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Systematic Expansion of the Antarctic Protected Areas Network

Systematic Expansion of the Antarctic Protected Areas Network

IP 134

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Agenda Item: CEP 9e Presented by: ASOC Original: English Submitted: 31/5/2019

Systematic expansion of the protected areas network

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IP 134

Systematic expansion of the Antarctic protected areas network

Information paper submitted by ASOC1

Summary This document examines some key issues concerning protected areas in and suggests practical ways forward with a focus on Antarctic Specially Protected Areas (ASPAs). There is a general understanding that the list of Antarctic protected areas needs expanding according to a “systematic environmental-geographic framework” as required in the Protocol’s Annex V, Art. 3(2). Conceptual progress has been made through the consideration of Environmental Domains and Antarctic Conservation Biogeographic Regions (ACBRs). Databases of relevant information are available and the methodology for systematic conservation planning is well established. Currently there are no legal, scientific or practical arguments to delay the expansion of the protected area network in Antarctica. ASOC recommends that ATCPs commit to a timeline of key activities for expanding the system and increasing protection levels for all ACBRs and beyond.

Introduction Human presence in Antarctica is increasing, driven by a range of regional and global processes. The human footprint takes a sizeable component of ice-free areas in Antarctica.2 Notwithstanding that activities related to science and associated logistics, as well as commercial activities, will continue for the foreseeable future (or precisely for that reason), Antarctic Treaty Parties need to limit the impact of human presence on the environment and other intrinsic values of Antarctica recognised by the Protocol. Further tangible steps are required to achieve this goal, and these include various forms of area protection. Globally the significance of protected areas has been recognised through the Sustainable Development Goals, and protected areas in Antarctica and the will be a contribution to these goals. Preservation and conservation are among the criteria of the 1959 Antarctic Treaty and are reflected in later instruments adopted by Antarctic Treaty Parties. These include a plethora of area protection and management categories adopted over the years, more recently with the adoption of the Protocol on Environmental Protection to the Antarctic Treaty. Annex V of the Protocol provides guidelines for the establishment of specially protected and management areas.3 This document examines some key issues concerning protected areas in Antarctica and suggests practical ways forward with a focus on Antarctic Specially Protected Areas (ASPAs). While not discussed here, it should be noted that other types of area protection and management in Antarctica are also relevant to the functioning of the ASPA network given issues of adjacency and ecosystem continuity. These include Antarctic Specially Managed Areas also adopted by the ATCM and marine protected areas adopted by the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR).

Analysis The analysis below is broadly structured around the main terms of reference of the “SCAR-CEP Joint SCAR/CEP Workshop on Further Developing the Antarctic Protected Area System” conducted before ATCM XLII, namely: 1. Review of the current status of the Antarctic protected area system. 2. Identification of information and resources relevant to designating ASPAs within a systematic environmental-geographic framework and 3. Identification of actions that could be taken to support the further development of the Antarctic protected area system.

1 Lead authors Ricardo Roura and Claire Christian, with contributions from Eli Webster and Rodolfo Werner. 2 Brooks et al 2019. 3 For an overview see for instance McIvor et al 2019. 3 IP 134

Reviewing the current status of the Antarctic protected area system Earlier spatial protection instruments in Antarctica aimed to protect planned or ongoing research and/or particular ecosystem features. In both instances, these protected areas were often located in close vicinity of existing research facilities.4 Practical and geopolitical reasons may have played a role in their location too.5 Subsequently, the protected area regime received some impetus with the adoption of the Protocol and its Annex V.6 Paradoxically, the adoption of ASPAs has slowed down since then. There are at present 72 ASPAs, over 70% of which were first adopted before the Protocol.7 However, the ATCM/CEP have been engaged in protected area discussions in the past 20+ years, including the clarification of some conceptual issues and active management of the network. About 50% of the Measures adopted by the ATCM in recent years have concerned the Protected Area network, and have largely focused on the periodic review of existing ASPAs and other Annex V instruments. More recently, three ASPAs have been de-designated and others have been earmarked for possible delisting in the future, following regular reviews. In parallel two new ASPA proposals are under development. CEP I in 1998 noted that there were “…gaps in the system with some protected area categories as set out in Article 3(2) of Annex V being very poorly represented or not represented at all”.8 Recent analysis reinforces that the network is not yet fully adequate and needs further expansion.9 The network of protected areas has gaps with respect to ASPA distribution and attributes as well as limited coverage outside ice-free areas, including ice shelves, the subglacial environment and the marine environment.10 This is contrary to requirements to identify and list a number of area categories according to a “systematic-environmental geographic framework” referred to in Annex V, Article 3(2). This framework itself was further conceptualized through the 2000s with work on Antarctic Domains and Antarctic Conservation Biogeographic Regions (ACBRs).11 Tables 1 and 2 illustrate aspects of the current protected area system.12 There is strong scientific evidence underscoring the need to enhance the current network of protected areas in accordance with requirements of the Protocol and its Annex V. In order to do this, the identification of particular areas within environmental domains or ACBRs for designation as ASPAs could follow well established processes of systematic conservation planning (hereafter SCP).13 This process should also consider local and global processes affecting Antarctica, as well as an expanding human footprint and the need for scientific reference areas and natural refugia. In addition, Table 3 illustrates the listing of ASPA categories A-I of Annex V Art. 3 of the Protocol with ACBR categories.

Information and resources relevant to designating ASPAs within a systematic- environmental - geographic framework Environmental Domains and ACBRs provide a framework for designating a representative series of ASPAs within a systematic environmental-geographic framework as referred to in Article 4(2) of Annex V of the

4 McIvor et al 2019. 5 Hughes and Grant 2016. 6 The Protocol on Environmental Protection to the Antarctic Treaty was signed in Madrid on October 4, 1991 and entered into force in 1998. Annex V on Area Protection and Management was adopted separately by the 16th ATCM in 1991 and entered into force in 2002. 7 ASOC 2017. 8 CEP I 1998 report, para 48. 9 Shaw 2014, Coetzee et al 2019. 10 See Roura, Steenhuisen and Bastmeijer (2018) for a discussion on the application of Annex V to the marine environment. 11 McIvor et al 2019. See also Morgan et al 2007, New Zealand 2008. 12 Based on Roura, Steenhuisen and Bastmeijer 2018 including supporting documentation. 13 ASOC 2016. For instance, Margules and Pressey (2000) identify the following SCP steps: measure and map biodiversity, identify conservation goals for the planning region; review existing reserves; select additional reserves; implement conservation actions on the ground; and management and monitoring of reserves. 4 IP 134

Protocol. The Antarctic Treaty Parties have agreed that these spatial frameworks can guide the designation of additional ASPAs, and the CEP has recognised the need for a more systematic approach to the development of the protected area system.14 Thus, the principal remaining task is to actually develop proposals and designate areas based on data availability and other factors. As noted above methodologies for strategic conservation planning are well established.15 In addition, a number of databases are available to begin the work of identifying areas that merit protection.16,17 While Environmental Domains and ACBRs focus essentially on the terrestrial environment, connectivity to the marine environment should also be a factor in the consideration of ASPAs. Local and regional pressures, and vulnerability (or resilience) to climate change impacts should also be considered.

Actions to support the further development of the Antarctic protected area system ASOC suggests that the ATCM should initiate a five- to ten-year SCP process to identify and designate new ASPAs. In practice, this requires agreeing on a SCP process that aims to: • Identify and eliminate gaps in protection from the nine categories of areas identified in Annex V, Article 3(2). • Combine evidence-based decision making with the precautionary approach, since the data available to feed into the ASPA designation process will vary locally, regionally and at a continental level. • Consider the current state of the environment as well as current and foreseeable future pressures. Both pristine and particularly threatened areas could merit additional protection through inclusion in the ASPA list.18 Threat factors include, but are not limited to, infrastructure development related to base construction, airlinks, overland traverses, tourism, fishing within the foraging range of land-based predators, and the introduction of non-native species. • Continue to consider other relevant processes outside the ATCM that may benefit the assessment and designation of ASPAs, including Important Bird Areas (IBAs), Important Marine Mammal Areas (IMMAs) and CCAMLR MPAs. • Consider protecting areas that can be used as reference areas to attribute changes to climate change with no or minimal interference from local and regional activities. Reference areas are particularly valuable in regions that are rapidly changing as a result of climate change such as the . • Consider ASPAs that might be redundant.

With respect to the last point, in recent years it has been considered useful to remove some areas from the ASPA list as a demonstration of flexibility of the Protocol’s Protected Area regime. While flexibility may help to enhance a protected area regime initiated decades ago, having areas protected from interference for a long time is in itself of value for science and other Protocol values. Such areas may merit consideration of extended protection, even if the original reasons for protection are no longer relevant. This is particularly the case for areas that have been well documented in the past and may provide evidence relevant to identify change.

14 McIvor et al 2019. 15 Margules and Pressey 2000. 16 In 2017, ASOC compiled a draft online database of datasets that it hoped could be useful in designating new ASPAs (ASOC 2017, Appendix 1). This database is based upon Supplementary Table S1 Major existing, and status of potential, biodiversity datasets across the Antarctic region from Coetzee et al. 2017. 17 For instance, Quantartica (https://quantarctica.npolar.no/) is a collection of Antarctic geographical datasets which works with the free, cross-platform, open-source software QGIS. The Antarctic Environments Portal (https://www.environments.aq) contains peer reviewed information summaries including basic bibliography and other information about key Antarctic environmental issues. 18 In a study of human footprint Antarctica-wide Brooks et al (2019) report that “the footprint of all buildings to be >390,000 m2, with an additional disturbance footprint of >5,200,000 m2 just on ice-free land. These create a visual footprint similar in size to the total ice-free area of Antarctica, and impact over half of all large coastal ice-free areas. Our data demonstrate that human impacts are disproportionately concentrated in some of the most sensitive environments, with consequential implications for conservation management.” 5 IP 134

Discussion: Taking action, implementing change The SCP process will ultimately result in the collection and analysis of spatial data aimed to define areas that meet certain conservation criteria. This process may involve some technical and scientific complexities, but these are not unsurmountable. Rather the greatest obstacles to completing it are likely to be political. To facilitate this aspect of the process running smoothly it would be helpful to take some practical measures that can help overcome the difficulties the ATCM often experiences in trying to achieve outcomes on complex topics. For example, CEP initiatives such as the Climate Change Response Workplan (CCRWP) have proved difficult to manage, due in part to numerous potential areas of work. The creation of the Subsidiary Group on Climate Change Responses (SGCCR) was a positive step forward as this led to a rethinking of the CCRWP. This experience could inform future work to operationalize and organize a SCP process for protected areas. However, the nature of the ASPA/ASMA designation process will in some ways require more individual commitments from ATCPs in terms of putting forward proposals. ASOC therefore suggests that there needs to be a mechanism for individual ATCPs and SCAR to commit to various activities or identify areas they can pursue further, rather than simply reiterating the deficiencies of the system. As an example, previous work identified five ACBRs as not having any ASPAs.19 This requires concrete steps towards identifying and designating ASPAs in these areas, and opportunities provided for ATCPs or SCAR to carry out various aspects of needed work. While there is a clear desire to strengthen the protected areas system, similar processes are often difficult and time-consuming even when occurring within a single country. Given the number of stakeholders and countries involved in the ATCM and CEP, it is worth further examining some aspects of previous SCP processes to identify characteristics that can help ensure a successful outcome. There is a large body of literature that has sought to quantify and analyse various aspects of SCP. While it has not always been easy to draw firm or universal conclusions, there is some useful guidance in this literature and from organisations like IUCN that have developed best-practice manuals. Resource requirements are one aspect of work that are not always explicitly discussed in the context of the protected areas system. IUCN notes in a guide for national planning processes that a “system plan” is important for any protected areas planning process, and that this plan: “[S]hould be based on a pragmatic assessment of the resources which need to be mobilised for its implementation…[w]ithout adequate social, political and financial support, protected area systems will fail.”20 ASOC does not expect that there will be a “budget” allocated per se for future ASPAs work. Nevertheless, estimating required resources, including personnel, could help move actions forward. ATCPs may find it easier to commit to various activities if they are well-defined. If a group of experts with experience in SCP could work together to analyse the current situation and develop a rough outline of tasks and the capacity required to do those tasks, ATCPs could more easily determine how to support the process. Ultimately SCP processes cannot be considered successful if there is no implementation in terms of actual protected areas. A recent paper highlights the importance of developing strategies for moving from SCP to implementation, and has developed a “conceptual framework” that can inform how planners can effectively make the transition.21Any future plans for expanding the ASPA network should include considerations using this and other analyses from the large literature on SCP.

19 Shaw et al 2014. 20 Davey 1998. 21 Adams et al. 2018. 6 IP 134

Conclusions There is a general understanding among Antarctic Treaty Parties and the conservation science community that the list of Antarctic protected areas needs expanding according to a systematic environmental- geographic framework. This work should further expand to all ASPA categories in the area covered by Annex V and extend beyond solely ACBRs. Some considerable progress has been made since the entry into force of the Protocol including developing a better understanding of Environmental Domains and ACBRs. ASOC is thankful to the Parties, organizations and individuals who facilitated this work. The recent SCAR/CEP protected areas workshop (27-28 June 2019) is also a positive step forward, as is the proposed work between SCAR and IAATO with respect to systematic conservation planning in the Antarctic Peninsula. Currently there are no legal, scientific or practical arguments to delay the expansion of the protected area in Antarctica in accordance to the requirements of the Protocol and other instruments. Rather, the obstacles seem to lie elsewhere; for example, in the tensions between commonly agreed environmental objectives (as outlined in the Protocol and other instruments adopted by the ATCM) and how well these align with the national interests of individual Treaty Parties. In this context ASOC urges Parties to work together towards achieving the area protection objectives of the Protocol to which all Parties have committed.

Recommendations ASOC recommends ATCPs to: • Commit to a timeline of key activities for expanding the protected system and increasing protection levels for all ACBRs. • Consider ways to streamline the process of ASPA listing and review so that there can be a focus on expansion of the network and less work spent on the minutiae of minor reviews. • Develop a process to earmark new areas as part of a systematic planning process rather than individually. • Expand this same analysis elsewhere in Antarctica beyond solely ACBRs.

References Adams et al. 1998. Adams VM, Mills M, Weeks R, Segan RB,Pressey RL, Gurney GG, Groves C, Davis FR, Álvarez-RomeroJG (2018). “Implementation strategies for systematic conservation planning.”AMBIO 48: 139–152. ASOC 2008. ATCM XXXI/CEP XI, IP057, Area Protection: Time for Action, ASOC (2008). ASOC 2012. ATCM XXXV/CEP XV, IP049, Annex V Inviolate and Reference Areas: Current Management Practices, ASOC (2012). ASOC 2013. ATCM XXXVI/CEP XVI, IP060, Mapping and modelling wilderness values in Antarctica: Contribution to CEP’s work in developing guidance material on wilderness protection using Protocol tools, ASOC (2013) ASOC 2015a. ATCM XXXVIII/CEP XVIII, IP109, Antarctic Tourism and Protected Areas, ASOC (2015) ASOC 2015b. TCM XXXVIII/CEP XVIII, IP112, Expanding Antarctica’s Protected Areas System, ASOC (2015) ASOC 2016. ATCM XXXIX/CEP XIX, IP080A Systematic Approach to Designating ASPAs and ASMAs, ASOC (2016). ASOC 2017. ATCM XL CEP XX, IP153, Considerations for the systematic expansion of the protected areas network. Brooks et al 2019. Brooks ST, Jabour J, van den Hoff J, Bergsrom DM. (2019). “Our footprint on Antarctica competes with nature for rare ice-free land”.Nature Sustainability (2019) Volume 2, pages185–190 (2019). DOI: 10.1038/s41893-019-0237-y

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Coetzee et al 2017. Coetzee, B.W.T, Convey, P &Chown, S. 2017. “Expanding the protected area network in Antarctica is urgent and readily available.”Conservation Letters: 1-32; Davey 1998. Davey, AG. 1998. National System Planning for Protected Areas. IUCN, Gland, Switzerland and Cambridge, UK. Hughes and Grant 2017. Hughes, K.A. & Grant, S.M. 2017.“The spatial distribution of Antarctica’s protected areas: A product of pragmatism, geopolitics or conservation need?” Environmental Science and Policy 72: 41-51; Margules and Pressey 2000.C. R. Margules & R. L. Pressey. (2000). “Systematic Conservation Planning.,” Nature 405, no. 6783: 243–253, doi:10.1038/35012251. McIvor et al 2019. McIvor E, Hughes KA, Ortúzar P, Penhale P, Terauds A. Specially protected and managed areas in Antarctica (Updated). Information Summary. Version: 2.0. Published: 03/04/2014 GMT. Reviewed: 15/04/2019 GMT. DOI: 10.18124/jwgc-aw03. https://www.environments.aq/information-summaries/specially-protected-and-managed-areas-in- antarctica-updated/ New Zealand 2008. ATCM XXXI/CEP XI.,WP057 submitted by New Zealand (2008): (Systematic Environmental Protection in Antarctica: Final report on Environmental Domains Analysis for the Antarctic continent as a dynamic model for a systematic environmental geographic framework for Annex V of the Protocol. Morgan et al 2007.F. Morgan, G. Barker, C. Briggs, R. Price, H. Keys, "Environmental Domains of Antarctica version 2.0 Final Report," (Manaaki Whenua Landcare Research New Zealand Ltd. Available at: http://www.ats.aq/devEM/documents/001718_np.pdf, 2007). Roura, Steenhuisen and Bastmeijer 2018. Roura RM, Steenhuisen F and Bastmeijer K (2018): "The shore is the limit: marine spatial protection in Antarctica under Annex V of the Environmental Protocol to the Antarctic Treaty". The Polar Journal 2018 Vol 2. https://doi.org/10.1080/2154896X.2018.1541549

Shaw et al 2014.Shaw, J.D., Terauds, A., Riddle, M.J., Possingham, H.P. &Chown, S. 2014. “Antarctica’s protected areas are inadequate, unrepresentative and at risk.” PLoS Biology 12: 1-5.

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Appendix 1 - Tables Data sources: See below.

Table 1 - ASPAs according to primary reason for designation with reference to the ASPA categories listed in Annex V, Art. 3(2) Primary reason for ASPA designation Area (km2) Total ASPAs

A - areas kept inviolate from human interference so that 5.44 2 future comparisons may be possible with localities that have been affected by human activities B - representative examples of major terrestrial, 59 10 including glacial and aquatic, ecosystems and marine ecosystems C - areas with important or unusual assemblages of 1643 36 species, including major colonies of breeding native birds or mammals D - the type locality or only known habitat of any species 0.00 n/a E - areas of particular interest to ongoing or planned 1022 9 scientific research F - examples of outstanding geological, glaciological or 658 6 geomorphological features G - areas of outstanding aesthetic and wilderness value 405 1 H - sites or monuments of recognised historic value 0.30 6 I - areas as may be appropriate to protect the values set 14 2 out in Article 3 paragraph1 of Annex V Grand Total 3808 72

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Table 2 - ASPAs listed according to primary reason for designation with reference to the ASPA categories listed in Annex V, Art. 3(2)according to date of designation (before or after entry into force of Annex V on 2002).

Primary reason for ASPA designation Pre- Post- Grand 2002 2002 Total

(km2) (km2) (km2)

A - areas kept inviolate from human interference so that future 0.04 5.40 5.44 comparisons may be possible with localities that have been affected by human activities

B - representative examples of major terrestrial, including glacial 59 59 and aquatic, ecosystems and marine ecosystems

C - areas with important or unusual assemblages of species, 1160 483 1,643 including major colonies of breeding native birds or mammals

D – the type locality or only known habitat of any species n/a

E - areas of particular interest to ongoing or planned scientific 988 33 1,022 research

F - examples of outstanding geological, glaciological or 112 546 658 geomorphological features

G - areas of outstanding aesthetic and wilderness value 405 405

H - sites or monuments of recognised historic value 0.12 0.17 0.30

I - areas as may be appropriate to protect the values set out in 15 15 Article 3 paragraph1 of Annex V

Grand Total 2740 1068 3808

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Table 3 ASPA categories listed in the Protocol Annex V, Art. 3(2), and their coverage in Antarctic Conservation Biogeographic Regions showing surface area in km2 and total number of ASPAs (in brackets). (Preliminary listing).

ACBRs 11 (), 12 (Marie Byrd Land). 14 (Ellsworth Land) and 15 (S Antarctic Peninsula) are not represented in the series of ASPAs, nor is the category D of ASPAs as listed in the Protocol Annex V 3 (2).

Data sources – see below.

ASPA categories ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR Grand Protocol Annex V, Art. 3(2) 1 2 3 4 5 6 7 8 9 10 13 16 Total Area NE South NW Central S Enderby Dronning E N S Transantarctic Adélie Prince km2 Antarctic Orkney Antarctic Antarctic Land Maud Antarctica Victoria Victoria Mountains Land Charles (No. Peninsula Is. Peninsula Peninsula Land Land Land Mountains ASPAs) A - areas kept inviolate from 0.04 5.4 5.44 human interference so that (1) (1) (2) future comparisons may be possible with localities that have been affected by human activities

B - representative examples of 27 4.7 4.9 21 1.5 0.4 59 major terrestrial, including (3) (3) (1) (1) (1) (1) (10) glacial and aquatic, ecosystems and marine ecosystems

C - areas with important or 860 181 6.5 30 271 (2) 226 54 14 1643 unusual assemblages of (13) (1) (1) (5) (9) (1) (4) (36) species, including major colonies of breeding native birds or mammals D - the type locality or only n/a known habitat of any species (0)

E - areas of particular interest 983 4.3 5.2 29 1021 to ongoing or planned (6) (1) (1) (1) (9) scientific research

F - examples of outstanding 0.4 2.5 109 102 424 21 658 geological, glaciological or (1) (1) (1) (1) (1) (1) (6) geomorphological features

G - areas of outstanding 405 405 aesthetic and wilderness value (1) (1)

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ASPA categories ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR ACBR Grand Protocol Annex V, Art. 3(2) 1 2 3 4 5 6 7 8 9 10 13 16 Total Area NE South NW Central S Enderby Dronning E N S Transantarctic Adélie Prince km2 Antarctic Orkney Antarctic Antarctic Land Maud Antarctica Victoria Victoria Mountains Land Charles (No. Peninsula Is. Peninsula Peninsula Land Land Land Mountains ASPAs) H - sites or monuments of 0.03 0.09 0.17 0.30 recognised historic value (1) (3) (2) (6)

I - areas as may be 15 15 appropriate to protect the (2) (2) values set out in Article 3 paragraph1 of Annex V Grand Total 0.36 27 1851 290 4.93 11 158 307 1069 54 0.55 35 3808 Area km2 (1) (3) (24) (2) (1) (2) (8) (6) (16) (1) (3) (5) (72) (No. ASPAs)

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Information sources for tables Data Sources Comments Basic Antarctic Treaty Secretariat Antarctic Treaty Secretariat Includes number, name, values information protected area database. protected, original designation about instruments, proponent/s. https://ats.aq/devPH/apa/ep_protected.aspx?lang=e) ASPAs/ASMAs Surface area Quantarctica data catalog data and (http://quantarctica.npolar.no/data-catalog/). coordinates for • ASPAs: Terauds, A. (2016, updated 2016) An ASPAs/ASMAs update to the Antarctic Specially Protected Areas (ASPAs), March 2016, Australian Antarctic Data Centre. http://dx.doi.org/10.4225/15/572995579cd36 Primary reason Antarctic Treaty Secretariat protected area database Descriptors are as follows: for ASPA (https://ats.aq/devPH/apa/ep_protected.aspx?lang=e), A. areas kept inviolate designation in based on reasons as stated by proponents during from human accordance submission of Annex V proposals and/or review of interference so that with Article 3 management plans. future comparisons (2) Resolution 3 (2018) Revised Guide to the presentation may be possible with of Working Papers containing proposals for Antarctic localities that have Specially Protected Areas, Antarctic Specially Managed been affected by Areas or Historic Sites and Monuments requires listing human activities; of primary reason for designation under Annex V, B. representative Article 3(2). Note many ASPAs have more than one examples of major reason for designation. terrestrial, including glacial and aquatic, ecosystems and

marine ecosystems; C. areas with important or unusual assemblages of species, including major colonies of breeding native birds or mammals; D. the type locality or only known habitat of any species; E. areas of particular interest to ongoing or planned scientific research; F. examples of outstanding geological, glaciological or geomorphological features; G. areas of outstanding

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Data Sources Comments aesthetic and wilderness value; H. sites or monuments of recognised historic value; and I. such other areas as may be appropriate to protect the values set out in paragraph 1 above. Basic Terauds et al 2012, 2016. information about ACBRs

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