ATCM 12, CEP 10
United States Report of Inspections
United States Report of Inspections
Information Paper submitted by the United States
The United States conducted an inspection under the Antarctic Treaty from November 12 to December 1, 2006. The attached report describes the observations and conclusions of the 2006 U.S. Antarctic Treaty Inspection Team. A summary of overall conclusions is included in this information paper.
The United States conducted an inspection under Article VII of the Antarctic Treaty and Article 14 of the Protocol on Environmental Protection from November 12 to December 1, 2006, the twelfth U.S. inspection since the Antarctic Treaty entered into force in 1961. The attached report produced by the Inspection Team describes the observations and conclusions of the Team.
The United States carries out a long-term program of inspections in order to promote peace and security in Antarctica and to determine whether parties to the Antarctic Treaty are meeting their obligations under the Treaty and related instruments. The United States’ program of inspections helps emphasize that the Antarctic continent is open to access by all countries. The last U.S. inspection was conducted in 2001.
As part of this inspection, the United States inspected a number of tour vessels operating in Antarctica. This was the first time that the United States had inspected tour vessels. A review of tour operations was undertaken because of the considerable attention that has recently been devoted by Treaty Parties to issues related to tourism and the increasing number of tourists visiting Antarctica. The United States hopes that observations made in this report will assist the Treaty Parties in assessing and weighing policies related to tourism in Antarctica this ATCM.
The Inspection Team arrived in the Antarctic Treaty Area on November 14, having departed Punta Arenas, Chile, on November 12, 2006, on the National Science Foundation’s ice-strengthened vessel M/V Laurence M. Gould. The Inspection Team inspected the following stations: Rothera (United Kingdom), O’Higgins (Chile), German Receiving Station at O’Higgins (Germany), Esperanza (Argentina), Bellingshausen (Russian Federation) and Great Wall (People’s Republic of China). The Team inspected the following vessels, with the permission of the masters of each: M/S National Geographic Endeavour, M/S Lyubov Orlova, and M/S Explorer II. The Team also visited the U.S. science field camp at Petermann Island in order to review how tour operations are conducted at the site, and U.S. Palmer Station. The Inspection Team returned to Punta Arenas on December 1, 2006.
The United States sent relevant chapters to the governments of stations inspected as well as to the three tour companies, and gave them an opportunity to comment. Comments received by February 12, 2006, were taken into account by the United States in the final draft. All governments were asked by the United States whether they wanted their comments to be distributed by the United States at the ATCM. As the Governments of Argentina and Chile indicated that they did wish their comments to be distributed by the United States, they are attached to this information paper.
2. General Conclusions in the Inspection Report
On the basis of its observations, the Inspection Team reached the general conclusions stated below. Conclusions, including recommendations, related to individual stations are contained at the end of the chapters in the report covering those stations.
A. Antarctic Station Operations
The inspectors found a high degree of knowledge of, and respect for, the Antarctic Treaty and the Environmental Protocol, in addition to applicable measures, guidelines, and domestic laws implementing those instruments. There was also a good understanding at stations of the role and importance of inspections, as shown by the universal cooperation and assistance provided to the Team by all stations visited.
All station leaders expressed support for scientific research at Antarctic facilities, which is the cornerstone of cooperation among parties to the Antarctic Treaty. In addition, all station personnel spoke of significant cooperation with other stations and Antarctic programs with respect to science, safety, logistics and equipment. It is clear that the stations form part of a community, and this attitude among station managers fosters international cooperation within Antarctica and beyond.
The Inspection Team found no arms violations, storage or disposal of hazardous or radioactive materials, or activities with military implications. All stations appeared to be in compliance with the provisions of the Treaty reserving Antarctica exclusively for peaceful purposes.
The Inspection Team found that several stations did not seem to be fully aware of the Environmental Impact Assessment (EIA) process and pointed to decisions made by the responsible agency in their home countries -- decisions that were apparently not shared with the station manager. Given that the activities that might have an impact on the environment take place at the station itself, and that implementation of EIA’s, including monitoring of environmental impacts, will be performed by personnel at the station, it is important that stations be more directly involved in the EIA process. The Inspection Team recommends that governments involve stations in all aspects of the EIA process, including the determination of whether an Initial Environmental Evaluation (IEE) should be prepared, the preparation of an IEE, the preparation of a Comprehensive Environmental Evaluation (CEE), and the monitoring of the environmental impacts of station activities.
Several stations had barrels of waste oil sitting exposed to the environment, without any secondary containment. In one case, the Inspection Team found a barrel of waste oil leaking its contents into the ground. The Inspection Team recommends that stations store such waste oil, prior to its removal from the Antarctic Treaty Area, in containers that will prevent leakage into the environment. In addition to waste fuel containment, the Inspection Team noted at several stations that clean, operational fuel for station, vehicle and aircraft use was either stored in permanent tanks or temporary drums that did not have secondary containment. Some permanent tanks were in need of sandblasting, ultrasonic or other testing, and re-coating. The Team recommends that all fuel storage containers, whether permanent or temporary, have secondary containment and that all permanent fuel storage tanks be subject to a regular testing and coating maintenance program. In addition, all stations should have a ready supply of absorbent pads, booms and other clean-up material to be used in the event of both small and large oil spills.
In two instances, the Inspection Team found large piles of paint and chemical cans, twisted scrap metal and other assorted solid waste stored in a haphazard manner. Annex III of the Environmental Protocol requires the removal of such waste from the Antarctic Treaty Area. The Inspection Team recommends that all stations review whether such waste exists on their premises, and that they expeditiously arrange safe and prompt removal of such waste from the Antarctic Treaty Area.
The Inspection Team experienced considerable difficulty in communicating with stations to give advance notice of its intended arrival, despite having access to relevant Council of Managers of National Antarctic Programs (COMNAP) materials (such as the Antarctic Telecommunication Operators Manual (ATOM)) and state-of-the-art communications equipment on board the Laurence M. Gould. Although this can in part be explained by errors that were discovered in the materials, and weather and other conditions that always make Antarctic communications uncertain, there was cause for concern. For example, in the event of distress, tour vessels and others may not be able to reach stations that might be able to assist with search and rescue activities if communications are not adequate. Moreover, stations may have difficulty seeking support from other stations in the event of medical emergencies, oils spills and other situations requiring immediate action.
The Inspection Team recommends that COMNAP and the ATCM consider means to improve communications as a matter of urgency. A potential solution, for at least those stations capable of supporting a more sophisticated communications suite, may be at hand. All vessels operating in the Antarctic are now required to carry an A4 GMDSS (Global Marine Distress & Safety System) communications suite, and some types of MF-HF transceivers incorporated into these packaged equipment suites are designed to transmit only on International Telecommunications Union (ITU) channels. It would facilitate communication between ships and Antarctic stations if shore establishments selected stand-by frequencies that were on the ITU channel lists, whether simplex or duplex.
It would further enhance communication between ships and stations, and between stations themselves, if stations included a standard marine MF/HF DSC (Digital Selective Calling) Controller in their MF/HF gear, and if stations were issued an MMSI number from the ITU. This would allow stations to be made aware of an attempt to contact them via MF/HF, with call-back information, in the event their communications equipment could not be continuously monitored.
There are also likely to be alternative means to accomplish this objective outside the realm of marine radio equipment. One simple but very important alternative that should apply to all stations would be for COMNAP to verify, on an annual basis, the entries made into the ATOM – particularly for the commonly available communications systems: e-mail, Inmarsat and Iridium. COMNAP could verify these numbers by annually attempting to call or e-mail each of the listed numbers. If no confirming reply is received, the respective COMNAP member should be notified with a request for an ATOM update. The COMNAP website, where the ATOM is posted, has now moved to a system of individually-named, password-protected entry. While the Team appreciates that information technology security is important, the result of this change is likely to be that myriad telecommunications operators at the various stations may not now be able to access the manual that was designed for them. The Team suggests that COMNAP consider a means of annually sending the ATOM, via e-mail, to each station that lists its e-mail address. Where a station does not list any e-mail, then COMNAP should send the ATOM to the respective member with a request to forward to the appropriate station. Finally, all stations should consider having Iridium, which is simple to operate.
B. Tourist Vessels
The Inspection Team was impressed by the dedication of the tour companies to ensure that the impacts of their operations on the Antarctic environment are no more than minor or transitory. The Inspection Team observed organized and well-managed landing and activities ashore conducted by three companies at two sites on the Antarctic Peninsula. The expedition staff implemented appropriate plans and guidelines at these sites and worked to ensure that passengers avoided restricted and sensitive areas. The activities observed were designed both to give tour passengers an enjoyable Antarctic experience and to avoid impacts on the Antarctic environment.
The Inspection Team also reviewed the operations of the tour ships and took note of two maritime incidents that had occurred in the past two years. While navigating through brash ice, one ship struck a growler (small iceberg) which caused minor damage to its hull. Another ship was caught on a sand bank for a number of hours and had to be pulled free by another ship. While the incidents are not necessarily representative of the Antarctic tour industry as a whole, and we understand that the number of such incidents overall is small, governments at the ATCM may wish to give further consideration to addressing the safety and environmental risks of tour ships in Antarctica.
The Team did not have the opportunity to inspect large vessels carrying over 500 passengers, which by and large do not land their passengers in Antarctica. Such vessels have been a major source of publicity and attention, and whether such vessels (as well as smaller vessels) pose particular safety and environmental risks is a matter that the ATCM may wish to consider.
C. Other Observations
The Team observed a number of dilapidated huts and refuges in several locations. Examples were the huts at Petermann Island and Neko Harbor. In the view of the Inspection Team, an effort should be made by those responsible for such huts to either repair them fully for some reasonable use (such as support for science) or remove them. There is no basis for old structures without historic designation to be left in such places simply on the basis that they might at some point provide a bit of safety to someone; if that were an appropriate basis for building and retaining huts, they would dot the landscape in contravention of basic environmental principles, if not the Environmental Protocol itself.
In addition to the aforementioned refuges, the Team passed by (but did not inspect closely) the following facilities that were unoccupied at the time: 1) a hut near Esperanza of uncertain ownership (the hut was referred to by Esperanza personnel as belonging to the UK but it had a Uruguayan flag painted on it), 2) Almirante Brown Station (Argentine, Paradise Bay) and 3) Deception Station (Argentine, Deception Island). If these facilities, and other similar ones reported, but not observed, are expected to remain unoccupied, consideration should be given to their removal.
The Inspection Team found value in visits by tourist ships to stations, especially to increase knowledge of scientific pursuits in Antarctica. Nevertheless, in light of the central role of science in Antarctica, the Team found it curious that some stations (including ones not visited by the Team) seemed to be going out of their way to attract tourist vessels. While there is nothing wrong with focusing attention on the historic aspects of stations and their locales, and visits by tourists can increase general understanding of the role of stations in Antarctica, the Team felt that resources might be better focused on expanding science programs than attracting tourists.
1. U.S. Report of Inspections, 2006
2. Comments of Argentina
3. Comments of Chile
Comments on the US inspection report at Esperanza Station
General note: The US inspection team undertook the inspection at Esperanza Station in English language. Being Spanish also an official Antarctic Treaty language, that fact should have been noted in the inspection report, since it might have been a source of likely misinterpretations.
The following comments are intended to broaden the scope of and/or to correct some information included by the inspection team in its inspection report. These pieces of information, as they were stated by the inspection team, might lead readers to conclusions which might not always match the actual scenario at Esperanza Station.
Transportation, Communications and Facilities
2nd para. 4th line
Argentina is currently evaluating the use of alternative energies in Esperanza Station. The project under analysis includes a combination of wind turbines and hydrogen batteries.
Pollution (Oil and chemical spills)
2nd. para. 2nd. line
This requirement stems from Resolution 6 (1998), which gave way to the elaboration of the COMNAP Environmental Incident Report System (EIRS). In order to fulfill the requirements of both Resolution 6 and EIRS the DNA has created as of 2002/03 a position among the members of their Antarctic Stations –the Environmental Officer- whose functions include, among others, preparation of these oil spill reports.
2nd. para. 4th. line
The Environmental & Tourism Management Program depends on the Dirección Nacional del Antártico (DNA).
1st para. 1st line
The Esperanza waste management plan is in accordance to an Antarctic Waste Management Master plan, prepared by the DNA in 2001 and applicable to all Argentine Antarctic Stations by setting out general principles for waste management activities.
1st para. last line.
Esperanza station (as well as any Argentine Antarctic Station) produces two kind of waste reports monthly: one sorting out all types of wastes, and the other especially devoted to hazardous wastes. The latter being done in accordance to the National law of Hazardous wastes (Nr. 24051). The Environmental officer from Esperanza is in charge of compiling, preparing and forwarding these reports to the DNA, on a monthly basis. He is particularly trained to do so through the DNA, by means of course prior to his departure to Antarctica. A copy of this report is kept at the station.
It is the DNA, via the Ministry of Foreign Affairs, the organization in charge of hiring contractors to conduct final disposal of wastes.
2nd para. 1st half
All likely wastes from PVC materials, in accordance to Article 2 of Annex III of the Madrid Protocol and the above mentioned Antarctic Waste Management Master plan, are to be removed from the Antarctic continent.
According to Annex III, only polystyrene beads, chips or similar forms of packaging are prohibited products. Other polystyrene products, such as foam, are not. The inspection report did not specify to what kind of packaging material it referred.
2nd para. last 3 lines
Waste oil drums at Esperanza have been kept at the station for no more than 2 years. In March 2005 all hazardous wastes (including waste oil) were removed from the station. The remaining drums are to be evacuated from Esperanza at the end of the 2006/07 summer season.
1st para. 7-9 lines
The helipad was relocated in 1996-97. An Environmental Impact Assessment was prepared for the occasion, even though the Madrid Protocol was not in force at that time.
2nd para. & 3rd para. 2nd sentence
The ASPA Nr. 148, Mount Flora, has been timely proposed for designation as an ASPA by the United Kingdom. Therefore, any management activity on this area (such as the installation of boundary markers, as suggested by the inspection team) should involve a close coordination with the British Antarctic Program.
Base personnel are briefed, before departure to Antarctica, on the general principles of Annex V and, in particular, on the existence and access requirement of ASPA 148 (other specific management requirements contained in the Management Plan are not covered since the area is closed for base personnel). This is done by DNA staff as part of a more comprehensive course on Antarctic matters.
The inspection report did not specify, however, how the survey among base personnel was done in order to determine that they were unaware of the existence of the ASPA 148 Management Plan.
On several occasions during the latest seasons the DNA has provided the station with paper and digital copies of the ASPA 148 Management Plan. Internet links to the ASPA 148 Management Plan have also been provided.
Environmental Impact Assessment
1st and 2nd para.
During the annual training courses for Esperanza staff, the DNA includes information on, among others, EIA requirements for Antarctic activities. Examples of EIAs prepared for Argentine Antarctic Stations, such as Esperanza, are included. However, personnel is only instructed on the EIA procedures in force. Particular requirements on how to prepare EIAs (e.g. how to distinguish between preliminary stage, IEE and CEE) are not included, since these go beyond the scope of their functions at the station. The Environmental & Tourism Management Program of the DNA, based in Buenos Aires, is particularly devoted to such an activity.
Additionally, on several occasions the DNA has provided the Station with copies of EIAs made for activities undertaken at Esperanza, including the following:
Installation of a tide gauge recording station, 1993
Construction of a new warehouse, 1994
Relocation of the helipad, 1996
Environmental review of Esperanza Station, 1996
Installation of a effluent treatment plan, 1999.
No IEEs nor CEEs have been prepared for annual maintenance activities at Esperanza, given that it has already been determined that they produce less than minor or transitory impacts. Nonetheless, these activities are annually assessed through appropriate national procedures, in accordance with Art. 1, Annex I of the Madrid Protocol.
Esperanza Station is far from being one of the most frequently visited sites in Antarctica. In fact, according to IAATO statistics, during the 2005-06 season Esperanza Station is ranked nr. 20 among the most visited Antarctic sites, with 2484 tourists landed. Just as a comparison, Whalers Bay (Deception Island), ranked in first place during the same season, has received 13500 visitors, 30% more than Esperanza received during the latest seven seasons together (10.398).
3rd sentence & 4th sentence
Although there is a rising trend observed during the latest two seasons in the number of tourists landed at Esperanza, before 2004-05 these were in all cases well below 1500.
Flights from Twin Otter and helicopters carry no tourists, as they are part of the National Programs’ activities.
Atcm30_att015_e.pdf: U.S. Report of Inspections, 2006
Atcm30_att016_e.doc: Comments of Argentina
Atcm30_att017_e.pdf: Comments of Chile