. The Expedition Leader, naturalists and lecturers accompany passengers while in the Zodiacs to interpret on the flora and fauna, as well as to convey information on other topics of particular interest (e.g. historic features, geology, sites of historic interest, etc.) and to ensure there is no environmental impact or disturbance.

Zodiac craft will be launched by crane, according to the prevailing conditions. An experienced mechanic is on hand for servicing the engines. Drivers are experienced individuals from the Expedition Team, however crew (from the deck department primarily) may also be utilized on occasion, e.g. for shuttling purposes.

Zodiac drivers and ship’s command strictly adhere to IAATO’s Wildlife Watching Guidelines (ref. Section 3.4.8), and the company’s Zodiac Operation Manual (presently being finalized), which outline specifics for operating inflatable boats in Antarctic waters (and other areas where the company operates). Zodiac drivers are also briefed on IAATO’s Guidelines for Small Boat Operations in the Vicinity of Ice (ref. Appendix 13.10) and the IMO/Marine Safety Committee (hereafter MSC) Guide for Cold Water Survival for safety purposes (http://www.ics- shipping.org/docs/default-source/refugee-migrant-rescue/imo-guide-for-cold-water-survival-msc-1-circ-1185-rev- 1.pdf?sfvrsn=2). The purpose of the IMO/MSC guide is to examine the hazards of cold exposure that may endanger life and provide advice on how to prevent or minimize these dangers.

Should wildlife such as whales or seals be observed, the ship might slow down or drift to provide opportunity for quality observation. Great care will be taken by ship’s command and the Expedition Team to ensure that this wildlife viewing is done in an appropriate manner and in accordance with IAATO’s Wildlife Watching Guidelines (ref. Section 3.4.8). The guidelines aim to provide guidance while viewing cetaceans, seals and birds in their marine environment. These guidelines minimize potential environmental impacts to wildlife and suggest ways to comply with Annex II (Conservation of Antarctic Fauna and Flora) of the Environmental Protocol. They do not replace national laws and regulations but provide an additional “code of conduct” to help reduce potential disturbance. The guidelines apply to members operating any type of vessel, including ships and Zodiacs.

Section 3.4.8 also provides further information about measures to avoid harmful interference with biota from the Zodiac operations.

In case conditions do not allow for landings on shore (ref. Section 4.5), the Expedition Leader may opt to have a back-up plan of landing passengers onto the ice (e.g. a solid piece of fast ice or a large enough ice floe) from the Zodiacs, if conditions are suitable. The ice would have to be solid enough, meaning it would have to be a couple of feet solid – not rotten sea ice -- and would need to be checked out with experienced staff who would test out the ice stability by scouting it first, then landing on it. Only flat pieces of sold sea ice would be attempted – not

19 International Association of Antarctica Tour Operators, IAATO Overview of Antarctic Tourism: 2016-17 Season and Preliminary Estimates for 2017-18 Season (IP 163 rev.1, XL ATCM, Beijing, 2017).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment icebergs or bergy bits – even if they are grounded. If the scout determines that the ice is solid enough to disembark passengers, the activity would commence, with small groups being brought onto the ice, and the passengers being rotating. The number of passengers on the ice each time would depend upon the ice quality, but a maximum of three Zodiac loads at a time (ten people per Zodiac) would be allowed. This might be reduced to one or two boat loads only depending upon the size and quality of the ice. Passengers would have time to take photographs. They would be kept to the area that was scouted and Zodiacs would remain on standby to retrieve guests quickly in the event of an emergency. Time on the ice would be kept short, e.g. 5-10 minutes for each group.

4.5 Landings and Shore Activities

Activities include shore landings at sites featuring flora and/or fauna or areas of unique geology or striking scenery; pre-arranged visits to scientific research stations; sites of historic interest and sites where supervised unguided walks within pre-determined areas (where supervision is offered), or longer guided hikes where permitted can occur for physical activity and to appreciate the scenery and wildlife of a given area. (Longer guided hikes, if offered, are for more experienced walkers and are always guided by an experienced expedition staff member.) A Polar Plunge, on a conditional basis each trip, will be offered if the conditions are suitable at Whalers Bay, Deception Island. (Details follow.) Fishing, hunting, and other sporting activities that might adversely impact wildlife or the environment are prohibited.

Shore landings and off-ship activities take place in strict accordance with ATCM Recommendation XVIII-1(1994); ATCM Resolution 3(2011), the Environmental Protocol and its Annexes II and V; any other specific applicable regulations, such as ATCM-adopted Site Guidelines for Visitors, Management Plans of any ASMAs that may be visited, details in regards to any HSMs being visited, station guidelines, as well as standard operating procedures and guidelines of IAATO.

The Expedition Leader will obtain advance permission for visits to scientific research stations. Some stations also have guidelines in place for tourist visits; others have visit procedures embedded in the ASMA Management Plans. In the absence of these IAATO has developed Standard Procedures for Station Visits (Appendix 13.11) to provide advice in this regard. These procedures will be strictly followed. Contact information for stations is provided by IAATO by means of the FOM. The Expedition Leader will adhere to the 72-hour prior notification of any visit to scientific stations and reconfirm with the station manager again 24 hours prior to a planned visit. Should the vessel not be able to make a scheduled landing, the Expedition Leader will relay the cancellation to the station manager at the earliest possible opportunity. Strict adherence to these operating procedures minimizes the impact on station personnel and scientific research being conducted.

Prior to the commencement of each shore landing, passengers will be briefed on board the vessel by the Expedition Leader (either during a recap and briefing session normally held the night before or over the public- address system prior to the landing) as to the details about the landing, any protected areas that must be avoided or respected as well as a reminder about maintaining appropriate distance from wildlife and flora, including mosses, lichens, etc. The briefings are augmented by ATCM Site Guidelines for Visitors (including any maps), digital photography and, sometimes, video footage to further explain highlights, restrictions and landing conditions.

Prior to passengers going ashore, the Expedition Leader and the Expedition Team, including Zodiac drivers, make a reconnaissance of the area of operation, including Zodiac areas of operation, as well as the landing sites with the specific purpose of evaluating environmental and safety conditions. If conditions are not suited to the activity the activity may be delayed, until the conditions improve, or cancelled and another site/activity considered instead. The Expedition Leader and the Expedition Team are responsible for checking the landing site before passengers come ashore. In most instances the ship will be a short distance away; however, this depends entirely upon the local conditions and other factors, such as familiarity of the landing site/anchorage to the Master and/or Bridge Officers. Factors such as wind, swell, presence of ice (if applicable), etc., can affect the time it will take for the Zodiacs to be loaded and get to shore and also whether or not it is safe to proceed with the activity.

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Naturalists and lecturers accompany passengers while in the Zodiacs and during shore landings to interpret on the flora and fauna, as well as to convey information on other topics of particular interest (e.g. historic sites, geology, protected areas, etc.), provide assistance and supervision, and ensure there is no environmental impact or disturbance.

Passengers are briefed upon arrival to shore and their activities ashore also monitored throughout the landing by the Expedition Team who will be on shore to supervise the landing. Any crew who will be ashore to assist with the landing or for recreational purposes will also be briefed and their activities on shore monitored. Crew when going ashore must join an escorted group and cannot walk around on their own, unless it is permitted within the Site Guidelines. All crew receive the IAATO briefing as part of their training (same as passengers).

When visits are made to research stations, passengers are briefed on station etiquette and the rules to observe so as not to disrupt on-going science and to ensure the visit has minimal impact on the base personnel as well as adherence to any station guidelines that may be in effect.

For Polar Plunges, with exceptions due to weather or scheduling, the Expedition Leader plans to offer this activity at Whalers Bay, Deception Island where the ATCM has established Site Guidelines for Visitors and a Visitor Management Plan, including Visitor Codes of Conduct, under ASMA No. 4 (http://www.ats.aq/devPH/apa/ep_protected.aspx?lang=e). As Deception is an active volcano, here one often finds thermally heated water which, when mixed with the seawater, provides an opportunity for quick ‘dip’ in Antarctic waters. In terms of procedures, passengers are briefed the previous evening regarding what to expect and how the activity will be organized; a head count is taken to organize the Expedition Team and arrange for beach towels. Mention is also made in the Daily Program, accompanied with instructions on how to prepare for the activity. There is always a disclaimer reminding passengers that all activities are subject to change or cancellation depending on prevailing conditions during the course of the activity. Additional wording with some variation is that: "the water may be very hot at the surface and near the edge of the beach, but as soon as they enter deeper into the water the temperature will drop to 2 to 4 degrees Celsius". Participants are advised they must protect their feet with thick socks or shoes they do not mind getting wet. A bathing costume is suggested. Participants should also have a friend that can look after their belongings on the beach in case the wind is strong and also to help them dry out after they finish the plunge. Passengers are instructed that the Polar Plunge consists of getting quickly into the water and back to shore where towels are provided and that they will have priority for the embarkation back into the Zodiacs to return to the ship. (Usually the ship is a very short distance away.) The briefing includes pictures of passengers in previous years as this helps compose the picture and set, as much as possible, the correct expectation. The Expedition Leader and/or the Assistant Expedition Leader delimit an area with markers (green PVC poles that we are also used to mark boundaries and operations areas on the other landings), as an area for participants to enter the water. This plunging zone is set away from the Zodiac landing area. Throughout the activity, as with all off-ship activities, weather, including sea and ice conditions, will be monitored. The shore team supervising the activity will watch for marine mammals, for example, orcas and/or leopard seals. (It is rare, due to the seawater temperature within the caldera, to see marine mammals.) Should the weather deteriorate or orcas or leopard seals be observed, the activity will be cancelled. As with the other shore landings, the ship’s doctor is on standby and has the right to refuse participation to anyone he/she feels might be unsuited to the activity; the same biosecurity measures apply; as does supervision throughout by the Expedition Team. Per IAATO standard operating procedure for this activity, ‘pits’ will not be dug by the Expedition Team to accumulate hot water nor will participants be allowed to dig them. The activity is run in and out of the cold polar waters.

At the conclusion of each voyage, and within 30 days, the Expedition Leader will compile the ATCM-adopted PVR Form (http://www.ats.aq/documents/recatt%5Catt074_e.pdf) to report on the activity in accordance with ATCM Recommendation XVIII-1(1994) and ATCM Resolution 6(2005). The PVR, updated in 2006 under ATCM Resolution 6, consists of two parts: 1) Expedition Record and 2) Site Visit Record. Once compiled, the Expedition Leader files the report with the home office. The home office then forwards the report on to the Competent Authority (US NSF) and to the IAATO Secretariat who will add this information to reports received from other member vessel operators to enable compilation of the statistical data on tourism activities from the season.

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The Expedition Leader and Deck Staff (e.g. Able-bodied Seamen) are responsible for ensuring that everyone going ashore (passengers, the Expedition Team and/or crew) makes use of the boot-washing stations before and after each landing along with arranging for a visual check of clothing and gear for any exotic organisms in order to avoid possible translocation of diseases and/or the introduction of alien species (e.g. alien species, soils or microbes, etc.). The prevention of introduction of non-native species is a particular concern of IAATO members to avoid significant impacts on the local biota. Boot washing stations, using a disinfecting (biocide) agent such as Virkon®S- brand or other, for example Virox5, are standard on IAATO-member operated vessels. IAATO’s Boot, Clothing and Equipment Decontamination Guidelines for Small Boat Operations are outlined in Appendix 13.11.

IAATO member vessel operators have also agreed to provide passengers with an Antarctic Pre-arrival Biosecurity Declaration (ref. Appendix 13.13). This form, included as part of the Boot, Clothing and Equipment Decontamination Guidelines for Small Boat Operations (referenced above), is made available by the Expedition Leader following his/her initial briefing and acknowledges that all those going ashore, by signing, have thoroughly cleaned all items that will come into contact with the ground ashore, removed any material (e.g. seeds, grasses or other loose items, etc.) from clothing and gear to be taken ashore (e.g. rucksacks, camera bags, etc.) and washed all footwear to be worn ashore, as well as snowshoes, tripod/monopod feet, the tips of walking sticks and ski poles, etc. The declaration also provides for passengers to agree neither to take any food with them ashore nor to dispose of any waste (either on shore or overboard from the ship or Zodiacs). Decontamination protocols continue throughout the voyage to ensure that clothing and gear is inspected and disinfected prior to each and every shore landing. (Ref. also to Section 7.5.)

All passengers and members of the Expedition Team receive copies of the “Don’t Pack a Pest” leaflet (http://iaato.org/dont-pack-a-pest) and ATCM Resolution 3 (2011) “General Guidelines for Visitors to the Antarctic” prior to their voyage in their pre-tour documentation as per IAATO requirements. Crew are briefed on the initiative during their on board briefing by the Expedition Leader.

The Committee for Environmental Protection’s (hereafter CEP) “Non-native Species Manual” (May, 2011), (http://www.ats.aq/documents/atcm34/ww/atcm34_ww004_e.pdf), adopted under ATCM Resolution 6(2011), is particularly useful for providing guidelines and resources to support the prevention of accidental or unintentional introduction of non-native species, including the transfer of species between sites in the Antarctic and to assist operators in meeting their obligations under Annex II of the Environmental Protocol. The key guiding principles include Prevention (Awareness and Operational Procedures), Monitoring and Response. IAATO Members developed their own guidelines, “IAATO Guidelines for the Discovery of Non-native Species,” as noted in Appendix 13.14.

To avoid the likelihood of harmful interference or any impacts on flora, fauna, and geologic features that could create more than a minor or transitory impact, tourist visits are carried out in strict accordance with ATCM Recommendation XVIII-1(1994), ATCM Resolution 3(2011), Annex II of the Environmental Protocol, relevant national laws and regulations, as well as IAATO’s established guidelines and standard operating procedures. The Expedition Leader is responsible for ensuring that time ashore is managed according to ATCM Site Guidelines for Visitors and/or IAATO’s Site Specific Guidelines (for sites not covered under ATCM Site Guidelines) and practical experience. Additional considerations, such as weather, safety, environment and ability to manage the group, are also considered. An approach such as this provides for a flexible approach towards visitor management and enables the Expedition Organizer and the Expedition Leader to implement new site management techniques as developed.

In absence of empirical evidence or scientific data proposing a rationale for a particular approach to visitor management, Expedition Leaders make decisions on visitor activities on a precautionary basis. An important factor to take into consideration when deciding upon shore activities is the ability of the particular group of passengers in regards to following instructions and behaving themselves ashore. Passengers face a steep learning curve during the course of a voyage as skill needs to be gained in negotiating getting into and out of the Zodiacs, in conducting themselves ashore and around wildlife and avoiding flora such as moss beds and lichens. Factors such as having an

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment experienced expedition staff team to educate passengers, and conduct and oversee shore activities, as well as the educational nature of the voyage and high incidence of repeat passengers helps to ensure that Antarctic visitors are predisposed to protecting the environment and enable each landing to be conducted in compliance with management decisions of the Expedition Leader.

Behavior on shore -- and especially around fauna and flora -- is an integral part of the Expedition Leader’s briefings. Desired behavior is reiterated throughout the voyage – in the recap and briefing sessions, during public address announcements made prior to passengers going ashore and as the Zodiacs arrive at the shoreline and the Expedition Leader reminds everyone of the “do’s” and “don’ts” for the landing. Although passengers are fully briefed on their legal obligations under the Antarctic Treaty, Environmental Protocol and national laws and regulations, operating procedures are in place to deal with potential situations whereby a passenger is unruly or disruptive in his/her behavior. Should a situation occur that warrants swift corrective action but meets with resistance from the passenger, the Expedition Leader is empowered to immediately remove an offending passenger from shore. The Captain may also prohibit the individual from going ashore on a future landing.

In most instances the ship will be a short distance away from the landing sites; however, this depends entirely upon the local conditions and other factors, such as familiarity of the landing site/anchorage to the Captain, Ice Pilot (if applicable) and/or Bridge Officers. Factors such as wind, swell, presence of ice, etc. can affect the time it will take for the Zodiacs to be loaded and to get to shore. Usually transfers are less than 30 minutes in duration.

Upon arrival to the landing site, the Expedition Leader, or another Expedition Team member, then briefs each boatload on the final points of the landing. Points covered include what activities are being offered (e.g. guided walks, hikes, bird-watching, the opportunity to view historic sites and/or relics, station visits, etc.). A reiteration of behavior around flora and fauna, the length of time ashore, areas to be avoided, etc., is also given. Expedition Team members serving as guides are positioned in the nearby vicinity to offer supervision, interpretation, guidance, to ensure safety to the participants and to also be on the lookout for behavior that needs correcting or to pick up any litter (e.g. Kleenex) that might inadvertently be left ashore. Areas that are off-limits or closed for safety or other purposes are pointed out (such as protected areas or areas where scientific research may be on- going); members of the Expedition Team are positioned at key points to ensure entry is not made.

Once on shore, passengers observe and photograph wildlife and landscape, appreciate the scenic attractions and take advantage of other opportunities and site highlights. Passengers will observe but not enter any man-made structures, whether occupied or not, unless specifically invited to do so by an authorized person. Passengers are advised to always remain within sight of a member of the Expedition Team. Zodiacs, whenever possible, are on standby for when passengers would like to return to the vessel prior to the end of the landing.

In practice, activity is concentrated in the immediate vicinity of the landing area; most passengers remain ashore for the maximum amount of time. Zodiacs cruises around ice floes, along coastal cliffs, or to other areas of interest in the nearby vicinity, are often offered in conjunction with landings.

The Expedition Team will remain ashore for the duration of the landing to oversee the operation.

The assessment of likely impacts, and minimization and mitigation methods, is made in Section 6. A matrix is presented in Table 3 (ref. Appendix 13.15).

4.6 Education and Training of Passengers, Crew and Expedition Team

The itinerary and the program in general have been designed to meet ATCM obligations under ATCM Resolution 3(2011), ATCM Recommendation XVIII-1(1994) “Guidance for Visitors to the Antarctic” and to meet obligations under ATS measures applicable to tourism noting especially ATCM Resolution 7(2009) to ensure the program has a “focus on the enrichment and education of visitors about the Antarctic environment and its protection.”

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The program is therefore a mix of on board and off-ship activities with the goal being to provide passengers with the best and most well-rounded educational experience possible.

A significant portion of each expedition is spent “at sea.” During this time various activities take place.

On board activities are comprised of a mixture of educational presentations imparted by an experienced team of lecturers with specialist knowledge of the Antarctic or during briefings given by the Expedition Leader. Information is also imparted while cruising in scenic or historic areas of interest and during whale, seabird and other wildlife observation from the outer decks of the ship (with interpretation imparted by the ship’s naturalists either over the ship’s public-address system to the outer decks or on a more informal basis to those wildlife watching nearby to the naturalist). The lecture team imparts information through an informal series of enrichment presentations covering topics, which may include topics such as history and politics (including the Antarctic Treaty System and related measures, geo-politics, and the history of Antarctic exploration); geography; natural history-related topics (including ornithology, marine biology, Antarctic conservation, geology, glaciology, ozone, science in Antarctica, etc.). In addition, the team also includes individuals that are referred to as general naturalists who, while not necessarily giving formal lecture presentations, share their knowledge of natural history-related topics (ornithology, marine ecology, marine mammals, etc.) while with passengers on deck, in the Zodiacs, and on shore.

Lecturers and other members of the Expedition Team are encouraged to spend time with passengers during meal times and at other times while in the public areas of the ship when they have free time to informally share their knowledge, experience and love of the Antarctic. The goal of the Expedition Team is to introduce Antarctica to the passengers in order to have them return home as “Antarctic Ambassadors” – knowledgeable champions of environmental protection of the continent.

In addition to the education program and expedition briefings (see below), passengers will be briefed on general ship operations, fire and abandon ship drills, and all conservation requirements. A mandatory lifeboat and safety muster takes place prior to departure from port at the start of the voyage or shortly after the ship has sailed.

Prior to the ship’s arrival to the ATA, the Expedition Leader is responsible for briefing passengers, crew and the Expedition Team to obligations under the Environmental Protocol and measures under the Antarctic Treaty System as well as obligations under ATCM Recommendation XVIII-1(1994) “Guidance for Visitors to the Antarctic,” ATCM Resolution 3(2011) (see also below) and applicable IAATO guidelines and standard operating procedures. Crew are also briefed on ATCM Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Tourism and Non-Governmental Activities in the Antarctic.” Attendees sign a list to prove they attended the briefings. Those who are not in attendance will be briefed at the first possibly opportunity. All passengers, Expedition Team members and crew will also receive a copy of the environmental-focused “General Guidelines for Visitors to the Antarctic” adopted by means of ATCM Resolution 3(2011). Passengers and members of the Expedition Team receive this with their pre-tour preparatory documentation along with the “Don’t Pack a Pest to Antarctica” document (http://iaato.org/dont-pack-a-pest); crew are briefed on the initiative on board.

The Expedition Leader’s mandatory briefing includes the presentation of an IAATO-developed PowerPoint presentation which details the operator’s and the individual’s legal obligations and provides general examples of appropriate behavior ashore and around wildlife, safety procedures, use of the Zodiacs, and recommended dress. If passengers and crew do not attend, they will not be allowed to go ashore while in Antarctica. During the IAATO briefing, passengers and crew are also educated on wildlife etiquette, safety ashore, etc., as well as on IAATO’s Biosecurity measures. Passengers have to undergo a Biosecurity check and sign the declaration (ref. Appendix 13.13).

Recognizing that in Antarctica the weather conditions can change rapidly, to safely take part in off-ship activities passengers are advised by way of a briefing that they must be appropriately dressed. Recommended clothing to be worn while riding in the Zodiacs and during the shore landings has been provided by way of a Packing List with pre- tour preparatory documentation. Information on dress is reiterated during the Expedition Leader’s initial briefing and as necessary during the voyage. As a backup, as passengers assemble to disembark the ship for off-ship

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment activities personnel at the gangway visually check them; anyone found not to be dressed properly is sent back to redress and return to the disembarkation area.

Prior to the commencement of each shore landing, passengers will be briefed by the Expedition Leader (either during a recap and briefing session normally held the night before or over the public-address system prior to the landing) as to the details about the landing, including information as to any protected areas that must be avoided as well as a reminder about maintaining the appropriate distance from flora and fauna. When visits are made to research stations, passengers are briefed on station etiquette, e.g. the rules to observe so as not to disrupt on- going science and to ensure the visit has minimal impact on the base personnel as well as to any station guidelines that may be in effect. When announcements are made to commence a landing, weather information is relayed and a reminder as to dress, e.g. dressing in layers, etc., is given.

The Expedition Organizer will employ an experienced Expedition Leader and Expedition Team to assist in the preparation and management of each cruise and associated activities, which includes the education and training of passengers and crew (including site supervision, guidance and the sharing of information). Key is ensuring that visitors are supervised by a sufficient number of guides, at a minimum ratio of 1:20 (unless a lower number is called for in any Site Guidelines), with Expedition Team guides who have adequate experience and training in Antarctic conditions and knowledge of ATS and IAATO requirements. This complies with requirements under ATCM Measure 15(2009) and ATCM Measure 4(2004), which recommend, among other things that “participants have sufficient and demonstrable experience appropriate for the proposed activity operating in polar, or equivalent, environments.”

Obligations under the ATS are communicated to the officers, the expedition staff and crew in a variety of ways and detailed in Section 4.5.2. In addition to the mandatory briefing described above (mandatory to all crew and Expedition Team members), department heads are responsible for communicating with their personnel information on obligations under the ATS, applicable national laws and regulations and IAATO guidelines and standard operating procedures as applicable to their area(s) of operation.

The Expedition Leader has taken and passed the Expedition Leader version of the IAATO Online Field Staff Assessment for Antarctica20. GCC also requires the other members of the Expedition Team to complete the IAATO Field Staff Online Assessment for Peninsula Guides. Unless staff have completed, and passed, the appropriate assessment the Expedition Organizer will not issue their flight tickets to join the ship. The aim of these assessments is to assist the Expedition Team with pre-season training. The assessment is comprised of five sections covering regulations and management, operational practices, environmental mitigation practices, area protection and general knowledge. By passing the assessment, certificate holders demonstrate a detailed understanding of the obligations inherent in the Antarctic Treaty, the Environmental Protocol and IAATO Best Practice Standards and Guidelines and show commitment to work towards ensuring safe and environmentally responsible private sector travel to the Antarctic in line with the IAATO Mission Statement.

The Expedition Leader is responsible for coordinating and overseeing all aspects of the shore landings. Passengers are briefed prior to leaving the ship, upon arrival to shore and their activities ashore also monitored throughout the landing by the Expedition Team who will be on shore to supervise the landing. Any crew who will be ashore to assist with the landing or for recreational purposes will also be briefed and their activities on shore monitored. Crew when going ashore must join an escorted group and cannot walk around on their own, unless it is permitted within the Site Guidelines. As noted above, all crew receive the IAATO and Zodiac briefing as part of their training (same as passengers).

The Expedition Leader and the Captains have been briefed on designated Antarctic Protected Areas (including ASPAs, ASMAs and HSMs) and, as mentioned previously, an updated list of these areas is included in the FOM. Strict adherence will be given to the appropriate management plans for these protected areas. Historic Sites and Monuments will be respected. The Expedition Organizer will not be requesting any permits to visit ASPA’s as there

20 IAATO. IAATO Online Field Staff Assessment & Logbook (IP 25, XXXIII ATCM, Punta del Este, 2010).

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment is no compelling scientific reason or legitimate need to do so. Visits to ASMAs will be conducted in line with the requirements under the applicable Management Plans. The shore team will be briefed by the Expedition Leader to ensure they are fully conversant with and adhere to the advice provided.

Documentary videos on Antarctica are available. The vessel also has a small library on board, stocked with Antarctic books on a variety of topics, as well as having copies of documents of the ATS and national laws and regulations available for reference by the passengers and members of the expedition team.

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5. ALTERNATIVES TO THE PROPOSED ACTIVITY

Six alternatives to the proposed activity are considered, including: 1) Changes to itinerary, 2) Changes to sites visited, 3) Changes to number of passengers, 4) Changes to vessel used, 5) Changes to Zodiac usage, and 6) Not proceeding with the cruise program.

Likely environmental impacts, assessment, minimization and mitigation of proposed activities are addressed in Section 6.

5.1 Changes to Itinerary

Itinerary changes include alternatives to the order, date and duration in the places visited or other activities occurring (if not involving shore landings) rather than the choice of specific locality (this is discussed below).

Prior to the commencement of the planned activities, detailed pre-season planning will have been undertaken taking into account knowledge – where known – of any planned voyages by other tourist and/or governmental or non-governmental vessel operators, research programs in the vicinity of the proposed activity and a determination of the seasonality of the planned site visits. Adjustments to the proposed schedule continue to be made during the course of each voyage and changes made as appropriate.

This alternative of changing the stated planned itinerary is deemed to not be warranted and would have no significant benefit.

5.2 Changes to Sites Visited

Expedition cruising to the Antarctic Peninsula has occurred since the mid-1960s and is considered to be legitimate activity under the Antarctic Treaty, Environmental Protocol and US law.

Company policy is to develop an itinerary based against pre-determined criteria that provide passengers with a well-rounded experience while at the same time meeting legal obligations under international and national laws and regulations, guidelines and standard operating procedures. Environmental, safety and educational considerations are all taken into account.

Should the need arise, alternative sites for shore landings will be considered, provided these alternative sites meet with the company’s criteria and can be carried out in a manner that will have no more than a minor or transitory impact on the environment and its dependent and associated ecosystems.

Because of the alternative number of sites available for landing activities, the parameters of the IAATO Ship Scheduler, the well-developed communication policy to assist Expedition Leaders with coordinating itineraries, and IAATO and the company’s standard operating procedures and guidelines, there is no basis for considering other changes to sites visited.

On this basis, there is no justifiable basis for considering other changes to sites visited.

5.3 Changes to Number of Passengers

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A reduction in the total number of passengers might reduce the absolute level of any impact, however, against this are weighed the factors of acceptable cost for passengers and financial return for GCC, as well as the carrying capacity of the vessel.

At present, ships conducting shore landings with tourists in Antarctica vary in carrying capacity from 35 to 500 passengers. Carrying a maximum of 100 passengers, the MV CORINTHIAN fits in the small end of this range. This enables the Expedition Organizer to comply with the aim of not compromising environmental concerns and quality of passenger experience for economic returns. Limiting to not more than 100 passengers ashore and with a guide- to-passenger ratio of 1:20 also meets with requirements under IAATO’s Bylaws, guidelines and standard operating procedures, and ensures compliance with ATCM Measure 15(2009).

Work permitting, crew ashore for leisure activities are only allowed provided the visitor ashore number never exceeds 100; if this were to happen additional crew will not be allowed ashore until others have returned from shore. Rarely do crew go ashore as most are busy with their work duties, but, on occasion, a few do choose to go ashore for a short amount of time. As discussed previously, crew who do go ashore (for leisure purposes or to assist with the landings) are briefed, same as passengers, and their activities ashore also closely monitored by the Expedition Leader and the expedition team.

Under these circumstances a change in overall passenger numbers is therefore not considered necessary to minimize potential environmental impact.

5.4 Changes to Vessel Used

Company policy is to operate an appropriate vessel -- one designed specifically for expedition cruising to the Polar Regions -- with experienced officers, crew and expedition team. A different vessel could be utilized but this could result in a vessel with a lower ice classification which would be more likely to encounter greater difficulties working the itineraries, and would also be more likely to require assistance should an emergency occur. Should a vessel of lesser qualification require assistance, a greater impact would result by having a second vessel in the vicinity rendering assistance. Additionally, an alternative vessel could result in a master, Bridge officers and/or crew with less Antarctic experience.

Due to the limited numbers of equally suitable ice-strengthened vessels, and contractual obligations, it is not feasible to make a change in vessel as decisions such as these require lengthy advance-planning and decisions such as this cannot be made quickly or immediately. Considering the commercial/economic case for the proposed activity of a small expedition ship operating with not more than 100 passengers, there is no rationale for considering an alternative vessel.

5.5 Changes to Zodiac Usage

There are alternative motorized craft that could be utilized for shore landings and scenic and wildlife cruising however there would be no differences in the potential impacts resulting from this change. Zodiac-brand inflatable boats outfitted with outboard engines have been the standard means of transporting passengers to and from shore of tourist operations since the mid-1960s when expedition cruising began and have proven to be the safest and most reliable means of transportation. The vessel is also utilizing four-stroke engines, which are presently the most environmentally-friendly engines available. Therefore, there is no basis for making any changes.

5.6 Alternative of Not Proceeding with the Cruise Program

The alternative of not proceeding with the cruise program is the only alternative that could remove all potential risks of environmental impact. Considering that there is national and international acceptance as to the legitimacy of Antarctic cruising and, provided that reasonable environmental standards have been considered and assessed to minimize the objective environmental risk, this alternative does not appear to be justified.

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The activities as proposed will be carried out in accordance with the provisions of the Environmental Protocol and its Annexes; the suite of applicable tourism-related ATCM Measures, Resolutions and earlier Recommendations; applicable marine regulations (MARPOL, SOLAS, ISM); national laws and regulations; and applicable IAATO guidelines and standard operating procedures.

These measures, taken together, will provide the basis for ensuring that impacts from these activities, if any, will be no more than minor or transitory. As a vessel and tour operator, any decision to cancel the planned series of cruises for anything less than the most compelling environmental reason would be contrary to its purpose, which is to operate tourist cruises to Antarctica.

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6. LIKELY IMPACTS, ASSESSMENT, MINIMIZATION AND MITIGATION OF PROPOSED ACTIVITIES

6.1 Affected Environment

The following description is included for background21:

Antarctica is composed of two major, geologically distinct parts bridged by a vast ice sheet. , the larger of two, is roughly the size of the U.S. and is composed of continental crust covered by an ice sheet that averages 1.6 miles thick. Rock exposures are limited to isolated coastal regions and to alpine elevations in the 2,000-mile long Transantarctic Mountains. , the smaller portion is a mosaic of small blocks of continental crust covered by the and an Andean-like mountain chain forming the Antarctic Peninsula. The West Antarctic Ice Sheet is grounded more than 1.5 miles below sea level in places.22

The present Antarctic ice sheet accounts for 90% of Earth’s total ice volume and 70% of its fresh water. It is the coldest, driest, highest (on average) and windiest continent on earth. Absolute humidity is lower than on the Sahara. Annual snowfall in much of the interior is less than two inches. Winds that flow down the surface of the ice towards the coast commonly reach speeds of 80 miles per hour and have been measured to exceed 180 miles per hour. Changes in wind speed and temperature can be quick and dramatic. Earth’s lowest surface temperature, -126.9°F, was recorded in the interior of Antarctica. In summer, temperatures at coastal locations occasionally rise above the freezing point.

Life forms on the Antarctic continent itself are sparse because of the severe climate, isolation and ice cover. The continent’s two species of flowering plants—a grass and an herb—are restricted to the Antarctic Peninsula, and native land animals are limited to arthropods. There are no terrestrial mammals. Sea life, however, is abundant, and the large number of birds and seals that live in Antarctica are marine animals, which spend most of their time in or over the water feeding. These animals come ashore only to breed and molt. By contrast, the oceanic areas surrounding the Antarctic are rich in life. The Atlantic sector of the Southern Ocean is a major breeding ground for seabirds and seals and a seasonal destination for migratory cetaceans.

6.2 Relevant Laws and Regulations

Information on the applicable international and national laws and regulations, Antarctic requirements, marine legislation, safety of vessels, safe vessel operations, emergency response action and environmental safeguards has been covered in Section 3.4.2.

6.3 Standard Operating Procedures

GCC’s efforts to avoid or minimize environmental impacts are in effect every day of the year and in all locations where its ships operate. GCC is an environmentally proactive cruise line that has extensive policies and procedures to ensure its ships always operate to the highest environmental standards.

Chapter 6 of GCC’s Ship Management Manual (hereafter SMM) serves to accomplish goals and objectives under the company’s Quality, Safety and Environmental Management System. The SMM describes in principle all activities related to ship management including, but not limited to, quality, safety and environmental protection. The SMM also addresses the requirements of the ISO 9001 (http://www.iso.org/iso/iso_9000) and ISO 14001 (http://www.iso.org/iso/iso14000) Standards, along with the ISM Code (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/ISMCode.aspx) and is the collection of

21 IAATO. Initial Environmental Evaluation Antarctic Cruise Program, Ship-Based Tourism to the Antarctic Peninsula, South Shetland Islands and South Orkney Islands, November 2002 – March 2007, Multi-Year Document. (Submitted to US EPA.) 22 Report of the U.S. Antarctic Program External Panel, April, 1997.

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment all environmental policies, procedures and training for every significant environmental aspect generated by a cruise ship and covers all the elements that make up the marine environment (air, water, land).

GCC’s Safety Management System (hereafter SMS) has been audited and complies with the requirements of the International Management Code for the Safe Operation of Ships for Pollution Prevention (ISM Code) (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/ISMCode.aspx) as a Passenger Ship. The Document of Compliance, valid until 16 December 2020, is available upon request (and subject to periodic verification).

Environmental training is provided to each sign-on crewmember by Department Heads, through specific On-the- Job training. The Chief Engineer and Chief Officer are also responsible for overseeing shipboard compliance with company policies (which often exceeds legal requirements), environmental laws, regulations and industry standards. An aggressive and comprehensive annual audit program evaluates each ship in the fleet.

GCC’s SMS describes in principle all activities related to management of the ship including but not limited to quality, safety and environmental protection. The documents in the SMS describe and implement the company’s standards, which is defined in the following documents:

1. Company Procedures Manual 2. Office Manual 3. Contingency Plan Seagoing Ships 4. Ship Management Manual (consisting of the following parts: - Ch.1 Introduction (Liability and Responsibility) - Ch.2 General (Company and Shipboard Organization, Communications & Reporting) - Ch. 3 Administration (Documentation and Manifests) - Ch. 4 Navigation - Ch. 5 Technical Operations (including Maintenance of the Ship and her equipment and systems) - Ch. 6 Safety, Quality and Environmental Operations

GCC has established and incorporated in the Company’s SMS Manual all the requirements of the following International standards: • Quality Management System ISO 9001:2008 (http://www.iso.org/iso/iso_9000) • International Safety Management System ISM Code:2010 (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/ISMCode.aspx) • Environmental Management System ISO 14001:2004 (http://www.iso.org/iso/iso14000) • Maritime Labor Convention MLC 2006 (http://www.ilo.org/global/standards/maritime-labour-convention/lang--it/index.htm)

Individual documents are dedicated to the management of specific environmental media: bilge and oily sludge waste water management; gray and black water management; ballast water management procedures, handling of hazardous materials and waste management (hazardous, regulated, universal and non-hazardous/solid waste management.

The SMM, as a part of GCC’s SMS, addresses the requirements of the ISO 9001, ISO 14001 and ISO 18001 Standards, along with the ISM Code. It is organized and developed in a way to achieve all of the Company’s goals and objectives and at the same time to secure 100% compliance with all applicable laws and regulations. Reviews and audits are done in regular intervals, to ensure that the SMS remains up to date.

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GCC’s Vessel Operations department monitors onboard compliance through a regular routine of auditing; furthermore, the same department is overseeing the extensive training program described previously.

In sum, the SMS and SMM as the upmost important part of it, sets out GCC’s overall policy. The day-to-day fulfillment of that policy is detailed in its waste stream-specific SMM sections. Policy goals are carried out by ship’s officers, supported with the training, and oversight of the Company’s Technical department, in charge of all Environmental Management programs.

GCC is responsible for ensuring that the vessel has in place all current relevant certificates and maintains the vessel by suitably qualified engineers or mechanics to meet requirements under the vessel’s classification society. While these are safety considerations, these also ensure that systems are maintained correctly and to optimal standards for servicing and maintenance.

GCC’s shore-side personnel and shipboard staff are comprised of highly qualified individuals with extensive experience in the maritime industry operating in some of the most environmentally-sensitive waters around the world. For Antarctic operations, the vessel’s regular shipboard contingent will be supplemented with an experienced Expedition Team, including an Expedition Leader and Assistant Expedition Leader, as well a team of lecturers, naturalists and Zodiac drivers, who bring specialized local knowledge to the planning and execution of each expedition.

The IAATO FOM contains the applicable ATS instruments applicable to tourism operations, marine regulations, IAATO guidelines and standard operating procedures (which include instructions, briefings and safety guidelines, procedures, emergency contingency plans including emergency and medical response plan, and information on landing sites). IAATO member operators have used manuals, such as these, since the late 1980s, however IAATO members saw value in utilizing one manual (used by all) to ensure consistency between operators on the various ships. The FOM is considered to be a vital document for IAATO operators to ensure environmentally responsible and safe operations in Antarctica.

Each IAATO member operator is responsible for providing the Expedition Leader, Captain and ship’s command (e.g. department heads) with their own supplemental information (specific to their jurisdiction and planned operation), including Advance Notification, Environmental Impact Assessment, copies of all relevant permits or authorizations received from their Competent Authority, individual activity guidelines, individual passenger medical questionnaires, relevant national laws and regulations, any relevant signed contract or company-specific procedures that complements the IAATO EMER, discussed below.

Additional minimization and mitigation measures are in place including the following, along with details provided elsewhere in this assessment.

As referenced in Section 3.4.12, appropriate contingency plans and sufficient arrangements for health and safety, search and rescue, and medical care and evacuation have been drawn-up and are in place for these proposed activities. Such plans and arrangements are designed so as not to be reliant on support from other expedition organizers or national authorities/programs.

All SOLAS ships are required to operate under the ISM Code (http://www.imo.org/OurWork/HumanElement/SafetyManagement/Pages/Default.aspx) and have an established SMS in place. Since it entered into place on 01 July 1998, the ISM Code for Safe Operating of Ships and for Pollution Prevention, adopted by all Flag States, has had a huge impact towards drastically improving the safe operation of ships and in pollution prevention. The ISM Code describes, in broad terms, what a ship operating company’s safety management system needs to include.

An emergency shore kit will be taken ashore prior to shore landings in the unlikely event of an emergency resulting in a stranding ashore. Details, including methods of dealing with waste resulting from a stranding, can be found in Section 3.4.12.

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As mentioned previously, during all small boat and landing operations, members of the Expedition Team are equipped with portable VHF marine radios and spare batteries. A listening watch between the ship and the Expedition Team is routinely maintained throughout these operations. IAATO’s Guidelines for General Wildlife, Cetacean, Seal and Bird Watching (ref. Sections 3.4.8 and 4.4) minimize potential environmental impacts to wildlife by vessels and auxiliary craft by providing a “code of conduct” to help reduce potential disturbance to the marine environment and are used as a generic set of standard operating procedures for worldwide operations for vessel and boat operations when in areas where marine wildlife is present. In cold weather climates where Zodiac activities will be offered, adherence to the IMO/MSC “Guide to Cold Water Survival” (http://imo.udhb.gov.tr/dosyam/EKLER/2013710143528MSC.1-Circ.1185-Rev.1- GuideForColdWaterSurvival(Secretariat).pdf) and IAATO’s Guidelines for Small Boat Operations in the Vicinity of Ice (ref. Appendix 13.10) provide advice on how to prevent or minimize dangers from cold exposure that may endanger life.

6.4 Assessment of Impacts

Likely impacts are assessed qualitatively using the criteria and methodologies summarized below in Table 1. Results are presented in Table 3 (ref. Appendix 13.15).

Table 1 Criteria for Assessment of Likely Impacts23 Heading Content Detail ACTIVITY Nature Type of activity Duration Time period of activity Listed in days, weeks, months, etc. OUTPUT Description of potential results of activity that may cause impact IMPACT ASSESSMENT Scope Geographical area affected Local, regional, continental (L, R, C) Short (minutes-hours), medium (days-weeks), long (months-years), Persistence Duration of impact permanent, unknown (S, M, L, P, U) Intensity Severity of impact Low, medium, high (L, M, H) Probability Likelihood of impact occurring Low (<25%), medium (25-75%), high (>75%) (L, M, H) Importance Importance of impact Low, medium, high (L, M, H) EFFECTS Direct Qualitative description of what is directly, indirectly and cumulatively impacted by the Activity/Output. Indirect Same Cumulative Same MINIMIZATION AND MITIGATION Methods to minimize and/or mitigate effects of the proposed activity

The terms used in this assessment have been based upon the following definitions24:

23 Source: Poles Apart Ltd., www.polesapart.org.

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Effects are the result or consequences of an activity that includes positive and adverse effects, temporary or permanent, direct and indirect and finally cumulative effects.

Direct, indirect and cumulative effects: direct effects result from an action, which causes a direct change to the environment. They are direct cause and effect interactions, for example people or stock trample plants, which as a result, may die. Indirect effects are those that occur as a result of primary effects but may be separated from them over time or from the area where the original action took place, for example erosion due to vegetation loss (caused by trampling). Cumulative effects have been described as the accumulation of impacts over time and space resulting from the combination of effects from one activity/development or the combination of effects from a number of activities. As a consequence, cumulative effects can be different in nature, larger in magnitude, greater in significance, longer lasting and/or greater in extent than any individual effect.

A ‘significant effect’ is an impact that is outside the limit of acceptance, which then must be avoided, remedied or mitigated back below this ‘acceptable limit’. If this cannot be undertaken the project or activity may not be approved.

Mitigation: measures to avoid, remedy or mitigate (reducing) adverse environmental effects. Ideally effects should always be avoided and only if this cannot occur should remedying and mitigating options be looked at. Mitigation could, for example, involve putting restrictions on numbers participating, routes taken, use of helicopters, and the avoidance of nesting times of bird species.

The following sections identify and assess the likely effects of MV CORINTHIAN’s voyages on the environment as described in Section 4. A summary of the likely outputs and effects are presented in Table 2 (below). Where appropriate, origins and outputs of activities are given and their likely effects assessed. Finally, minimization and mitigation measures are described.

Table 2 Summary of Likely Environmental Effects

Environmental Effects Flora Fauna Water/Ice Soil Further afield Emissions to air X X X Emissions to water X X X Wastes generated X X X X X Noise X X Physical Disturbance X X X X Translocation of X X X diseases/alien species

In the following sections of this assessment, the assumption has been made that the minimization and mitigation measures outlined will be applied.

24 New Zealand, department of Conservation “Guide to preparing EIA for Concession Applications” document (Docdm367160), http://www.doc.govt.nz/Documents/about-doc/concessions-and-permits/concessions/guide-to-environmental-impact- assessments.pdfhttp://www.doc.govt.nz/Documents/about-doc/concessions-and-permits/concessions/guide-to-environmental-impact- assessments.pdf

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GCC proposes to remove completely, as far as practicable, all solid wastes, including food and garbage. Thus, the main potential sources of environmental impacts will be emissions, fuel spills, gray water, noise, physical disturbance and translocation of diseases/alien species.

The operations of GCC would need to be added to activities by others, to consider cumulative effects on the environment described in Section 7.

Antarctic post visit reporting to the applicable Competent Authority will occur as required under ATCM obligations and the operator’s authorization from the US Department of State.

6.5 Air

6.5.1 Origins

Emissions to air generated by fuel burn during the proposed activity will originate from: • Ship cruising, and • Small boat operation (e.g. Zodiacs).

In addition, fueling activities or fuel spills could result in a small amount of fugitive emissions to be released. The incineration of waste will also result in emissions.

The following fuels will be used by GCC during the proposed activity: • Marine Gas Oil (MGO) (MV CORINTHIAN), and • Unleaded gasoline (Zodiacs).

The major components of exhaust emissions from engines comprise free nitrogen (N₂) and oxygen (O₂) with smaller quantities of carbon dioxide (CO₂), oxides of sulfur, water vapor and a variable mix of partially-reacted or non-combusted gases. Nitrogen, forming most of the air intake to an engine, is largely un-reacted during combustion, although a small proportion will form various oxides, especially from the oxidation of organic nitrogen in the fuel.

Exhaust emissions from combustion and emissions from evaporation of fuels used by the ship, Zodiacs will include: • Carbon dioxide (CO₂), • Carbon monoxide (CO), • Nitrogen oxides (NOx, N₂O), • Sulfur oxides (SOx), • Methane (CH₄), • Volatile organic compounds (VOC) including Gasoline Range Organics (GRO) and Diesel Range Organics (DRO), and • Particulate material.

These emissions contribute both directly and indirectly to the greenhouse effect and to local and regional air pollution.

The estimate of MV CORINTHIAN’s fuel use for a single voyage is estimated in Table 4 below.

Table 4 Estimated fuel use for a single proposed activity

Fuel Type Estimated Use (liters) Marine Gas Oil (MV CORINTHIAN) 16,000 liters per day 60 liters/day for Mark V HD Zodiacs (6 Mark V) Antarctic operations

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Gaseous emissions will result from the exhaust emissions noted above.

6.5.2 Assessment

Likely impacts of emissions from marine combustion (from ship operations and routine small boat operations) are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Emissions resulting from marine combustion are typically close to the source (ship and/or small boat engines) and well away from land. This is usually an environment where wind is a common feature. Particulates and micro pollutants (trace levels of marine pollutants that have severe adverse effect at low concentrations, e.g. organic micro pollutants and heavy metals) may be significant in marine emissions, than, for example aircraft emissions. Lloyd’s Register25 noted that micro pollutants, such as heavy metals, are well known “inhibitors of biological processes, particularly in aqueous ecosystems.”

Emissions will generally be rapidly dispersed by wind, however any activity producing atmospheric emissions will contribute to regional and global air pollution burdens.

Marine combustion emissions are overall assessed to be of high importance due to high probability, and a medium-to-long-term persistence and potential for local to continental scope due to dispersal effects.

6.5.3 Minimization and Mitigation

Careful, thorough and routine maintenance is the primary method for minimizing emissions of carbon oxides, unburned hydrocarbon and black smoke. As noted elsewhere, it is not planned to utilize the incinerator while in the ATA.

Partial mitigation is also possible through the use of ‘clean’ fuels and lubricants, and regular care and maintenance of engines. As noted previously, the vessel uses MGO, a lighter and cleaner fuel. No Heavy Fuel Oil (HFO) is used or carried on the vessel.

GCC’s nautical department is continually investigating new technologies and methods to increase the level of safety and environmental impact associated with its operations.

6.6 Water – Fuel and Oil Spills

6.6.1 Origins

Maintenance and fueling of Zodiacs and by leakage from fuel containers may result in fuel and oil spills. A catastrophic loss from the ship may result in an emergency fuel jettison however this is an unlikely scenario.

Table 5 gives the total fuel capacity to be carried aboard MV CORINTHIAN during a given proposed activity.

Table 5 Total fuel capacity to be carried during a given proposed activity (estimating an activity to be a 10 day voyage with 5 days in Antarctica per voyage)

Estimated Total Fuel to be Carried Fuel Type (liters) Marine Gas Oil (MV CORINTHIAN) 222,600 liters

25 Lloyds Register, 1995. Marine exhaust emissions research programme. London, Lloyd’s Register of Shipping.

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Unleaded gasoline - 6 Mark V HD Zodiacs (based on using an estimated average of 60 liters/day for Antarctic operations) (based on 5 days in Antarctic on each voyage) 1,000 liters

In addition, lubricating oils and four-stroke oil will be carried aboard the vessel for the ship and Zodiac engines.

Standard operating procedure calls for refueling of the Zodiacs to be done aboard ship and not in the boats.

Local and regional contamination of the marine and coastal environments and their dependent ecosystems could result as a direct effect of any spill.

6.6.2 Assessment

Likely impacts from fuel and oil spills are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Fuel spills are most likely to occur due to fueling of the gasoline tanks for the Zodiacs. Should a spill occur aboard ship, it is estimated a spill would be <10 liters.

The likelihood of a catastrophic puncture of a fuel tank with a loss of 1,000 liters or more of fuel is extremely low.

Fuel spills rapidly evaporate however the rate of evaporation depends upon the conditions (e.g. polar or tropical), for example since at low temperatures evaporation is less complete.26 In addition, as a number of hydrocarbons are highly soluble in water, their effect depends upon dilution.27

6.6.3 Minimization and Mitigation

Fuel spills constitute the most unpredictable accident aboard ship; however, occurrence can be minimized through strict adherence to sound operating procedures.

Provided spill procedures are followed according to established standard operating procedures, spills occurring on the ship during fueling operations will be contained. The resultant spill from two fully-loaded tanks of fuel (5 US gallons each) in a Zodiac during a catastrophic event could be in the order of 37.85 liters (equivalent to 10 US gallons) per Zodiac however this would be an extremely rare occurrence. The resultant spill could be significant, especially if it occurred near concentrations of marine wildlife, with local contamination being the direct effect. The amount of fugitive emissions (defined by US EPA28 as being “those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally-equivalent opening”) would be dependent upon the scale of the spill.

There is a medium probability of minor fuel spills (less than approx. 10 liters) occurring during the proposed activity due to regular use of the Zodiacs and the need for refueling. Minor spills are assessed to be of medium- high importance due to their medium probability and the likelihood that the impact residues will persist for a medium-term period.

26 OSRL. 1998. Antarctic oil pollution course: 20-12 August 1998. Southampton, Oil Spill Response Ltd [published course handbook]. 27 Cripps, G.S. and J. Shears. 1997. The fate in the marine environment of a minor diesel fuel from an Antarctic research station. Environmental Monitoring and Assessment, 46, 221-232. 28 Source: http://www.epa.gov/region7/air/title5/t5memos/fug-def.pdf

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Despite a low probability, major fuel oil spills (more than approximately 1000 liters) during the cruise are assessed as being of high importance due to the local to regional scope, medium-to-long-term effect, high intensity and potential for direct, indirect and cumulative effects.

The most effective methods for minimization and mitigation are having a dedicated emergency contingency plan, ensuring strict adherence to established standard operating procedures, having an oil spill kit on board, and effective containment procedures, spill contingency planning, and effective communications. Spill prevention procedures include, but are not limited to, following established fuel bunkering procedures during bunkering operations, the use of funnels, spill mats during fueling and engine maintenance, use of drip trays; and utilizing absorbents.

6.7 Wastes Generated During the Expedition

6.7.1 Origins

The proposed activity will result in liquid wastes being generated during the course of normal ship operation.

Wastes include: • Domestic waste water (e.g. from cooking and ablution activities), • Sewage, • Macerated food waste, and • Oily Mixtures.

Solid wastes will also be generated, including: • Garbage (e.g. waste paper, clean packaging materials, glass and wood from domestic and work activities on the vessel), • Food waste (e.g. excess or spoiled food waste which is not suitable for maceration), and • Hazardous or special waste (e.g. batteries, paints, oils, oily rags, etc., from maintenance or other work on the vessel).

Other sources of waste include ballast water and anti-fouling paint (ref. Section 6.7.2).

6.7.2 Assessment

While the ship is operated in the ATA – as in any ocean of the world – waste materials, including refuse, waste fluids from mechanics and sewage waste will be generated.

Likely impacts from wastes generated during the expedition are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Sewage will be treated by a Warsila Hamworthy Super Trident 13 Biological Sewage Treatment Plant. Effluent will be stored in sewage holding tanks for disposal at sea or return to port for disposal at a certified shore side reception facility. As required under MARPOL, no sewage disposal will be permitted within 12 nautical miles of land or ice shelves. All sewage, gray water, and kitchen sink water will be stored in the holding tanks. Discharge will occur when the tanks are full, with the vessel ensuring a location appropriate to MARPOL requirements. The waste will be discharged from the vessel while underway at a speed of no less than four knots.

The marine pollution impacts caused by disposal of these wastes generated during the proposed activity are assessed to be of low importance due to their local scope, short-term effect and low intensity.

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Burnable wastes will be incinerated if required; with the resultant incinerator ash disposed of in an appropriate manner, however while the vessel has an incinerator is it not planned to incinerate while in the ATA.

Relevant disposal routes are show in Table 6.

Table 6 Types of waste generated by MV CORINTHIAN activities and proposed disposal routes

Waste Type Classification* Route Non-hazardous Group 3 Paper, plastics, timber Separated and incinerated or removed for Recycling and disposal Metal, glass Group 4 Separated and incinerated or removed for recycling and disposal Incinerator ash Disposed of as per regulation Biodegradable Food waste Group 3 or 4 Food suitable for maceration will be passed through A macerator and disposed as gray water Food not suitable for maceration will be segregated and refrigerated for disposal at certified reception port Human waste Group 1 Treated on board, stored and disposed as per MARPOL Requirements Gray water Group 1 To be stored on board and disposed as per MARPOL Requirements Hazardous Batteries Group 4 Separated and removed for recycling or disposal at certified reception port Medical and sanitary waste Group 4 Frozen and removed for disposal at certified reception port Fuels and oils Group 2 Removed for disposal at certified reception port

*Classification based on Annex III of the Protocol on Environmental Protection to the Antarctic Treaty (ref. http://www.ats.aq/documents/recatt/Att006_e.pdf)

MV CORINTHIAN has TBT FREE SPC anti-fouling paint on its hull. Organotin biocides are not contained in the particular brand of anti-fouling paints thereby complying with the IMO Antifouling Systems Convention (AFS/CONF/26) and the Vessel General Permit Scheme under the US Clean Water Act.

The vessel’s International Anti-Fouling System Certificate and Record of Anti-Fouling Systems is available upon request.

It is not possible to estimate the marine pollution impact caused by leaching of the paint, though it is perceived that the impact caused by anti-fouling systems may have a more persistent effect than those caused by other wastes (e.g. waste water and sewage).

MARPOL prohibits the discharge of oil-contaminated ballast water, which could cause marine pollution and also introduce exotic species into local waters, resulting in the transfer of aquatic organisms such as plankton, algae and invertebrates, as well as pathogens.29 Due to the higher diversity of species in shallow coastal zones, the effects of this may be exacerbated. The introduction of invasive marine species could also have serious impacts on the surrounding ecosystem.

29 Niimi, A.J., 2000. Influence of vessel transit patterns on developing a ballast water treatment strategy for exotic species. Marine Pollution Bulletin 40(3), 253-256.

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6.7.3 Minimization and Mitigation

All waste products will be disposed of according to MARPOL Guidelines and Annexes II and IV of the Environmental Protocol – or contained on board ship while in the ATA for shore side disposal once the ship is back to port at the conclusion of the each voyage following the procedures outlined in IAATO’s Statement on Waste Management as identified in Section 3.4.4.

Where practicable or required by permit, all hazardous and non-hazardous wastes, including ash from the incinerator, will be removed. As stated above, sewage and gray water will be stored in holding tanks until the ship is at sea and can be discharged in accordance with MARPOL requirements. An alternative method of disposal is to pump out on return to port at certified reception facilities.

Some solid wastes may be re-used or recycled, for example empty fuel drums. Wastes returned to port for shore side disposal will be removed from the ship utilizing a certified company for licensed disposal.

Oily mixtures, such as from bilge water from machinery spaces, will be separated from liquid wastes according to established standard operating procedures. A separation process will be used to recover oils from oily mixtures; oils will be retained on board for discharge upon return to port. MARPOL 73/78 allows for the discharge at sea of oil/water mixtures with an oil content of less than 15ppm. The vessel’s Oil Record Book will log all discharges.

Waste release incidents will be avoided according to adherence with international standards. Appropriate protocols are in place to minimize accidental releases or discharges that do occur and mitigated by clean-up efforts. Natural dispersion – through wave and wind action – will also assist with clean-up efforts should a waste release incident occur. Therefore, accidental discharge of these waste products into the environment will have no more than minor or transitory impacts.

While unlikely, the potential of an accident discharge of fuel and waste products from a marine collision or other event does exist. Impacts to the environment from such events could include the accidental discharge of refuse or accidental release of petroleum fuel, in addition to small quantities of lubricating fluids, oils, and unleaded gasoline for the Zodiacs. Through the implementation of standards as described above, impacts will be no more than minor or transitory.

For the Zodiac operations, standard operating procedures dictate that waste products, if any (for example as a result of an unexpected stranding ashore), are to be contained on board the Zodiacs – not only while underway, but also when ashore. Any waste products and refuse will be returned to the ship for disposal in accordance with MARPOL Guidelines and Annex III and IV of the Environmental Protocol, including if any emergency food from the emergency shore kit was used during a stranding ashore or for a medical purpose. Waste mechanical fluids will not be disposed of while the Zodiacs are being utilized for landings or excursion purposes. It is therefore deemed that impacts resulting from waste disposal will be no more than minor or transitory.

No poultry products will be taken on land, introduced into the water or onto the ice (if applicable) to avoid the spreading of the Infectious Bursal Disease Virus. Poultry products (poultry or parts not consumed) will be handled in a matter that eliminates risk to native flora and fauna; either being incinerated, kept refrigerated or in frozen storage for disposal upon return to port.

As stated in Section 6.7.2, organotin biocides are not contained in the particular brand of anti-fouling paint used on MV CORINTHIAN, thereby complying with the IMO Antifouling Systems Convention (AFS/CONF/26) (http://www.uscg.mil/hq/cg5/cg522/cg5224/docs/Antifouling.pdf).

6.8 Noise

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6.8.1 Origins

Noise will be generated by: • Ship operations, and • Small boat operations.

6.8.2 Assessment

Likely impacts from noise generated during the expedition are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Effect of noise upon wildlife and wilderness and aesthetic values is a key concern. Wildlife can be impacted by noise in two ways: 1) increased stress leading to changes in an individual’s behavior and 2) disturbance of whole communities leading to breeding mortality. Species that could be disturbed include whales, seals, penguins and seabirds with disturbance occurring on shore at the colony, nest or haul-out site during breeding, where impact could be the greatest. Other effects of noise can impact species that are resting; in cases such as this, the impact is likely to be less significant. Small boat operations can result in impact by noise disturbance, for example resulting in disturbance to penguins at local colonies (as the birds come and go from their nest sites) and seals and whales in open water. Disturbance to some species could result in them entering the water, potentially increasing predation.

The level of noise disturbance is related to the number of boats used, their movements, speeds, and whether or not the equipment is maintained at optimal conditions. Noise is caused by a combination of engine and engine speeds. Defective exhaust systems or other faulty equipment can also result in greater noise.

While it is perceived that noise may have a transitory effect on the wilderness and aesthetic value of a given location for the duration of the visit, the likely impact is not considered significant provided minimization and mitigation measures are in place and adhered to.

Noise impact from the ship and small boat operations is assessed to be of low importance due to being of low intensity, short-term persistence and local scope.

6.8.3 Minimization and Mitigation

Impacts of noise effect from small boat activities have been poorly studied. As a US-based operator, the vessel and small boat activities of GCC will be managed in accordance with: • MMPA, 1972 and subsequent amendments (http://www.nmfs.noaa.gov/pr/laws/mmpa/), • 50 CFR 216 MMPA Regulation (http://www.nmfs.noaa.gov/pr/pdfs/laws/mmpa_regs_216.pdf), • IAATO’s Wildlife Watching Guidelines (General and for Cetaceans, Seals, Seals, Birds and Leopard Seals) (ref. Section 3.4.8), and • GCC’s Zodiac Operation Manual (available upon request).

6.9 Physical Disturbance

6.9.1 Origins

Physical disturbance may result from the following activities: • Ship operations, • Small boat operations, and • Shore landings.

6.9.2 Assessment

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Likely impacts from physical disturbance generated during the expedition are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Likely physical disturbance from the vessel and related small boat operations includes activities such as water turbulence from ship passage, the breaking of light sea ice, damage to coral reefs and benthic communities from anchoring and mooring, and effect on wilderness and aesthetic values. The itinerary design will likely result in the vessel not being at anchor for more than one day and plans are for the ship to stop sufficiently far from any wildlife colonies or open water access area in order that its physical presence should have no effect or impact on their behavior. A transitory effect on the wilderness and aesthetic values of the area will result from the vessel’s presence. Impact from the physical presence of the ship is assessed as being of low-medium importance due to the local scope, short-to-medium-term persistence, high probability and low intensity.

Landing and shore operations can adversely impact flora and fauna – including native, rare and endangered species. Boat beaching, pedestrian traffic, and physical contact can also adversely impact land, air and water quality, and historic and geologic features. Notably landing and shore operations may adversely impact on nesting birds, hauled out seals, and on the intertidal marine ecosystem. Habitat destruction may be impacted due to trampling nesting sites and fragile plant communities, or impacts to wildlife, for example forced behavior modification, for example causing animals to scatter (and possibly abandoning their nests, possibly also leaving eggs and our young susceptible to predation), or by restricting their movements. Impacts can result from the noise from passengers ashore as well as noise from the Zodiac engines, which could disrupt the activities of shore animals and benthic communities. The introduction of alien species may also occur to island ecosystems. In some areas, impacts may extend to rare and/or endangered species. Site degradation could occur from Polar Plunges if bathing ‘pits’ were to be dug, however as noted in Section 4.5, this will not occur and is against IAATO standard operating procedures for this particular activity. (It should be noted that any pits dug in the sand would fill back in with seawater when the next high tide occurred.)

In some areas, soil erosion can result from pedestrian traffic as well as walking tracks from repeated passage. The natural processes of the environment can be disrupted or damaged by physical contact, either by landing craft or by visitors traversing through a given area. The degradation of buildings and artifacts through physical contact can result from visits to historical sites. Visits can also result in increased humidity inside buildings, the removal of objects or defacement. The introduction of alien species can disrupt scientific studies or from intrusions into protected areas.

Damage to coral reefs and other substrates can occur if operations of the Zodiacs are not conducted properly to avoid damage to reefs and other biota if coral or other substrates are touched. Damage can be significant and lead to local loss of fragile species. Impacts can contribute to the degradation of coral communities both biologically and aesthetically.

The impact due to physical presence of shore landings and the use of small boats is assessed as being of medium- high importance due to the local scope, potential for medium-permanent persistence, low probability and low intensity.

6.9.3 Minimization and Mitigation

Minimization and mitigation measures include education, which is viewed as being the key factor towards ensuring that crew, staff and passengers are educated and briefed appropriately. The Expedition Leader is responsible for ensuring that the appropriate briefings are provided to passengers and staff and that the relevant training is provided to the vessel’s crew. Briefings will include examples of non-interfering behavior, specific points regarding movement and behavior ashore at the various landing sites. As the Zodiacs arrive to the landing sites the Expedition Leader and/or expedition staff will brief the passengers, emphasizing specific points of importance. In

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment all briefings, conservation issues will be stressed. Printed materials and lectures serve to address the potential areas of adverse impact by assessing activities that may result in impacts before the first disembarkation.

In some cases, national authorities will provide visitor guidelines. These will form the basis of mandatory pre- landing briefings to advise all who are going ashore of their obligations under national law and the legal implications of their conduct.

Protected areas will be known in advance and checked to be certain that landing sites are not in the vicinity of these areas, that landings do not compromise area boundaries or that entry is made. Anchoring is prohibited within marine protected areas or marine reserves.

Ship’s command and the Expedition Leader are also aware of protected species in order to ensure that activities do not impact these species.

Prior to disembarking passengers for activities ashore, the Expedition Leader will assess the landing site with the specific purpose of evaluating the landing against safety and environmental conditions. Visits will be managed according to factor such as any visitor site guidelines (if applicable), whether or not the site is in close proximity to any protected area, available space for passenger activities (is there space for the passengers to walk freely without disruption to flora and/or fauna?), species diversity at the site, etc.

The Expedition Leader is responsible for managing activities ashore, with the assistance of a team of experienced field staff. Activities ashore will depend upon the highlights of each site but may include walks or hikes; visits to cultural sites of interest; opportunities to view wildlife, flora and sites of unique geological interest and, on a conditional basis, Polar Plunges at Whalers Bay. At some landing sites visits will be made to historic sites and/or research stations. In these cases, the visits will be conducted according to established visit guidelines or management procedures established by national authorities. At all times, particular attention will be paid to supervision of passenger activities to minimize impact, etiquette at wildlife areas, personal conduct, geologically- fragile features and boundaries of protected areas.

Should any participant violate the ‘rules,’ the Expedition Leader and Expedition Staff supervising shore activities may remove the offending participant from the site and prohibit participation should he/she be concerned over the individual’s future behavior. Experience has shown that in nearly all cases, participants are champions of the environment and willingly support measures to minimize adverse environmental impact.

Standard operating procedures minimize physical disturbance and protecting the environment while ensuring safe and responsible operations. As noted in Section 6.9.2, bathing pits at Whalers Bay will not be dug to support the Polar Plunge activity.

Standard operating procedure includes the reporting of any noted physical disturbance in the Expedition Leader’s Post Visit Reporting.

6.10 Introduction of Alien Species and Translocation of Diseases

6.10.1 Origins

The risk of introduction of non-native alien species (those species that do not naturally occur in an area and have been introduced intentionally or unintentionally) and translocation of external diseases is ever-present due to direct and rapid inter-continental transfers. Introduced species include microbes, algae, fungi, vascular plants, invertebrates, fish, birds and mammals. Introduction could occur through a number of pathways, including packaging, decontaminated clothing or equipment, and even importing uncooked food.

6.10.2 Assessment

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Human activities have the potential to act as a vector for non-native species. Populations are susceptible to infection by disease and scavenging of unsecured food waste by birds, for example, is a simple route for these to enter the system. The possibility exists for the spread of diseases from one colony to another should disruption occur. The local biota could be significantly impacted should introduction or translocation of alien species, soils or microbes occur. In some areas, impacts may extend to rare and/or endangered species. Unclean footwear, clothing or equipment and on small boats can introduce soil and seeds which may result in the accidental transfer of non- native organisms. The greatest potential risk to the health of wildlife are highly contagious viral diseases, such as morbillivirus, Newcastle disease and influenza; immuno-suppressant diseases, such as infectious bursal disease and retrovirus; and from agricultural and zoonotic diseases such as brucellosis, tuberculosis and leptospirosis.

The impact is assessed to be of high importance due to its potential to have a regional scope, permanent persistence and high intensity.

6.10.3 Minimization and Mitigation

Likely impacts from the introduction of alien species and translocation of diseases during the expedition are assessed qualitatively using the criteria and methodologies summarized above in Table 1. Results are presented in the matrix contained in Table 3 (ref. Appendix 13.15).

Standard operating procedures and procedures such as boot, clothing and equipment decontamination procedures for small boat operations and shore landings will be followed strictly to ensure the prevention of introduction of translocation of non-native species and disease.

GCC will apply the following practices to minimize the likelihood of introduction of alien species or diseases:

For the vessel: • Rat guards in place on mooring lines, • Gang plank lifted at night or, if lowered, lit with flood lights, • External doors and windows closed whenever possible, • Proper food handling, secure storage and proper disposal of waste generated on board, • Insect traps in place in food storage areas, • Old foods removed from food storage areas at the end of each voyage, • Prohibiting the taking of uncooked poultry products or eggs ashore, and • Ensuring that procedures are followed for boot, clothing, and equipment decontamination.

For the auxiliary craft (Zodiacs): • Inside watercraft cleaned, • Hulls of watercraft cleaned before loading, and • Cleaning of the Zodiacs in between landings and between areas of operation.

The Expedition Leader has responsibility for briefing all those going ashore (passengers, expedition staff and crew) on Biosecurity measures, including any requirements from national authorities, for example, for visits to the Antarctic and IAATO’s Boot, Clothing and Equipment Decontamination Procedures (Appendix 13.12). Participants will be strongly encouraged to check and, if necessary, clean their clothing (including Velcro cuffs, pockets, seams, socks, trouser hems and cuff turn-ups, fleece, zippers, and/or hood of jackets) and equipment (including items such as camera tripods, trekking poles, daypacks, camera bags and rucksacks, etc.) prior to the shore landings. Those who may have recently gone trekking, tramping, backpacking, or farm visiting prior to the voyage will be advised they must check their items especially carefully to ensure they have removed all foreign material.

The strict observance of ATS Recommendations, adherence to IAATO’s Boot, Clothing and Equipment Decontamination Guidelines, and washing boots with a disinfecting (biocide) agent (such as Virkon®-S, Virox5 or other) before and after each site landing will reduce the likelihood of impacts from occurring, as will following the

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment recommendations in the COMNAP “Checklist for Supply Chain Managers of National Antarctic Programmes for the Reduction in Risk of Transfer of Non-native Species (2011)” (https://www.comnap.aq/Publications/Comnap%20Publications/Forms/Publications.aspx?Category=Operational% 20Guidelines) and the ATCM “Manual for the Prevention of the Introduction of Non-native Species (2011)” (http://www.ats.aq), both of which are provided to member vessel operators by way of the FOM.

On shore, participants will be advised to, where possible, avoid walking in concentrations of organic material such as bird guano, seal placenta, or seal or other animal feces in order to avoid moving this material around the landing site. Before boarding the Zodiacs for return to the ship, debris, especially organic matter, will be washed off boots and clothing as much as possible. Vigilant checks will be made to ensure that seeds and other vegetation are not transported back to the ship.

At the end of each landing, Zodiacs will be inspected when raised for stowage at the conclusion of the boat operations, and when necessary cleaned, to ensure that no foreign matter is transported between sites.

Should a non-native species be discovered, Expedition Leaders follow the “IAATO Guidelines for the Discovery of a Non-native Species” (Appendix 13.14), which is provided by way of the FOM, and include details in their Post Visit Reporting.

Expedition Leaders are mindful to watch for extreme situations, such as a high mortality event, and to report the event to assist in the swift dissemination of observed and recorded information to the appropriate authority. They are advised to report any highly unusual event, whether indisputable or perceived, immediately to assist in the analysis of the event and hopeful containment of the potential threat.

Should the discovery of a high mortality event be discovered, the Expedition Leader should: • Abort the landing, • Not allow those on shore to walk among sick or dead animals, • Not allow anyone to collect samples or handle sick or dying animals, • Photo-document the event and/or obtain video records if possible, • Immediately report the event, and • Notify the appropriate Competent Authority of the incident.

The probability of introducing alien species or diseases is assessed to be extremely low.

6.11 Dependent and Associated Ecosystems

6.11.1 Origins

Aspects of the proposed activity that are likely to affect dependent and associated ecosystems are:

• Emissions to air (ref. Section 6.4): contribution to regional and global air pollution burdens, • Removal of wastes (ref. Section 6.6): increased landfill in port reception facilities; indirect effect of contamination of soil and groundwater and disease transfer during sewage handling, and • Physical presence (ref. Section 6.8): disturbance of migratory species or dependent and associated ecosystems.

Habitat disruption is a potential impact to marine animals that can result from the presence of the Zodiacs. Potential impacts could include noise from the tour operations and activities, water turbulence resulting from the operation of the Zodiacs, pollution from exhaust and inadvertent engine discharges, and, although highly unlikely, a direct vessel strike. Piloting the Zodiacs with improper navigation and a high rate of speed could result in harmful interference of sea birds, penguins and marine animals in the water, in near shore environments or on ice floes. An unlikely scenario is that a Zodiac could run aground in an area other than what was determined to be the landing

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IEE Antarctic Peninsula Cruise Program – MV Corinthian Multi-year Assessment site for shore-based activities. Although the potential impact from a Zodiac grounding is minor in comparison to that of scraping the boat alongside an iceberg, unintentional contacts such as this can cause physical damage to the sea floor (and benthic communities) or shoreline and create turbulence in the water. Physical damage could also result to animal life.

6.11.2 Assessment

Emissions from routine operations have the possibility to lead to impact from airborne pollution and contamination of soils, snow and/or ice with an indirect effect of pollution of local environments. The potential cumulative effect is a contribution to regional and global air pollution.

Routine operations involving domestic, food and/or hazardous waste (removed if possible) can result in an increase in landfill (when offloaded) and an increase in engine emissions (when transporting waste to disposal sites) leading to an indirect impact by contamination of soil and groundwater; damage to local ecosystems and loss of habitat. The potential cumulative effect is a need for more landfill space at reception sites; loss of habitats; increasing soil and groundwater contamination; and an increasing contribution to regional air pollution.

Routine operations involving human waste (solid and liquid) has a direct effect of increasing sewage treatment at reception sites and an increase in engine emissions in the transportation of waste. The indirect effect is disease transfer during sewage handling; impact on human health at reception sites; contamination from the use of detergents during cleaning of containers, and loading on surrounding ecosystems and habitats. The potential cumulative effect is an increased loading on the surrounding ecosystems and increased air pollution.

The physical disturbance from routine operations can lead to a loss of aesthetic or wilderness value and disturbance of wildlife leading to an indirect effect of an increase in the “footprint.” A cumulative effect is the loss of tourism value. The potential cumulative effect is a loss of tourism value.

6.11.3. Minimization and Mitigation

The IAATO “Assessment of Potential Impacts and Mitigation Measures” matrix (Appendix 13.15) lists the nature and duration of ship- and voyage-related activities; the output, if any, of those activities; and the type and degree of impact of a number of activities related to Zodiac or small boat activities, including potential impacts from these activities to penguins, flying birds and marine mammals (seals and whales). As noted, the primary means of ensuring that any impacts are no more than minor or transitory is through avoidance and following ATCM Resolution 3(2011), ATCM Recommendation XVIII-1(1994), as well as the US MMPA at all times in regards to marine mammals. Since the adoption of Recommendation XVIII-1 other measures are in place to provide for guidance for minimizing impact to fauna and discussed elsewhere in this evaluation. The matrix for penguins, flying birds and marine mammals includes the potential impacts as well as actions to be taken.

Avoidance (if possible), enforcement of strict operating procedures such as ATCM Resolution 3(2011), ATCM Recommendation XVIII-1(1994), ATCM- and IAATO-adopted Site Guidelines for Visitors, recommendations for visitor activities in the various ASMA Management Plans, and proper supervision based on IAATO’s guidelines and standard operating procedures are the primary means to avoid or minimize impact to the environment. Passengers are thoroughly briefed on their legal obligations, as well as appropriate behavior ashore to minimize impacts to flora and fauna. Effective supervision requires the Expedition Leader and expedition staff to reiterate landing procedures prior to departing the ship, while in the Zodiacs and upon arrival to shore. This includes, for example, establishing boundaries or perimeters where passengers can and cannot go and, wherever possible, conducting guided walks with small groups of passengers). The Expedition Leader is responsible for being aware of, and enforcing guidelines for station visits and when visiting historic sites and monuments or Protected Areas (e.g. ASMAs), and also being aware of and remaining outside of any ASPA boundaries.

Ship’s command and the Expedition Leader are aware of protected species in order to ensure that activities do not impact these species.

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Measures to mitigate these potential impacts also includes proper training and supervision, following IAATO guidelines and standard operating procedures, as well as following established standard operating procedures, good maintenance, use of newer equipment (emissions); minimize wastes and reduce packaging (domestic/good/hazardous waste); and secure containment and biodegradable containers (human waste).

As noted in Section 6.10.3, IAATO has developed Guidelines for the Discovery of Non-native Species, (updated 2010) (Appendix 13.13) that are distributed by way of the FOM, which are based on the UK guidelines for visitors upon finding a suspected terrestrial or freshwater non-native species within the ATA.30

IAATO has also developed two report forms for Expedition Leader reporting on wildlife interactions: 1) IAATO Wildlife Reporting Form (Appendix 13.3) and 2) IAATO Whale Collision Reporting Form (Appendix 13.4). In addition, standard operating procedure is for the Expedition Leader to report on any incidents in their Post Visit Reporting.

30 United Kingdom. Guidance for Visitors and Environmental Managers Following the Discovery of a Suspected Non-native Species in the Terrestrial and Freshwater Antarctic Environment (WP 15, XXXIII ATCM, Punta del Este, 2010).

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7. CUMULATIVE IMPACTS

Cumulative impact is the impact of combined past, present and reasonably foreseeable activities occurring over time and space. It is understood that cumulative impact may be the result of the repetitive occurrence of a single activity, the combined effect of multiple activities by some or several agents and that cumulative impact may be additive, interactive, synergistic, and antagonistic or a result of bio-magnification.

Cumulative impact can be defined as “the impact on the environment which results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions.”31

Examples of cumulative impacts to which the proposed activity may contribute include: • Contribution to regional and global air pollution burdens, • Increased emission loads leading to regional and global climate change, • Increased landfill in port reception facilities, • Indirect effect of contamination of soil and groundwater and disease transfer during sewage handling, • Effect on vegetation or periglacial features through additive effects of pedestrian traffic, • Gradual establishment of new microbial or plant assemblages through inadvertent introductions over time, • Effect on breeding populations through long-term modifications due to increased pedestrian traffic, • Disturbance of migratory species, • Degradation of historic artifacts from handling, abrasion, theft, etc., • Changes in attitudes over time and hence acceptable uses of localities through familiarity and precedent, • Reduction in scientific, wilderness and aesthetic values of landing sites visited, and • Changes in the level of visitation to existing sites; interest in finding new sites.

Since IAATO’s inception in 1992 members have seriously considered the issue of cumulative impact. In June of 2000 IAATO jointly hosted -- with the U.S. EPA and the U.S. NSF -- a workshop in San Diego, California entitled “Assessment of the Possible Cumulative Environmental Impacts of Commercial Ship-Based Tourism in the Antarctic Peninsula Area” (http://www.nsf.gov/pubs/2002/nsf02201/nsf02201.pdf). The Executive Summary was tabled at ATCM XXIV.32 Examples of possible cumulative environmental impacts identified by the workshop participants included: • Landscape (the topography, geology, and other physical characteristics of the sites visited by tourists and others may be changed in a number of ways over time as a consequence of those visits): o Repeated grounding of Zodiacs and off-loading and loading of passengers at access sites may disturb sand and gravel and increase the rate of beach erosion. o Visitors walking from landing beaches to points of interest at the site may compact soil and wear footpaths, which in turn may cause increased wind and water erosion, alter the topography of the area, and affect where snow, ice and rain water accumulate, and when and how snow and ice melt and run-off occur. o Visitors – if not well educated – may discard and over time sites may accumulate litter. o Visitors may unintentionally introduce non-indigenous flora and fauna including microorganisms which can affect soil formation, and potentially displace or harm indigenous flora and fauna. • Terrestrial Flora (repeated visits of sites with assemblages of grasses, mosses, and lichens can have a variety of effects on the distribution, abundance, and productivity of the vegetation): o Walking on mosses and lichens can crush and uproot them, and over time wear pathways and compact soil.

31 Council on Environmental Quality. 1997. Considering Cumulative Effects under the National Environmental Policy Act. Washington, USA. 32 IAATO. Issues Relating to Cumulative Environmental Impacts of Tourist Activities (IP 52, XXIV ATCM, St. Petersburg, 2001).

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• Terrestrial Fauna (various species of penguins, flying birds and seals that are present on land during the spring and summer reproductive seasons). If visits are not conducted carefully and without adequate supervision, people visiting sites to see these species first-hand could o Accidentally trample cryptic eggs and nests and disturb animals in ways that: § Cause them to abandon nesting and pupping sites. § Interfere with the incubation of eggs, formation of mother-pup bonds, and tending of young. § Increase the vulnerability of bird eggs and chicks to skua predation and of penguins and young to leopard seal predation. § Cause stress that makes animals more susceptible to diseases and parasites. • Historic Sites and Monuments -- while ATCM Recommendation XVIII-1 makes specific reference to not defacing or vandalizing buildings, or taking parts or contents of buildings or other artifacts as souvenirs, visitors might remove rocks, bones, and other artifacts that may be present in and around the sites that are visited. • The Marine Environment (operation of tour ships and related small-boat operations may have a number of cumulative effects on the marine environment and its component parts): o Repeated anchoring of ships while passengers are transported to landing sites can disturb bottom substrate and damage, destroy, or cause changes in the species composition of benthic communities. o Fuel oil and leaks, and illegal dumping of sewage and waste likewise can have cumulative effects on benthic communities near terrestrial sites that are visited repeatedly. o In some areas, noise from the ship and small-boat operations, and repeated attempts to approach whales, seals, and penguins for viewing could interfere with biologically important activities such as feeding and, over time, cause animals to abandon or avoid areas traditionally use for such purposes. • Science and Science-Support Operations (tourists are interested in visiting and seeing first-hand the kinds of science being done at research stations). Visits could interfere with: o The daily routine of station personnel and, if they occur frequently, may interfere with station operations if passengers are not well educated before going ashore and supervised while on shore. o Repeated visits may interfere with on-going research (however it was noted that most national programs have established restrictions on station visits and procedures for structuring visits to minimize impact on station operations and personnel).

The workshop was a first step in the process of beginning to understand the future direction for the tourism industry, scientific communities and government policy makers to better understand, minimize and mitigate cumulative impact from tourist activities in Antarctica.

There are many other factors that should be considered when looking at the potential for cumulative impacts to result from tourism activities. Reported tourism numbers are not in itself a good indicator as to whether or not cumulative impacts are any more or less likely to occur. A detailed analysis needs to be done to consider the specific activities of the ship and the activities ashore. Other vessels (e.g. non-IAATO member operated vessels and small sailing vessels, government program operated ships, etc.) are often in the places where tourist ships visit and the activities of these operations must also be taken into consideration, as must physical and biological factors must be considered, including:

• Biological diversity at the site Wildlife is the biggest draw for tourists wishing to visit the Antarctic. Sites with the most species diversity and largest numbers will most likely be the most desired sites when the Expedition Leader is developing an itinerary. The frequency of visits and the number of visitors are two of the principal factors determining the likelihood of cumulative impacts.

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• Location relative to the distributional range of the species present Sites that feature the greatest diversity of flora and fauna are usually the areas where the ranges of multiple species overlap. Geographic variable environmental factors usually determine species’ distribution. This includes ice-free areas at critical times (for breeding), the absence of competing species (for the same nest site).

• Species robustness Some species of flora or fauna are more sensitive to disturbance than others. For example, grasses are more robust than mosses or lichens; penguins and flying birds that lay eggs in advance of the tourist season are less likely to be disturbed than those that lay during the visitor season.

• Availability of open space The availability of open space is a critical factor at minimizing disturbance. Sites with restricted space leaving little or no room to walk around in without disturbing wildlife or trampling vegetation are less desirable than those where access is greater. Factors such as the location of walking trails, beach access and observation sites, relative to wildlife colonies and plant communities will also determine the extent of disturbance. Provided that sites with limited access are visited by tourists who are well educated at behavior ashore (and are supervised adequately), visits can occur without risk of disturbance.

• General topography Sites featuring limited or difficult access, steep terrain or long walks to get to points of interest are less likely to receive visits than those with easier access. Supervision on shore is a must in sites where access is limited to ensure that passengers don’t take the easiest route to and from the landing site (which might be through a penguin nest site or plant community).

• Novelty of the site Some sites have “uniqueness” to them or are “novel”, such as sites that have breeding colonies of crested (macaroni) penguins or a site like Deception Island whereby the ship sails into the water-filled caldera of an active volcano. Sites such as this will be more highly visited than sites that are not unique or novel.

• Ice and weather conditions Weather and the presence of sea ice are the two primary factors that will determine the day-by-day itinerary. Sites where sea ice does not break up until later in the season will be visited less than sites where there is no ice. Likewise, weather conditions, such as high winds or fog, will affect the number of landings at a particular site. Captains, ice masters and Expedition Leaders know sites that are usually “safe” – meaning that there is protection from the wind -- and will often rely on these sites when “blown- out” of another site. Sites such as these will be visited more often.

• Availability of safe anchoring or waiting sites The ability to get passengers to and from the ship safely and in a timely manner is crucial to the Zodiac and shore operations. Sites that feature weather conditions that are somewhat predictable (e.g. bays that are sheltered from prevailing winds), or with waiting areas where the ship has room to drift will be more desirable than sites that do not. From a risk standpoint, sites with protected anchorages present less risk of a vessel being blown on shore or being hit by drifting ice.

• Acoustic characteristics Acoustic disturbance (the sounds produced by the ship and Zodiac engines) can vary from site to site depending upon the depth of the water (where sound can be reflected off the bottom and shoreline) or topography of the land (where sound can be bounced off points of land and be focused in certain areas). If noise is loud or long lasting, the hearing of animals on land and in the water can be damaged.

• Location of comparable sites nearby

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Expedition Leaders strive to provide passengers with a wilderness experience – where they feel they are alone in the vast wilderness of the Antarctic. Expedition Leaders go to great lengths to avoid taking passengers to areas where other ships are known to be and IAATO Bylaws [and now ATCM requirements under Measure 15(2009)] prohibit more than one ship to land passengers at a site at one time. Therefore, in areas where there are a number of desired sites, Expedition Leaders will tend to congregate their visits in a small area to maximize landing opportunities (while avoiding other ships) rather than visit sites a farther distance away (but where another vessel is known to be).

Other factors include: • Meteorological information, • Availability of food sources or krill in close vicinity (to ensure wildlife have sufficient resources), • Presence of floating ice or snow pack, and • Presence or absence of an ice edge.

Following the workshop in 2000, IAATO members developed Wildlife Watching Guidelines (presently re-named General Wildlife, Cetacean, Seals and Birds) for vessel and Zodiac operations as part of the association’s suite of standard operating procedures. The guidelines were trialed during the 2001-02 season and adopted as an operational document in 2002. The guidelines are intended for use by any vessel (ship, small sailing vessel, Zodiac, kayak, etc.) to provide standard operating procedures while viewing cetaceans, seals and birds in their marine environment in order to avoid harmful impacts on marine wildlife populations by ensuring that the normal patterns of daily and seasonal activity of the animals are maintained in the short and long term. In addition, the guidelines suggest additional ways to comply with Annex II (Conservation of Antarctic Fauna and Flora) of the Environmental Protocol. The guidelines do not replace any domestic governmental laws or regulations, but provide an additional “code of conduct” to help reduce potential disturbance to the marine environment. As of the 2013- 14 season these guidelines were revised as IAATO General Information for Wildlife Watching, IAATO Cetacean Watching Guidelines, IAATO Seal Watching Guidelines, and IAATO Guidelines for Birdwatching. Guidelines for Leopard Seals were added more recently. As noted in Section 3.4.8, these can be found on the IAATO website at: http://iaato.org/wildlife-watching-guidelines.

IAATO’s Site Specific Guidelines33 were developed to minimize and further address potential cumulative impacts. The guidelines trialed during the 2003-04 season and adopted in 2004 are part of a wider strategic approach to minimizing impacts and go hand-in-hand with the ATCM-adopted Site Guidelines for Visitors (http://ats.aq/e/ats_other_siteguidelines.htm). (Some sites are covered under both sets of guidelines.) IAATO’s guidelines address the most popular visitor sites in the Antarctic Peninsula, with each site given an environmental sensitivity rating of low, medium or high. The basic reasons for ranking sites focuses on: • Species diversity, • Potential impact to flora and fauna, and • The amount of space available for tourists to walk around in.

Within IAATO there are standard operating procedures for Expedition Leaders to communicate (and make amendments to schedules) if there becomes a concern over a particular site that might be negatively impacted by future visits. There are also possible impact avoidance/mitigation measures, which can be considered (as addressed in Section 6). IAATO has also recommended modifications to ATCM-adopted “Site Guidelines for Visitors” when changes were deemed appropriate. Expedition Leaders are obligated to report on any environmental disturbances noted when filing their PVRs to their Competent Authority and IAATO, and in their end-of-season report to IAATO. IAATO also has a standard operating procedure for Incident Reporting should an environmental incident occur, e.g. pollution (oil spill, accidental discharge, etc.) or wildlife-related (e.g. harmful disturbance). As noted in Section 6.10.3, there is also a policy providing procedures for Expedition Leaders should a mass mortality event be discovered at any of the landing sites.

33 International Association of Antarctica Tour Operators, IAATO Site Specific Guidelines 2003 in the Antarctica Peninsula Further Addressing Potential Cumulative Impacts (IP 72, XXVI ATCM, Madrid, 2003).

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The proposed activities by the Expedition Organizer will produce outputs that will lead to cumulative impacts, however based on present knowledge, it is believed that the tourism activities that have occurred since Antarctic tourism began in 1966 – and as planned for the next five years – will have no more than a minor or transitory impact on the biological and physical aspects of the Antarctic Peninsula environment and associated and dependent ecosystems. However, if repeated often enough, all impacts have the potential to become cumulative.

GCC has planned their proposed activity to sites that are being visited by other tour operators and expeditions; however, limited baseline environmental monitoring data exists for the sites that will be visited by MV CORINTHIAN so it is difficult to judge the likely long-term cumulative effects of the visitation.

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8. MONITORING AND VERIFICATION

To ensure that the proposed activity complies with the minimization and mitigation measures outlined in Section 6, GCC has responsibility for monitoring and verification.

This will largely take place by the Expedition Leader in the day-to-day monitoring of activities and the compilation of the ATCM-adopted Post Visit Report (http://ats.aq/documents/recatt/att267_e.pdf) by the Expedition Leader at the conclusion of each voyage. Reports will include the details on off-ship and shore landings (site visit data), including the date, time, numbers involved, and the activities.

Reports to the head office will be supplemented by photo documentation, if necessary, to monitor and manage the ongoing effects of the activity on the locations being visited and their conservation values.

Any noted environmental disturbance, incidents (see below), scientific support or transport and medical evacuation will be noted and reported as appropriate.

Incidents may include but are not limited to any of the following: • Medivac involving several or many people, • Medical emergency involving serious injury or loss of life, • Vessel loss or incapacitation (e.g. grounding, sinking, collision, etc., • Any incident that involves the need to ask for assistance by another vessel or research station, • Logistical (e.g. a group stranded ashore for an extended period of time), • Environmental: Pollution (e.g. oil spill, accidental discharge, etc.), and • Environmental: Wildlife-related (e.g. harmful disturbance).

Day-to-day assessment and verification is the responsibility of ship’s command and the Expedition Leader for deciding whether a particular site will be visited. Among other things, the Expedition Leader will assess whether a particular site is showing signs of visitation and/or sensitivity and, if so, whether another site should be selected. Should this be the case, information is reported back to the Expedition Organizer and to the IAATO Secretariat for further action or follow up (e.g. with other tour vessels) if appropriate.

Nine factors have been identified that would suggest a site’s sensitivity to potential environmental damage. These include:34 1. Unusually high science values, which have the potential of being easily disturbed (e.g. the probability of disturbing a major project being conducted on site, or disturbing a site like the Dry Valleys, which has clearly “recognized” science value). 2. Presence of unusually high species diversity. 3. Presence of geological or physical features that may be easily disturbed (e.g. a rare penguin or other fossils). 4. Close proximity to a boundary of a protected area, which is poorly defined or easily encroached. 5. Presence of environmental elements that focus visitor attention and may be disrupted (e.g. species with very limited distribution or rare occurrence in the area, like macaroni penguins at Hannah Point). 6. Close proximity to southern giant petrel nests, this being one species of flying bird that is easily disturbed (Emslie, 1996; Trivelpiece, 1991). 7. Situations where nests of regularly encountered flying birds like blue-eyed shags, kelp gulls or Antarctic terns may be easily disturbed. 8. Restricted visitor space at a particular site, where there are only a very narrow (or perhaps, non-existent) pathways between visitors and penguins. 9. Presence of large beds or patches of moss or foliose-fruticose lichens, which may be easily accessed and trampled.

34 Ron Naveen, Oceanites, Antarctic Peninsula Compendium (1997a, revised 2011 3rd edition).

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These factors are known to Expedition Leaders through the work of the Antarctic Site Inventory Project and results published in the Antarctic Peninsula Compendium (http://www.oceanites.org/visiting/2011/APC_2011_3rd.pdf) that is used to make informed judgments about what landings sites to visit. As mentioned previously, this document is one of the key reference documents utilized by Expedition Leaders.

Along with other members of IAATO, a representative of the Expedition Organizer attends the IAATO Annual Meeting where representatives of government agencies and other interested parties are often in attendance. A review of the past season takes place, with comments from the Expedition Organizers received. Observer reports are also discussed and issues and concerns are raised. Updates to the FOM are made, ahead of the next operating season, to incorporate changes resulting from the Annual Meeting, as well as the most recent ATCM.

IAATO members continue to support a number of monitoring projects in the Antarctic Peninsula, which have attempted to establish baseline data against which the effects of tourist activity on shore can be measured.

Activities will be monitored throughout each season so that improvements can be made immediately to ensure not more than a minor or transitory impact on the locations, environment and culture (if applicable) being visited. An end of season review will also take place with the involvement of pertinent individuals so that improvements can be made to future operations as necessary.

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9. CONCLUSION

Antarctic tourism is a legitimate activity under the Antarctic Treaty System and GCC is committed to protecting the integrity of the Antarctic environment and its associated and dependent ecosystems through careful experience, pre-planning, and adherence to laws, regulations, guidelines and standard operating procedures.

Provided that the minimization and mitigation measures outlined in Section 6, the cumulative impacts in Section 7 and the monitoring and verification measures in Section 8 are met, the conclusion of this assessment is that the proposed activities of GCC are likely to have no more than a minor or transitory impact and no higher-level evaluation (e.g. a Comprehensive Environmental Evaluation) is necessary and the activity should be authorized to proceed.

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10. SKETCH MAP OF THE ANTARCTIC PENINSULA AREA

Sketch map of the proposed area of operation: Northern Antarctic Peninsula and the South Shetland Islands

Including the Falkland Islands (Las Malvinas) and South Georgia

Source: US Tour Operator’s Programmatic IEE, October 2007 – March 2012, multi-year document.

For illustrative purposes only; not for navigation.

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11. ACKNOWLEDGMENTS

• Alastair Newton, Captain Josko Duric, Rene Oosterhuis, Magdalena Zoroza, Sukie Reyes, Ana Rossi, Lenka Sliacka and Claudia Roedel for their assistance with the preparation of this document and for their insightful comments.

• The current and past IAATO Secretariat and the many IAATO member companies and expedition teams involved for their efforts since the association was founded in 1991 to develop the standard operating procedures and guidelines that have served as the foundation for safe and responsible Antarctic tourism operations to this day.

• Ron Naveen and colleagues at Oceanites for the Antarctic Site Inventory Project that has provided much of the data collection at the Antarctic Peninsula sites visited by the tour ships and for the knowledge this project has contributed towards the management and monitoring of human activity in Antarctica.

• Poles Apart Ltd. who developed the framework for the matrix of likely environmental impacts in Section 6 that this assessment has been modeled after.

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12. ACRONYMS

ACAP Agreement on the Conservation of Albatrosses and Petrels AIS Automatic Identification System AMVER Automated Mutual-Assistance Vessel Rescue System (http://www.amver.com) ARPA Automatic Radar Plotting Aids radar ASMA Antarctic Specially Managed Area (under Annex V of the Environmental Protocol) ASPA Antarctic Specially Protected Area (under Annex V of the Environmental Protocol) ATA Antarctic Treaty Area ATCM Antarctic Treaty Consultative Meeting ATCP Antarctic Treaty Consultative Party ATOM Antarctic Telecommunication Operators Manual (COMNAP) ATS Antarctic Treaty System (http://www.ats.aq) CCAMLR Convention on the Conservation of Antarctic Marine Living Resources CCAS Convention for the Conservation of Antarctic Seals CEP Committee for Environmental Protection (ATCM) CFR Code of Federal Regulations (US) COLREG Convention on the International Regulations for Preventing Collisions at Sea (IMO) COMNAP Council of Managers of National Antarctic Programs (ATCM) (http://www.comnap.aq) ECDIS Electronic Chart Display System EIA Environmental Impact Assessment (under Annex I of the Environmental Protocol) EMER Emergency and Medical Response Plan (IAATO) EPA Environmental Protection Agency (US) (http://www.epa.gov) EPIRB Emergency Position Indicating Beacon FOM Field Operations Manual (IAATO) GCC Grand Circle Corporation d.o.o. (Dubrovnik) GCCL Grand Circle Cruise Line (Boston and Buenos Aires) (http://www.gct.com/) GCF Grand Circle Foundation (Boston) (http://www.grandcirclefoundation.org/) GCSSC Grand Circle Small Ship Cruises (Boston) GCT Grand Circle Travel (Boston) (http://www.gct.com) GCTBA Grand Circle Travel (Buenos Aires) GCD Grand Circle Dubrovnik d.o.o. (Dubrovnik) GMDSS Global Maritime Distress and Safety System HFO Heavy Fuel Oil (under IMO) HSM Historic Sites and Monuments (under Annex V of the Environmental Protocol) IAATO International Association of Antarctica Tour Operators (https://www.iaato.org) IACS International Association of Class Societies IEE Initial Environmental Evaluation (under Annex I of the Environmental Protocol) IFO Intermediate Fuel Oil (IMO) IHO International Hydrographic Organization (http://www.iho.int) ILO International Labor Organisation (http://www.ilo.org/global/lang--en/index.htm) IMO International Maritime Organisation (http://www.imo.org/Pages/home.aspx) ISM International Management Code for the Safe Operation of Ships (as in ISM Code) ISPS International Ship and Port Facility Security Code (IMO) (as in ISPS Code) LRIT Long Range Identification and Tracking system MAPPPD Mapping Application for Penguin Populations and Projected Dynamics (http://www.penguinmap.com) (Oceanites/Lynch Lab at Stony Brook University & NASA) MARPOL International Convention for the Prevention of Pollution from Ships (IMO) MEPC Marine Environment Protection Committee (IMO) MGO Marine Gas Oil (under IMO) MLC Maritime Labour Convention (under ILO)

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MMPA Marine Mammal Protection Act (US) MRCC Marine Rescue Coordination Centre MSC Marine Safety Committee (IMO) NSF National Science Foundation (US) (http://www.nsf.gov) OAT Overseas Adventure Travel (Boston) (http://www.oattravel.com) PFD Personal Floatation Device (under SOLAS) PVR Post Visit Report (ATCM) PWOM Polar Water Operational Manual (IMO) SAR Search and Rescue SART Search and Rescue Transponder SCAR Scientific Committee on Antarctic Research (http://www.scar.org) SMM Ship Management Manual (GCC) SMS Safety Management System (IMO) (under ISM Code) SOLAS International Convention for the Safety of Life at Sea (under IMO) SOPEP Shipboard Oil Pollution Emergency Plan (under MARPOL/IMO)

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13. APPENDICES

13.1 Advance Notification 13.2 Background Information for Captains, Ice Pilot and Expedition Leader 13.3 IAATO Wildlife Incident Report Form 13.4 IAATO Whale Collision Reporting Form 13.5 IAATO Emergency Contingency Plan 13.6 IAATO Incident Report Form 13.7 IAATO Emergency and Medical Evacuation Response Plan (EMER) 13.8 IAATO List of South Orkneys and Antarctic Peninsula Sites 13.9 IAATO Criteria for Assessing New Sites 13.10 IAATO Guidelines for the Operation of Small Boats in the Vicinity of Ice 13.11 IAATO Standard Procedures for Station Visits 13.12 IAATO Boot, Clothing and Equipment Decontamination Guidelines for Small Boat Operations 13.13 IAATO Antarctic Pre-arrival Biosecurity Declaration 13.14 IAATO Guidelines for the Discovery of Non-native Species 13.15 Table 3 Matrix of Likely Environmental Impacts 13.16 IAATO Assessment of Potential Impacts and Mitigation Measures

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Appendix 13.1

ADVANCE NOTIFICATION

Please refer to the next 12 pages. Additional information is contained in Addendum 1 (six pages) and Addendum 2 (three pages).

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ADDENDUM 1 DS-4131 MS Corinthian - Grand Circle Corporation

A. Expedition Organizer

9. Explain activities undertaken by the organizer, including, for example, acquiring the use of vessels or aircraft, hiring expedition staff, or planning itineraries.

As the Expedition Organizer, GCC has responsibility for: -- acquiring the use of the vessel -- ensuring that the Master and Bridge Officers have experience appropriate to operations within the Antarctic Treaty Area as per IAATO Bylaws -- planning the itineraries -- filing Advance Notification for all voyages and serving as the point of contact -- filing an Environmental Impact Assessment and serving as the point of contact -- serving as the liaison with IAATO -- ensuring the planned activities comply with obligations under US law and tourism-related ATCM Measures, Resolutions and (older) Recommendations and according to IAATO’s membership standards -- scheduling the pre-season landing site visits through the IAATO Ship Scheduler -- overseeing the pre-season briefings of the department heads to applicable national regulations; ATCM tourism-related Measures, Resolutions and older Recommendations; and applicable IAATO guidelines and standard operating procedures -- taking the IAATO online assessment and ensuring the Expedition Leaders and Expedition Team are also certified at the appropriate level -- overseeing the day-to-day operation of all voyages during the season -- ensuring the IAATO Field Operations Manual is aboard ship for reference by appropriate personnel and that IAATO’s suite of standard operating procedures and guidelines are followed -- overseeing the off-ship passenger activities including the Zodiac operations and shore activities -- ensuring that passengers, crew and expedition staff are briefed appropriately prior to entry to the Antarctic Treaty Area including but not limited to briefings on ATCM Recommendation XVIII-1 (1994); any applicable ATCM Site Guidelines for Visitors; ATCM Resolution 3(2011); ASMA Management Plans; Protected Areas (e.g. ASPA, ASMAs and HSMs); as well as station visit guidelines, codes of conduct for behavior around wildlife, etc. -- compiling and filing the ATCM-adopted Post Visit Report at the conclusion of each voyage to US NSF and IAATO -- reporting on conducted activities at the conclusion of the season to IAATO

11. Explain whether any organizing activities will be or are being performed by a party or parties other than the named expedition organizer; e.g., a sub-charter. Identify the nationality of individuals or commercial entities to whom the expedition organizer has delegated specified organizational responsibilities.

Related companies include:

Grand Circle Corporation (GCC): GCC is the largest US provider of international vacations for Americans aged 50 and older. We’re a family of three brands: Grand Circle Cruise Line, Overseas Adventure Travel (OAT), and Grand Circle Travel. Our small group sizes, unsurpassed value and excellence, and unique itineraries position us as the industry leader in travel and discovery. GCC is a full (voting) Member (at the level of Operator) in good standing of the International Association of Antarctica Tour Operators (IAATO) having joined the Association on 08 August 2014. Website: www.iaato.org.

Grand Circle Dubrovnik d.o.o. (GCD):

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GCD is the largest GCT office in Europe, with ship and land operation departments, port agency, crewing agency and IT support, exclusively serving GCCL, Overseas Adventure Travel (OAT) and GCT land and ship programs, currently employing 60 people. The ship operation department is the holder of Document Of Compliance for passenger ship’s operation issued by the Flag State (Malta) proving that ships are operated in accordance with International Ship Management (hereafter ISM) standards on Safety, Security and Environmental Protection.

Grand Circle Cruise Line (GCCL): GCCL, based in Boston, MA has responsibility for sales and marketing, itinerary development (in concert with GCD), marine hotel operations, guest services (e.g. preliminary and final tour documentation), and the expedition team- related issues, including the selection and hiring of the expedition team and day-to-day supervision of this team. GCCL has an affiliated office in Buenos Aires, Argentina, where sales and marketing is also done. Website: www.gct.com. GCCL is also the corporation’s award-winning cruise division for Grand Circle Cruise Line Small Ship Cruise Tours and River Cruise vacations. This fleet consists of 50- to 250-passenger vessels that we either own or privately charter. All vessels are operated exclusively for GCCL, and have been custom-built according to the company’s specifications.

Grand Circle Travel (GCT): GCT handles sales and marketing activities at the company’s Boston, MA headquarters. GCT offers distinctive international vacations for older Americans. Established in 1958 by Ethel Andrus, educator and foundation of the American Association of Retired Persons (AARP), we view world travel as a powerful lever for lifelong learning. We make it accessible through trips that deliver unmatched discoveries, leisurely pacing, more travel choices, and comprehensive value.

Grand Circle Travel Buenos Aires (GCTBA): GCTBA handles organization of all South American trips on site, leading teams of Program Directors and Expedition Leaders and arranging all local activities.

The management teams at GCC, GCD, GCCL and GCTBA, are all highly experienced in expedition cruising having previous Antarctic experience, starting from 2001 and cooperating with different ship/tour operators. Through the 2016-17 season more than 6963 people have traveled to Antarctica with GCT/OAT.

Section B Details of Transport and Equipment to be Used for the Tour/Expedition

B1. Vessel/Aircraft Used for Transport To/From Antarctica

25. INMARSAT Number/Fax

Telephone: +49 172 6621252 Telefax: 00 1 3219539293 Inmarsat: 424955611/610 Iridium: 001 321 9539292 Inmarsat-C: 00870 764870072 MMSI: 249556000 SelCall: N/A Sat C. Telex: 00870 764870073

C. Contingency Planning

31. Type and Amount of Insurance Coverage, including Name(s) of Insurer(s)

P&I Club Class I – Protection & Indemnity Insurance Cover through Steamship Mutual Underwriting Association Limited / Aquatical House 39, Bell Lane, London E1 7LU (Association); Steamship P&I management LLP; Aquatical House 39, Bell Lane, London E1 / LU (managers). The Certificate of Entry is under GCCL (Malta) Fleet 4 Ltd.

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(Owner). Cover is extended from 20 February 2017 through 20 February 2018 for 1) Oil Pollution 2) Passengers and Seamen, and 3) Collision. Certificate no. 55294/1.

Hull & Machinery – Marine / War Risks – 2016/2018 through Aon Insurance (8 Devonshire Square, London, England, EC2M 4PL, UK). The Policyholder is Grand Circle Cruise Lines Holding B.V. with Grand Circle Corporation as one of the Insured. Policy number C0085728014. Cover is extended from 01 June 2016 through 01 June 2018.

Tour Operator’s General Liability Insurance, including Errors and Omissions, is in place through the producer Risk Strategies Company (160 Federal Street, Boston, MA 02110) and insured through Lloyds of London with Grand Circle Holdings, LLC as the insured. Certificate number 180/PD1431768. Cover is extended from 01 May 2017 through 01 May 2018.

32. Arrangements for self-sufficiency and contingency plans including for medical evacuations and search and rescue in the event of an emergency.

Appropriate contingency plans and sufficient arrangements for health and safety, search and rescue, and medical care and evacuation have been drawn-up and are in place for the proposed activities to meet obligations under ATCM Measure 4(2004) “Insurance Contingency Planning for Tourism and Non-governmental Activities in the Antarctic Treaty Area,” ATCM Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities in the Antarctic Treaty Area,” and IAATO requirements. Such plans and arrangements are designed so as not to be reliant on support from other operators or national programs.

The M/V CORINTHIAN maintains her Passenger Ship Certificate for unlimited worldwide expedition cruising under the SOLAS 1974 Convention (and as amended – see below), and is in compliance with present SOLAS (International Convention for the Safety of Life at Sea) and MARPOL (International Convention for the Prevention of Pollution From Ships) 1973/78 regulations. The vessel is also in compliance with ISM regulations.

Additional international agreements applicable to Antarctica of which the vessel is in compliance with include: -- International Convention on Oil Pollution, Preparedness, Response and Cooperation (OPRC), -- The Antarctic Treaty (1959), and -- Protocol on Environmental Protection to the Antarctic Treaty (1991) and its Annexes.

Lifesaving equipment includes 4 partially-enclosed Lifeboats for 48 persons each, 5 automatically inflated Life Rafts for 60 persons total, and 6 inflatable Zodiac-brand boats (type Mark V) for 12 persons each. The Lloyds Register Record of Equipment For The Passenger Ship Safety Certificate (Form P), which is a record of compliance with the International Convention for the Safety of Life At Sea 1974, as modified by the Protocol of 1988 relating thereto, is available upon request.

Members of IAATO, as well as ship’s command and Expedition Leaders, maintain regular and close coordination with Expedition Leaders aboard other tour vessels and small sailing vessels (e.g. yachts) in the Antarctic Peninsula. The vessel has a tracking device and participates in IAATO’s Vessel Tracking System, which is compulsory for members. (See also below.)

GCC complies with the IAATO-wide Emergency Contingency Plan agreed to at IAATO’s 14th General Meeting (May 2003, Seattle). The Plan provides for coordination of Emergency Plans (Emergency Contingency and Search and Rescue Plans) amongst IAATO Members. The cornerstones are to ensure that there is adequate emergency equipment available on board IAATO Member-operated ships, that ship schedules and positions are frequently updated and exchanged (as per IAATO’s Ship Reporting Schema), that an effective communication Plan (using the GMDSS system) is in place and that a reporting schema is developed in the event of a possible event and to provide for medical evacuation support. The Plan considers emergency situations, identifies currently existing plans and standard operating procedures to deal with emergencies, and recommends preventive measures.

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In terms of arrangements for self-sufficiency with specific regard to medical emergencies, in the event of a serious medical injury/illness to a passenger or crewmember, circumstances could require the ship to divert and to proceed as rapidly as possible to the closest port where competent medical care is available. Emergency evacuation, if required, is coordinated by ship's command, with the appropriate assistance of land agents, port agents or evacuation assistance companies to make whatever arrangements are necessary to safely evacuate or transport the passenger to the closest shore side facility where competent medical care can be provided. Evacuation may include transportation by any land, water, or air conveyance as required to transport the injured. The most suitable arrangements would be made, taking into consideration the severity of the illness or injury, the location where the evacuation or transportation must occur and the availability of shore side medical facilities. The ship's physician is to do whatever he/she possibly can to sustain the passenger until evacuation or transport can be enacted. Every effort is made to deal with the situation on board ship or by means that do not involve National Antarctic Program bases.

To minimize this potential impact, IAATO members are required to be part of a Emergency and Medical Evacuation Response Plan (EMER). GCC takes part in this plan, last updated in 2014. The IAATO EMER provides a checklist for member’s to follow in the event of a medical emergency. Each member is responsible for establishing arrangements its own air rescue service. Accordingly, we have contracted with AeroRescate S.A. for medivac services as of the 2014-15 season, subscribing to their priority service again for the 2015-16 season. This gives subscribers priority access to their aircraft (over non-subscribers) should a life-threatening medical emergency present itself that we were unable to deal with on board. AeroRescate is a Punta Arenas, Chile-based company, with more than 25 years’ experience operating small ambulance-equipped aircraft into Frei/Marsh Base on King George Island (South Shetland Islands). Their aircraft includes a King Air (10 pax) for passenger transport, manned by 2 pilots and 1 assistant, as well as a Twin Otter. AeroRescate’s pilots are highly experienced and have more than 10,000 flying hours on average. If AeroRescate is unable to assist, other medical evacuation companies would be contacted, for example, Aero Cardal, also based in Punta Arenas. In the worst-case scenario, the voyage would be cancelled if an air evacuation from Antarctica was not possible.

IAATO’s Emergency Contingency Plan and EMER and our company’s own established standard operating procedures provide for self-sufficiency under Antarctic Treaty Recommendation XVIII-1(1994) “Guidance for Those Organising and Conducting Tourism and Non-governmental Activities in the Antarctic,” Resolution 3(2011) “General Guidelines for Visitors to the Antarctic,” obligations under the Protocol on Environmental Protection to the Antarctic Treaty including the Environmental Impact Assessment procedure mandated in Annex I of the Protocol, and Resolution 6(2017) “Guidelines on Contingency Planning, Insurance and Other Matters for Tourist and Other Non-governmental Activities in the Antarctic Treaty Area.”

To minimize potential (and perhaps avoidable) medical emergencies, detailed medical questionnaires are forwarded to all passengers in advance of the tour. Completed questionnaires are screened by office personnel and the ship’s physician contacted should a question arise over someone’s suitability to undertake the voyage. Participants are advised that they may be cancelled from a program if deemed to have a physical condition or other disability that might create a hazard or lead to an unsuitable risk medical or otherwise. Once a reservation has been placed, participants are also provided with the company’s insurance carrier as it is a requirement to take out medical evacuation insurance coverage to cover the costs of a medical evacuation from Antarctica.

The vessel maintains a well-equipped medical infirmary on board, with a physician in attendance. Expedition staff members are trained in CPR and basic First Aid; two also have training in Wilderness Medicine.

To deal with the highly unlikely event of an emergency resulting in a stranding ashore, an emergency shore kit is taken ashore prior to every shore landing and returned to the ship at the conclusion of the landing, once passengers have been returned to the ship. The contents of the shore kit were determined by considering an emergency situation whereby up to 109 individuals (considering 100 passengers, 7 expedition staff plus 2 crew assisting) were stranded on shore for a time period of up to 12-24 hours. Our kit meets the requirements under IAATO’s “Advice on Shore Stranding Equipment for Vessel Operations” (adopted at IAATO’s Annual Meeting in

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June, 2009). It has been verified that a waste management permit is not required by the Office of Polar Programs/National Science Foundation since cook stoves and/or fuel are not contained in our emergency shore kit.

Garbage and human waste (liquid and solid) resulting from a stranding will be collected and returned to the ship for proper disposal using garbage/waste bags. If urine cannot be collected in garbage/waste bags the liquid wastes will be discharged directly into the sea in a manner that does not adversely affect the local environment (as per §671.12 Waste Disposal under the Antarctic Conservation Act of 1978). At no times will liquid waste (e.g. urine) be disposed of onto sea ice, ice shelves or grounded ice-sheets.

During all field operations, members of the expedition staff are equipped with portable VHF marine radios. A listening watch between the ship and staff is routinely maintained throughout.

D. Expedition Details 33. Planned Port of Embarkation 34. Planned Date of Embarkation (mm-dd-yyyy) 35. Planned Port of Disembarkation 36. Planned Date of Disembarkation (mm-dd-yyyy) 37. Planned Cruise/Flight Number or Voyage Name 38. Estimated Number of Passengers to be carried

Please see the listing below for answers to questions 33-38.

Voyage #1: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 12-12-2017 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 12-21-2017 Voyage Name/Number: “Antarctica’s White Wilderness”- Cruise #COR12DEC2017 Estimated number of passengers to be carried: 100

Voyage #2: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 12-21-2017 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 12-30-2017 Voyage Name/Number: Cruise “Antarctica’s White Wilderness”- Cruise #COR21DEC2017 Estimated number of passengers: 100

Voyage #3: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 12-30-2017 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 01-08-2018 Voyage Name/Number: Cruise “Antarctica’s White Wilderness”- Cruise #COR30DEC2017 Estimated number of passengers: 100

Voyage #4: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 01-08-2018 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 01-17-2018 Voyage Name/Number: Cruise “Antarctica’s White Wilderness”- Cruise #COR08JAN2018 Estimated number of passengers: 100

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Voyage #5: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 01-17-2018 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 01-26-2018 Voyage Name/Number: “Antarctica’s White Wilderness” – Cruise #COR17JAN2018 Estimated number of passengers: 100

Voyage #6: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 01-26-2018 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 02-07-2018 Voyage Name/Number: “Journey to the Antarctic Circle” – Cruise #COR26JAN2018 Estimated number of passengers: 100

Voyage #7: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 02-07-2018 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 02-19-2018 Voyage Name/Number: “Journey to the Antarctic Circle” – Cruise #COR07FEB2018 Estimated number of passengers to be carried: 100

Voyage #8: Port of Embarkation: Ushuaia, Argentina Date of Embarkation: 02-19-2018 Port of Disembarkation: Ushuaia, Argentina Date of Disembarkation: 02-28-2018 Voyage Name/Number: “Antarctica’s White Wilderness” – Cruise #COR19FEB2018 Estimated number of passengers: 100

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ADDENDUM 2 DS-4131 MS Corinthian - Grand Circle Corporation

Please see the listing below for answers to question 40.

40. Proposed itinerary with dates and places to be visited. Include a proposed itinerary for all expeditions that will proceed south of 60 degrees South Latitude, even if there is no intention for individuals to disembark onto land.

The itineraries as scheduled on IAATO’s Ship Scheduler follow, however the itineraries are still preliminary and can change at the last minute based on weather and ice conditions, unknown conflicts with other vessels or other reasons outside of our control. Dates and landing sites in the Antarctic Treaty Area are highlighted.

The final itineraries will be determined on board by the Captain and Expedition Leader.

Corinthian Grand Circle Corporation CLE 12-Dec Tue (EP) Ushuaia (15:00) 13-Dec Wed At Sea 14-Dec Thu Yankee Harbor (14:01) Orne Harbor (09:01) / Orne Islands (14:01) / Ronge 15-Dec Fri Island/Georges Point (14:01) Petermann Island (09:01) / Pleneau Island (14:01) / Port 16-Dec Sat Charcot (14:01) Goudier Island (09:01) / Jougla Point (09:01) / Damoy 17-Dec Sun Point/Dorian Bay (14:01) 18-Dec Mon Whalers Bay (09:01) / Half Moon Island (14:01) 19-Dec Tue At Sea 20-Dec Wed At Sea 21-Dec Thu (DP) Ushuaia (11:00) / (EP) Ushuaia (15:00) 22-Dec Fri At Sea 23-Dec Sat Aitcho Islands - Barrientos Island (14:01) Orne Islands (09:01) / Ronge Island/Georges Point (09:01) / 24-Dec Sun Neko Harbor (14:01) 25-Dec Mon Yalour Islands (09:01) / Hidden Bay (14:01) 26-Dec Tue Palmer Station (09:01) / Palmer Station (14:01) 27-Dec Wed Half Moon Island (09:01) / Whalers Bay (14:01) 28-Dec Thu At Sea 29-Dec Fri At Sea 30-Dec Sat (DP) Ushuaia (15:00) / (EP) Ushuaia (15:00) 31-Dec Sun At Sea 1-Jan Mon Aitcho Islands - Barrientos Island (14:01) Brown Station (09:01) / Skontorp Cove (09:01) / Neko Harbor 2-Jan Tue (14:01)

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Pleneau Island (09:01) / Port Charcot (09:01) / Yalour Islands 3-Jan Wed (14:01) Damoy Point/Dorian Bay (09:01) / Goudier Island (14:01) / 4-Jan Thu Jougla Point (14:01) 5-Jan Fri Whalers Bay (09:01) / Half Moon Island (14:01) 6-Jan Sat At Sea 7-Jan Sun At Sea 8-Jan Mon (DP) Ushuaia (15:00) / (EP) Ushuaia (15:00) 9-Jan Tue At Sea 10-Jan Wed Aitcho Islands - Barrientos Island (14:01) 11-Jan Thu Neko Harbor (09:01) / Cuverville Island (14:01) 12-Jan Fri Petermann Island (09:01) / Vernadsky Station (14:01) Goudier Island (09:01) / Jougla Point (09:01) / Damoy 13-Jan Sat Point/Dorian Bay (14:01) 14-Jan Sun Whalers Bay (09:01) / Half Moon Island (14:01) 15-Jan Mon At Sea 16-Jan Tue At Sea 17-Jan Wed (DP) Ushuaia (15:00) / (EP) Ushuaia (15:00) 18-Jan Thu At Sea 19-Jan Fri Aitcho Islands - Barrientos Island (14:01) Esperanza Station (09:01) / Kinnes Cove/Madder Cliffs 20-Jan Sat (14:01) 21-Jan Sun Half Moon Island (09:01) / Whalers Bay (14:01) 22-Jan Mon Torgersen Island (09:01) / Palmer Station (14:01) 23-Jan Tue Danco Island (09:01) / Melchior Islands (14:01) 24-Jan Wed At Sea 25-Jan Thu At Sea 26-Jan Fri (DP) Ushuaia (09:00) / (EP) Ushuaia (15:00) 27-Jan Sat At Sea 28-Jan Sun Aitcho Islands - Barrientos Island (14:01) 29-Jan Mon Cuverville Island (09:01) / Neko Harbor (14:01) Petermann Island (09:01) / Pleneau Island (14:01) / Port 30-Jan Tue Charcot (14:01) 31-Jan Wed Detaille Island (09:01) / Detaille Island (14:01) 1-Feb Thu Vernadsky Station (09:01) / Yalour Islands (14:01) Damoy Point/Dorian Bay (09:01) / Goudier Island (14:01) / 2-Feb Fri Jougla Point (14:01) 3-Feb Sat Cierva Cove (09:01) / Mikkelsen Harbor (D'Hainaut) (14:01) Whalers Bay (09:01) / Hannah Point (14:01) / Walker Bay (by 4-Feb Sun Hannah Point) (14:01) 5-Feb Mon At Sea 6-Feb Tue At Sea 7-Feb Wed (DP) Ushuaia (10:00) / (EP) Ushuaia (15:00)

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8-Feb Thu At Sea 9-Feb Fri Aitcho Islands - Barrientos Island (14:01) 10-Feb Sat Melchior Islands (09:01) / Neko Harbor (14:01) Brown Station (09:01) / Skontorp Cove (09:01) / Danco Island 11-Feb Sun (14:01) Petermann Island (09:01) / Pleneau Island (14:01) / Port 12-Feb Mon Charcot (14:01) 13-Feb Tue Detaille Island (09:01) / Detaille Island (14:01) 14-Feb Wed Yalour Islands (09:01) / Vernadsky Station (14:01) Goudier Island (09:01) / Jougla Point (09:01) / Damoy 15-Feb Thu Point/Dorian Bay (14:01) Whalers Bay (09:01) / Hannah Point (14:01) / Walker Bay (by 16-Feb Fri Hannah Point) (14:01) 17-Feb Sat At Sea 18-Feb Sun At Sea 19-Feb Mon (DP) Ushuaia (10:00) / (EP) Ushuaia (15:00) 20-Feb Tue At Sea 21-Feb Wed Aitcho Islands - Barrientos Island (14:01) 22-Feb Thu Cuverville Island (09:01) / Neko Harbor (14:01) Petermann Island (09:01) / Pleneau Island (14:01) / Port 23-Feb Fri Charcot (14:01) Damoy Point/Dorian Bay (09:01) / Goudier Island (14:01) / 24-Feb Sat Jougla Point (14:01) Hannah Point (09:01) / Walker Bay (by Hannah Point) (09:01) 25-Feb Sun / Whalers Bay (14:01) 26-Feb Mon At Sea 27-Feb Tue At Sea 28-Feb Wed (DP) Ushuaia (10:00)

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Appendix 13.2

Background Information for Captain and Expedition Leaders

Captain and Ice Pilot:

Captain Yaroslav Gonta will be in command as Master of the vessel for the season – from 12 December 2017 through 28 February 2018. Joining him for the season as Ice Pilot is Ivan Karavka.

Their Resumes follow.

Expedition Leader:

Claudia Roedel will join as the Expedition Leader for the season – from 12 December 2017 through 28 February 2018.

Her biographical sketch follows.

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Expedition Leader Biography

Claudia Roedel

Claudia Roedel is a biologist graduated by the University of São Paulo, Brazil. After graduation she moved to Manaus, in the Amazon, where she trained as a field researcher in Tropical Ecology by INPA (Institute for Research in the Amazon). She lived in the Amazon for five years, assisting research projects on the ecology of lizards, alligators, turtles, amphibians and birds. She also conducted radio telemetry and vertebrate population surveys for subsequent population dynamics analysis.

In 1989 Claudia started working with expedition cruises first as a guide on the Amazon River and then expanded to leading eco-tourism adventure travelers in the forest of Costa Rica, Panama, Venezuela, the Guianas and further around the world to Africa, Asia and Australia. Not limiting herself only to the tropical ecosystems, her knowledge includes also the polar and sub-polar Antarctic regions.

Working aboard expedition vessels, Claudia has found the perfect opportunity to combine her knowledge of the underwater world and her expertise as a dive master with her profound interest in history and art – being a skilled watercolor artist and photographer.

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Appendix 13.3

IAATO Wildlife Incident Report Form

Background: At IAATO 24 in Punta Arenas, it was noted that there appears to be increasing reports of incidents with wildlife. It was decided by the Field Operations Committee to compile a list of incidents every year to attempt to establish a baseline and to determine if there is any need for any measures to address specific incidents with wildlife. The incidents that need to be reported include: 1. Any incident where an animal has been injured or killed as a result of human activities, whether or not by tourism operations. E.g. removing fishing nets from around seals’ necks etc. (Note: it is against the law in many countries to euthanize injured animals in the Antarctic) 2. Any incident where the animal interacts with tourists or tourism operations in a threatening manner e.g. where a leopard seal bites and punctures a zodiac or interacts with a kayak, or a diver, in a manner that could be potentially dangerous. This report form is for information and data collection purposes only. A complete description of the incident is particularly useful.

Information needed: Date / Time (local): Site or GPS co-ordinates: Ship name: Expedition Leader: Description of incident:

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Appendix 13.4

IAATO Whale Collision Reporting Form Updated August 2014

In case of a whale collision, please send the following information to [email protected]. This report will be forwarded to the International Whaling Commission for their database.

1. Date of event: (Day/month/year)

2. Species struck: (Known or suspected species struck)

3. Fate of Whale: (Killed, Injured, Unknown)

4. Name of Ship/Length of Ship/Tonnage:

5. Speed of Ship at time of Collision: (in Knots)

6. Location of Event: Latitude / Longitude

7. Brief Description of the Event: • Time of event (hour and was this during day, night or dusk)? • Sighting conditions (sea state, weather, visibility)? • Was whale seen just before the collision? • If seen before the collision, distance in front of the vessel? • What was the whale’s behavior (e.g. swimming at surface, feeding, breaching, etc.)?, Was there any sign of a response to the vessel (e.g. sudden dive or change of course)?, Were other whales seen with the whale or in the area? • Was the strike felt or heard aboard ship? • Was an injured or dead animal or blood in water seen after strike? • Was the whale caught and carried to the bow of the ship? • Was there any damage to the ship?

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Appendix 13.5

IAATO Emergency Contingency Plan

Please refer to the next three pages.

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Appendix 13.6

IAATO Incident Report Form

Please refer to the next two pages.

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Appendix 13.7

IAATO Emergency and Medical Evacuation Response (EMER), 2006 (September 2006 – Updated April 2014)

The following is IAATO’s emergency contingency outline, which can be used by its members as a checklist and, if needed, incorporated into their emergency procedures. Each company is responsible for establishing its own air rescue service if required.

IAATO VESSEL MEDICAL EMERGENCY CONTINGENCY PLAN

1. The Antarctic Treaty Consultative Meeting (“ATCM”) Recommendation XVIII-1obligates organizers and operators going to the Antarctic to be self-sufficient. Procedures to assist IAATO-member passenger vessels in the Antarctic in the event of critically sick or injured passengers are designed to facilitate self-sufficiency.

2. IAATO Members are encouraged to strongly recommend that its passengers provide the company and or medical doctor on board the vessel with a medical evaluation form as reference during the voyage. In addition, IAATO Members are encouraged to strongly recommend that their passengers take out comprehensive medical and evacuation insurance, which will reimburse passengers for the cost of medical evacuation in the event of an emergency.

MEDICAL EMERGENCY CONTINGENCY PLAN

In the event of serious accident or life-threatening situation, requiring medical attention beyond the ship's medical capabilities/facilities, the following procedure should be implemented.

ASSESSMENT

Consider the alternatives. A decision is made onboard that the best option for the critically sick or injured individual is emergency evacuation. This decision, by the shipboard physician and patient or family, is to be made in concert with the expedition leader and captain of the vessel.

INITIAL ACTION

Prior to contacting an appropriate or agreed medevac agency, confirm the following information is available:

1. Name of the staff member on board who will coordinate the situation.

2. Current position, route and speed of the vessel.

3. Current weather and recent forecasts available.

4. Information on any other vessels in the local area, and the contact details.

5. Name and precise details of the injured/sick person and their condition, with a complete medical evaluation by the ship's physician in writing. Include the time of the incident, abstract from the ship's log,

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chronology of intervention and any medical history. Provide the name of the patient's consulting physician at home and emergency contact information for the patient.

6. How many other persons will accompany the injured party from the vessel and the approximate weight and volume of their luggage?

7. What medical facilities/anticipated treatment will be required at the destination, and any drugs needed for the patient or to restock the vessel.

8. The anticipated final destination of the injured/sick person.

SECONDARY ACTION

1. Contact the 24-hour emergency number in the home office and be prepared to provide the above information -- and anything else that may be relevant to the situation.

2. The emergency station is to contact all known means of evacuation and research the availability of aircraft, cost and best available option for the passenger and vessel.

3. The emergency station is to advise the contact person aboard the vessel and await a decision regarding the injured party.

4. Once a decision is made for action, the emergency station is to contact the transportation company and arrange for evacuation at a specified time and place. A suitable landing site is to be agreed and a suggested time, pending weather conditions. Details of how the passenger will be moved are to be given to the emergency station.

5. Medical facilities at the destination are to be alerted and an ambulance or other requested form of transport should be at the airport upon arrival of the patient.

6. The emergency station is to advise the cruise company's home office or 24-hour contact of the situation and provide the patient's emergency contact information.

7. Two copies of a detailed medical report completed by the attending ship's physician is to be transferred with the patient for the attention of the emergency station. A copy is to be given to the doctor at the destination.

8. Advise the emergency station of any anticipated additional forms or paperwork that may be required by a medical insurance company.

9. Advise the emergency station of any vessels, stations or organizations you have contacted regarding the situation.

10. The vessel is to maintain regular contact with the emergency station until the passenger is uplifted from the agreed point and a schedule established with the ship's captain for the preferred means of communication (telephone, fax or radio).

FINAL ACTION

1. Once the evacuation of the passenger is completed, the vessel is to be informed of the arrival of the vessel or aircraft and passenger at the destination.

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2. From this point, the emergency station is to coordinate directly with the cruise company's home office regarding the ongoing condition of the passenger, providing regular updates.

3. The emergency station is to remain in regular contact with the passenger until the situation is normalized or responsibility is transferred to another party.

4. A full report is to be submitted by the emergency station to the cruise company regarding the pick-up and services of the station, including an invoice for expenses incurred.

5. The cruise company is to send a brief report to [email protected] providing the date and reason for the medical evacuation. The report should include what, happened when it happened, where it happened and the follow up.

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Appendix 13.8

IAATO List of South Orkneys and Antarctic Peninsula Sites

Please refer to the next 13 pages.

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Appendix 13.9

IAATO Criteria for Assessing New Sites (rev 2012)

Periodically, visitor landings take place at sites that have not been visited before (at all, or by those involved in the expedition) and for which there is only limited information available. These opportunistic visits are rarely pre- planned: more often they arise from adjustments to itineraries, although occasionally simply to explore a new area. Before landing passengers, the expedition leader and staff reconnoiter the site to assess practicability, environmental sensitivity, and safety of the landing.

The following guidelines formalize the on-going process of assessment prior to landing visitors, which are used by IAATO member operators with the aim of encouraging similar assessments by other non-IAATO ‘visitors’. These criteria should be considered in conjunction with the other guidelines that regulate IAATO-member shore activities.

Environmental & scientific considerations o Is the site in close proximity to a protected area? o Is there unusually high species diversity? o Are there species on the edge of their biogeographical distribution? o Are their rare species that may be easily disturbed? o Are there giant petrel, Antarctic tern or Kelp gull nesting sites that may be easily disturbed? o Are there geological or physical features that maybe easily disturbed? o Are there extensive areas of vegetation to be avoided? o Are there any scientific activities taking place which might be disturbed o Does the site hold unusually high scientific values that you are aware of? (e.g. on Deception Island, in the Dry valleys etc.)

Visitor Management considerations

o Is there sufficient visitor space to land up to 100 people? o Is it an area which requires small guided groups? o Are there specific areas to keep visitors out of or away from?

Safety considerations. o How exposed is the landing area, and is it safe for small boat operations? o Are there any specific environmental hazards which visitors need to be kept away from?

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Appendix 13.10

IAATO GUIDELINES FOR SMALL BOAT OPERATIONS IN THE VICINITY OF ICE

Please refer to the next three pages.

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Appendix 13.11

IAATO Standard Procedures for Station Visits

As the number of visits to stations increases, it is increasingly important to remember the basic procedures for visiting stations. These procedures also apply to stations, which are only intermittently occupied, e.g. Almirante Brown (Brown Base).

A recurring problem is accurate contact details for stations. If during the season, updated information on best means of contacting individual stations becomes available, please circulate this to other vessels and to IAATO at [email protected].

General Procedures

• Station visits should be requested well in advance of the voyage; note that certain countries have very specific procedures for requesting visits to their stations (e.g. UK and USA) – these must be followed. • Expedition Leaders should always contact station leaders of any planned station visit 72 hours in advance of the visit. • Individual procedures determined by national programs/station leaders should always be followed. • Provide timely notice of cancellation, generally 48 hours in advance. • Please include any additional station contact information, standard procedures or incidents involving stations, ships or government personnel in your voyage report to the home office.

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Appendix 13.12

IAATO Boot, Clothing and Equipment Decontamination Guidelines for Small Boat Operations

Introduction: Aware of the potential for visitors, including tourists, to be vectors either for disease or introduction of non-native species into the unique Antarctic ecosystem IAATO Members developed these procedures in 1999/2000. Regularly reviewed and updated, these procedures have become a recognized cornerstone of IAATO Member’s actions to promote and practice safe and environmentally responsible tourism to the Antarctic. The procedures are similar to the decontamination practices of those countries which protect themselves against the introduction of external diseases or alien organisms, and are mandatory on all IAATO member operations. We ask you to be fully familiar with these procedures and take strict steps ensure they are followed. We strongly encourage you to have passengers, crew and staff sign a declaration, similar to the sample below.

Please note: the term ‘visitors’ refers to all ship’s crew, boat drivers, staff, guides and lecturers as well as to passengers. For the purposes of this information small boat is defined as a Zodiac, RIB, Naiad, Avon, Polarcirkle or similar small landing craft.

1. Pre-Voyage Information • Visitors are advised that Antarctica is an isolated continent and believed to be largely free of introduced diseases and non-native species. We must ensure that it remains so. • Visitors are advised that all boots and clothing must be clean before joining the ship. Those who go trekking, tramping, backpacking, or farm visiting prior to the voyage must clean their boots, clothing and equipment thoroughly to remove all foreign material. Tripod feet and backpacks can also collect mud and seeds and should be checked thoroughly before joining the ship. Velcro attachments attract seeds and must be thoroughly checked and cleaned before departure to Antarctica.

2. Pre-Landing Briefing • Visitors need to be reminded that they must have clean boots, clothing and equipment before proceeding ashore. A vacuum cleaner will be provided to clean backpacks, bags and pockets, and facilities, known as the boot-washing station, will be available on deck for them to clean their equipment and their clothing. Equipment will be checked thoroughly, preferably by a member of the ship’s staff or crew, prior to their first landing. • In particular, checks of pockets, seams, turn-ups in trousers, hoods of jackets and Velcro fastenings should be made to ensure that no soil, seeds or any other organic material remain. Daypacks and bags should be brushed out and vacuumed to remove all such material prior to arrival in the Antarctic. • Any outer clothing or equipment that might be used ashore should be thoroughly decontaminated.

3. Boot-Washing Station • This is a facility on the deck, at the head of the gangway, or close to where passengers board the ship. It requires: § running water and a hose – preferably high pressure to ensure complete removal of debris; § drainage of water off the ship; § scrubbing brush and/or coarse mat and shallow tray in which all debris can be scrubbed from boots and clothing;

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§ a second tray of water with disinfectant such as Virkon S35; § a member of staff or crew to assist visitors to inspect their boots and clothing for complete decontamination. • Before and after each landing all visitors going ashore must walk through the boot-washing station and ensure that boots are free of debris and disinfected. • Boat crews may board via a different route to their passengers and should ensure they also complete the decontamination process. • Take care to also ensure that small boats and the gangway are clean.

4. Landings • Where possible, avoid walking in concentrations of organic material such as guano, seal placenta, or seal faeces, in order to avoid moving this material around the landing site. • Before boarding the small boat to return to the ship, debris especially organic matter such as guano – should be washed off boots and clothing as much as is possible. A simple brush scrubber at the landing site should be used to clean boots before entering the Zodiac (or other small boat landing craft) at the end of the landing period. Do not forget to clean the debris off the brushes before returning to the ship. Ensure that whatever touched the ground (backpacks in particular), boot cuffs, or exposed velcro are inspected, and cleaned before leaving the landing site. Seeds and other vegetation in the Sub-Antarctic islands can easily be transported if all visitors are not vigilant. • Where appropriate, clothing pockets can be turned out for vacuuming by staff on the ship as a precaution against transport of seeds. • On returning to the ship, boots, clothing and equipment must be cleaned thoroughly and disinfected at the boot-washing station. The disinfectant should not be rinsed off, but allowed to dry thoroughly on the article between landings. • At the end of each landing, small boats should be inspected, and when necessary cleaned, to ensure that no foreign material is transported between sites.

5. Between Landings • Every effort must be made to ensure that boots and clothing dry out completely between landings. (Desiccation is an important mode of controlling some micro-organisms.) Visitors should be reminded in subsequent pre-landing briefings to inspect their boots and clothing to ensure that they are clean and no foreign material is present.

35 As detailed in the IAATO Introduction and Detection of Diseases in Antarctic Wildlife and the paper Identification of an Agent Suitable for Disinfecting Boots of Visitors, it is recommended that a disinfectant be used at the boot washing station. To date, the disinfectant Virkon S is perceived as being the most effective. Be aware that careful handling of Virkon S is essential and instructions for use should be adhered to.

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Appendix 13.13

ANTARCTIC PRE-ARRIVAL BIOSECURITY DECLARATION

I have thoroughly cleaned all items which will come into contact with the ground ashore. This includes removing any material and washing with the disinfection solution all footwear to be worn ashore, tripod/monopod feet and walking sticks, ski poles, snowshoes etc. In addition, I have removed all seeds and loose items from the pockets, folds and Velcro of all items to be worn or taken ashore, including all clothing, particularly outerwear, my backpack, camera bag, etc.

• I understand the need for biosecurity between Antarctic regions and individual landing sites to prevent the introduction of alien plants or diseases. • I undertake to clean all necessary items before and after each landing in the Antarctic & Sub-Antarctic Islands including South Georgia. • I agree not to take food ashore (except if individually permitted by the Expedition Leader) and not to dispose of any waste either ashore or overboard.

Cabin Name

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Appendix 13.14

IAATO Guidelines for the Discovery of Non-Native Species

Based on UK guidelines for visitors upon finding a suspected terrestrial or freshwater non-native species within the Antarctic Treaty Area

Introduction

A species apparently new to the Antarctic Treaty Area may be (i) a recent natural colonist (e.g. by wind or bird transport), (ii) a recent human introduction (e.g. associated with cargo, clothing or personal belongings) or (iii) a long-term inhabitant that has never before been identified by science. It is important to know the colonisation history of a new species as this will affect how it is managed: for example, non-native species introduced by human activities should be eradicated if possible.

Determining which category a newly discovered species falls into is often difficult and it is essential that expert advice is sought at the earliest opportunity. The discovery of a suspected non-native species should be treated as a potentially serious environmental incident. Those new species that show clear signs of reproducing and increasing their distribution range are of greatest concern. Please follow the guidelines detailed below.

General guidelines

1. Ensure all recommended biosecurity/quarantine procedures are performed (boot washing/clothes inspection, etc.) to minimise the risk of distributing the newly discovered species or its propagules to other locations.

2. At the earliest opportunity, inform the relevant Competent Authority (i.e. the authority that issued the permit or authorisation to enter the Antarctic or alternatively the authority who has jurisdiction over any recognised expert in a position to eradicate the species) and send the information outlined in paragraphs 4-6 below.

3. Do not remove or eradicate a newly discovered species upon first finding it unless: a) specifically directed to by a relevant Competent Authority or a recognised expert, b) removal can be achieved safely, or c) it is a rodent, in which case it should be eradicated immediately.

4. Please take digital photographs of the newly discovered species as found initially. Include in the image an object for scale (e.g. pen or coin) and, if possible, take close-up pictures of any features (e.g. for plants this may include leaves, flowers and/or seeds).

5. General information to be recorded and supplied to the CEP and relevant Competent Authority a) location where new species was discovered including, if possible, the GPS co-ordinates b) time and date of discovery c) weather conditions d) extent of snow cover e) type of substratum colonised by the new species (e.g. moss/lichen/rock/mineral soil/organic material-rich soil/guano/etc.). f) purpose of your visit to the location g) contact details of (i) the members of the discovering party and (ii) their logistics coordinator (Base Commander and National Operator/Tour Leader and Tour Company)

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6. If the newly discovered species is a plant, please also record: • the number of plants and/or the ground area covered • the presence of seeds or flowering structures • the relative sizes of the individual plant, i.e. are all the plant individuals roughly the same size, or is there a variety of plant sizes?

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Appendix 13.15

Table 3 - Matrix of Likely Environmental Impacts

Please refer to the next two pages.

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Appendix 13.16

IAATO Assessment of Potential Impacts and Mitigation Measures

Ship and Voyage Matrix

Activity Output Impacts Nature Duration Nature Scope Persis- Inten- Proba- Impor- tence Sity bility Tance Burn Fuel Seasonal/ Hydrocarbons, Contamination/ L L L H L Constant Heat, Trace, Chemical Pollution Fuel Spill Seasonal/ Fuel Contamination/ L M-L H L H Constant Pollution Waste Oil Seasonal/ Oil Contamination/ L M-L L L H Constant Pollution Waste Seasonal/ Sewage Nutrient L S L L L Generation Constant Grey water Enrichment/ Contamination Seasonal/ Garbage Pollution L S L L M Constant Seasonal/ Batteries Heavy Metal L S L L H Constant Pollution Seasonal/ Poultry Infect Birds L M-L H L H Constant Incinerate Seasonal/ Emission Contamination/ L S L L H Constant Pollution Discharge Seasonal/ Ballast Introduced R L H L H Ballast Constant Species Litter Seasonal/ Waste Aesthetic L M L M M Constant Use Lights Seasonal/ Light Disturbance L S L L L Constant Transit Disturbance/ R M L H L Ocean Aesthetic Breaking Nov, Feb, Noise Contamination/ L S L L L Ice Mar/Hours Disruption Pollution Maneuver- Seasonal Noise/ Feeding/ L M L H L Ing 1-3 days Turbulence Distribution Wildlife Nov-Dec/ Noise/ Contamination/ L S L M L Watching Hours Turbulence Pollution Anchoring Seasonal/ Disturbance L M-L M-L H M-H 4-12 hours Benthos/ Turbulence Entering Seasonal/ Disturbance/ L S-M S-M L H Protected 4-12 Hours Affect Science Areas Scope L-Local, R=Regional Probability L=Low, M=Medium, H=High Persistence L=Long, M=Medium, S=Short Importance L=Low, M=Medium, H=High Intensity….L=Low, M=Medium, H=High

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Note: This preliminary presentation of potential impacts of tour ships and voyages was developed at the IAATO Workshop on Environmental Assessment 1997 along with tables for impacts of boat activity and shore activity. These tables are being further developed and this sample table is included for discussion only.

Nesting Penguins and Potential Impacts

The primary method of ensuring that any impacts are no more than minor or transitory is through avoidance and management of visits. Recommendation XVIII-1 will be observed at all times.

Species Potential Impact Action Taken Adélie Penguin Disturbance of readily accessible Remain outside periphery of rookeries colonies at nest site, at landing beaches, during nesting period; give penguins right and of molting birds. of way at landing beaches; move slowly around molting birds Chinstrap Penguin Disturbance of nests (often in small Remain outside periphery of rookeries groups on steep ground up to 100 during nesting period; give penguins right meters in elevation), at landing beaches, of way at landing beaches; move slowly and of molting birds around molting birds. Gentoo Penguin Disturbance of easily accessible nests, at Remain outside periphery of rookeries landing beaches, and of molting birds during nesting period; give penguins right of way at landing beaches; move slowly around molting birds. Macaroni Penguin Potential disturbance of birds due to its Maintain distance from nesting rarity in the region. This species is a rare individuals; avoid surrounding birds, post local breeder, nesting on Elephant staff at site to supervise. Remain outside Island, and in small numbers at Hannah periphery of rookeries during nesting Point. period; give penguins right of way at landing beaches; move slowly around molting birds.

Nesting Flying Birds and Potential Impacts

The primary method of ensuring that any impacts are no more than minor or transitory is through avoidance and management of visits. Recommendation XVIII-1 will be observed at all times.

Species Potential Impact Action Taken Southern Giant Petrel May be particularly vulnerable to Identify nesting areas in briefings, post staff disturbance at nests, which are on site and maintain distance from nests. often exposed. Birds will vigorously defend eggs and chicks Southern Fulmar Nil, nest on inaccessible ledges Observe with binoculars at sea Cape Petrel Unintentional disturbance of hidden nests Most colonies inaccessible, view from Zodiac or small boats or approach colonies on inland cliffs in company of staff only Snow Petrel Nil, uncommon summer breeder high on cliffs or nunataks Generally observed with binoculars at sea in

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areas of pack ice Antarctic Petrel Nil, transient in region Generally observed with binoculars at sea Wilson’s Storm Petrel Unintentional disturbance of Avoid scree, glacial rubble and other hidden nesting sites potential nest sites, view from Zodiac Antarctic Blue-eyed Shag Unintentional disturbance at Maintain distance and watch for threat colonial nest sites, usually displays. Incubating or brooding birds tend conspicuous and often accessible to hold fast to nests Greater Sheathbill Unintentional disturbance at Locate and maintain distance from nest nests, usually solitary and in sites. Disturbed birds will often run from crevices or overhangs near nests and vocalize penguin rookeries South Polar Skua Unintentional disturbance at Avoid wandering, particularly on high, difficult-to-see, scattered nests snow-free ground. Pay attention to on open ground. Chicks vocalizing birds and back off. Skuas will dive- camouflaged. bomb intruders Brown Skua Unintentional disturbance at nest Avoid wandering, particularly on high, scrapes, usually near penguin snow-free ground. Pay attention to rookeries. vocalizing birds and back off. Skuas will dive- bomb intruders Kelp Gull Unintentional disturbance at nest Avoid nest sites, watch for calling gulls. sites, often colonial in rocky Birds will easily fly-off nests and not defend areas near the sea from skuas and other predators Antarctic Tern Unintentional disturbance of Avoid nesting areas. Birds will loudly nests, often on pebbly ground advertise and dive-bomb if approached too above high tide. Typically closely. Suffer predation colonial.

Marine Mammals and Potential Impacts

The primary method of ensuring that any impacts are no more than minor or transitory is through avoidance, Zodiac guidelines for operating around wildlife, instructions to Captains, and management of visits. Recommendation XVIII-1 and the Marine Mammal Protection Act will be observed at all times.

Species Potential Impact Action Taken Seals Antarctic Fur Seal Disturbance on non-breeding or Avoid landing at beaches with numbers of fur post-breeding individuals at seals, view from Zodiac. Maintain distance landing beaches in February and from individuals encountered ashore, do not March block egress to sea Crabeater Seal Disturbance on individuals Follow Zodiac guidelines around wildlife, resting on ice floes or rarely maintain distance ashore, do not block egress ashore to sea Leopard Seal Disturbance of individuals resting Follow Zodiac guidelines around wildlife, on ice floes, trailing Zodiac or maintain course and speed, maintain distance rarely ashore ashore, do not block egress to sea Weddell Seal Disturbance on individuals Follow Zodiac guidelines around wildlife, resting on ice floes or ashore maintain distance ashore, do not block egress to sea Southern Elephant Seal Disturbance of pups ashore early Maintain distance ashore, do not block egress in season and of molting groups to sea, post staff at wallows ashore later in season Whales

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Orca Disturbance of groups at bow Maintain vessel course and speed wake of vessel Minke Whale Disturbance of individuals Follow Zodiac or small boat guidelines and encountered while in Zodiac or instructions to Captain, maintain parallel small boat or in vicinity of vessel course and speed Humpback Whale Disturbance of individuals in Follow Zodiac or small boat guidelines and vicinity of vessel or Zodiac or instructions to Captain. Depending on activity, small boat humpbacks will approach stopped Zodiac small boat or vessel. Do not surround Hourglass Dolphin Disturbance of small groups, Maintain vessel course and speed associated with Antarctic Convergence, will follow ships Other Whales Disturbance of individuals Follow Zodiac or small boat guidelines and encountered in vicinity of vessel instructions to Captain. Rarely encountered or Zodiac or small boat

Terrestrial Flora and Fauna and Potential Impacts

The primary method of ensuring that any impacts are no more than minor or transitory is through avoidance and management of visits. Recommendation XVIII-1 will be observed at all times. Lakes, melt water pools, stream banks and extensive areas of moss will not be visited.

Species Potential Impact Action Taken Grass (Deschampsia Antarctica) Physical disturbance of low Avoid areas of grass, keep to tracks where mats established Pink (Colobanthus quitensis) Physical disturbance of Avoid stepping on cushions, keep to tracks compact cushions Crustaceous lichens including species Physical disturbance of low- Avoid stepping on or holding onto lichen-covered of Verrucaria, Caloplaca, and growing brown, black, yellow rocks, avoid climbing on cliffs Xanthoria) or orange colonies, characteristic of coastal cliffs Fruticose and foliose Lichens Physical disturbance of Avoid stepping on or holding onto lichen-covered including Usnea and Umbilicaria delicate hairy or upright rocks, avoid climbing on cliffs lichens, characteristic of dry, exposed, rocky terrain Moss hummocks, including Bryum, Physical disturbance of Avoid stream banks and edges of meltwater pools Brachythecium and Tortula carpets and tall hummocks associated with melt water Moss cushions and turf, including Physical disturbance of Avoid extensive areas of moss, walk carefully so as stands of Chorisodontium and patches, often on sandy or not to disturb Polytrichum peaty soil Bryophyte carpet and mat, including Physical disturbance of Avoid wet ground with extensive moss carpets Brachythecium and Drepanocladus carpets, usually found in wet habitats at visitor sites Algal mats (Prasiola crispa) Nil, thrives on disturbed None. Widespread, conspicuous species in coastal ground in areas of regions mechanical disturbance Terrestrial invertebrates, including Habitat disruption in areas of Avoid disturbing habitats springtails, mites, midges and soil, rock, gravel and moss tardigrades

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Natural • Annual variations in climate and marine productivity • Microclimatic effects • Predation at the colony and at sea

Human-induced • Global warming and ozone depletion • Fisheries • Tourism • Scientific studies • Research stations and permanent bases

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