Baltic Marine Environment Protection Commission

Baltic Marine Environment Protection Commission Cooperation Platform on Special Area According to MARPOL Annex IV (CP PRF) Hamburg, Germany, 13 September 2017 CP PRF 7-2017 Document 1 CLIA Europe Baltic Exercise on Sewage 2016 The report of the CLIA Europe Baltic Exercise on Sewage 2016 is attached. Page 1 of 1

CLIA Europe Montoyerstraat 40 1000, Brussels CLIA Europe Baltic Exercise on Sewage 2016

Brussels, 8 May 2017 CLIA Europe Montoyerstraat 40 1000 Brussels Belgium www.cliaeurope.eu +32 (0)2 709 01 31 Contact person: P.R. Altena paltena@cruising.org +32 (0) 2709 01 38 Page 2

I. Introductory note During the 2016 cruise season in the Baltic Sea, CLIA Europe organised a sewage operational exercise during which multiple cruise ships operated as if the IMO Marpol Annex IV requirements were already in place. With this very extensive exercise and sharing of information, CLIA Europe would like to ensure a smooth entry into force of the Marpol Annex IV Special Area and a continued and sustainable blue growth of the cruise industry in the Baltic Sea Region. The requirement comes into force for new passenger ships on 1 June 2019 and for existing passenger ships in principle on 1 June 2021. This was agreed at the 69 th meeting of the IMO MEPC in 2016. Without an approved Advanced Wastewater Treatment System installed on board and meeting the Annex IV requirements, all cruise ships will need to discharge their sewage at a Port Reception Facility (PRF) as it will not be allowed to discharge at sea. In addition to have adequate PRFs available when the regulations enter into force from 2019, certainty of the future availability of those PRFs at least two years in advance is of utmost importance for the cruise industry. Both cruise and ports have been invited to document their positive and negative experiences during this exercise and to share those with CLIA Europe. The report intends to provide cruise ship operators and other stakeholders with an assessment of the current and future availability and adequacy of the PRFs and identify the (potential) bottlenecks. It provides an analysis of all data received, both qualitative and quantitative, and shows key findings which need to be addressed in order to maintain the Baltic Sea Region as the 2 nd most visited cruise destination in the world. This extensive operational exercise has been made possible thanks to the participating ports and the vast support from CLIA members and dedicated crew diligently completing the reporting forms and documenting their experiences during the 2016 season. Page 3

Page 4

II. Contents I. Introductory note... 3 II. Contents... 5 1 Executive Overview... 7 1.1 Feedback received from cruise ships... 7 1.2 Feedback received from ports... 7 1.3 Feedback from cruise ships and ports... 8 1.4 Key findings from the operational analysis... 9 2 Preamble... 13 3 Rationale for the Simulation 2016 Exercise... 17 4 Simulation Overview... 19 4.1 Methodology and Scope... 19 4.2 Timeline... 19 4.3 Ships and Ports involved... 20 5 Findings and Observations... 23 5.1 Planning/Operation... 23 5.2 Issues experienced... 31 5.3 Port and Port Reception Facilities providers... 38 5.4 Discharge operation... 39 5.5 HELCOM, 2014 versus Simulation 2016 Exercise 2016... 44 6 Conclusions and Recommendations PRF Baltic Sea Region... 45 7 Roadmap and next steps... 49 8 Annexes... 50 8.1 Annexes contents... 50 8.2 Ship based feedback data received... 51 8.3 Port based feedback data received... 65 8.4 Ports - Berth based feedback data received... 82 8.5 Analysis of amendments and assumptions related to the exercise... 90 8.6 Baltic Sea map and ports and ships routing... 95 8.7 Communication with Ports and information received... 104 8.8 Reporting forms for ships and ports... 116 8.9 Marpol Annex IV Requirements... 120 9 List of Tables... 126 10 List of Figures... 127 Page 5

Number of entries 1 Executive Overview 1.1 Feedback received from cruise ships CLIA Europe commenced an ongoing analysis on the impact to both ship and shore on the impending legislation covering Sewage treatment and disposal in the Baltic Sea. Importantly, 29 Cruise Ships (40% of 74 cruise ships sailing in the Baltic region) 1 joined the Marpol Annex IV 2016 Exercise and provided feedback on their experiences with Port Reception Facilities during the season. They provided 565 reports in total, representing almost 300 operations during which a discharge took place at a PRF. In addition to the operation specific reporting forms, ships personnel provided general feedback on their experiences during the season. Almost 50,000 quantitative and qualitative records have been received by CLIA Europe from the participating cruise ships. 2 The participating cruise ships range from being built in 1981 to 2016 (majority built after 2000) and from a maximum capacity of only 682 to 5216 persons on board, with over 30% of the ships mixing Grey Water (GW) with Sewage (BW). Figure 1: Number of entries received per size of cruise ship Number of entries received per size of cruise ship 270 92 56 Small (<1500) Medium (>1500, <3000) Large (>3000) Size cruise ship (total number of persons on board) 1.2 Feedback received from ports During 2016, over 2200 port calls by cruise ships occurred in the Baltic Region, where over 26% of these were analysed by CLIA Europe. The investigation included all major ports and a significant number of the small to medium ports as shown in Table 1 below. 1 https://www.cruisebaltic.com/ 2 Some of the participating ships during this operational exercise in the Baltic still discharged BW and/or GW at sea; overall volumes will therefore be higher when the regulations become effective. Page 7

Table 1: Baltic Ports visited / Confirmed PRF present Baltic ports Country Overview Total number of single visits by ships participating Total number of single visits during 2015 3 Confirmed presence of the following types of PRF: Tank car/trucks Barges Fixed PRF Aarhus Denmark 3 26 Present Copenhagen Denmark 99 304 Present Present Fredericia Denmark 3 3 Gdansk Poland 2 24 Present Present Gdynia Poland 9 Present Gothenburg Sweden 4 35 Present Present Helsingborg Sweden 2 10 Present Helsinki Finland 73 243 Present Present Hundested Denmark 1 Karlskrona Sweden 1 2 Kiel Germany 21 140 Present Present Present Klaipeda Lithuania 19 48 Present Present Travemu nde Germany 2 Lulea Sweden 1 Mariehamn Finland 3 11 Present Malmö Sweden 1 10 Present Nynashamn Sweden 7 Örnsköldsvik Sweden 1 Pori Finland 1 Riga Latvia 20 61 Present Present Rønne Denmark 1 21 Rostock 6 184 Present Present Germany Warnemünde 52 19 Present Present St Petersburg Russia 71 281 Present Present Present Skagen Denmark 2 16 Present Stockholm Sweden 76 250 Present Tallinn Estonia 83 282 Present Present Umea Sweden 1 Visby Sweden 3 49 Present Wismar Germany 1 Totals: 569 13 7 12 1.3 Feedback from cruise ships and ports Project specific reporting templates have been developed by CLIA Europe in close cooperation with both cruise companies and ports providing the opportunity for the ports and ships to submit both quantitative and qualitative feedback including general impressions along with observations during the (discharge) operations. Receiving feedback from both sides provided an opportunity to mirror the information received. Almost 50% of the ports visited provided information on their Port Reception Facilities using part of the template provided. Some ports provided aggregated values for Sewage (and Grey Water) with two ports (Stockholm and St. Petersburg) providing values for waste waters discharged (BW and/or GW) 3 For comparison Page 8

for specific discharge operations. Only one port, the Port of Kiel provided valuable feedback on specific discharge operations using the CLIA Europe designed template. 1.4 Key findings from the operational analysis 1. Issues experienced Recognising that this is the first stage of an ongoing analysis over the coming years into the operational challenges with both cruise ships and the Baltic ports meeting the impending Marpol Annex IV Special Area requirements. It is expected that more issues are to be experiences when all ships and ports are analysed in future studies. New ships from 2019 and all cruise ships from 2021 are obliged to discharge their sewage at a port to comply with Marpol Annex IV Special Area requirements or use installed and approved 4 Advanced Wastewater Treatment Systems (AWTS) 5 exceeding the IMO Marpol Annex IV standards. Cruise ships reported no issues at all during calls in some ports. However, they also reported issues during a significant number of port calls at some other ports 6. During 565 port calls investigated, 220 issues were reported by the Cruise ships: No facility available (12.7%) Undue delay (21.8%) Use of facility technically not possible (5.9%) Inconvenient location (5.0%) Unreasonable charges for use of facilities (25.5%) Other (29.1%). It should be noted that at no occasion did a vessel report it had to change berth involving delay and or additional cost. 2. Logistical issues The 2016 Exercise represents only 26% of total port calls during 2016. Consequently, 74% of the total number of port calls were excluded from this Marpol Annex IV operational Exercise. Adequacy is described by the IMO 7 as: 6 Adequacy as used in the MARPOL Annexes means that PRFs meet the needs of ships using the ports without causing undue delay. PRF operators and users may refer to the Guidelines for ensuring the adequacy of port waste reception facilities (resolution MEPC.83(44)), section 3, How to Achieve Adequacy, or section 2.3.1 of the Comprehensive Manual on Port Reception Facilities (1999), for further information. Section 3.2 of the Guidelines further states that "adequate facilities can be defined as those which: mariners use; fully meet the needs of the ships regularly using them; do not provide mariners with a disincentive to use them; and contribute to the improvement of the marine environment". Additionally, section 3.3 of the Guidelines specifies that the reception facilities must " allow for the ultimate disposal of ships' waste to take place in an environmentally appropriate way". 4 IMO MEPC Resolution 227(64) (Section 4.2) 5 Typically installed to meeting faecal coliform, BOD and suspended solids, and residual chlorine requirements for US/VGP/Alaska operations. 6 See Annexes 7 MEPC.1/Circ.834 Consolidated Guidance for Port Reception Facility Providers and Users 2014 Page 9

Even though (larger) ports may have (multiple) fixed PRFs available, it may not be sufficient to service to the total number of ships calling at the same time. These potential bottle-necks need to be identified and alternative PRF strategies should be detailed within the Port Waste Management Plan (PWMP). 8 Further detailed investigation regarding the operations with tank trucks should be considered. Due to their low capacity (pumping and volumetric), the need to have multiple trucks and (dis)connecting operations, the use of these mobile units clearly increase the risk of spills during operation. Moreover, they lead to an increase in the administrative burden on board, with some ships needing tank trucks may miss out altogether during peak periods of activity. Where ships need to mix the volumes of BW and GW, the capability of using tank trucks is not possible in the vast majority of cases. It should be noted that at berth, multiple Hotel and Engine Room operations take place at the same time which are likely to interfere such as; Bunkering activities, delivery of other chemicals such as caustic soda and urea associated with SO x and NO x reduction, discharge of multiple types of liquid waste (sludge, Annex 4, Annex 5, EGCS waste residues etc.), garbage removal and loading of Hotel and Engine Room stores, not to mention the transfer of passengers. When only one type of PRF is available or available pumping volumes are low, the discharge operation may have to be deferred to the next port of call or if necessary a legally permitted discharge takes place while on route. Of particular note is a case example in the port of Gdansk, where the sewage truck was not allowed to come alongside the ship, "in order not to disturb the passengers". This caused a considerable delay to the ship s operation and increased administrative burden. 3. Next port of call vs next port of delivery The existing version of the European Directive 9 does not specifically distinguish between Next port of call and Next port of delivery for the Delivery of ship-generated waste 10. However, the Interpretative Guidelines by the European Commission published spring 2016 11 provide a very strict interpretation. The table below shows that in 47% of the cases in this exercise, the next port scheduled was not equal to the next port of delivery. The strict interpretation by the EC which may be included in an updated European legislation would therefore lead to significant operational problems. The open interpretation that next port of delivery need not be the same as the next port of call needs to be maintained. Table 2: Next Port of Delivery vs Next Port of Call Next port is scheduled to be Number of Percentage total next port of delivery? (Yes/No) operations Count "Yes" 260 53% Count "No" 226 47% Totals 486 100% 8 Note that no PWMP have been included in this operational analysis 9 Directive 2000/59/EC on port reception facilities for ship-generated waste and cargo residues 10 Directive 2000/59/EC Article 7 11 Guidelines for the interpretation of Directive 2000/59/EC on port reception facilities for ship generated waste and cargo residues (2016/C 115/05) Page 10

The current interpretation of the paragraphs in article 7 allows the operator to organise its operation more (cost) efficiently and to select for the most appropriate PRF taking into account the operational requirements. It should be noted however, that this possibility needs to be approved by the relevant Port Authority of the current port. 4. Competition among PRF providers Overall, there are very few PRF providers to select from in a port and there is a lack of competition. The cruise ship is therefore generally obliged to make use of the services provided by a single operator and is not in a position to select. The cruise industry would like to be able to select the PRF provider, providing the best services at reasonable costs. The lack of competition may have a negative influence, but not necessarily. Table 3: Number of PRF providers to select from How many PRF providers can the ship select from in the port? Number reported by (maximum) participating ships 1 12 2 5 3 1 Average: 1.39 5. Fees and charges The cruise ships have been asked to provide feedback on the following question for a specific discharge operation: Does the cruise ship consider the fees disproportionately high such that they create a disincentive to utilize the PRFs? The cruise ships responded positively during 32% of total number of port calls, ranging from 4% to 100% of calls at a specific port. This very high percentage of confirmations received is consistent with the findings by the European Commission s Ex-Port evaluation of Directive 2000/59/EC 1213. Included in the general impressions form, cruise ships have been asked to specify the Cost Recovery System (CRS) that worked best. The overwhelming majority of ships reported a clear preference to have all sewage to be included in the port fees. 6. Need to discharge while on route It should also be noted that feedback received from ports indicate that usually, there is no Plan B in case a PRF would not be available. This aspect is of great concern due to the many issues encountered and included in this analysis which has been based on more than the 26% of the port calls. This operational exercise shows that there have been too many issues during this simulation and that there is a clear need for a good Plan B. The revised European Directive and the ports Waste Management Plans should facilitate this. Such plans should be clearly documented and communicated to the relevant stakeholders. Importantly, they need to be suitable for the operations concerned at the port and if included, facilitate the operation of the ship while on route. 12 European Commission Ex-Post evaluation of Directive 2000/59/EC on port reception facilities for shipgenerated waste and cargo residues 13 See also Annexes, Table 2 and 3, Column F Page 11

2 Preamble The HELCOM Baltic Sea Action Plan 14 The HELCOM Baltic Sea Action Plan (BSAP) was adopted in 2007 and aims to restore the good ecological status of the Baltic marine environment by 2021. The vision is formulated as follows in the BSAP: A healthy Baltic Sea environment, with diverse biological components functioning in balance, resulting in good environmental/ecological status and supporting a wide range of sustainable human economics and social activities. Furthermore, the BSAP includes the following key points specifically on eutrophication: Baltic Sea unaffected by eutrophication, Clear water, Natural level of algal blooms, Natural distribution and occurrence of plants and animals, and Natural oxygen levels. Estimation nutrient loads in the Baltic Sea from the total shipping sector A report by the Finnish institute VTT 15 provides an analysis of the contributors to eutrophication I the Baltic Sea. It provided the following analysis of the contribution from shipping: The ship-borne nitrogen load represents approximately 0.05% of the total nitrogen load, and the phosphorus load represents approximately 0.5% of the total phosphorus load both into the Baltic Sea and into the Gulf of Finland. The nutrient load from ships exhaust gases contributes to 6% of the total atmospheric deposition of nitrogen. The main nutrient load into the Baltic Sea is derived from water-borne inputs and atmospheric deposition. IMO and Special Area on Marpol Annex IV granted for Baltic Sea During the 69 th session on the IMO MEPC spring 2016, the IMO established the Baltic Sea Special Area under MARPOL Annex IV (Prevention of pollution by sewage from ships). In the special area, the discharge of sewage from passenger ships will generally be prohibited unless the ship has in operation an approved sewage treatment plant that meets the applicable additional effluent standards for nitrogen and phosphorus in accordance with the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants 16. For new passenger ships the requirement come into force on 1 June 2019 and for existing passenger ships in principle on 1 June 2021. For existing passenger ships while on route directly to or from a port located outside the special area and to or from a port located east of longitude 28 10' E within the special area that do not make any other port calls within the special area, the entry into force will be on 1 June 2023. An MEPC resolution adopting the effective dates encourages Member Governments, industry groups and other stakeholders to comply immediately on a voluntary basis with the Special Area requirements for the Baltic Sea Special Area. 14 http://helcom.fi/baltic-sea-action-plan 15 Estimated nutrient load from waste waters originating from ships in the Baltic Sea area http://www.vtt.fi/inf/pdf/tiedotteet/2007/t2370.pdf 16 Resolution MEPC.227(64). Page 13

The adequacy or Inadequacy of PRF s has long been a cause of contention during IMO meetings. In 2006, a working group of various stakeholders investigated and developed the Guide to good practice for port reception facilities and users which was adopted July 2009 MEPC.1/Circ.671). Most recently ISO embarked on a root and branch review of PRF s for IMO resulting in the approval by the Committee, at its sixty-sixth session (April 2014), the Consolidated guidance 17 for port reception facility providers and users, consolidating in a single document the Guide to good practice for port reception facility providers and users 18 and four other circulars related to port reception facilities 19. MEPC.1/Circ.834 contains the necessary consequential amendments of the earlier circulars following the entry into force of the revised MARPOL Annex V on 1 January 2013, and the designation of the Baltic Sea as a Special Area under MARPOL Annex IV and the designation of the North American and United States Caribbean Sea emission control areas under MARPOL Annex VI. Importantly, this consolidated guidance is not intended to provide guidance to Party State authorities and Governments who wish to implement reception facilities under MARPOL. The Manual on Port Reception Facilities and the Guidelines for Ensuring Adequacy, previously published by IMO, should be referred to for these purposes. Definitions for adequacy of Port Reception Facilities The IMO s Consolidated Guidance for Port Reception Facility Providers and Users provides the following definition of adequacy: Adequacy as used in the MARPOL Annexes means that PRFs meet the needs of ships using the ports without causing undue delay. PRF operators and users may refer to the Guidelines for ensuring the adequacy of port waste reception facilities (resolution MEPC.83(44)), section 3, How to Achieve Adequacy, or section 2.3.1 of the Comprehensive Manual on Port Reception Facilities (1999), for further information. Section 3.2 of the Guidelines further states that: "adequate facilities can be defined as those which: mariners use; fully meet the needs of the ships regularly using them; do not provide mariners with a disincentive to use them; and contribute to the improvement of the marine environment". Additionally, section 3.3 of the Guidelines specifies that the reception facilities must " allow for the ultimate disposal of ships' waste to take place in an environmentally appropriate way". Definition as applied with the European PRF Directive 2000/59/EC: adequate to meet the needs of the ships normally using the port without causing undue delay to ships to determine such adequacy the Directive refers to the capability of receiving the types and quantities of ship-generated waste and cargo residues from ships normally using that port, taking into account: operational needs of the users of the port, size and geographical location of the port, type of ships calling at that port, exemptions provided for under Article 9. The European Commission s 2016 Guidelines for the interpretation of Directive 2000/59/EC on port reception facilities for ship generated waste and cargo residues contains the following elaboration of the definition: 17 MEPC.1/Circ.834 18 MEPC.1/Circ.671/Rev.1 19 MEPC.1/Circ.469/Rev.2, MEPC.1/Circ.644/Rev.1, MEPC.1/Circ.645/Rev.1 and MEPC.1/Circ.470/Rev.1 Page 14

As regards the necessary operational conditions, the Commission underlines that the mere provision of facilities does not necessarily mean the facilities are adequate. Poor location, complicated procedures, restricted availability and unreasonably high costs for the service provided are all factors which may deter the use of reception facilities. For a port reception facility to be considered adequate, the facility should be available during a ship's visit to the port, be conveniently located and easy to use, cater for all types of waste streams usually entering the port and not cost so much as to present a disincentive to users. At the same time, the Commission emphasizes that both the size and geographical location of the port may limit what can technically and reasonably be provided in terms of reception and handling of the waste. In addition, to meet the environmental performance criteria and contribute to the improvement of the marine environment, the facility must allow for the ultimate disposal of ships' waste to take place in an environmentally appropriate way. According to the PRF Directive, ship-generated waste and cargo residues shall be considered to be waste within the meaning of Directive 2008/98/EC of the European Parliament and of the Council on waste and repealing certain directives (9) (10) (the Waste Framework Directive). Consequently, Article 12(g) requires that the treatment, recovery or disposal of ship-generated waste and cargo residues to be carried out in accordance with the Waste Framework Directive and other relevant EU waste legislation. Reporting of inadequacies The IMO has a platform in place for ships and ports to report and comment on inadequacies within the IMO GISIS database. As such, all stakeholders should encourage and facilitate effective use of this method to report inadequacies in port reception facilities. In accordance with the regulations, those allegations should be reported accurately and in a timely manner via the ship's flag State to the Organization and to the appropriate port State authorities or port operators, using the suggested format for reporting 20. Reducing environmental footprint of Sewage and Grey Water Cruise Lines have taken a pro-active stance on reducing their environmental footprint and discharges at sea via numerous initiatives including cooperation with environmental NGOs and governmental organisations like HELCOM and WWF. This 2016 Exercise is one of several projects initiated which benefits from cooperation among different stakeholders in the industry. The industry commitment by cruise line members of CLIA Europe Spring 2016, CLIA Europe re-affirmed its commitment to utilize Port Reception Facilities for sewage in the Baltic region where available and at no special fee, via amendment to the cruise industry s CLIA Europe Waste Management Policy. This is an important incremental step toward the operating environment that the cruise industry will have in the Baltic when the Special Area enters into force. Introduction of advanced waste water technology In close cooperation with suppliers, the cruise industry has developed and is still further improving Advanced Waste Treatment Systems which would allow for discharging treated sewage at sea in accordance with the IMO Marpol Annex IV and the European Directive criteria. These complex multi-million dollar investments make the specific ship less dependent on the (in-)adequacy of Port Reception Facilities. 20 MEPC.1/Circ.834 Page 15

3 Rationale for the Simulation 2016 Exercise The Baltic Sea Region (BSR) is very important for the cruise industry as it is the second cruise destination worldwide, after the Caribbean. Moreover, many suppliers to the shipping sector including the cruise industry are located in Baltic states. Almost all cruise ships are built at European yards of which most are located in Baltic states as well. Due to these elements, the cruise industry has very significant contributions to the local and regional economy. The BSR is also an environmentally sensitive sea area and has received several protective statuses by the IMO: it is a Special Area under MARPOL Annex IV and Annex V and both a SO x and NO x ECA under Marpol Annex VI. Spring 2016, ahead of the designation of the Baltic Sea as a Special Area under Marpol Annex IV, CLIA Europe agreed on a Baltic Sea Engagement Plan to enhance the proactive involvement of the cruise industry and cooperation with other stakeholders, including member states, ports and (environmental) NGOs. This 2016 Exercise assessing the availability and adequacy of PRFs in the BSR is an important first stage of this engagement plan. CLIA Europe wants to continue to engaging with all the stakeholders involved in the process in order to ensure a good implementation of the Special Area that will allow cruise ships to continue to operate in the Baltic Sea once the provisions come into effect as anticipated in 2019/21. Page 17

4 Simulation Overview CLIA Europe has committed to coordinating a 2016 Exercise in the Baltic Sea during the course of the 2016 season to test the availability and adequacy of PRFs in the regions cruise ports, identify challenges and potential bottlenecks in compliance with the future legislation. 4.1 Methodology and Scope Methodology CLIA Europe members were requested to operate several of their cruise ships in the Baltic as if the Special Area provisions were already in force and to share their experience with CLIA Europe. CLIA Europe has used the input received to produce a report assessing the availability and adequacy of PRFs in the region, notably highlighting the challenges cruise ships currently face when endeavouring not to discharge wastewater offshore and setting a roadmap to address the issues identified in a timely manner. For the 2016 Exercise to provide conclusive results it has been important to ensure participation by a significant number of representative cruise ships that together cover most of the region s cruise ports and ship capacities. This would allow CLIA Europe to build a thorough representation regarding the availability and adequacy of PRFs in the region, and the possibility of cruise ships to pursue Baltic itineraries without discharging wastewater offshore when the Special Area provisions come into force. This will also provide all stakeholders with a clear impression of the situation and bottlenecks. Both cruise ships and ports have been provided the opportunity to provide comments on coordinated reporting forms for qualitative and quantitative feedback on both port operations and general impressions. Scope Cruise ships taking part in the 2016 Exercise would simulate Special Area conditions during the course of a specific time period as agreed with CLIA Europe. During the simulation, the cruise ship would avoid discharging MARPOL Annex IV wastewater at sea in the Baltic, using instead the range of options offered by the region s cruise ports to discharge while at berth. The Russian part of the Baltic Sea has been part of this Baltic Sea simulation, regardless of the (future) MARPOL Annex IV requirements. The cruise ship s crew has been responsible for collecting relevant data at every port of call by completing a project specific reporting template provided by CLIA Europe. Special fees: in case those disproportionately high fees have created a disincentive to utilize PRFs at a particular port, the crew has been requested to carefully document this using the reporting template provided. 4.2 Timeline The focus for this exercise was originally planned for a 2-month period, from late May to late July. However, as more members and ships wanted to contribute, the timeline was extended to also allow ships in August and early September to participate. It was up to the participating member lines to determine when to simulate Special Area operational conditions. CLIA Europe has also coordinated with specific cruise lines to ensure that the most (if not all) of the Baltic cruise ports are included within the selected ships itineraries. Page 19

From April 2016, onwards, the Baltic ports received the final reporting format in order to mirror the exercise and provide additional input for verification. CLIA Europe also liaised with NGOs like WWF in terms of objective, scope and terms of reference. 4.3 Ships and Ports involved 4.3.1 Ships involved 29 Ships (40% of 74 cruise ships sailing in the Baltic region) 21 participated in the CLIA Europe Marpol Annex IV 2016 Exercise and provided feedback on their experiences with Port Reception Facilities during the 2016 season. They provided 565 reports in total, representing almost 300 operations during which a discharge took place at a PRF. In addition to the operation specific reporting forms, they provided general feedback on their experiences during the season. More than 48.000 quantitative and qualitative entries have been received by CLIA Europe from these cruise ships. Table 4: Ships involved: parameters / data entries / unique ports visited Ship Code Year of Built Guest capacity Number of quantitative data Number of unique ports visited in (maximum) entries quantitative analysis S101 2003 1300 13 10 S102 2001 1266 17 13 S103 2009 2260 8 4 S104 2001 372 8 8 S105 2011 450 0 7 S106 2000 686 19 8 S107 2002 1848 6 6 S108 2013 3560 47 7 S128 1999 826 6 6 S129 2004 3080 7 6 S109 1981 1158 0 S110 1981 602 9 9 S111 2000 1950 5 5 S112 2010 2853 38 7 S113 2011 2853 47 11 S114 1991 2744 22 5 S115 2000 3807 8 4 S116 2003 2100 52 12 S118 1996 2681 3 S119 2015 2790 58 10 S120 2016 2790 2 2 S121 2006 2550 25 5 S122 2004 1712 48 8 S123 2001 2348 50 5 S124 1998 702 29 11 S125 1998 702 7 7 S126 2011 1258 15 6 S127 2003 706 14 9 S130 2016 2650 2 2 The participating cruise ships cover a broad range: Date of Build 1981 to 2016 (majority built after 2000) and Maximum passenger capacity of 372 to 3.807 guests. The mixing on board of GW and BW was confirmed by 31% of the ships participating. 21 https://www.cruisebaltic.com/ Page 20

Number of entries GUEST CAPACITY (MAXIMUM) Figure 2: Ships' Year built vs Guest Capacity 4000 3000 2000 1000 Overview Cruise ships participating in CLIA's Simulation 2016 Exercise 0 1970 1980 1990 2000 2010 2020 YEAR BUILT The majority of feedback (366 reports) has been received from medium sized cruise ships, with between 1500 and 3000 passengers on board. Figure 3: Ships' Guest Capacity vs Number of entries Number of entries received per size of cruise ship 270 92 56 Small (<1500) Medium (>1500, <3000) Large (>3000) Size cruise ship (total number of persons on board) 4.3.2 Ports involvement The following table provided provides an overview of the ports in the Baltic Region identified and visited by a cruise ship participating in the 2016 Exercise. A total of 30 ports have been included in the reports received from the ships, which equates to over 95% of Cruise call representation 22. 22 Baltic Sea calls 2014 statistics Page 21

Table 5: Ports Identified vs Visited Baltic ports Country Visited by cruise ship during 2016 Exercise? Aalborg Denmark No Aarhus Denmark Yes Copenhagen (*) Denmark Yes Fredericia Denmark Yes Flensburg Germany No Gdansk(*) Poland Yes Gdynia(*) Poland Yes Gothenburg(*) Sweden Yes Helsingborg Sweden Yes Helsingør Denmark No Helsinki(*) Finland Yes Heiringsdorf Germany No Hundested Denmark Yes Kaliningrad Russia No Kalmar Sweden No Kalundborg Denmark No Karlskrona Sweden Yes Kemi Finland No Kiel(*) Yes Germany Holtenau No Klaipeda(*) Lithuania Yes Kotka Finland No Lu beck No Germany Travemu nde Yes Lulea Sweden Yes Mariehamn Finland Yes Malmö Sweden Yes Nynashamn Sweden Yes Örnsköldsvik Sweden Yes Pori Finland Yes Riga(*) Latvia Yes Rønne Yes Denmark Bornholm No Rostock(*) Yes Germany Warnemünde Yes Saaremaa Estonia No St Petersburg(*) Russia Yes Sassnitz Germany No Skagen Denmark Yes Stockholm(*) Sweden Yes Stralsund Germany No Szczecin No Poland Sẃinoujsćie No Tallinn(*) Estonia Yes Turku Finland No Umea Sweden Yes Veere Estonia No Ventspils Latvia No Visby(*) Sweden Yes Wismar Germany Yes (*) Significant Ports of Call - Designation Page 22

5 Findings and Observations Chapter 5 shows findings and observations relating to the planning/operation (Section 5.1), issues experienced (Section 5.2), port and Port Reception Facilities providers (Section 5.3) and subsequent discharge operation (Section 5.4). 23 5.1 Planning/Operation 5.1.1 Open interpretation that next port of delivery need not be the same as the next port of call needs to be maintained Article 7 of the European PRF Directive (2000/59/EC) specifies the delivery of ship-generated waste at port. Section 2, distinguishes between proceeding of the ship to the Next Port of Call and the intended voyage of the ship until the Next Port of Delivery. In the Commission Notice Guidelines for the interpretation of Directive 2000/59/EC on port reception facilities for ship generated waste and cargo residues, the European Commission concludes that the Intended Port of Delivery should be understood as the next port of call. Conclusion 1: CLIA Europe does not agree with this very strict interpretation for the next port of delivery and the below overview provides a clear insight in the major effects that interpretation would have on the operations. In almost half of the reported cases, the next port scheduled was not the same as the next port of delivery. Table 6: Next port of call vs next port of delivery Next port is scheduled to be next Number of port of delivery? (Yes/No) operations Percentage total Count "Yes" 260 53% Count "No" 226 47% Totals 486 100% 5.1.2 Almost all Advance Notification Forms (ANFs) submitted more than 24 hrs ahead of the Actual Time of Arrival 95% Of the Advance Notification Forms (ANFs) are submitted more than 24 hrs ahead of the Actual Time of Arrival. Of the 5% submitted within 24 hrs, almost half of the ships were engaged in a journey with duration of less than 24 hrs between the last port of call and the current port. This very high percentage shows that the communication from the ship to the port and the usage of the ANF takes place at an appropriate time and with sufficient time ahead of the port call. 23 Generally, further input from other stakeholders (including Ports) is welcomed to analyse the reported experiences and verify the conclusions. Page 23

Table 7: Time between ANF and ATA Time between ANF and ATA (hrs) Number of discharge operations Percentage total Between 0 and 24 hrs ahead of ATA 29 5.2% Between 24 hrs and 96 hrs ahead of ATA 385 69.2% More than 96 hrs ahead of ATA 96 17.3% Never submitted/no discharge taken place 46 8.3% Totals 556 100% The current requirement reads: at least 24 hours in advance of arrival or upon departure of the previous port if the voyage is less than 24 hours. 51.7% Of ANFs have been submitted within 24 hrs while engaged in a journey taking more than 24 hrs. Table 8: Submitting within 24 hrs vs duration of travel Comparison time submitting ANF and scheduled duration of travel Number of discharge operations Percentage total Between 0 and 24 hrs ahead of ATA 29 5.2% Of total Between 0 and 24 hrs and scheduled Of submitted between 0 duration of travel less than 24 hrs 14 48.3% and 24 hrs ahead of ATA Conclusion 2: No next steps are necessary regarding the timing of submitting the ANF to a port. Other steps regarding the ANF may be appropriate but are analysed in the relevant sections. 5.1.3 Sewage discharged at port in line with expected volume to be discharged at port according to the ANF? The description of volumes reported by ships and by ports has not been consistent during the exercise. Some ships and some ports included Black Water (and mixed BW and GW) and Grey Water in the total volumes although not necessarily consistently. Due to the vast difference in volumes on board between BW and GW, very large differences would most likely be due to this effect. However, from the feedback received it can be concluded that during the majority of occasions, the estimation of sewage to be delivered as reported in the Advance Notification Form is in line with the volumes actually delivered. Table 9: Difference between estimation of sewage and sewage delivered Size of difference between estimation of sewage and sewage delivered Occasions Percentage smaller than 10 m3 334 60% 10-40 m3 45 8% 40-80 m3 39 7% 80-200 m2 72 13% more than 200 m3 71 13% Totals 561 100% Conclusion 3: In most of the cases, the volumes delivered are in line with the estimation provided in advance via the ANF. The feedback received could be improved by including a clearer description of the volumes in the reporting forms. 5.1.3 Amount of time underway to ports Out of 363 reports received on this specific aspect, 298 ships travelled up to 1.5 days through the Baltic Sea to the current port. On only 4 occasions, ships travelled more than 2 days through the Baltic Sea. Of the 20 Baltic ports included in this analysis, 3 received cruise ships on a leg taking more than Page 24

2 days (Copenhagen, St Petersburg and Tallinn) and 12 other ports received cruise ships on a leg taking more than 1.5 days. Clearly, when a cruise ships spends more time at sea, it will accumulate larger amounts of Sewage and Grey Water. Table 10: Time underway through the Baltic Sea to specific ports Baltic ports Average amount of time underway to this port (compensated for entry of Baltic Sea) Maximum amount of time underway to this port (compensated for entry of Baltic Sea) Time underway through the Baltic Sea to specific ports 0-0.5 days 0.5-1 days 1-1.5 days 1.5-2 days >2 days Copenhagen 01/01/1900 05:44 2.03 4 9 6 17 1 Fredericia 00/01/1900 10:13 0.43 1 0 0 0 0 Gdansk 00/01/1900 13:21 0.83 1 1 0 0 0 Gdynia 01/01/1900 08:38 1.57 1 0 6 1 0 Gothenburg 00/01/1900 16:54 1.00 1 1 1 0 0 Helsinki 00/01/1900 18:45 1.75 6 34 5 4 0 Karlskrona 00/01/1900 14:00 0.58 0 1 0 0 0 Kiel 01/01/1900 02:01 1.56 1 4 0 6 0 Klaipeda 00/01/1900 17:11 1.45 1 13 2 0 0 Travemu nde 00/01/1900 09:13 0.38 1 0 0 0 0 Mariehamn 00/01/1900 14:45 0.61 0 1 0 0 0 Nynashamn 00/01/1900 13:45 0.61 0 3 0 0 0 Riga 00/01/1900 19:39 1.56 0 15 0 2 0 Rønne 00/01/1900 09:50 0.41 1 0 0 0 0 Rostock 00/01/1900 14:11 0.61 0 3 0 0 0 Warnemünde 00/01/1900 17:12 1.65 5 21 3 3 0 St Petersburg 00/01/1900 16:43 2.29 2 48 0 6 1 Stockholm 00/01/1900 22:34 1.67 0 36 2 13 0 Tallinn 00/01/1900 22:39 2.53 1 43 18 6 1 Visby 01/01/1900 01:06 1.52 0 1 0 1 0 Wismar 01/01/1900 16:26 1.68 0 0 0 1 0 Totals: 26 234 43 60 3 Table 11: Average amount of time underway to ports Average amount of time underway to this port (compensated for entry of Baltic Sea) Number of ports 0-0.5 days 3 14% 0.5-1 days 13 62% 1-1.5 days 4 19% 1.5-2 days 1 5% >2 days 0 0% Totals 21 100% Percentage of total Conclusion 4: Those ports receiving ships with extensive Sea Time when developing adequate Port Reception Facilities for Sewage. should take this into account Page 25

5.1.4 Clockwise or counter clockwise Itinerary It has been hypothesised that there may be a difference in the amount of problems experienced by ships between those with a clockwise and counter-clockwise itinerary 24. The below table specifies the amount of problems experienced for the different types of itineraries. Of the total 472 itineraries included in this analysis 25, 221 entries were made by a ship on a clockwise itinerary. Of those entries, 41% experienced a problem against 55% of vessels on a counter clockwise itinerary. Table 12: Problems experienced in Clockwise and counter clockwise itineraries Clockwise or counter clockwise Number of discharge operations Percentage total Number of problems Percentage Number of clockwise itineraries 221 47% 90 41% Number of counter clockwise itineraries 251 53% 139 55% Totals 472 100% 251 49% Conclusion 5: The feedback received suggests there is a slightly higher chance of a problem when on a counter clockwise itinerary. More in-depth analysis and data is required before any conclusions can be derived. 5.1.5 Delay (Actual Time of Departure (ATD) versus Estimated Time of Departure (ETD)) Ships experienced delays in 16% of the port calls reported in the 2016 Exercise of more than 0.5 hrs of which 31% coincides with experiencing a problem 26. In 10% of the calls a delay of more than 1 hr was experienced of which 23% coincides with a problem. During the 2016 Exercise, 264 problems have been reported as part of feedback received for 498 operations on this subject, representing 53% of operations. Considering the fact that on time departure is of paramount importance to the operation of a cruise ship, more than 30 minutes and more than 1 hr delays can be very significant. Problems experienced during discharge operations do not seem to have a significant effect on the delay experienced at berth. Table 13: Delays and problems experienced Aspect Number of entries (excl zero entries) Percentage exceedance Delay larger than 0.5 hour? Delay larger than 0.5 hr and problem experienced? Delay larger than 1 hour? Delay larger than 1 hr and problem experienced? 55 27 21 12 10.1% 4.9% 3.8% 2.2% Share of delay more than 0.5 hrs 49.1% Share of delay more than 1 hrs 57% 24 Appendix Section 8.4 provides an analysis of the definition of (counter-) clockwise itineraries 25 Not relevant entries have been removed from this analysis. 26 See section 5.2: problems/issues include: Question A: When relevant: please indicate the problems encountered by using one of more of the following code letters; Question B: In your opinion, is the port facility properly accommodated to meet the needs of the ship?; Question C: Did the volume of sewage discharged conform the wishes of the ship? Page 26

Table 14: Total number of problems experienced Issues experienced as percentage of Problems experienced total feedback received Total number of problems experienced 264 53% Total number of feedback received 498 Conclusion 6: Although each delay experienced has very significant effects on the operation of cruise ship, from the data received, in general, there is no significant effect of problems experienced during discharge operations. Additional research may be interesting to conduct. 5.1.6 Number of persons on board when arriving at berth During the exercise, 577 port calls have been registered of which the majority (>70%) was performed by larger vessels (more than 4000 persons on board). Table 15: Number of people on board vs Operations Number of persons (passengers and crew) on board Number of operations Percentage total Small (0-1500) 88 15% Medium (1500-3000) 82 14% Large (3000-4000) 237 41% Very large (>4000) 170 29% Totals 577 100% Conclusion 7: This information provides an indication of the operations presented in this analysis of the experiences during the 2016 exercise and may be of use when relating general conclusions to specific cases. 5.1.7 Time spent at berth and time needed for discharging operation Some ships connect for the full stay at a port e.g. when at berth for two days in St Petersburg. It should be noted that being connected for two days will not require the full pumping capacity for the duration of the connection. On average, during a port call, cruise ships spend 12 hrs at berth. This varies from only (0.23*24hrs) 5.5 hrs in Travemu nde to the maximum average (1.55*24 hrs) 37.2 hrs in St Petersburg. Table 16: Average time spent at berth in ports Overview Total number of single visits NOT Confirmed mixing BW and GW on board Time spent at berth (days) Baltic ports Average time spent Confirmed mixing BW at berth (days) and GW on board Time spent at berth (days) Aarhus 3 0.34 0.33 0.35 Copenhagen 99 0.49 0.51 0.47 Fredericia 3 0.41 0.40 0.42 Gdansk 2 0.30 0.30 Gdynia 9 0.46 0.46 Gothenburg 4 0.51 0.68 0.34 Helsingborg 2 0.63 0.63 Helsinki 73 0.39 0.38 0.39 Hundested 1 0.46 0.46 Karlskrona 1 0.38 0.38 Kiel 21 0.51 0.43 0.52 Klaipeda 19 0.40 0.41 0.40 Page 27

Overview Total number of single visits NOT Confirmed mixing BW and GW on board Time spent at berth (days) Baltic ports Average time spent Confirmed mixing BW at berth (days) and GW on board Time spent at berth (days) Travemu nde 2 0.23 0.23 Lulea 1 0.42 0.42 Mariehamn 3 0.39 0.42 0.38 Malmö 1 0.56 0.56 Nynashamn 7 0.51 0.50 0.55 Riga 20 0.41 0.41 0.41 Rønne 1 0.44 0.44 Rostock 6 0.75 0.60 1.50 Warnemünde 52 0.57 0.61 0.53 St Petersburg 71 1.55 1.46 1.61 Skagen 2 0.40 0.38 0.43 Stockholm 76 0.63 0.54 0.70 Tallinn 83 0.41 0.46 0.37 Visby 3 0.34 0.34 Wismar 1 0.65 0.65 Average: 0.50 0.5270 0.5296 The table below shows the time between starting the discharge operation and ending the discharge operation at a port per size of ship and per age of ship 27. As reference, the total number of operations and percentage of total number of operations is provided. Table 17: Time needed for discharge operation Time for discharging (hrs) Size of ship (total number of persons on board) Small (<1500) Medium (1500-3000) Large (3000-4000) Very Large (>4000) Number of operations Percentage total 0-5 years Age of ship 5-10 years 10-15 years 0-1 2 0 13 2 17 6% 0 3 6 8 1-2 2 2 10 5 19 6% 2 5 7 5 2-3 5 8 14 3 29 9% 2 1 16 11 3-4 2 7 17 9 35 11% 5 12 13 5 4-5 1 9 16 9 35 11% 5 12 10 8 5-6 8 6 14 8 36 12% 3 8 14 11 6-7 6 11 21 14 52 17% 3 11 23 15 7-8 0 10 11 3 24 8% 5 6 8 5 8-9 1 8 4 2 15 5% - 4 8 3 More 9 hrs 9 10 22 5 46 15% 2 6 10 28 Totals 36 71 142 60 308 100% 27 68 115 99 more than 15 years The following figures are based on the foregoing table. The first figure Time for discharging vs ages of ships shows clearly the relative high score for older vessels staying at berth for a longer time. The latter figure shows the time for discharging vs the sizes of ships. 27 Only completed feedback received regarding this specific aspect is included (309 reports) Page 28

Figure 4: Time for discharging vs ages of ships Time for discharging vs ages of ships 30 25 20 15 10 5 0 0-1 1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 More 9 hrs 0-5 years 5-10 years 10-15 years more than 15 years 2 per. Mov. Avg. (0-5 years) 2 per. Mov. Avg. (5-10 years) 2 per. Mov. Avg. (10-15 years) 2 per. Mov. Avg. (more than 15 years) Figure 5: Time for discharging vs sizes of ships 25 20 15 10 5 Time for discharging vs sizes of ships 0 0-1 1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 More 9 hrs Small Medium Large Very Large 2 per. Mov. Avg. (Small) 2 per. Mov. Avg. (Medium) 2 per. Mov. Avg. (Large) 2 per. Mov. Avg. (Very Large) Conclusion 8: More than 3 out of 4 port operations included in this exercise stayed less than 8 hrs at berth and more than half of the discharge operations took place between 3 and 7 hrs. the input received is dominated by vessels with between 3000-4000 people on board. Except some specific ports, on average, there is no difference in time spent at berth between ships with confirmed mixing of BW and GW on board and ships with no confirmed mixing of BW and GW on board. 5.1.8 Is the current berth equal to the one assigned at first instance? In only 2% of the feedback received, the actual berth was not equal to the berth assigned at first instance. Page 29

Table 18: Actual Berth vs berth assigned at first Berth equal to the one assigned? Number of feedback received Percentage Issues experienced? Berth not equal to the one assigned 10 2% 8 Berth equal to the one assigned 508 98% Total feedback received 518 Conclusion 9: Although 98% of feedback confirms that the berth is equal to the one assigned at first instance, in 80% of cases when that does not happen a problem is experienced by the cruise ship. Page 30

5.2 Issues experienced Apart from the opportunity to provide general feedback through the ship s reporting forms, there were three specific questions (A, B, C) included per port call regarding problems experienced. Conclusion 10: The analysis shows that during a significant number of port calls, issues have been experienced. It should be noted that the negative responses to specific individual questions may be lower (resp. 34%, 31% and 22%), however, overall, during 46% of all port calls some kind of issue has been experienced. Table 19: Overall feedback received on problems Total Percentage Count Problem 264 46% Count No Problem 315 54% Total 579 times 5.2.1 Question A: When relevant: please indicate the issues encountered by using one of more of the following code letters The code letters included: (A) No facility available; (B) Undue delay; (C) Use of facility technically not possible; (D) Inconvenient location; (E) Vessel had to shift berth involving delay/cost; (F) Unreasonable charges for use of facilities; (G) Other (please specify under additional comments). Table 20: No problem vs Problems A-G No issues vs Issues A-G Operations Percentage of total Count "No issue" 381 66% Count number of operations with issues A-G 198 34% Total 579 100% Further analysis of the code letters for problems experienced A-G The total number of operations differs from the total number of entries because some reports contained more than 1 response (A/B/C/E/F/G) for this specific question. Table 21: Problems experienced - indication When relevant: please indicate, the problems encountered by using one of more of the following code letters Code Operations Percentage Description A 28 13% No facility available B 48 22% Undue delay C 13 6% Use of facility technically not possible D 11 5% Inconvenient location; E 0 0% Vessel had to shift berth involving delay/cost F 56 25% Unreasonable charges for use of facilities G 64 29% Other (please specify under additional comments) Total number of entries 220 Total number of operations 198 A significant number of reports answered G and additional comments were provided. Page 31

5.2.2 Question B: In your opinion, is the port facility properly accommodated to meet the needs of the ship? In total, 422 reports were received containing Yes or No responses. 31% Of those responses were negative. There is not significant difference between ships where mixing of BW and GW has been confirmed and those not. Table 22: Port facility properly accommodated? Port facility properly accommodated? Total Percentage Percentage Confirmed mixing BW and GW on board Percentage NOT Confirmed mixing BW and GW on board Percentage Count "Yes" 292 50% 69% 117 67% 175 71% Count "No" 130 22% 31% 57 33% 73 29% Count "Empty" or "n/a" 157 27% Total 579 times The reporting format did not ask additional questions in order to enable an additional assessment of the feedback received. Although a port may be considered by the ship to be properly accommodated, this does not necessarily mean that the facility is considered to be adequate as well. The table below provides further insight into which ports were considered not properly accommodated by the visiting cruise ships. If the ports visited only a very few times (max 3) are excluded from this analysis (marked grey in the table), the ports with the highest percentage (above 30%) are: Copenhagen, Klaipeda, Riga, Rostock and St Petersburg (marked yellow in the table). Page 32

Table 23: Port facility properly accommodated? Port analysis Confirme d mixing BW and GW on board NOT Confirme d mixing BW and GW on board In your opinion, is the port facility properly accommodated to meet the needs of the ship? (No) Baltic ports Overvie w Total number of single In your opinion, is the port facility properly accommodat Averag e time spent Onboard mixing of BW and GW Onboard mixing of BW and GW not visits ed to meet at Time Time confirmed confirmed the needs of the ship? (No) Percentag e berth (days) spent at berth spent at berth Aarhus 3 1 33% 0.34 0.33 0.35 0 0.0% 1 33.3% Copenhagen 99 36 36% 0.49 0.51 0.47 1 7 17.2 % 1 9 19.2% Fredericia 3 1 33% 0.41 0.40 0.42 1 33.3 % 0 0.0% Gdansk 2 1 50% 0.30 0.30 0 0.0% 1 50.0% Gdynia 9 2 22% 0.46 0.46 0 0.0% 2 22.2% Gothenburg 4 0 0% 0.51 0.68 0.34 0 0.0% 0 0.0% Helsingborg 2 0 0% 0.63 0.63 0 0.0% 0 0.0% Helsinki 73 3 4% 0.39 0.38 0.39 0 0.0% 3 4.1% Hundested 1 0 0% 0.46 0.46 0 0.0% 0 0.0% Karlskrona 1 0 0% 0.38 0.38 0 0.0% 0 0.0% Kiel 21 0 0% 0.51 0.43 0.52 0 0.0% 0 0.0% Klaipeda 19 8 42% 0.40 0.41 0.40 2 10.5 % 6 31.6% Travemu nde 2 1 50% 0.23 0.23 0 0.0% 1 50.0% Lulea 1 0 0% 0.42 0.42 0 0.0% 0 0.0% Mariehamn 3 0 0% 0.39 0.42 0.38 0 0.0% 0 0.0% Malmö 1 1 100% 0.56 0.56 0 0.0% 1 100.0 % Nynashamn 7 0 0% 0.51 0.50 0.55 0 0.0% 0 0.0% Örnsköldsvi k 1 0 0% 0.00 0.00 0 0.0% 0 0.0% Pori 1 0 0% 0.00 0.00 0 0.0% 0 0.0% Riga 20 10 50% 0.41 0.41 0.41 7 35.0 % 3 15.0% Rønne 1 0 0% 0.44 0.44 0 0.0% 0 0.0% Rostock 6 2 33% 0.75 0.60 1.50 2 33.3 % 0 0.0% Warnemünd e 52 12 23% 0.57 0.61 0.53 0 0.0% 1 2 23.1% St Petersburg 71 26 37% 1.55 1.46 1.61 1 1 15.5 % 1 5 21.1% Skagen 2 0 0% 0.40 0.38 0.43 0 0.0% 0 0.0% Stockholm 76 2 3% 0.63 0.54 0.70 1 1.3% 1 1.3% Tallinn 83 22 27% 0.41 0.46 0.37 1 7 20.5 % 5 6.0% Umea 1 0 0% 0.00 0.00 0 0.0% 0 0.0% Visby 3 1 33% 0.34 0.34 0 0.0% 1 33.3% Wismar 1 1 100% 0.65 0.65 0 0.0% 1 100.0 % 569 130 23% 0.45 0.53 0.47 5 8 5.6% 7 2 17.0% Page 33

Table 24: Port facility properly accommodated? Ship analysis Ship Code Confirmed mixing of GW and BW on board Average number of people on board Max. storage / Average number of people on board capacity Total number of entries In your opinion, is the port facility properly accommodated to meet the needs of the ship? (No) Percentage In your opinion, is the port facility properly accommodated to meet the needs of the ship? (No) Mixing BW and GW confirmed Mixing BW and GW not confirmed S101 Yes 1721 0.67 13 5 38.5% 5 38.5% S102 1633 0.74 17 10 58.8% 10 58.8% S103 3022 0.60 8 3 37.5% 3 37.5% S104 682 0.34 8 1 12.5% 1 12.5% S105 785 1.75 0 0 0 S106 1003 0.09 19 13 68.4% 13 68.4% S107 Yes 2680 0.19 6 2 33.3% 2 33.3% S108 Yes 5216 0.67 47 0 0.0% 0 0.0% S128 1034 0.34 6 1 16.7% 1 16.7% S129 4421 0.44 7 0 0.0% 0 0.0% S109 #N/A 0 0 0 S110 Yes 688 0.34 9 0 0.0% 0 0.0% S111 2630 0.20 5 1 20.0% 1 20.0% S112 Yes 4204 0.83 38 1 2.6% 1 2.6% S113 Yes 4174 0.83 47 7 14.9% 7 14.9% S114 3258 0.25 22 1 4.5% 1 4.5% S115 Yes 4650 0.80 8 6 75.0% 6 75.0% S116 Yes 3223 0.85 52 32 61.5% 32 61.5% S118 #N/A 3 0 0.0% 0 0.0% S119 3618 0.56 58 3 5.2% 3 5.2% S120 3077 0.57 2 0 0.0% 0 0.0% S121 3627 0.12 25 0 0.0% 0 0.0% S122 3007 0.04 48 33 68.8% 33 68.8% S123 Yes 3586 0.29 50 5 10.0% 5 10.0% S124 1034 0.85 29 5 17.2% 5 17.2% S125 1021 0.41 7 0 0.0% 0 0.0% S126 2020 1.53 15 0 0.0% 0 0.0% S127 1150 0.12 14 1 7.1% 1 7.1% S130 #N/A 2 0 0.0% 0 0.0% 0.55 565 130 23.0% 58 26.2% 72 17.6% Conclusion 11: Regarding the question whether the port facility is properly accommodated to meet the needs of the ship; the ports with the highest percentage (above 30%) of negative responses are: Copenhagen, Klaipeda, Riga, Rostock and St Petersburg (yellow in the table). It would be interesting to further investigate and compare the quantitative and qualitative feedback received on whether the port facility is properly accommodated vs other indicators for instance per berth. 5.2.3 Question C: Did the volume of sewage discharged conform the wishes of the ship? Generally, ships for which the mixing of BW and GW on board has been confirmed, provide a more negative response (41% of cases) compared to ships which do not mix BW and GW on board (11%). Excluding ports visited less than 3 times, most negative feedback from ships mixing BW and GW have been received from ships visiting the ports (ratio): Helsinki (1.5), Warnemünde (5.5), Stockholm (15.0) and Tallinn (1.5). Page 34

Table 25: Did the volume of sewage discharged conform the wishes of the ship? Volume sewage discharged conform wishes of ship? Total Percentage Percentage Confirmed mixing BW and GW on board Percentage NOT Confirmed mixing BW and GW on board Percentage Count "Yes" 261 45% 78% 68 59% 193 89% Count "No" 72 12% 22% 47 41% 25 11% Count "Empty" or "n/a" 246 42% Total 579 times The table below provides further insight into which ports were considered not properly accommodated by the visiting cruise ships. If the ports visited only a very few times (less than 4) are excluded from this analysis (marked grey in the table), there are no ports with percentages above 30%. Most notable ports are: Klaipeda (26%), Warnemünde (29%) and Stockholm (22%). Table 26: Did the volume of sewage discharged conform the wishes of the ship? Port Analysis and BW/GW Mixing Port Baltic ports Overview Total number of single visits Did the volume of sewage discharged conform the wishes of the ship? (No) Percentage Did the volume of sewage discharged conform the wishes of the ship? (No) Onboard mixing of BW and GW confirmed Onboard mixing of BW and GW not confirmed Ratio (Confirmed Mixing- Not Confirmed Mixing)/ Not Confirmed Mixing Aarhus 3 1 33% 0 0.0% 1 33.3% -1.00 Copenhagen 99 7 7% 4 4.0% 3 3.0% 0.14 Fredericia 3 1 33% 1 33.3% 0 0.0% 1.00 Gdansk 2 1 50% 0 0.0% 1 50.0% -1.00 Gdynia 9 1 11% 0 0.0% 1 11.1% -1.00 Gothenburg 4 0 0% 0 0.0% 0 0.0% Helsingborg 2 0 0% 0 0.0% 0 0.0% Helsinki 73 7 10% 5 6.8% 2 2.7% 0.43 Hundested 1 0 0% 0 0.0% 0 0.0% Karlskrona 1 0 0% 0 0.0% 0 0.0% Kiel 21 1 5% 1 4.8% 0 0.0% 1.00 Klaipeda 19 5 26% 1 5.3% 4 21.1% -0.60 Travemu nde 2 0 0% 0 0.0% 0 0.0% Lulea 1 0 0% 0 0.0% 0 0.0% Mariehamn 3 1 33% 0 0.0% 1 33.3% -1.00 Malmö 1 1 100% 0 0.0% 1 100.0% -1.00 Nynashamn 7 0 0% 0 0.0% 0 0.0% Örnsköldsvik 1 0 0% 0 0.0% 0 0.0% Pori 1 0 0% 0 0.0% 0 0.0% Riga 20 1 5% 0 0.0% 1 5.0% -1.00 Rønne 1 0 0% 0 0.0% 0 0.0% Rostock 6 1 17% 1 16.7% 0 0.0% 1.00 Warnemünde 52 15 29% 13 25.0% 2 3.8% 0.73 St Petersburg 71 3 4% 0 0.0% 3 4.2% -1.00 Skagen 2 0 0% 0 0.0% 0 0.0% Stockholm 76 17 22% 16 21.1% 1 1.3% 0.88 Tallinn 83 7 8% 5 6.0% 2 2.4% 0.43 Umea 1 0 0% 0 0.0% 0 0.0% Page 35

Visby 3 2 67% 0 0.0% 2 66.7% -1.00 Wismar 1 0 0% 0 0.0% 0 0.0% 569 72 15% 47 4.1% 25 11.3% 1.88 Table 27: Did the volume of sewage discharged conform the wishes of the ship? Port Analysis and BW/GW Mixing Ship Ship Code Confirmed mixing of GW and BW on board Max. storage / Average number of people on board capacity Total number of entries Did the volume of sewage discharged conform the wishes of the ship? (No) Percentage Did the volume of sewage discharged conform the wishes of the ship? (No) Mixing BW and GW confirmed Mixing BW and GW not confirmed S101 Yes 0.67 13 3 23.1% 3 23.1% S102 0.74 17 10 58.8% 10 58.8% S103 0.60 8 2 25.0% 2 25.0% S104 0.34 8 1 12.5% 1 12.5% S105 1.75 0 0 0 S106 0.09 19 3 15.8% 3 15.8% S107 Yes 0.19 6 1 16.7% 1 16.7% S108 Yes 0.67 47 0 0.0% 0 0.0% S128 0.34 6 0 0.0% 0 0.0% S129 0.44 7 0 0.0% 0 0.0% S109 0 0 0 S110 Yes 0.34 9 0 0.0% 0 0.0% S111 0.20 5 0 0.0% 0 0.0% S112 Yes 0.83 38 2 5.3% 2 5.3% S113 Yes 0.83 47 22 46.8% 22 46.8% S114 0.25 22 0 0.0% 0 0.0% S115 Yes 0.80 8 0 0.0% 0 0.0% S116 Yes 0.85 52 5 9.6% 5 9.6% S118 3 0 0.0% 0 0.0% S119 0.56 58 0 0.0% 0 0.0% S120 0.57 2 0 0.0% 0 0.0% S121 0.12 25 0 0.0% 0 0.0% S122 0.04 48 0 0.0% 0 0.0% S123 Yes 0.29 50 16 32.0% 16 32.0% S124 0.85 29 0 0.0% 0 0.0% S125 0.41 7 0 0.0% 0 0.0% S126 1.53 15 5 33.3% 5 33.3% S127 0.12 14 0 0.0% 0 0.0% S130 2 2 100.0% 2 100.0% 0.55 565 72 12.7% 49 14.8% 23 13.6% Compared to other bigger cruise ports in the Baltic, Stockholm received 47% port calls by cruise ships mixing BW and GW on board. This is not significantly different from Copenhagen (46%), Helsinki (53%), St Petersburg (48%) and Tallinn (53%). Also, Stockholm did not receive a small part of the cruise ships participating which would have twisted the data analysis. In fact, Stockholm received the highest amount of unique cruise ship visits (25 ships). Page 36

Table 28:In-depth analysis Ports vs Ships and mixing BW and GW Baltic ports Overview Total number of single visits Amount of unique cruise ships visiting the specific port Average amount of visits per cruise ship Mixing BW and GW confirmed Amount of unique cruise ships visiting the specific port (mixing BW and GW Confirmed) Percentage of unique cruise ship visits (mixing BW and GW confirmed) Aarhus 3 2 1.5 1 33% Copenhagen 99 23 4.3 46 46% Fredericia 3 3 1.0 2 67% Gdansk 2 2 1.0 Gdynia 9 4 2.3 Gothenburg 4 4 1.0 2 50% Helsingborg 2 2 1.0 2 100% Helsinki 73 23 3.2 39 53% Hundested 1 1 1.0 1 100% Karlskrona 1 1 1.0 Kiel 21 4 5.3 3 14% Klaipeda 19 10 1.9 2 11% Travemu nde 2 2 1.0 Lulea 1 1 1.0 1 100% Mariehamn 3 2 1.5 1 33% Malmö 1 1 1.0 Nynashamn 7 1 7.0 7 100% Örnsköldsvik 1 1 1.0 1 100% Pori 1 1 1.0 1 100% Riga 20 10 2.0 7 35% Rønne 1 1 1.0 Rostock 6 5 1.2 5 83% Warnemünde 52 11 4.7 30 58% St Petersburg 71 21 3.4 34 48% Skagen 2 2 1.0 1 50% Stockholm 76 25 3.0 36 47% Tallinn 83 23 3.6 44 53% Umea 1 1 1.0 1 100% Visby 3 2 1.5 Wismar 1 1 1.0 569 267 63% Conclusion 12: The ports of Klaipeda (26%), Warnemünde (29%) and Stockholm (22%) have the highest percentage of occasions when the volume of sewage discharged did not conform with the wishes of the ship. 5.2.4 Reported IMO/GISIS/Flagstate notification on the lack of adequate Port Reception Facilities In case Port Reception Facilities are found to be inadequate by the user of the facility, a report of that should be submitted to the IMO database. This GISIS database is available online, however, does not include all relevant aspects. For instance, it does not include an option to specify facilities per berth. Although many ships experienced problems during multiple occasions during this exercise, only 44 positive feedbacks were received on the following question in the reporting form: In case the cruise ships finds the PRF inadequate, has or will an inadequacy report (be) submitted to the Flag State? Conclusion 13: It should be noted that this question on notification of (in)adequacy may have been interpreted as a hypothetical situation and the actual decision to submit such an inadequacy report Page 37

may not need to be up to the crew on board. This question would need to be rephrased in future project. 5.3 Port and Port Reception Facilities providers 5.3.1 Generally, there appears to be very few PRF providers to select from in a port Overall, there are very few PRF providers to select from in a port and hence a lack of competition. The cruise ship is therefore generally obliged to make use of the services provided by a single operator and is not in a position to select. The cruise industry would like to be able to select the PRF provider, providing the best services at reasonable costs. The lack of competition may have a negative influence, but not necessarily. Table 29: Number of PRF providers to select from How many PRF providers can the ship select from in the port? (maximum) Amount reported by participating ships 1 12 2 5 3 1 Average: 1.39 Conclusion 14: It would be recommendable to developed Key Performance Indicators for PRF providers and to benchmark them against Best of Class. 5.3.2 Maximum pumping capacity vs volumes and time for discharging Based on feedback from ships on the maximum pumping capacity available in a port and specifically requested from the ships: the actual volume delivered, the time for discharging compared to the actual volume on board and time for discharging; the PRFs in ports can be assessed for their individual capability to provide adequate PRFs to the users of that port. This is by no means intended to provide a conclusive approach to assess the adequacy. However, some level of relationship is expected between this indicator and the experiences of ships at specific ports. Differences may also be expected due to the actual amount and type of wastewater delivered at port, the difference between reported and applied pumping capacity and the possibility that the reported applied pumping capacity is not related with the type volume discharged. The following two tables provide the same analysis and list the top performances from ports, although the first is based on the pumping capacity reported and the second is based on the pumping capacity calculated (volume delivered/time for discharging). Page 38

Table 30: Performances of ports based on pumping capacity reported Best performing ports: Based on the actual volume currently delivered and time for discharging, the maximum pumping capacity is relatively high in the following ports; this indicates that the port is relatively well equipped. 28 Based on the actual volume on board and time for discharging, the maximum pumping capacity is relatively high in the following ports; this indicates that the port is relatively well equipped. 1 Tallinn (60-100cubm/h) Mariehamn (30cubm/h) 2 Copenhagen (250-300cubm/h) Gdansk (Tank trucks) 3 Klaipeda (Tank trucks or Barges) Klaipeda (Tank trucks or Barges) 4 Warnemünde (up to 300cubm/h in total) Visby (16-20cubm/h) Table 31: Performances of ports based on pumping capacity calculated Based on the actual volume currently Based on the actual volume on delivered and time for discharging, board and time for discharging, the Best the maximum pumping capacity is maximum pumping capacity is performing relatively high in the following ports; relatively high in the following ports: this indicates that the port is ports; this indicates that the port is relatively well equipped. 29 relatively well equipped. 1 Tallinn (60-100cubm/h) Mariehamn (30cubm/h) 2 Copenhagen (250-300cubm/h) Visby (16-20cubm/h) 3 Warnemünde (up to 300cubm/h in total) Tallinn (60-100cubm/h) 4 Klaipeda (Tank trucks or Barges) Conclusion 15: The best performing ports according to these two indicators are relatively in line. This means that possible errors do not have a significant effect on the outcome. It would be interesting to develop more indicators of the (potential) port performances and to assess the performances on a regular basis. 5.4 Discharge operation The discharge operation itself includes many different aspects under safety, environmental and operational. This section only covers the quantitative input received during the exercise. For instance, there were very few references to safety and environmental aspects during the discharge operation included in the questionnaires. Some additional feedback regarding safety and environmental aspect has been received from the qualitative analysis. Conclusion 16: It is recommended to include safety and environmental (risk) more prominently in a future study. 5.4.1 Maximum pumping capacities applied 30 Feedback was given on the pumping capacity applied and the types of PRF available and/or applied in order to discharge waste water. The following figures provide some insight in the maximum pumping capacity reported for the specific type of PRF available and/or applied. The maximum pumping capacity is highest when a fixed PRF is available. The table below shows that there is some relationship between the Total pumping capacity and the Total capacity available of a tank car/truck. 28 Figures in brackets are taken from HELCOM overview 2014 29 Figures in brackets are taken from HELCOM overview 2014 30 Zeros in the following figures are due to the fact there was no feedback received on this specific question. Page 39

Maximum pumping capacity applied Table 32: Relation between a tank cars Total pumping capacity / Total capacity available Total pumping capacity / Total capacity available (unit: ((m3/hr) /m3)=1/hr) Number of feedback received 0-0.25 0 0.25-0.50 4 0.50-0.75 16 0.75-1 8 1-2 2 2-3 1 3-4 1 4-5 1 5-6 0 6-7 0 7-8 1 Figure 6: Max. Pumping Capacity Truck 80 70 Max pumping capacity applied at Truck 60 50 40 30 20 Max pumping capacity applied at Truck 10 0 0 500 1000 1500 2000 2500 3000 3500 4000 Guest Capacity The table below shows that there is some relationship between the Total pumping capacity and the Total capacity available of a barge. However, it is less pronounced when compared to the tank cars/truck. Table 33: Table 28: Relation between a barge Total pumping capacity / Total capacity available Total pumping capacity / Total capacity available (unit: ((m3/hr) /m3)=1/hr) Number of feedback received 0-0.1 1 0.1-0.2 2 0.2-0.25 0 0.25-0.50 5 0.50-0.75 1 0.75-1 0 1-2 0 2-3 0 3-4 0 4-5 0 5-6 0 Page 40

Maximum pumping capacity applied Maximum pumping capacity applied Total pumping capacity / Total capacity available (unit: ((m3/hr) /m3)=1/hr) Number of feedback received 6-7 0 7-8 0 Figure 7: Max. Pumping Capacity Barge 90 Max. pumping capacity applied at Barge 80 70 60 50 40 30 Max. pumping capacity applied at Barge 20 10 0 0 500 1000 1500 2000 2500 3000 3500 4000 Guest Capacity Figure 8: Max. Pumping Capacity Fixed PRF 160 Max. pumping capacity applied at Fixed Reception Point 140 120 100 80 60 Max. pumping capacity applied at Fixed Reception Point 40 20 0 0 500 1000 1500 2000 2500 3000 3500 4000 Guest Capacity Page 41

Average Stockholm Helsinki Stockholm Helsinki Stockholm Helsinki Helsinki Stockholm Helsinki Stockholm average Copenhage n Warnemün de Helsinki Stockholm Stockholm Helsinki Stockholm Helsinki Stockholm Summary of qualitative feedback received from ship S116 This ship provided some extensive descriptions including a timeline on the actual discharge operations. From the information provided, it is noted that the reported discharging time may include discharge operation for Bio-Residue and Sewage. Before actual discharge operations commence, approximately 15 minutes from making the connection is needed for preparation. The same time would be needed to close down the operations after the discharge operation is stopped ( Bunker station clean-up ). Both for pumping of sewage as for Bio-residue, approx. 2 m3 of sea water is used to prime the pump. Table 34: Summary of qualitative feedback received from ship S116 a Time between connection made and 0.17 0.08 0.20 0.17 0.43 0.27 0.33 0.42 0.25 0.42 0.27 start discharge (hrs) Time for treated Sewage discharge (hrs) 3.75 3.50 4.25 3.00 6.40 7.25 3.00 5.50 1.50 5.50 4.37 Pace reported (m3/hr) 74.80 47.20 78.60 87.70 68.30 89.00 56.30 87.80 88.70 87.80 76.62 Time for Bio Residue discharge (hrs) 1.75 2.17 2.25 2.67 2.42 1.25 1.58 1.17 2.13 1.17 1.86 Pace reported 55.00 42.70 41.00 33.30 40.90 41.60 37.10 32.70 31.70 32.70 38.87 Table 35: Summary of qualitative feedback received from ship S116 b Time between connection made and start discharge (hrs) 0.42 0.25 0.58 0.17 0.17 0.28 0.18 0.13 0.17 0.18 Time for treated Sewage discharge (hrs) 3.45 1.42 3.92 3.25 4.25 4.75 5.30 2.87 6.38 3.95 Pace reported (m3/hr) Volume (m3) 87.8 88.7 88.25 Time for Bio Residue discharge (hrs) 483 133 403 248 324 319 259 300 489 328.67 Pace reported Volume (m3) 32.7 31.7 51.8 38.73 Conclusion 17: The limiting factor for the pumping capacity as well as which pump(s) is/are actually used in practice (the ship s or the port s) needs to be further assessed, including the possible different pumping capacities for GW and BW. 5.4.2 Wastewater (Black and/or Grey Water and/or mixtures) discharged at sea During the 2016 Exercise, ships discharged at the Port Reception Facilities as well as at sea. Those discharges at sea were not specifically recorded as BW, GW or mixtures of waste water. Therefore, the total volumes received by ports represent only part of the total volumes which may be expected when all ships would have discharged everything at the PRF. Page 42

Reasons applied The reporting format did not provide ship specific options to record their reasons for discharge at sea. Therefore, different input received from the ships has been combined were appropriate. Table 36: Reasons for discharging at sea Percentage Why was this sewage discharged? number Number of reports reasons given Limited storage capacity 91 23.7% Stability problems 49 12.8% As per MARPOL 66 17.2% Ships operation 77 20.1% Trim 47 12.2% Draft limitation 6 1.6% Safety 48 12.5% Number of reasons given for 384 100.0% Number of discharges at sea 294 of Ships were specifically asked whether the waste water was discharged because of the safety of the ship. It was left to the specific ship to interpret a definition for safety of the ship which may include several of the reasons stated above. In 36% of discharges at sea, the ships reported that the discharge was performed due to the safety of the ship. Table 37: Discharge at sea because of the safety of the ship Was the sewage discharged because of the safety of the ship? Number of feedback Percentage n/a 175 32.8% No 231 43.3% Yes 128 24.0% 534 100.0% Conclusion 18: In the next phase of the exercise, the reporting format generally needs to be clearer and needs to provide ship specific options to record their reasons for discharge at sea, including quantity and type of GW and BW volumes. Moreover, the Page 43

5.5 HELCOM, 2014 versus Simulation 2016 Exercise 2016 This section provides additional information on the use of port reception facilities by cruise vessels in the Baltic Sea. Results shown in the table include the annual number of expected calls, as well as presently observed maximum wastewater discharge rates. These results are presented in the context of the theoretical maximum discharge rate (calculated by HELCOM, 2014) that may be required by cruise vessels utilizing port reception facilities at those ports. The calculated maximum discharge rate is based on the amount of sewage / waste water delivered divided by the duration of the discharge operation. It should be noted that although the discharge operation may be discontinued just before the departure (as to discharge as much as possible, in line with the requirements), the maximum pumping capacity may not have been applied during that operation. Also, multiple discharge operations of different waste water streams may have been included. Although some data has been received from ports which may have allowed verification of the data received from ships, the data from specific ports seems to be inconsistent. Table 38: Observed and estimated theoretical maximum discharge rates at the top ten cruise ports by calls in the Baltic Sea Port Name Cruise Calls HELCOM, 2014 31 2016 Exercise 2016 Observed Maximum Discharge Rate (m3/hr) Theoretical Maximum Discharge Rate (HELCOM, 2014) Cruis e Calls Reported Maximum Discharge Rate (m3/hr) Calculat ed (m3/hr) Copen hagen 300 30 1500 99 100 67 Gothe nburg 71 37 1600 4 50 97 Helsin ki 257 120 1500 73 100 94 Kiel 120 36 900 21 61 62 Klaipe da 63 28 1200 19 75 45 Rostoc k 181 NA 1100 6 60 3.5 Stockh olm 236 (Port Statistics, 280) 85 1000 76 270 218 Riga 52 40 700 20 80 50 St. Peters burg 312 28 500 71 100 60 Tallinn 285 40 1600 83 77 140 31 http://www.helcom.fi/lists/publications/baltic%20sea%20sewage%20port%20reception%20facilities.%20hel COM%20overview%202014.pdf Page 44

6 Conclusions and Recommendations PRF Baltic Sea Region A. Ahead of the entry into force of the Marpol Annex IV requirements, the focus should be on: Clear communication of future PRFs Inclusion of the possible clients, cruise ships visiting a port, on the development of port infrastructure The adequacies of PRFs in the BSR. The developments of a contingency / Plan B option, at port as well as at sea, e.g. when facilities are not adequate. B. CLIA Europe does not agree with this very strict interpretation for the next port of delivery and the below overview provides a clear insight in the major effects that interpretation would have on the operations. In almost half of the reported cases, the next port scheduled was not the same as the next port of delivery. (Conclusion 1) C. No next steps are necessary regarding the timing of submitting the ANF to a port. (Conclusion 2) D. In most of the cases, the volumes delivered are in line with the estimation provided in advance via the ANF. The feedback received could be improved by including a clearer description of the volumes in the reporting forms. (Conclusion 3) E. Those ports receiving ships on an extended Sea Time voyage through the Baltic Sea should take this into account when developing adequate Port Reception Facilities for Sewage. (Conclusion 4) F. The feedback received suggests there is a slightly higher chance of a problem when on a counter clockwise itinerary. More in-depth analysis and data is required before any conclusions can be derived. (Conclusion 5) G. Although each delay experienced has very significant effects on the operation of cruise ship, from the data received, in general, there is no significant effect of problems experienced during discharge operations. Additional research may be interesting to conduct. (Conclusion 6) H. This information provides an indication of the operations presented in this analysis of the experiences during the 2016 exercise and may be of use when relating general conclusions to specific cases. (Conclusion 7) I. More than 3 out of 4 port operations included in this exercise stayed less than 8 hrs at berth and more than half of the discharge operations took place between 3 and 7 hrs. the input received is dominated by vessels with between 3000-4000 people on board. (Conclusion 8) J. Although 98% of feedback confirms that the berth is equal to the one assigned at first instance, in 80% of cases when that does not happen a problem is experienced by the cruise ship. (Conclusion 9) K. The analysis shows that during a significant number of port calls, issues have been experienced. It should be noted that the negative responses to specific individual questions may be lower (resp. 34%, 31% and 22%), however, overall, during 46% of all port calls some kind of issue has been experienced. (Conclusion 10) Page 45

L. Regarding the question whether the port facility is properly accommodated to meet the needs of the ship; the ports with the highest percentage (above 30%) of negative responses are: Copenhagen, Klaipeda, Riga, Rostock and St Petersburg (yellow in the table). It would be interesting to further investigate and compare the quantitative and qualitative feedback received on whether the port facility is properly accommodated vs other indicators for instance per berth. (Conclusion 11) M. The ports of Klaipeda (26%), Warnemünde (29%) and Stockholm (22%) have the highest percentage of occasions when the volume of sewage discharged did not conform with the wishes of the ship. (Conclusion 12) N. It should be noted that this question on notification of (in)adequacy may have been interpreted as a hypothetical situation and the actual decision to submit such an inadequacy report may not need to be up to the crew on board. This question would need to be rephrased in future project. (Conclusion 13) O. It would be recommendable to developed Key Performance Indicators for PRF providers and to benchmark them against Best of Class. (Conclusion 14) P. The best performing ports according to these two indicators are relatively in line. This means that possible errors do not have a significant effect on the outcome. It would be interesting to develop more indicators of the (potential) port performances and to assess the performances on a regular basis. (Conclusion 15) Q. It is recommended to include safety and environmental (risk) more prominently in a future study. (Conclusion 16) R. The limiting factor for the pumping capacity as well as which pump(s) is/are actually used in practice (the ship s or the port s) needs to be further assessed, including the possible different pumping capacities for GW and BW. (Conclusion 17) S. In the next phase of the exercise, the reporting format needs to provide ship specific options to record their reasons for discharge at sea, Including quantity and type of GW and BW volumes. (Conclusion 18) T. The Standard Format of the Advance Notification Form (ANF) for waste delivery to Port Reception Facilities 32 should include specific definitions and quantities for the following: Grey Water (GW), Black Water (BW) (sewage) consisting of: Only Black Water and Mixture of BW and GW, Bio residues, Other waste waters including EGCS/Marpol Annex VI, Caustic Soda delivery. U. The cruise industry would like to see PRF providers with high operating standards which understand and support the high environmental operating standards from the cruise industry and the public interest. The cruise industry is very much concerned about the operational risks with sewage on board, sewage treatment and sewage discharges. Those legal, safety and environmental risks can only be managed successfully in close cooperation with the other stakeholders, especially the port and PRF provider. More long term partnerships with key PRF 32 MEPC.1/Circ.644. Page 46

providers where core competences are very high with regard to safety and environment may support managing this operational risk. V. Ports need to update their individual Port Waste Management Plans s to account for the impending legislation. The cruise industry should be included in those discussions the amendments and updates. W. Standard discharge connections are essential to facilitate operational compliance. X. Many ships fitted with AWTP s may not have adequate capability to segregate BW and GW on board or in their piping arrangement for discharging 33. PRF s accepting only BW or only GW may then be considered to be inadequate. Y. Ship fitted with an AWTP may need to discharge (higher volumes) mixed BW and GW at berth which would be classified as BW or treated BW. Z. Dealing with different methods of discharging in multiple ports is considered to be a considerable administrative burden as crew needs to dedicate time and efforts in coordinating the logistics. In addition, multiple discharge operations (of different waste streams) (taking place at the same time or not) may interfere with one another. AA. Also, it is considered to be an administrative burden for the ship s crew and increasing the safety and environmental risk of spills is when too small trucks are available. For example, the port of Gdansk, where off-load has been performed by small trucks, 8-10 m3 capacity each at a rate of only one truck / hour. BB. Tallinn allows only 7m3 of Sewage to be discharged in the fixed fee part. The requirement to deliver that low amount is considered to be an administrative burden and not in line with on board production of sewage. CC. Some facilities do not accept Bio-Residue and/or treated sewage. DD. A cruise ship does not want to run the risk of having to discharge at sea while at berth because of problems experienced connecting to a PRF. The crew would therefore always prefer to not have reached the berth with completely filled tanks. EE. Operational challenges at berth include an occasion where a local Port Authority representative didn't allow the sewage truck to come next to the ship, "in order not to disturb the passengers". The Staff Captain had to interfere, to have the sewage truck allowed to be connected, which took 2 additional hours. FF. Specific feedback received on the Port of St. Petersburg, the Main Passenger Terminal (Pier B): included that it was considered to be a logistic nightmare, because all activities are performed by barges (Sewage, Fresh Water, Garbage and Fuel). An extremely tight schedule and good planning is necessary, to accommodate all the barges. GG. Specific feedback received indicate that shore side facilities for vacuuming BW/GW hoses or flushing them after disconnection is poor (Tallinn/Stockholm/Helsinki). The feedback 33 Note that in order to keep the treatment system operational certain quantities of BW and GW need to be maintained on board to keep the biological components healthy. Page 47

concluded that of the ports need to retrofit equipment to their systems to accommodate the ships, or the ships may have to retrofit a pump on board to flush sea water through the hoses upon completion. This would need to be coordinated. HH. Specific feedback received on the port of Copenhagen: Should encourage ships to dock on the new piers where there are shore side connections for waste water or install shore connections on the old piers II. Specific feedback received on the port of Helsinki: Helsinki: Only 1 designated line for Grey, TS and Bio-Residue, transfer could not be done at the same time. Page 48

7 Roadmap and next steps General remarks Clarity and certainty on the availability and adequacy of Port Reception Facilities is required at least two years in advance due to the itinerary planning deadline for the cruise industry. At the same time, the current and future operational demands of cruise ships visiting Baltic ports (volumes, mixing of BW and GW on board, pumping capacities/requirements etc.) need to be communicated in advance. Table 39: Roadmap and next steps Year Subjects and next steps 2023 Entry into force Marpol Annex IV requirements for all vessels a) Clear information required on the existing and future status of the PRFs for sewage in the Baltic 2021 Entry into force Marpol Annex IV requirements for almost all vessels Possible entry into force of a revised European PRF Directive a) Clear information required on the existing and future status of the PRFs for sewage in the Baltic 2020 a) Clear information required on the existing and future status of the PRFs for sewage in the Baltic 2019 Entry into force Marpol Annex IV requirements for new built vessels a) Clear information required on the existing and future status of the PRFs for sewage in the Baltic 2018 a) Clear information required on the existing and future status of the PRFs for sewage in the Baltic 2017 a) 2017 is two years ahead of the entry into force of the special area for new built ships. Taking into account the two years itinerary planning deadline for new built vessels, clarity of adequacy needs to be provided. b) The conclusions of the 2016 Exercise to be included in the ongoing revision of the EU PRF Directive. c) Providing the cruise industry, both ships and ports, and other stakeholders with insight into the status of the (in-) adequacy of PRF in the region ahead of the entry into force of the Marpol Annex IV Special Area requirements. d) Continuation of the Operational Exercise during 2017 or use information from this study for a purely desktop study in 2017 and 2018, supported by fact checking by some ships. e) Amendments to the Ships and Ports reporting forms f) Identify Key Performance Indicators g) Ports to be more closely involved in drafting the reporting forms and providing qualitative and quantitative feedback on the facilities and per discharge operation. h) Except for Part A and B of the Reporting Format supplied to the ports, the format has not been applied by the overwhelming majority of the port. During a next exercise, more ports need to join and all ports need to apply the correct forms. i) End 2017, Report Exercise 2017 j) Comparison outcomes 2017 Exercise with 2016 Exercise. Page 49

8 Annexes 8.1 Annexes contents 8 Annexes... 50 8.1 Annexes contents... 50 8.2 Ship based feedback data received... 51 8.3 Port based feedback data received... 65 8.4 Berth based feedback data received... 82 8.5 Analysis of amendments and assumptions related to the exercise... 90 8.6 Baltic Sea map and ports and ships routing... 95 8.7 Communication with Ports and information received... 104 8.8 Reporting forms for ships and ports... 116 8.9 Marpol Annex IV Requirements... 120 9 List of Tables... 126 10 List of Figures... 127 Page 50

8.2 Ship based feedback data received Both ships and ports have been invited to provide both qualitative and quantitative feedback on a general and port/ship visit specific basis using the templates provided by and agreed with CLIA Europe. The ports were provided with a worksheet Reporting Overview and multiple worksheets Reporting Ship visit 1 etc. The ships were provided with a worksheet Reporting Overview and multiple worksheets Reporting Port 1 etc. Section 8.2.1 contains the ships qualitative information received and section 8.2.2 contains an analysis of the ships quantitative information received. 8.2.1 Ships qualitative information received 8.2.1.1 Summary qualitative information received Conclusions of impressions received on question main challenges 34 A. Standard discharge connections are essential to operational compliance. B. Many ships fitted with AWTP s may not have adequate capability to segregate BW and GW. C. Ship fitted with an AWTP may need to discharge mixed BW and GW at berth which would be classified as BW. D. Deal with different methods of discharging in multiple ports is considered to be an administrative burden. E. 93 hours of Sea Condition F. Tallinn allows only 7m3 of Sewage in the fixed fee part. The requirement to deliver that low amount is considered to be an administrative burden and not in line with on board production of Sewage. G. Multiple discharge operations may interfere with one another. H. Some facilities do not accept Bio-Residue and/or treated sewage. Conclusions of impressions received on question tanks were nearly filled.. 35 I. This specific question may need to be rephrased in a future exercise J. The administrative burden and risk of spills is increased when too small trucks are available. K. We could have reached the port with completely filled tanks, but the time in port was always too short to discharge all waste water that we had. A cruise ship does not want to run the risk of having to discharge at sea while at berth because of problems experienced connecting to a PRF. L. The most challenging port was Gdansk, where the off-load is performed by trucks, 8-10 m3, one truck / hour. In addition, there was conflict, caused by local Port Authority representative, who didn't allow the sewage truck to come next to the ship, "in order not to disturb the passengers". The Staff Captain had to interfere, to have the sewage truck allowed to be connected, which took 2 additional hours. Summary of impressions received 36 M. The reporting template should be amended as it is not user friendly. N. Port of St. Petersburg, Main Passenger Terminal (Pier B), is a logistic nightmare, because all activities are performed by barges - Sewage, Fresh Water, Garbage and Fuel. An extremely tight schedule and good planning is necessary, to accommodate all the barges. O. Facilities shore side for vacuuming BW/GW hoses or flushing them after disconnection is poor. Had to manually lift the hoses in Tallinn and Stockholm. Helsinki had to take the capped hoses away with them to dispose of BW/GW residue in hoses as their sewage system would not 34 Section 8.2.1.3 35 Section 8.2.1.4 36 Section 8.2.1.5 Page 51

accept the left-over residue unless it was under pressure. Ports need to retrofit something to their systems to accommodate the ships, or the ships may have to retrofit a pump on board to flush sea water through the hoses upon completion as on Arcadia. Of course, if the ships have to accommodate the ports this would cause additional expenses for any ships cruising in the Baltic. P. Tallinn should offer more than 7m3 of waste water in their fixed fees and Copenhagen should encourage ships to dock on the new piers where there are shore side connections for waste water or install shore connections on the old piers Q. Helsinki: Only 1 designated line for Grey, TS and Bio-Residue, transfer could not be done at the same time 8.2.1.2 Specific feedback received from a cruise ship operator One of the participants in the 2016 Exercise provided some additional feedback on their experiences 37 at Baltic ports during the 2016 season. In this analysis, the ports of Copenhagen, Gdansk, Helsinki, Klaipeda, Riga, Stockholm, St. Petersburg and Tallinn are included. Feedback received includes: amounts of sewage under no special fee limited, logistical problems, conflicting operations, reposition of the vessel a few days before arrival, delay of barge operations, strict interpretation of the requirement to deliver waste ashore and the type of PRF specified for the amount of sewage to be delivered. Copenhagen According to the local regulations, collection of sewage is made under "no special fee", provided that the amounts are reasonable and were generated from pervious port of call ( reasonable amounts approximately 130 litres per person on board, per day). For higher amounts the fee is as follows: Fee per m3 - DKK 118,00; Hourly rate for waiting time, for every hour started - DKK 1.450,00. The major problem we experienced was logistic on the pier Langelinie 8-21 both Fuel Bunkering and Sewage Off-load was performed by trucks, and both from the Fuel Bunker Station on board. For that reason, we had to constantly coordinate the trucks, in order not to compromise the fuel bunker. Gdansk According to the local regulations, collection of sewage is as follows: 1/3 of the delivered amount of waste water is included in the tonnage due, the surplus 10 Euro per m3 38. The discharge is performed by two cistern trucks 10 m3, returning each hour. Our port stay was 8 hours. This would allow us to discharge only 7-8 trucks. The beginning of the operation was delayed by a Port Representative, who didn t give permission for the sewage truck to come alongside the ship with the explanation that it will be in conflict with the passengers operation. The Staff Captain had to intervene, to re-organize the passengers landing area and to allow the truck next to the ship, but this already had cost an hour delay. Helsinki The ship stayed overnight. The sewage was discharged by a shore connection, which is included in the compulsory waste management fee, without limitation. The hose stayed connected from arrival until departure. In the light of the 2016 Exercise, Helsinki can be considered the best organized port regarding sewage water discharge. Klaipeda 37 From July 25th 2016 till August 5th 2016 38 http://www.portgdansk.pl/shipping/types-of-waste Page 52

The sewage was discharged by a barge, with capacity 250 m3. The discharged quantity (150 m3) was included in the sanitary dues. The barge came on time and the operation was smooth. Riga The sewage was discharged by a barge, with capacity 350 m3. The discharged quantity (150 m3) was included in the sanitary dues (according to the local Agent, up to 200 m3 is included in the sanitary dues). The barge came on time and the operation was smooth. Stockholm Waste (including sewage water) offloading is compulsory in Stockholm. The waste offloading is included in the port fee, to an amount possibly accumulated from the last port of call. It is done by a shore connection. St. Petersburg Few days before arrival, the ship was re-positioned to Main Passenger Terminal Berth B, instead of the regular English Embankment on Neva River. This turned out to be a logistic nightmare, since all the services were performed by barges sewage and garbage off-load, fresh water and fuel bunkering. The fact called for planning of the barges arrival and stay well in advance, which was excellently assisted by the Local Agent. At a certain point, we had 2 barges alongside simultaneously one for sewage water discharge and one for fresh water bunkering, in order to accommodate our needs and the 2016 Exercise. The price for the sewage off-load is very high: 23 USD/ton + 350 USD hour barge fee + overtime. The discharge usually takes about 6-7 hours, and the tendency is the barge operator to try to delay the operation, in order to accomplish more overtime. On the English Embankment pier the operation is lighter, due to the fact, that the fresh water is bunkered by a shore connection. According to a local environmental regulation Before the ship leaves the sea port, all waste and garbage must be transferred to reception facilities excluding food waste and oily bilge water which quantity does not exceed 25% of the ship's storage tank, which, if followed strictly, would mean a huge cost of not only the sewage discharge, but for the garbage as well, considering the high price of the barges. Tallinn The sewage is discharged either by trucks (if less than 80 m3 are delivered) or by shore connection (for more than 80 m3). We had to deliver estimated 100 m3, which was done by a shore connection. The price was calculated as follows: first 7 m3 on port fee, the rest 5.9 EUR / m3. 8.2.1.3 Question: What were the main challenges that you experienced? 23 Cruise ships provided feedback on the following question included in the standard reporting format for ships; What were the main challenges that you experienced? It should be noted that some of these ships are equipped with AWTS. Impressions received per cruise ship: Shipcode: S101 maximum flow rates accepted by ports often too low to discharge all during port stay "To deal with three different methods of discharging in five ports: Tallinn: Trucks due to jetty No 25 (too small trucks 8cbm); St Petersburg: Barge; Helsinki: Shore connection. If two ships calling port of Kiel only one ship can discharge sewage to shore facility due to limited pump capacity" Page 53

"Broken barge in Klaipeda, only two small barges were available instead of one big barge with a capacity of 400 cbm If two ships calling port of Kiel only one ship can discharge sewage to shore facility due to limited pump capacity" Shipcode: S102 Reception facilities couldn't receive the amount we wanted to discharge, trucks were small and inefficient, pumping rate from the ship was not sufficient to pump out all the waste water in the short time in port. On some calls the hose connections were not fitting, the port rectified this. Reception facilities couldn't receive the amount we needed to discharge, trucks are delayed, they were small and inefficient. Pumping rate from the ship was not sufficient to pump out all the waste water during short time in port. On some calls the hose connections were not fitting or the trucks did not bring add. hoses, even they were requested by us. Shipcode: S104 Segregation of Black and Grey Water streams, since the ship is not designed to do so Shipcode: S106 Coordinating the Manpower necessary to man the bunker stations during long discharges, multiple night overnights, Coordination and communication of flushing of sewage lines. Shipcode: S107 When discharging grey water, the connection flange was different in many countries. Finland, Denmark and Sweden all had different sized flanges. Shipcode: S107b Reception capacity is far too low to handle current volumes of waste water from cruise ships Shipcode: S108 No challenges. Shipcode: S110 nil Shipcode: S111 Due to itinerary voyage plan we were very restricted with discharging in the Baltic. Shipcode: S112 93 hours of Sea Condition with two overnights in Russia Tallinn: only 7m3 are covered in the fixed fee - since they are part of HELCOM they should allow at least 400m3 of waste water to be covered under fixed fee Shipcode: S113 Shore Connection in Tallinn extra Fee Challenges to deliver Waste Water in Tallinn & Copenhagen because of extra Fee Shipcode: S115 Only ports that met the criteria of agreement to treat the Baltic Sea as a "Special Area" under Annex IV of MARPOL was the PRF in Helsinki. Shipcode: S116 We were initially told wrong information regarding reception facilities. Initial information stated that there was only 30 m3 truck available for landing sewage. Upon arrival (May 15, 2016) I met with pier superintendent for wastewater and he showed me the shore side connection on the pier for discharge to the city's municipal treatment facility. Upon further review of port waste plan with the superintendent, we concluded that the criteria for the voluntary agreement with CLIA Europe (MARPOL Annex IV Baltic Special Area) was not met by the port. Grey water is not covered under port fees (additional payment needed) and Bio- Residue cannot be accepted at the facility. Only untreated Blackwater (which we do not have on board). Overnight in St. Petersburg, we utilized combined ballast / GW tanks for additional storage of Treated Sewage to avoid landing costs. Page 54

2 overnights (3 days) in St. Petersburg - utilized combined ballast / GW tanks for additional storage of Treated Sewage to avoid landing costs. Overnight in Copenhagen Aug 5 with no sea condition or Exemption for AWP/TS d/charge after departure from Berlin Aug 3. Next sea condition will be Aug 7 (sea day) after departure from Copenhagen Aug 6. Copenhagen PRF does not meet RCCL requirements for discharging to shore side facility (d/c of TS not included in port fees) therefore vessel had to pay to discharge TS/TWW to port facility due to itinerary restrictions. 1 overnight (2 days) in Copenhagen, Denmark Aug 5 & 6 with no sea condition or Exemption for AWP/TS d/charge since departure from Berlin Aug 3. Next sea condition will be Aug 7 (sea day), day after departure from Copenhagen Aug 6. Port of Copenhagen finally agreed that the vessel could dispose of TS to pier facility under "No Special Fee". We estimate approx. 450 m3 will be accumulated between departure from Fredericia Aug 4 & arrival into Copenhagen, Denmark Aug 5. Actual TS disposed of Aug 5 to PRF was 489 m3 (required to be listed as BW on Copenhagen Port waste declaration). For this voyage, we will only land waste in Copenhagen Aug 6. We have been advised by shore side to avoid landing waste in Norwegian ports due to high cost / too expensive. Shipcode: S119 Large offload in Tallinn gave us no operational time to offload TSG Barge in Klaipeda Shipcode: S120 if port has no fee and fixed reception facility we do not face any challenges Shipcode: S121 Tallinn Shipcode: S122 Warnemünde Shipcode: S123 When missing a port of call, due to unfavourable weather condition Shipcode: S124 Own systems Not too many but for St. Petersburg we had 3 days of retention and on Lt. Schmitt embankment offloading by barge is expensive. None Shipcode: S125 No Challenges Shipcode: S126 Some delay on connection or no information regarding the availability of the Barge (Klaipeda) Shipcode: S127 No challenges for our ship were faced. Shipcode: S129 Based on the ports used, none to date. 8.2.1.4 Question: Were there any moments, in which the tanks were nearly filled, with no prospect of being able to discharge onshore in the short term? Where? 39 As a matter of safety, each ship should look to connect ashore and discharge. However, with other operational demands (bunkering, garbage disposal, Caustic soda, urea loading, EGCS residues, etc...) Ship reporting format, worksheet general impressions received. 39 The way the question was written may not have been expected by ships staff as for each ship, the tank capacity can be determined as hours (under total complement) plus margin. That way, each ship can determine maximum time without discharge at sea or ashore. Page 55

Impressions received per cruise ship: Shipcode: S101 each full sea day, as tank capacity lasts only for max. 36h, then disposal must take place to avoid risks of TK overflow (this could be mitigated with a guaranteed unlimited (Qty, & flow rate) and timely service in the next port of call) Shipcode: S102 Capacity was not reached, but it was too risky to rely on a perfect discharge in the next port. We could have reached the port with completely filled tanks, but the time in port was always too short to discharge all waste water that we had. Furthermore, if we would have problems during this disposal (e.g. delay of the barge), we would have left the port with full tanks and no capacity left. Capacity was nearly reached, but on safety reasons and not knowing if we would have a perfect discharge in the next port we could not take the risk and could not completely avoid a discharge to sea. If we would have reached the port with completely filled tanks, the time in port was always too short to discharge all necessary waste water. Furthermore, if there would have been problems during disposal (e.g. delay of a barge, less trucks available, sewage system blocked...), we would have left the port with full tanks and no capacity left. This could have result in a risk for the whole ship. Shipcode: S103 No Shipcode: S104 Yes, but mostly during sea passage. The most challenging port was Gdansk, where the off-load is performed by trucks, 8-10 m3, one truck / hour. In addition, there was conflict, caused by local Port Authority representative, who didn't allow the sewage truck to come next to the ship, "in order not to disturb the passengers". The Staff Captain had to interfere, to have the sewage truck allowed to be connected, which took 2 additional hours. Shipcode: S106 Yes, refer to the comment sections under the Copenhagen Tab. Yes, during our 3 night overnight stay in St. Petersburg. The issue is not so much with Black water but with Grey Water. Although the port provides grey water barges if needed, the fee is exorbitant and we had difficulties reaching an efficient pumping rate. No Shipcode: S107 No Shipcode: S107b Never Shipcode: S108 No Shipcode: S110 None Shipcode: S111 Yes, please see forms where discharges were made between ports. Shipcode: S112 no Yes, In St. Petersburg n/a Shipcode: s113 no Shipcode: s115 no Shipcode: S116 Page 56

n/a no Shipcode: s119 no Shipcode: s120 no Shipcode: s121 n/a Shipcode: S122 n/a Shipcode: S123 No Shipcode: S124 No No as no so long retention periods. Shipcode: S125 No Shipcode: S126 n/a Shipcode: S127 n/a Shipcode: S129 R. No 8.2.1.5 Question: Other comments / impressions Ship reporting format, worksheet general impressions received. Shipcode: S102 In general, this template needs to be better prepared. It is not user friendly for doing all the requested entries and needs to be much better formatted. At the current condition, it takes very much time to make all entries. Partly content of the questions is not clear. User needs to repeat information in different parts of the template. Some information requested are not available. Shipcode: S104 Port of St. Petersburg, Main Passenger Terminal (Pier B), is a logistic nightmare, because all activities are performed by barges - Sewage, Fresh Water, Garbage and Fuel. An extremely tight schedule and good planning is necessary, to accommodate all the barges S108 For Tallinn, Estonia and St Petersburg, Russia; the rates are too expensive. Shipcode: S111 Cost of discharging BW & GW should be at no cost if being discharged to Municipal Sewer System. Facilities shore side for vacuuming BW/GW hoses or flushing them after disconnection is poor. Had to manually lift the hoses in Tallinn and Stockholm. Helsinki had to take the capped hoses away with them to dispose of BW/GW residue in hoses as their sewage system would not accept the left-over residue unless it was under pressure. Ports need to retrofit something to their systems to accommodate the ships, or the ships may have to retrofit a pump on board to flush sea water through the hoses upon completion as on Arcadia. Of course, if the ships have to accommodate the ports this would cause additional expenses for any ships cruising in the Baltic. Retaining BW extremely difficult. On return from Helsinki had almost 24 hours inside 4nm going thru islands. Decision to discharge prior to reaching this area near Denmark was made ensure holding capacity of BW would not be exceeded. Page 57

Shipcode: S112 Tallinn should offer more than 7m3 of waste water in their fixed fees and Copenhagen should encourage ships to dock on the new piers where there are shore side connections for waste water or install shore connections on the old piers Shipcode: S115 Helsinki: Only 1 designated line for Grey, TS and Bio-Residue, transfer could not be done at the same time Shipcode: S116 Pier 24 / 25 in Tallinn, Estonia was under construction for the shore side connection. Progress being made, port agent confirmed by end of the summer the PRF will be available. Told to reduce pumping rate when pumping Treated Sewage in Stockholm, due to smell in terminal bathroom. Shipcode: S119 We also did Sewage offload in Oslo as per ports request to test their new facility (outside of Baltic) Shipcode: S123 Port of Copenhagen & St. Petersburg was not used for discharging/disposal of sewage due to high cost/pricing. Port of Copenhagen, Tallinn & St. Petersburg was not used for discharging/disposal of sewage due to high cost/pricing. Delayed departure from Stockholm due to engine problem. Shipcode: S124 Helsinki and Stockholm providing very good and free service. Warnemünde only on other berth offloading free service available with GW limits.. Shipcode: S126 Some ports the Sanitary Dues cover little quantity for dispose GW/BW (max 7,5m3) and have high Fee for the exceeding quantity Shipcode: S127 The best reception facilities were in Stockholm (shore connection to city municipal line - free of charge) and at Helsinki (shore connection to municipal line - and charges included in compulsory port fee). Shipcode: S129 In every port, we received the service we requested. The operators were on time, did everything well. Had no any issue at all. Next port of call 'Helsingborg' on 06/07/2016 was cancelled due to bad weather. Instead it was a sea day. 8.2.2 Ships Quantitative information received 8.2.2.1 Ships Table particulars / pumping capacity Table 40: Ships Table particulars / pumping capacity Ship Code Year of Built Guest capacity (maximum) Average number of guests on board Average amount of people on board Percentage occupation Average pumping capacity applied (reported) Average pumping capacity applied / average number of guests on board Maximum pumping capacity applied S101 2003 1300 1325 1721 102% 40.92 0.031 61 S102 2001 1266 1243 1633 98% 43.54 0.035 52 S103 2009 2260 2149 3022 95% 41.67 0.019 50 Page 58

Ship Code Year of Built Guest capacity (maximum) Average number of guests on board Average amount of people on board Percentage occupation Average pumping capacity applied (reported) Average pumping capacity applied / average number of guests on board Maximum pumping capacity applied S104 2001 372 386 682 104% 45.63 0.118 75 S105 2011 450 785 0 S106 2000 686 601 1003 88% 10.00 0.017 20 S107 2002 1848 1838 2680 99% 50.00 0.027 50 S108 2013 3560 3880 5216 109% 81.25 0.021 94 S128 1999 826 651 1034 79% 30.00 0.046 30 S129 2004 3080 3261 4421 106% S109 1981 1158 1564 0 S110 1981 602 418 688 69% S111 2000 1950 1816 2630 93% 41.52 0.023 64 S112 2010 2853 2975 4204 104% 78.29 0.026 100 S113 2011 2853 2923 4174 102% 36.72 0.013 75 S114 1991 2744 2456 3258 89% 60.45 0.025 70 S115 2000 3807 3431 4650 90% 23.00 0.007 23 S116 2003 2100 2332 3223 111% 99.94 0.043 117.64 S118 1996 2681 3590 0 S119 2015 2790 2602 3618 93% 45.21 0.017 50 S120 2016 2790 2050 3077 73% 0 S121 2006 2550 2689 3627 105% 56.96 0.021 80 S122 2004 1712 2269 3007 133% 27.68 0.012 100 S123 2001 2348 2524 3586 107% 85.42 0.034 144 S124 1998 702 644 1034 92% 35.00 0.054 35 S125 1998 702 626 1021 89% 15.00 0.024 15 S126 2011 1258 1255 2020 100% 21.80 0.017 33.3 S127 2003 706 701 1150 99% 46.09 0.066 72 S130 2016 2650 2584 3578 98% 0 8.2.2.2 Ships Table particulars / time for discharging / spare time available Table 41: Ships Table particulars / time for discharging / spare time available Ship Code Average time for discharging Standard Deviation Average Spare time available Standard Deviation Small deviation? Number of entries S101 7.96 4.28 3.28 3.25 0.99 13 S102 10.63 7.92 2.20 1.60 0.73 13 S103 18.30 19.50 3.08 2.02 0.66 6 S104 12.67 9.96 6.49 8.16 1.26 8 S105 0 S106 8.90 6.99 18.25 18.89 1.04 7 S107 0 S108 6.42 0.34 2.10 0.23 0.11 4 S128 6.00 0.00 28.72 0.00 0.00 1 S129 11.37 0.00 7.40 0.00 0.00 1 S109 0 S110 1.03 0.00 27.38 0.00 0.00 1 S111 9.95 8.12 3.75 3.05 0.81 5 S112 4.87 2.37 5.63 4.68 0.83 21 S113 8.73 10.80 4.11 4.12 1.00 21 S114 18.93 10.92 2.85 3.90 1.37 22 S115 4.38 1.29 2.26 0.04 0.02 2 S116 7.57 5.71 3.47 5.10 1.47 16 S118 0 Page 59

Ship Code Average time for discharging Standard Deviation Average Spare time available Standard Deviation Small deviation? Number of entries S119 4.76 1.92 6.90 6.42 0.93 19 S120 0 S121 2.53 1.54 6.04 1.93 0.32 23 S122 6.48 4.99 3.73 2.17 0.58 46 S123 2.69 1.53 7.82 5.14 0.66 26 S124 6.18 1.93 2.20 0.97 0.44 8 S125 175.50 0.00 10.12 8.92 0.88 2 S126 6.11 2.31 3.48 2.28 0.66 14 S127 3.30 1.52 13.12 18.93 1.44 6 S130 0 7.44 5.82 total: 286 8.2.2.3 Ships Table max. pumping capacity per type of PRF / number of entries / problems Table 42: Ships Table max. pumping capacity per type of PRF / numer of entries / problems Ship Code Max pumping capacity applied at Truck Max. pumping capacity applied at Barge Max. pumping capacity applied at Fixed Reception Point Number of entries (ship mentioned) Number of entries with problems (excl height of fees Row 60) Percentage Problems S101 50 50 61 13 7 54% S102 40 52 17 12 71% S103 50 8 4 50% S104 30 75 50 8 2 25% S105 13 0 S106 20 3.21 10 19 13 68% S107 50 6 2 33% S108 47 24 51% S128 30 6 1 17% S129 35 7 1 14% S109 1 0 S110 9 0 0% S111 35 64 5 2 40% S112 70 100 38 14 37% S113 47 39 83% S114 60 70 22 1 5% S115 23 8 6 75% S116 117.64 52 35 67% S118 3 0 0% S119 40 50 50 58 3 5% S120 2 0 0% S121 20 80 25 0 0% S122 80 100 48 48 100% S123 144 50 21 42% S124 29 12 41% S125 7 2 29% S126 33.3 20.3 15 8 53% S127 60 72 14 5 36% S130 2 2 100% Maximum 70 80 144 Page 60

8.2.2.3 Ships Table height fees / Discharge operations / problems Table 43: Ships Table height fees / Discharge operations / problems Ship Code Does the cruise ship consider the fees disproportionately high such that they create a disincentive to utilize the PRFs? (Row 60) Percentage Fees too high (row 60) Amount of reported discharge operations (based on reported pumping capacity) Amount of entries with problems (excl Row 60) AND discharge operation has taken place (based on reported pumping capacity) Percentage problems S101 8 62% 13 7 54% S102 9 53% 13 10 77% S103 5 63% 6 2 33% S104 4 50% 8 2 25% S105 2 0 0 S106 9 47% 7 4 57% S107 0 33% 1 1 100% S108 0 62% 4 4 100% S128 3 50% 1 1 100% S129 7 100% 1 1 100% S109 0 0 0 S110 0 11% 1 0 0% S111 0 60% 5 2 40% S112 0 55% 21 3 14% S113 0 53% 23 23 100% S114 21 95% 22 1 5% S115 0 50% 2 0 0% S116 0 42% 4 2 50% S118 0 0% 0 0 S119 46 79% 19 2 11% S120 2 100% 0 0 S121 23 92% 23 0 0% S122 10 21% 41 41 100% S123 26 52% 26 16 62% S124 10 34% 4 0 0% S125 6 86% 2 0 0% S126 0 100% 14 7 50% S127 8 57% 6 0 0% S130 0 0% 0 0 8.2.2.4 Ships Table total volume on board / Confirmed mixing of GW and BW on board Table 44: Ships Table total volume on board / Confirmed mixing of GW and BW on board Ship Code Total volume on board per ship when arriving in port (average): Confirmed mixing of GW and BW on board S101 313 Yes S102 S103 685 S104 89 S105 430 S106 217 S107 Yes S108 473 Yes S128 168 S129 112 S109 S110 28 Yes Page 61

Ship Code Total volume on board per ship when arriving in port (average): Confirmed mixing of GW and BW on board S111 551 S112 1020 Yes S113 749 Yes S114 257 S115 1569 Yes S116 1273 Yes S118 S119 484 S120 1750 S121 738 S122 459 S123 301 Yes S124 62 S125 74 S126 416 S127 194 S130 8.2.2.5 Ships Overview issues received specified per ship No participating ship reported an occasion during which a shift in berth had to take place leading to delay or costs. Out of 188 cases, the negative feedback most received Unreasonable charges (56 times) and Undue delay (48 times). Table 45: Feedback issues A-G per ship Ship Code Total number of entries Percentage When relevant: please indicate, the problems encountered by using one of more of the following code letters (C) Use of (E) Vessel (F) (G) Other (B) (D) (A) No facility had to shift Unreasonabl (please specify Undu Inconveni facility technicall berth e charges for under e ent available; y Not involving use of additional delay; location; possible; delay/cost; facilities; comments) S101 13 7.7% 0 0 0 0 0 0 1 S102 17 17.6% 0 1 1 0 0 1 0 S103 8 12.5% 0 0 0 0 0 0 1 S104 8 37.5% 0 1 0 0 0 0 2 S105 0 0 0 0 0 0 0 0 S106 19 15.8% 0 0 0 0 0 1 2 S107 6 0.0% 0 0 0 0 0 0 0 S108 47 51.1% 0 0 0 0 0 0 24 S128 6 0.0% 0 0 0 0 0 0 0 S129 7 14.3% 0 0 0 0 0 0 1 S109 0 0 0 0 0 0 0 0 S110 9 0.0% 0 0 0 0 0 0 0 S111 5 20.0% 0 0 0 0 0 1 0 S112 38 36.8% 4 0 0 0 0 7 3 S113 47 83.0% 0 0 0 0 0 16 23 S114 22 9.1% 0 0 0 1 0 1 0 S115 8 100.0% 4 0 2 0 0 2 0 S116 52 92.3% 19 0 8 8 0 13 0 S118 3 0.0% 0 0 0 0 0 0 0 S119 58 0.0% 0 0 0 0 0 0 0 S120 2 0.0% 0 0 0 0 0 0 0 S121 25 0.0% 0 0 0 0 0 0 0 S122 48 100.0% 0 44 0 2 0 0 2 S123 50 0.0% 0 0 0 0 0 0 0 S124 29 34.5% 0 0 1 0 0 8 1 S125 7 28.6% 0 0 1 0 0 0 1 Page 62

Ship Code Total number of entries Percentage When relevant: please indicate, the problems encountered by using one of more of the following code letters (C) Use of (E) Vessel (F) (G) Other (B) (D) (A) No facility had to shift Unreasonabl (please specify Undu Inconveni facility technicall berth e charges for under e ent available; y Not involving use of additional delay; location; possible; delay/cost; facilities; comments) S126 15 46.7% 0 2 0 0 0 2 3 S127 14 35.7% 1 0 0 0 0 4 0 S130 2 0.0% 0 0 0 0 0 0 0 Number of entries 28 48 13 11 0 56 64 8.2.2.6 Ships Table Amount of unique ports visited by a specific cruise ships Table 46: Ships Table Amount of unique ports visited by a specific cruise ships Ship Code Total number of entries Amount of unique ports visited by a specific cruise ships S101 13 10 S102 17 13 S103 8 4 S104 8 8 S105 0 7 S106 19 8 S107 6 6 S108 47 7 S128 6 6 S129 7 6 S109 0 S110 9 9 S111 5 5 S112 38 7 S113 47 11 S114 22 5 S115 8 4 S116 52 12 S118 3 S119 58 10 S120 2 2 S121 25 5 S122 48 8 S123 50 5 S124 29 11 S125 7 7 S126 15 6 S127 14 9 S130 2 2 Page 63

Maximum dedicated sewage storage capacity (m3) Max. storage / Average # people on board (m3/guest) 8.2.2.7 Ships - Graph Sewage storage capacity and Average number of people on board Figure 9: Ships Graph Sewage storage capacity and Average number of people on board Sewage storage capacity and average # people on board 4,000 3,500 3,000 2,500 2,000 1,500 1,000 500 0 1000 2000 3000 4000 5000 6000 2.0 1.8 1.6 1.4 1.2 1.0 0.8 0.6 0.4 0.2 0.0 0 1000 2000 3000 4000 5000 6000 Average number of persons on board Maximum dedicated sewage storage capacity (current trim-adjusted maximum capacity) (average) Max. storage / Average number of people on board capacity Page 64

8.3 Port based feedback data received It should be noted that although general feedback has been received, only few ports actually provided feedback during this exercise. 8.3.1 Ports Qualitative information received 8.3.1.1 Port s Reporting Except for Part A and B of the Reporting Format supplied to the ports, the format has not been applied by the overwhelming majority of the port. One single port provided feedback using the format provided by CLIA Europe for discharge operations. This supported the verification and mirroring of this project and is very much appreciated. 8.3.1.2 Additional information received from ports Some ports provided an overview of deliveries at their port containing the total amounts of Black and/or Grey Water deliveries at their port per ship. However, this information on total amounts delivered in general did not provide any additional means of verification. 8.3.1.3 General Impressions received from the Baltic Ports Feedback received from ports Table 47: Ports - General Feedback Aalborg/Fredericia/Gothenburg/Helsingborg Question Aalborg Fredericia Gothenburg Helsingborg What are your expectations on future demand for PRF in your port? 500 cbm pr call. We expect between 35-40 calls per year. 17.500-20.000 cbm pr year We have not received anything yet, so we cannot answer. 6060 m3 of sewage was received from cruise ships in 2014 (44% of the cruise ships) Last year 2015 1850 m3 (30% of the cruise ships) was received. This year we expect to receive 3000 m3 (expectation 70% of the cruise ships). Our ambition is to be able to receive 100% on our dedicated cruise berths. The sometimes-used berths in container and roro-terminal we anticipate the use of trucks the coming five years. We had only 4 cruise ships at berth 2015 and received 43 m3 waste ( no black or grey water) and 2016 there will come 4 cruise ships at berth and how are you planning to cope with this demand? Yes. We expect to invest in a shore connection (min 200 cbm/hrs) or a barge with a capacity of about 700-800 cbm We will invest during 2017 in PRF for the inner-city berth. The capacity will be decided due to the ship sizes possible on the berth. Discussion is ongoing on increasing the PRF-capacity in Arendal but no FID is taken yet. For the berths used just a few times a year e.g. in container and roro-terminal trucks will be the possible solution. We have no problem to receive more waste Please elaborate on the future investments in PRFs in the port and other relevant developments We expect to invest in a shore connection or a barge with a capacity of about 700-800 cbm Investments will be made, but we do not know the level yet The dedicated cruise berths will be connected to the sewage system. We have a welldeveloped PRF and can take sewage by truck Please describe the cost fee structure and the fees, as described in EU Directive 2000/59 5-7 cbm sludge/black- /greywater will be no special fee. Remaining will be charged at cost price sewage is included in the Port of Gothenburg waste fee (no special fee system) No Limit. Waste is included in the Harbour dues if created from previous harbour Page 65

Question Aalborg Fredericia Gothenburg Helsingborg How many independent PRF Several providers providers are present with trucks 3 1 0 in the port? Does the port allow for a profit by the PRF provider? Yes No No Please elaborate on the foregoing answer As the providers are privately owned company, they are setting the price them self. We will always sign a contract with the cheapest and most reliable provider. We have not received anything in the past. We are identifying the need at the moment. Legislation says that PRF should only cover its costs. Continued: Table 48: Ports - General Feedback Kiel/Lubeck/Ronne Question Elsinore Kiel Lu beck Rønne Less than 100 only few calls Since we experienced a growing number of cruise passengers in M3 of sewage What are your at Terminal the last years and due to the fact of new HELCOM regulations, was received expectations on Burgtorkai we expect the demand for PRF in our Port to be growing. In the from cruise future demand due to last years, we had only a couple of cruise liners asking us to ships in 2015. for PRF in your limitation of deliver grey- and Blackwater. We expect that a growing number 2000 M3-5000 port? vessel size (2 of vessels will have the need to discharge in the future. M3 is expected calls in 2016) in the future. and how are you planning to cope with this demand? Please elaborate on the future investments in PRFs in the port and other relevant developments Please describe the cost fee structure and the fees, as described in EU Directive 2000/59 How many independent PRF providers are present in the port? Port of Kiel is currently working on enlarging our PRF at our two main cruise berths, which are Berth 27 and Berth 28 at Kiel Ostseekai. The future investments at our 2 main cruise berths as described above foresees the construction of a new pressure pipeline (penstock) from our terminal through the city of Kiel to the next big municipal collector. At our terminal and berth area at Kiel Ostseekai, we will therefore install a new pump that will be able to cope 300 m³ per hour, so that we will be able to receive 150m³ per hour per berth. Over an estimated berthing time of 10 hours, every cruise vessel will then be able to discharge up to 1.500 m³ per call - or even more, if the other berth is not occupied. The investment furthermore will include a throughput-tank, which will be built to measure and treat the received water in a flow before it will be sent it to the municipal system. We will be able to measure not only the amount of water going through, but also the key parameters that the municipal department for sewages demands from our side. The treatment possibility will then have the option to adjust PH-values and H2S-values of the water and the extracted air. Since the directive asks for a no-special-fee system to cover the expenses of the ports, we decided to include certain quantities for cruise liners calling Kiel in our port dues. This will be implemented in 2017. The included volumes will be 300m³ for smaller vessels and 500m³ for larger cruise vessels. If a cruise liner wants to discharge more than that, an extra fee per m³ will apply. Due to the situation described above, it will be Port of Kiel receiving the volumes and giving it away to the municipal system. No other provider in between. n/a no investment planned for Terminal Burgtorkai no cost free structure; minimum fee is 30% of tariff for all vessels one 1 See below We'll consider to invest in new pipelines (pier 31/32). As well we are working with a port extension (A new cruise pier) 4 M3 of sewage is included in the ship dues. Rest would be charged separately. Page 66

Question Elsinore Kiel Lu beck Rønne Does the port allow for a profit by the PRF provider? No other provider, as described above. n/a Yes Please elaborate on the foregoing answer Continued: No other provider, as described above. Table 49: Ports - General Feedback Tallinn/Travemunde/Visby/Warnemunde Reasonable profit is allowed for discharging the obligations Question What are your expectations on future demand for PRF in your port? and how are you planning to cope with this demand? Please elaborate on the future investments in PRFs in the port and other relevant developments Please describe the cost fee structure and the fees, as described in EU Directive 2000/59 How many independent PRF providers are present in the port? Does the port allow for a profit Stockholm Tallinn Travemu nde Visby Warnemünde We see no problems in being in compliance 2019-2021. We do have accurate PRF at all piers We plan to continue developing facilities as needed. We make considerations in planning new berths to include proper PRFs. No special fee, no limit, One is present and that is Stockholm Water, own by the municipality 8 267 m3 of sewage was received from cruise ships in 2015. 50 000-60 000 m3 is expected in the coming years. cruise ships will soon be able to discharge unlimited amounts of sewage under waste fee (at the moment there is a limit - 7m3 ) New pipelines (piers 24, 25) and microtunnel will be built. Deadline: end of 2016. The capacity of wastewater reception from ships will increase from 100m3 to 1000m3 per hour. 7m3 of sewage is included in the waste fee. Rest would be charged separately. average of 20 cruise calls per year; focus on smaller ships up to 200mL PRF by tank truck sufficient for the time being Development of fixed connection PRF at Ostpreussenkai is in process. no cost-free structure; minimum fee is 30% of tariff for all vessels Approximately 2000 m3 sewage was received from cruise ships in 2015. We don t have any information about the capacity in the future. Sewage will be stored and pumped to the purifier. New cruise quay are under construction and will be finished 2018. The quay will be prepared for sewage and the capacity will totally be 300 m3/hr. There is no fee. Many question marks depending on the qualities and quantities of grey water and the great variety of ship pumping rates. High uncertainties due to unknown investment decisions of cruise ship companies. The demand is not clear so the planning cannot be clear. Unsure, because cruise companies will improve ship technology for waste water treatment on board. First design studies show limited further improvement options for PRF. No special fee means not no fee. Sewage disposal costs are included in the port fee (up to 300m³). The municipal wastewater treatment is financed by fees for each m³ of waste water from every citizen/household/company. 1 one 2 One public provider. Not applicable. yes n/a no No, but losses due to sewage disposal are not allowed too. Page 67

by the PRF provider? Please elaborate on the foregoing answer Stockholm Tallinn Travemu nde Visby Warnemünde There is a need to refinance the investment of PRF. reasonable profit is / allowed for discharging / the obligations 8 Main challenges experienced Feedback received from ports Table 50: Ports - Main Challenges Aalborg/Fredericia/Gothenburg/Helsingborg Question Aalborg Fredericia Gothenburg Helsingborg What were the main The main focus is only what are available now. We will be ready with an challenges that you alternative solution to None, we encourage the experienced during this trucks prior 2019. We simulation and will do None simulation 2016 expect it to be a shore our best to support it. Exercise? connection or possible a barge. Please take this in to your consideration Other comments / impressions Continued: Table 51: Ports - Main Challenges Elsinore/Kiel/Lubeck/Ronne Question Elsinore Kiel Lu beck Rønne What were the main challenges that you experienced during this simulation 2016 Exercise? Other comments / impressions Continued: Table 52: Ports - Main Challenges Stockholm/Tallinn/Travemunde/Visby/Warnemunde Question Stockholm Tallinn Travemu nde Visby Warnemünde What were the main challenges that you experienced during this simulation 2016 Exercise? Other comments / impressions 8 Overview of the availability of PRF Feedback received from ports Table 53: Ports - Overview PRF Aalborg/Fredericia/Gothenburg/Helsingborg Question Aalborg Fredericia Gothenburg Helsingborg Please provide an overview of the availability of PRF: Berth # A Royal Cruise Berth (working progress) Arendal All Berths Pumping capacity (m3/hr) 200 45 30 MARPOL standard connections fitted (Yes/No) yes Yes yes Type of PRF (Barge/Truck/Fixed connection) Fixed or Barge fixed Truck Connection to local storage/municipal waste Will be connected to waste treatment plant municipal treatment waste municipal treatment waste Page 68

Question Aalborg Fredericia Gothenburg Helsingborg treatment/other (please specify) What would be Plan B if (e.g. due to a technical problem) the truck trucks planned PRF is not available? B Berth 4110 Frihamnen until season 2017 Pumping capacity (m3/hr) 60 45 MARPOL standard connections fitted (Yes/No) yes Yes Type of PRF (Barge/Truck/Fixed connection) Truck fixed Connection to local Not directly. But the storage/municipal waste trucks will unload at municipal waste treatment/other (please the waste treatment treatment specify) plant What would be Plan B if (e.g. due to a technical problem) the truck trucks planned PRF is not available? C America-quay from season 2018 Pumping capacity (m3/hr) 150 MARPOL standard connections fitted (Yes/No) Yes Type of PRF (Barge/Truck/Fixed connection) fixed Connection to local storage/municipal waste municipal waste treatment/other (please treatment specify) What would be Plan B if (e.g. due to a technical problem) the trucks planned PRF is not available? Continued: Table 54: Ports - Overview PRF Elsinore/Kiel/Lubeck/Ronne/Stockholm/TAllinn/Travemunde/Visby/Warnemunde Question Elsinore Kiel Lu beck Rønne Please provide an overview of the availability of PRF: Berth # A 27 Pumping capacity (m3/hr) MARPOL standard connections fitted (Yes/No) Type of PRF (Barge/Truck/Fi xed connection) Connection to local storage/munici pal waste treatment/othe r (please specify) ships 30 Fixed Connecti on municipa l waste treatmen t Burgtor kai 20-25m³/h Berth 13 Stockhol m Availabl e at all berths Tallinn Travemu nde Visby Berth 26/27 Ostpreussen kai 25 100 20-25 m³/h 20 Berth 4 yes No yes yes no yes yes fixed connecti on municipa l waste treatme nt by tank truck no Truck fixed by tank truck Fixed Fixed Municip al waste treatme nt municipal waste treatment under developmen t municip al waste treatme nt Warnemün de all berths (3) summed up 140 m3/hour cruise port municipal waste water plant Page 69

Question Elsinore Kiel Lu beck Rønne What would be Plan B if (e.g. due to a technical problem) the planned PRF is not available? B 28 Pumping capacity (m3/hr) MARPOL standard connections fitted (Yes/No) Type of PRF (Barge/Truck/Fi xed connection) Connection to local storage/munici pal waste treatment/othe r (please specify) What would be Plan B if (e.g. due to a technical problem) the planned PRF is not available? C 1 Pumping capacity (m3/hr) MARPOL standard connections fitted (Yes/No) Type of PRF (Barge/Truck/Fi xed connection) Connection to local storage/munici pal waste treatment/othe r (please specify) What would be Plan B if (e.g. due to a technical problem) the planned PRF is not available? truck order trucks from Hambur g Trucks alternati ve Berth 22/23 Stockhol m Availabl e at all berths Tallinn Travemu nde Visby trucks Berth 24/25 order trucks from Hamburg Skandinavien kai 30 25 60 20-25 m³/h 20 yes yes yes no yes fixed connecti on municipa l waste treatme nt truck truck Berth 7 Truck truck by tank truck Fixed Municip al waste treatme nt Trucks alternati ve Berth 31/32 Availabl e at all berths municipal waste treatment trucks (outsourci ng) Berth 1 no order trucks from Hamburg 15 25 80 40 yes yes yes yes municip al waste treatme nt Truck Berth 10 truck Truck fixed Truck municipa l waste treatme nt n/a Municip al waste treatme nt Trucks alternati ve municipal waste treatment trucks D 26 Berth 17 Pumping capacity (m3/hr) 15 60 municip al waste treatme nt truck Warnemün de tank trucks (limited capacity) Page 70

Question Elsinore Kiel Lu beck Rønne MARPOL standard connections fitted (Yes/No) Type of PRF (Barge/Truck/Fi xed connection) Connection to local storage/munici pal waste treatment/othe r (please specify) What would be Plan B if (e.g. due to a technical problem) the planned PRF is not available? yes truck municipa l waste treatme nt n/a Stockhol m Tallinn Travemu nde Visby yes truck municipal waste treatment trucks (outsourci ng) E 22 Berth 8 Pumping capacity 15 60 (m3/hr) MARPOL standard connections fitted (Yes/No) yes yes Type of PRF (Barge/Truck/Fi xed connection) truck truck Connection to local municipa storage/munici municipal l waste pal waste waste treatme treatment/othe treatment nt r (please specify) What would be Plan B if (e.g. due to a technical n/a problem) the planned PRF is not available? trucks (outsourci ng) Warnemün de Page 71

8.3.2 Ports Quantitative information received 8.3.2.1 Ports Table visited / Feedback received from port? Table 55: Ports Quantitative feedback Visits / Feedback received from port Baltic ports Country Visited by cruise ship during 2016 Exercise? Overview Total number of single visits Number of unique cruise ships visiting the specific port Average number of visits per cruise ship Amount of unique cruise ships visiting the specific port (mixing BW and GW Confirmed) Percentage of unique cruise ship visits (mixing BW and GW confirmed) Feedback Received: Overall (Yes/No) Feedback Received: Discharge Operations (Yes/No) Aalborg Denmark No 0 0 Yes Yes Aarhus Denmark Yes 3 2 1.5 1 33% Copenhagen Denmark Yes 99 23 4.3 46 46% Fredericia Denmark Yes 3 3 1.0 2 67% Yes Flensburg Germany No 0 0 Gdansk Poland Yes 2 2 1.0 Gdynia Poland Yes 9 4 2.3 Gothenburg Sweden Yes 4 4 1.0 2 50% Yes Helsingborg Sweden Yes 2 2 1.0 2 100% Yes Helsingør Denmark No 0 0 Helsinki Finland Yes 73 23 3.2 39 53% Heiringsdorf Germany No 0 0 Hundested Denmark Yes 1 1 1.0 1 100% Kaliningrad Russia No 0 0 Kalmar Sweden No 0 0 Kalundborg Denmark No 0 0 Karlskrona Sweden Yes 1 1 1.0 Kemi Finland No 0 0 Kiel Yes 21 4 5.3 3 14% Yes Yes Germany Holtenau No 0 0 Klaipeda Lithuania Yes 19 10 1.9 2 11% Kotka Finland No 0 0 Lu beck No 0 0 Yes Germany Travemu nde Yes 2 2 1.0 Yes Lulea Sweden Yes 1 1 1.0 1 100% Mariehamn Finland Yes 3 2 1.5 1 33% Malmö Sweden Yes 1 1 1.0 Nynashamn Sweden Yes 7 1 7.0 7 100% Örnsköldsvik Sweden Yes 1 1 1.0 1 100% Pori Finland Yes 1 1 1.0 1 100% Riga Latvia Yes 20 10 2.0 7 35% Rønne Yes 1 1 1.0 Yes Denmark Bornholm No 0 0 Rostock Yes 6 5 1.2 5 83% Germany Warnemünde Yes 52 11 4.7 30 58% Yes Saaremaa Estonia No 0 0 St Petersburg Russia Yes 71 21 3.4 34 48% Sassnitz Germany No 0 0 Skagen Denmark Yes 2 2 1.0 1 50% Stockholm Sweden Yes 76 25 3.0 36 47% Yes Stralsund Germany No 0 0 Szczecin No 0 0 Poland Sẃinoujsćie No 0 0 Tallinn Estonia Yes 83 23 3.6 44 53% Yes Turku Finland No 0 0 Umea Sweden Yes 1 1 1.0 1 100% Veere Estonia No 0 0 Ventspils Latvia No 0 0 Visby Sweden Yes 3 2 1.5 Yes Wismar Germany Yes 1 1 1.0 30 569 267 63% 12 2 Page 72

8.3.2.2 Ports Table Max. pumping capacity / Time taken to discharge / Time available for discharge Table 56: Ports Quantitative feedback Pumping Capacity / Discharge time / Time available Baltic ports Maximum pumping capacity Time taken to discharge Time available for discharge Maxim Averag um Maximu Standa Standa Average e Standa pumpin m time Small rd Avera rd time for Spare rd g for deviatio Deviati ge Deviati dischargi time Deviati capacit dischargi n? on on ng availa on y ng ble applied Copenhag en 100.00 26.20 42.62 12.00 2.96 5.18 5.40 4.06 0.75 41 Gdansk 30.00 0.00 30.00 6.00 0.00 6.00 1.50 0.00 0.00 1 Gdynia 40.00 0.50 39.50 9.50 0.08 9.42 1.67 0.17 0.10 2 Gothenbur g 50.00 11.00 39.00 21.83 10.04 11.79 4.70 3.13 0.67 2 Helsingbor g 50.00 0.00 50.00 7.00 0.00 7.00 2.65 0.00 0.00 1 Helsinki 100.00 28.71 48.51 21.00 2.78 6.27 2.95 4.37 1.48 57 Kiel 61.00 11.41 38.90 8.50 2.34 5.51 5.50 2.49 0.45 9 Holtenau 0.00 0.00 0 Klaipeda 75.00 18.11 33.93 8.00 2.05 4.43 4.26 1.70 0.40 11 Marieham n 50.00 10.00 40.00 8.00 0.25 7.75 0.87 0.13 0.14 2 Riga 80.00 17.94 42.54 23.00 7.30 6.99 5.16 3.55 0.69 8 Rostock 60.00 0.00 60.00 0.00 11.50 0.00 0.00 1 Warnemü nde 117.64 37.30 61.25 12.17 2.20 4.42 8.77 3.28 0.37 30 St Petersburg 100.00 25.80 39.57 33.25 11.79 19.23 15.76 16.67 1.06 20 Stockholm 270.00 39.03 68.55 48.00 11.82 9.79 3.73 4.44 1.19 63 Tallinn 77.00 23.12 45.92 7.00 2.19 4.43 3.31 2.53 0.76 23 Visby 49.00 8.04 38.00 8.00 2.66 4.27 3.33 2.63 0.79 3 Numb er of entrie s 8.3.2.3 Ports Table Type of PRF present / Problems encountered The following table provides an overview of feedback received on the type of PRF present per port. It also provides an overview of the problems encountered, per port and per total number of single visits. Table 57: Ports - Quantitative feedback Type of PRF present / Problems encountered Confirmed presence of types of PRF Problems encountered Problems Baltic ports Problems encountered per Tank car/trucks Barges Fixed PRF encountered per port: all / Overview port: all Total number of single visits Aalborg 0 Aarhus Present 2 67% Copenhagen Present Present 49 49% Fredericia 1 33% Flensburg 0 Gdansk Present Present 1 50% Gdynia Present 2 22% Gothenburg Present Present 0 0% Helsingborg Present 0 0% Helsingør 0 Helsinki Present Present 20 27% Heiringsdorf 0 Hundested 0 0% Page 73

Confirmed presence of types of PRF Problems encountered Problems Baltic ports Problems encountered per Tank car/trucks Barges Fixed PRF encountered per port: all / Overview port: all Total number of single visits Kaliningrad 0 Kalmar 0 Kalundborg 0 Karlskrona 1 100% Kemi 0 Kiel Present Present Present 1 5% Holtenau 0 Klaipeda Present Present 12 63% Kotka 0 Lu beck 0 Travemu nde 1 50% Lulea 0 0% Mariehamn Present 1 33% Malmö Present 1 100% Nynashamn 0 0% Örnsköldsvik 0 0% Pori 0 0% Riga Present Present 13 65% Rønne 0 0% Bornholm 0 Rostock Present Present 5 83% Warnemünde Present Present 39 75% Saaremaa 0 St Petersburg Present Present Present 47 66% Sassnitz 0 Skagen Present 1 50% Stockholm Present 19 25% Stralsund 0 Szczecin 0 Sẃinoujsćie 0 Tallinn Present Present 45 54% Turku 0 Umea 0 0% Veere 0 Ventspils 0 Visby Present 2 67% Wismar 1 100% Page 74

8.3.2.4 Ports Table Definition of Adequacy / Proportionanilty of fees Table 58: Ports Definition of Adequacy / Proportionanilty of fees Definition of Adequacy Baltic ports Does the cruise ship consider the fees disproportionately high Disincentive / number such that they create a disincentive to utilize the PRFs? of single visits Aalborg 0 Aarhus 3 100% Copenhagen 35 35% Fredericia 1 33% Flensburg 0 Gdansk 0 0% Gdynia 2 22% Gothenburg 0 0% Helsingborg 1 50% Helsingør 0 Helsinki 3 4% Heiringsdorf 0 Hundested 0 0% Kaliningrad 0 Kalmar 0 Kalundborg 0 Karlskrona 0 0% Kemi 0 Kiel 2 10% Holtenau 0 Klaipeda 2 11% Kotka 0 Lu beck 0 Travemu nde 1 50% Lulea 0 0% Mariehamn 0 0% Malmö 0 0% Nynashamn 0 0% Örnsköldsvik 0 0% Pori 0 0% Riga 10 50% Rønne 0 0% Bornholm 0 Rostock 6 100% Warnemünde 17 33% Saaremaa 0 St Petersburg 48 68% Sassnitz 0 Skagen 1 50% Stockholm 4 5% Stralsund 0 Szczecin 0 Sẃinoujsćie 0 Tallinn 43 52% Turku 0 Umea 0 0% Veere 0 Ventspils 0 Visby 1 33% Wismar 1 100% 181 27% Page 75

8.3.2.5 Ports Table Definition of Adequacy / indication of the problems encountered Overview issues received specified per port Table 59: Ports - Quantitative Feedback Visits / Issues A-G per port Baltic ports Overvie w Total number of single visits Percentag e When relevant: please indicate the problems encountered by using one of more of the following code letters (E) Vessel (G) Other (C) Use had to (F) (please (A) No (B) of facility (D) shift Unreasonabl specify facility Undu technicall Inconvenie berth e charges for under available e y not nt location; involving use of additional ; delay; possible; delay/cos facilities; comment t; s) Aarhus 3 100.0% 0 1 1 0 0 1 0 Copenhagen 99 44.4% 4 12 1 2 0 10 15 Fredericia 3 66.7% 1 0 0 1 0 0 0 Gdansk 2 100.0% 0 1 0 0 0 0 1 Gdynia 9 0.0% 0 0 0 0 0 0 0 Gothenburg 4 0.0% 0 0 0 0 0 0 0 Helsingborg 2 0.0% 0 0 0 0 0 0 0 Helsinki 73 24.7% 0 7 0 0 0 1 10 Hundested 1 0.0% 0 0 0 0 0 0 0 Karlskrona 1 100.0% 0 0 0 0 0 0 1 Kiel 21 0.0% 0 0 0 0 0 0 0 Klaipeda 19 47.4% 1 2 0 1 0 1 4 Travemu nde 2 0.0% 0 0 0 0 0 0 0 Lulea 1 0.0% 0 0 0 0 0 0 0 Mariehamn 3 0.0% 0 0 0 0 0 0 0 Malmö 1 0.0% 0 0 0 0 0 0 0 Nynashamn 7 0.0% 0 0 0 0 0 0 0 Örnsköldsvik 1 0.0% 0 0 0 0 0 0 0 Pori 1 0.0% 0 0 0 0 0 0 0 Riga 20 85.0% 6 2 0 6 0 3 0 Rønne 1 0.0% 0 0 0 0 0 0 0 Rostock 6 66.7% 0 0 0 1 0 3 0 Warnemünd e 52 53.8% 1 12 1 0 0 0 14 St Petersburg 71 56.3% 5 5 0 0 0 24 6 Skagen 2 50.0% 0 0 0 0 0 1 0 Stockholm 76 10.5% 0 1 0 0 0 0 7 Tallinn 83 51.8% 10 5 10 0 0 12 6 Umea 1 0.0% 0 0 0 0 0 0 0 Visby 3 0.0% 0 0 0 0 0 0 0 Wismar 1 0.0% 0 0 0 0 0 0 0 Total 28 48 13 11 0 56 64 Percentag e 12.7% 21.8% 5.9% 5.0% 0.0% 25.5% 29.1% 8.3.2.6 Ports Table number of PRF providers / destination sewage / local storage available? Table 60: Ports - Quantitative feedback Number PRF providers / Destination sewage / Local storage Baltic ports Page 76 How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Local sewage storage available? Aarhus 1 Yes Municipal waste treatment Copenhagen 3 system Yes Yes Fredericia Yes Gdansk 1 Yes Gdynia 1 Yes Yes Municipal waste treatment Gothenburg 1 system Yes Yes? No?

Baltic ports Helsingborg 1 How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Municipal waste treatment system Municipal waste treatment Local sewage storage available? Helsinki 1 system Yes Yes Karlskrona Yes Municipal waste treatment Kiel 1 system Yes Yes Municipal waste treatment Klaipeda 2 system Yes Yes Travemu nde Yes Mariehamn 1 Yes Malmö Yes Nynashamn Yes Pori Yes Municipal waste treatment Riga 2 system Yes Yes Rønne Yes Municipal waste treatment Rostock 1 system Yes Municipal waste treatment Warnemünde 1 system Yes Yes Municipal waste treatment St Petersburg 2 system Yes Yes Skagen 2 Yes Municipal waste treatment Stockholm 1 system Yes Yes Municipal waste treatment Tallinn 2 system Yes Yes Visby 1 Yes Wismar Yes Yes? No? Yes 8.3.2.7 Ports Table Average amount of time underway to this port Table 61: Ports - Quantitative feedback Time underway Baltic ports Average amount of time underway to this port (compensated for entry of Baltic Sea) Maximum amount of time underway to this port (compensated for entry of Baltic Sea) Time underway through the Baltic Sea to specific ports 0-0.5 days 0.5-1 days 1-1.5 days 1.5-2 days >2 days Copenhagen 01/01/1900 05:44 2.03 4 9 6 17 1 Fredericia 00/01/1900 10:13 0.43 1 0 0 0 0 Gdansk 00/01/1900 13:21 0.83 1 1 0 0 0 Gdynia 01/01/1900 08:38 1.57 1 0 6 1 0 Gothenburg 00/01/1900 16:54 1.00 1 1 1 0 0 Helsinki 00/01/1900 18:45 1.75 6 34 5 4 0 Karlskrona 00/01/1900 14:00 0.58 0 1 0 0 0 Kiel 01/01/1900 02:01 1.56 1 4 0 6 0 Klaipeda 00/01/1900 17:11 1.45 1 13 2 0 0 Travemu nde 00/01/1900 09:13 0.38 1 0 0 0 0 Mariehamn 00/01/1900 14:45 0.61 0 1 0 0 0 Nynashamn 00/01/1900 13:45 0.61 0 3 0 0 0 Riga 00/01/1900 19:39 1.56 0 15 0 2 0 Rønne 00/01/1900 09:50 0.41 1 0 0 0 0 Rostock 00/01/1900 14:11 0.61 0 3 0 0 0 Warnemünde 00/01/1900 17:12 1.65 5 21 3 3 0 Page 77

Baltic ports Average amount of time underway to this port (compensated for entry of Baltic Sea) Maximum amount of time underway to this port (compensated for entry of Baltic Sea) Time underway through the Baltic Sea to specific ports 0-0.5 days 0.5-1 days 1-1.5 days 1.5-2 days >2 days St Petersburg 00/01/1900 16:43 2.29 2 48 0 6 1 Stockholm 00/01/1900 22:34 1.67 0 36 2 13 0 Tallinn 00/01/1900 22:39 2.53 1 43 18 6 1 Visby 01/01/1900 01:06 1.52 0 1 0 1 0 Wismar 01/01/1900 16:26 1.68 0 0 0 1 0 26 234 43 60 3 8.3.2.8 Ports Table General impressions received from ships Table 62: Ports - Quantitative feedback General impression received from ships Ship General impressions: Questions and answers (number of entries) 40 Baltic ports B: In your opinion, what PRF system D: In your opinion, what Cost Recovery (Fee) worked best? In which Baltic port was this System worked best? In which Baltic port was PRF system applied? this Cost Recovery system applied? Aalborg 0 0 Aarhus 0 0 Copenhagen 9 4 Fredericia 0 0 Flensburg 0 0 Gdansk 0 0 Gdynia 0 0 Gothenburg 2 1 Helsingborg 1 0 Helsingør 0 0 Helsinki 29 15 Heiringsdorf 0 0 Hundested 0 0 Kaliningrad 0 0 Kalmar 0 0 Kalundborg 0 0 Karlskrona 0 0 Kemi 0 0 Kiel 1 0 Holtenau 0 0 Klaipeda 0 0 Kotka 0 0 Lu beck 0 0 Travemu nde 0 0 Lulea 0 0 Mariehamn 1 1 Malmö 0 0 Nynashamn 0 0 Örnsköldsvik 0 0 Pori 0 0 Riga 0 0 Rønne 0 0 Bornholm 0 0 Rostock 0 0 Warnemünde 9 0 Saaremaa 0 0 40 Whether or not a port is included in this list would also depend on whether that port was visited. Page 78

Ship General impressions: Questions and answers (number of entries) 40 Baltic ports B: In your opinion, what PRF system D: In your opinion, what Cost Recovery (Fee) worked best? In which Baltic port was this System worked best? In which Baltic port was PRF system applied? this Cost Recovery system applied? St Petersburg 2 0 Sassnitz 0 0 Skagen 0 0 Stockholm 37 26 Stralsund 0 0 Szczecin 0 0 Sẃinoujsćie 0 0 Tallinn 2 2 Turku 0 0 Umea 0 0 Veere 0 0 Ventspils 0 0 Visby 1 1 Wismar 0 0 8.3.2.9 Ports Table Number of PRF providers / Sewage treatment / Local sewage storage Baltic ports How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Local sewage storage available? Aarhus 1 No Municipal waste treatment Copenhagen 3 system Yes No Fredericia No Gdansk 1 No Gdynia 1 Yes No Municipal waste treatment Gothenburg 1 system No Municipal waste treatment Helsingborg 1 system No Municipal waste treatment Helsinki 1 system Yes No Karlskrona No Municipal waste treatment Kiel 1 system Yes No Municipal waste treatment Klaipeda 2 system Yes No Travemu nde No Mariehamn 1 No Malmö No Nynashamn No Pori No Municipal waste treatment Riga 2 system Yes No Rønne No Municipal waste treatment Rostock 1 system No Municipal waste treatment Warnemünde 1 system Yes No Municipal waste treatment St Petersburg 2 system Yes No Skagen 2 No Municipal waste treatment Stockholm 1 system Yes No Municipal waste treatment Tallinn 2 system Yes No Yes? No? Page 79

Baltic ports How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Local sewage storage available? Visby 1 No Wismar No Yes? No? Page 80

8.3.2.10Ports Table Volumes waste water / Pumping capacities feedback Table 63: Ports - Quantitative feedback Volumes waste water / Pumping capacities Baltic ports Total volume on board when arriving in port (average) Average volume delivered Total volume on board /average time underway (m3/hr) Max. pumping capacity / average volume delivered (1/hr) Pumping capacity reported Max. pumping capacity / average volume on board (1/hr) Average time for discharging (hr) Max. pumping capacity Reported / average volume delivered / average time for discharging (1/1) Max. pumping capacity Reporting / average volume on board / average time for discharging (1/1) Max. pumping capacity Calculated / average volume delivered (1/hr) Pumping capacity calculated Max. pumping Max. capacity pumping Calculated / capacity average Calculated volume / average delivered / volume average time on board for (1/hr) discharging (1/1) Max. pumping capacity Calculated / average volume on board / average time for discharging (1/1) Aarhus 395 60.00 #N/A 0.00 0.00 #N/A #N/A #N/A 0.60 0.09 #N/A #N/A Copenhagen 593 53.62 19.93 1.86 0.17 5.18 0.36 0.03 1.24 0.11 0.24 0.02 Fredericia 1241 0.00 121.48 #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Gdansk 52 40.00 3.89 0.75 0.58 6.00 0.13 0.10 0.33 0.26 0.06 0.04 Gdynia 276 78.56 8.45 0.51 0.15 9.42 0.05 0.02 0.53 0.15 0.06 0.02 Gothenburg 665 271.25 39.32 0.18 0.08 11.79 0.02 0.01 0.36 0.15 0.03 0.01 Helsingborg 278 119.00 #N/A 0.42 0.18 7.00 0.06 0.03 0.29 0.12 0.04 0.02 Helsinki 694 210.94 37.02 0.47 0.14 6.28 0.08 0.02 0.45 0.14 0.07 0.02 Karlskrona 30 0.00 2.14 #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Kiel 568 103.12 21.83 0.59 0.11 5.51 0.11 0.02 0.61 0.11 0.11 0.02 Klaipeda 236 60.00 13.72 1.25 0.32 4.43 0.28 0.07 0.75 0.19 0.17 0.04 Travemu nde 327 0.00 35.48 #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Mariehamn 60 223.33 4.07 0.22 0.83 7.75 0.03 0.11 0.20 0.73 0.03 0.09 Nynashamn 513 0.00 37.31 #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Riga 483 69.70 24.59 1.15 0.17 6.41 0.18 0.03 0.72 0.10 0.11 0.02 Rostock 1164 14.00 81.99 4.29 0.05 #N/A #N/A #N/A 0.25 0.00 #N/A #N/A Warnemünde 483 121.04 28.03 0.97 0.24 4.76 0.20 0.05 1.03 0.26 0.22 0.05 St Petersburg 581 147.06 34.71 0.68 0.17 19.23 0.04 0.01 0.41 0.10 0.02 0.01 Skagen 187 0.00 #N/A #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Stockholm 582 344.40 25.77 0.78 0.46 9.79 0.08 0.05 0.64 0.38 0.06 0.04 Tallinn 508 30.71 22.40 2.51 0.15 4.43 0.57 0.03 4.56 0.28 1.03 0.06 Visby 154 125.67 6.14 0.39 0.32 4.27 0.09 0.07 0.40 0.32 0.09 0.08 Wismar 142 0.00 3.51 #N/A 0.00 #N/A #N/A #N/A #N/A 0.00 #N/A #N/A Maximum 4.29 0.83 19.23 0.57 0.11 4.56 0.73 1.03 0.09 Tallinn Mariehamn Tallinn Mariehamn Ports with highest scores Copenhagen Gdansk Copenhagen Visby Klaipeda Klaipeda Warnemünde Tallinn Warnemünde Visby Klaipeda Page 81

8.4 Ports - Berth based feedback data received 8.4.1 Ports - Berths Qualitative feedback received No qualitative feedback has been received from Berths. 8.4.2 Ports - Berths Quantitative feedback received 8.4.2.1 Ports - Berths Visits / Pumping rate / Type of PRF available Table 64: Berths - Quantitative feedback Visits / Pumping rate / Type of PRF available Specific berth visited Total number of visits Maximum pumping rate applied Number of discharges Availability of Tank/Barge/Fixed PRF Confirmed Confirmed Confirmed tank barge fixed PRF car/truck available? available? available? 0 Unknown 7 0 0 Aarhus Berth 129 3 0 0 Available Copenhagen Container terminal 266 2 15 0 Available Copenhagen Langelinie 15 50 0 Available Copenhagen Langelinie 008-021 1 30 0 Available Copenhagen Langelinie 19 1 0 0 Available Copenhagen Langelinie 33-54 7 40 1 Available Copenhagen Langelinie Berth C190 2 35 2 Available Copenhagen Langelinie Berth C192 5 42 1 Available Available Copenhagen Nordre Toldbod C177 4 20 1 Available Copenhagen Ocean Berth 11 80 0 Available Available Copenhagen Ocean Berth Terminal 1 C331 18 100 3 Available Copenhagen Ocean Berth Terminal 2 C332 1 50 1 Copenhagen Ocean Berth Terminal 3 C333 24 80 2 Available Available Copenhagen Unknown 2 0 0 Available Dover CT1 0 0 3 Fredericia Cruise Terminal Kastelkajen Berth 1-3 3 0 2 Gdansk Westerplatte 2 30 1 Available Available Gdynia Francuskie Berth 7 40 21 Available Gdynia Unknown 2 0 1 Available Gothenburg Inner Harbor Frihamnen 107 1 0 0 Gothenburg Outer Harbor Arendal 751-752 2 50 0 Available Available Gothenburg Unknown 1 0 1 Available Helsingborg At anchor 1 0 2 Helsingborg South Harbor 500 1 50 0 Available Helsinki Berth 11 83 0 Available Helsinki KatajaNokka Berth EKL 9 70 2 Available Helsinki Port Of Helsinki 1 94 1 Available Helsinki South Harbor ERA 1 51 0 Available Helsinki Unknown 1 0 1 Helsinki West Harbor 2 80 11 Available Helsinki West Harbor Melkki Berth LMA 19 100 7 Available Available Helsinki West Harbor Munkkisaari Berth 4 77 1 Available Helsinki West Harbor Munkkisaari Berth LHB 4 20.8 1 Available Helsinki West Harbor Munkkisaari Berth LHC 16 88.7 0 Available Helsinki West Harbor Ocean Berth LJ8 1 10 1 Available Helsinki West Harbour Melkki Berth LMA 1 16 Available Hundestad Traffikhaven 0 0 4 Karlskrona At anchor 1 0 4 Kiel Ostseekai LP 27 11 44 15 Available Available Available Kiel Ostseekai LP 28 7 61 1 Available Available Available Kiel Ostuferhafen 1 2 20 1 Available Available Klaipeda Berth 80 1 16.62 0 Available Available Klaipeda Cruise Terminal Berth 28-33 11 75 0 Available Klaipeda Cruise Terminal Berth 29 1 0 3 Available Klaipeda Cruise Terminal Berth 30-33 3 33.3 4 Available Klaipeda Klaipeda Cruise Terminal 1 39 2 Available Klaipeda PAX terminal 2 0 1 Available Lulea Unknown 0 0 6 Malmö Frihamnskajen No. 602 1 0 0 Available Page 82

Specific berth visited Total number of visits Maximum pumping rate applied Number of discharges Availability of Tank/Barge/Fixed PRF Confirmed Confirmed Confirmed tank barge fixed PRF car/truck available? available? available? Mariehamn Berth 1-2 2 50 3 Available Mariehamn Unknown 1 0 1 Non Baltic Port (Oslo, Norway) Unknown 0 0 0 Non Baltic Port (Stavanger, Norway) Unknown 0 0 0 Nynashamn At anchor 1 0 0 Nynashamn SeaWalk 6 0 2 Ornskoldsvik Unknown 0 0 1 Pori Unknown 1 0 0 Riga Krievu Salas Terminal 7 0 0 Available Available Riga Pasazieru Terminal 1 46 0 Available Riga Riga Terminal 1 0 0 Rønne At anchor 1 0 0 Rostock Rostock Berth 3 60 0 Available Available Rostock Rostock Cargo Port 1 0 0 Rostock Rostock P31 1 0 1 Available Skagen Cruise Berth 10 1 0 0 Available Skagen Cruise Berth 9 1 0 0 St Petersburg Berth 14 60 1 Available St Petersburg English Embankment 6 30 0 Available Available Available St Petersburg Lt Schmidt Embankment 5 60 0 Available Available Available St Petersburg Main Passenger Terminal, Berth B 1 30 0 Available St Petersburg Marine Façade 19 52 0 Available Available Available St Petersburg Marine Façade Terminal 1 Berth 6 4 100 6 Available St Petersburg Marine Façade Terminal 1 Berth 7 1 50 3 Available Available St Petersburg Marine Façade Terminal 2 Berth 5 1 19 2 Available St Petersburg Marine Façade Terminal 3 Berth 3 2 0 1 Available Available St Petersburg Marine Façade Terminal 4 Berth 1 10 0 1 Available Stockholm At anchor 1 0 3 Stockholm Berth 6 60 1 Available Stockholm Berth 523 1 0 1 Stockholm Frihamnen 7 80 1 Available Stockholm Frihamnen 634 6 0 Available Stockholm Frihamnen 638 1 0 0 Stockholm Frihamnen 650 5 58.4 6 Available Stockholm Ocean Berth 3 1 80 0 Available Stockholm Stadsgården 4 45 6 Available Stockholm Stadsgården 165/167 17 144 5 Available Stockholm Stadsgården 167 4 45 0 Available Stockholm Unknown 4 77 5 Available Stockholm Vartahamnen 3 0 1 Available Stockholm Vartahamnen 523 2 35 4 Available Tallinn Berth 6 70 16 Available Tallinn Berth 24 16 77 2 Available Available Tallinn Berth 24/25 7 0 4 Tallinn Berth 25 4 35 3 Available Available Tallinn Berth 26 9 52 2 Available Available Tallinn Berth 27 38 60 6 Available Available Tallinn East 2 0 7 Tallinn Unknown 1 32 0 Available Available Travemu nde Unknown 2 0 2 Umea Unknown 0 0 3 Visby Berth 7 3 49 11 Available Warnemünde Rostock Berth 0 107 0 Available Available Warnemünde Rostock Berth 41 5 0 1 Available Warnemünde Warnemünde 1 0 0 Warnemünde Warnemünde Cruise Terminal 2 98 0 Available Available Warnemünde Warnemünde Cruise Terminal Berth 7 0 117.64 3 Available Available Warnemünde Warnemünde Cruise Terminal Berth 8 10 77 0 Available Available Wismar Unknown 15 0 4 Page 83

8.4.2.2 Ports - Berths Problems encountered? Table 65: Ports - Berths - Quantitative feedback Problems encountered Specific berth visited A problem experien ced (excl height of fees Row 60) Percenta ge of total number of visits When relevant: please indicate the problems encountere d etc. Problems encountered? Percenta ge of total number of visits In your opinion, is the port facility properly accommodat ed to meet the needs of the ship? (no) Percent age of total number of visits Was the volume of sewage discharg ed conform the wishes of the ship? (no) Perce ntage of total numb er of visits 0 Unknown 0 0% 0 0% 0 0% 0 0% Aarhus Berth 129 2 67% 2 67% 1 33% 1 33% Copenhagen Container terminal 266 2 100% 2 100% 1 50% 0 0% Copenhagen Langelinie 10 67% 10 67% 6 40% 3 20% Copenhagen Langelinie 008-021 0 0% 0 0% 0 0% 0 0% Copenhagen Langelinie 19 0 0% 0 0% 0 0% 0 0% Copenhagen Langelinie 33-54 0 0% 0 0% 0 0% 0 0% Copenhagen Langelinie Berth C190 1 50% 1 50% 0 0% 0 0% Copenhagen Langelinie Berth C192 3 60% 0 0% 3 60% 1 20% Copenhagen Nordre Toldbod C177 3 75% 2 50% 3 75% 1 25% Copenhagen Ocean Berth 8 73% 8 73% 2 18% 0 0% Copenhagen Ocean Berth Terminal 1 C331 6 33% 6 33% 6 33% 0 0% Copenhagen Ocean Berth Terminal 2 C332 1 100% 0 0% 1 100% 1 100% Copenhagen Ocean Berth Terminal 3 C333 10 42% 10 42% 10 42% 0 0% Copenhagen Unknown 1 50% 1 50% 0 0% 0 0% Dover CT1 0 0 #DIV/0! 0 0 Fredericia Cruise Terminal Kastelkajen Berth 1-3 1 33% 1 33% 1 33% 1 33% Gdansk Westerplatte 1 50% 1 50% 1 50% 1 50% Gdynia Francuskie Berth 2 29% 0 0% 2 29% 1 14% Gdynia Unknown 0 0% 0 0% 0 0% 0 0% Gothenburg Inner Harbor Frihamnen 107 0 0% 0 0% 0 0% 0 0% Gothenburg Outer Harbor Arendal 751-752 0 0% 0 0% 0 0% 0 0% Gothenburg Unknown 0 0% 0 0% 0 0% 0 0% Helsingborg At anchor 0 0% 0 0% 0 0% 0 0% Helsingborg South Harbor 500 0 0% 0 0% 0 0% 0 0% Helsinki Berth 0 0% 0 0% 0 0% 0 0% Helsinki KatajaNokka Berth EKL 0 0% 0 0% 0 0% 0 0% Helsinki Port Of Helsinki 0 0% 0 0% 0 0% 0 0% Helsinki South Harbor ERA 1 100% 0 0% 0 0% 1 100% Helsinki Unknown 0 0% 0 0% 0 0% 0 0% Helsinki West Harbor 1 50% 1 50% 0 0% 0 0% Helsinki West Harbor Melkki Berth LMA 10 53% 10 53% 1 5% 3 16% Helsinki West Harbor Munkkisaari Berth 3 75% 3 75% 1 25% 1 25% Helsinki West Harbor Munkkisaari Berth LHB 3 75% 2 50% 0 0% 2 50% Page 84

Specific berth visited A problem experien ced (excl height of fees Row 60) Percenta ge of total number of visits When relevant: please indicate the problems encountere d etc. Problems encountered? Percenta ge of total number of visits In your opinion, is the port facility properly accommodat ed to meet the needs of the ship? (no) Percent age of total number of visits Was the volume of sewage discharg ed conform the wishes of the ship? (no) Perce ntage of total numb er of visits Helsinki West Harbor Munkkisaari Berth LHC 2 13% 2 13% 1 6% 0 0% Helsinki West Harbor Ocean Berth LJ8 0 0% 0 0% 0 0% 0 0% Helsinki West Harbour Melkki Berth LMA 0 0% 0 0% 0 0% 0 0% Hundestad Traffikhaven 0 0 #DIV/0! 0 0 Karlskrona At anchor 1 100% 1 100% 0 0% 0 0% Kiel Ostseekai LP 27 1 9% 0 0% 0 0% 1 9% Kiel Ostseekai LP 28 0 0% 0 0% 0 0% 0 0% Kiel Ostuferhafen 1 0 0% 0 0% 0 0% 0 0% Klaipeda Berth 80 0 0% 0 0% 0 0% 0 0% Klaipeda Cruise Terminal Berth 28-33 7 64% 4 36% 7 64% 1 9% Klaipeda Cruise Terminal Berth 29 0 0% 0 0% 0 0% 0 0% Klaipeda Cruise Terminal Berth 30-33 3 100% 3 100% 0 0% 3 100% Klaipeda Klaipeda Cruise Terminal 1 100% 0 0% 1 100% 1 100% Klaipeda PAX terminal 1 50% 1 50% 0 0% 0 0% Lulea Unknown 0 0 #DIV/0! 0 0 Malmö Frihamnskajen No. 602 1 100% 0 0% 1 100% 1 100% Mariehamn Berth 1-2 1 50% 0 0% 0 0% 1 50% Mariehamn Unknown 0 0% 0 0% 0 0% 0 0% Non Baltic Port (Oslo, Norway) Unknown 0 0 #DIV/0! 0 0 Non Baltic Port (Stavanger, Norway) Unknown 0 0 #DIV/0! 0 0 Nynashamn At anchor 0 0% 0 0% 0 0% 0 0% Nynashamn SeaWalk 0 0% 0 0% 0 0% 0 0% Ornskoldsvik Unknown 0 0 #DIV/0! 0 0 Pori Unknown 0 0% 0 0% 0 0% 0 0% Riga Krievu Salas Terminal 6 86% 6 86% 6 86% 0 0% Riga Pasazieru Terminal 1 100% 0 0% 1 100% 1 100% Riga Riga Terminal 0 0% 0 0% 0 0% 0 0% Rønne At anchor 0 0% 0 0% 0 0% 0 0% Rostock Rostock Berth 2 67% 2 67% 1 33% 0 0% Rostock Rostock Cargo Port 1 100% 0 0% 0 0% 1 100% Rostock Rostock P31 1 100% 1 100% 0 0% 0 0% Skagen Cruise Berth 10 1 100% 1 100% 0 0% 0 0% Skagen Cruise Berth 9 0 0% 0 0% 0 0% 0 0% St Petersburg Berth 8 57% 8 57% 8 57% 0 0% St Petersburg English Embankment 5 83% 2 33% 5 83% 2 33% St Petersburg Lt Schmidt Embankment 3 60% 2 40% 3 60% 0 0% St Petersburg Main Passenger Terminal, Berth B 1 100% 1 100% 0 0% 0 0% St Petersburg Marine Façade 10 53% 9 47% 2 11% 0 0% St Petersburg Marine Façade Terminal 1 Berth 6 4 100% 4 100% 3 75% 0 0% St Petersburg Marine Façade Terminal 1 Berth 7 0 0% 0 0% 0 0% 0 0% St Petersburg Marine Façade Terminal 2 Berth 5 1 100% 1 100% 0 0% 0 0% Page 85

Specific berth visited A problem experien ced (excl height of fees Row 60) Percenta ge of total number of visits When relevant: please indicate the problems encountere d etc. Problems encountered? Percenta ge of total number of visits In your opinion, is the port facility properly accommodat ed to meet the needs of the ship? (no) Percent age of total number of visits Was the volume of sewage discharg ed conform the wishes of the ship? (no) Perce ntage of total numb er of visits St Petersburg Marine Façade Terminal 3 Berth 3 1 50% 1 50% 0 0% 0 0% St Petersburg Marine Façade Terminal 4 Berth 1 8 80% 6 60% 2 20% 1 10% Stockholm At anchor 0 0% 0 0% 0 0% 0 0% Stockholm Berth 0 0% 0 0% 0 0% 0 0% Stockholm Berth 523 0 0% 0 0% 0 0% 0 0% Stockholm Frihamnen 0 0% 0 0% 0 0% 0 0% Stockholm Frihamnen 634 0 0% 0 0% 0 0% 0 0% Stockholm Frihamnen 638 0 0% 0 0% 0 0% 0 0% Stockholm Frihamnen 650 0 0% 0 0% 0 0% 0 0% Stockholm Ocean Berth 3 0 0% 0 0% 0 0% 0 0% Stockholm Stadsgården 2 50% 2 50% 0 0% 2 50% Stockholm Stadsgården 165/167 13 76% 3 18% 0 0% 13 76% Stockholm Stadsgården 167 1 25% 0 0% 0 0% 1 25% Stockholm Unknown 0 0% 0 0% 0 0% 0 0% Stockholm Vartahamnen 0 0% 0 0% 0 0% 0 0% Stockholm Vartahamnen 523 0 0% 0 0% 0 0% 0 0% Tallinn Berth 0 0% 0 0% 0 0% 0 0% Tallinn Berth 24 10 63% 7 44% 4 25% 0 0% Tallinn Berth 24/25 7 100% 7 100% 7 100% 0 0% Tallinn Berth 25 2 50% 1 25% 1 25% 0 0% Tallinn Berth 26 3 33% 2 22% 1 11% 1 11% Tallinn Berth 27 23 61% 16 42% 9 24% 6 16% Tallinn East 0 0% 0 0% 0 0% 0 0% Tallinn Unknown 0 0% 0 0% 0 0% 0 0% Travemu nde Unknown 1 50% 0 0% 1 50% 0 0% Umea Unknown 0 0 0 0 Visby Berth 7 2 67% 0 0% 1 33% 2 67% Warnemünde Rostock Berth 4 0 0 4 Warnemünde Rostock Berth 41 1 20% 1 20% 0 0% 0 0% Warnemünde Warnemünde 2 200% 0 0% 2 200% 0 0% Warnemünde Warnemünde Cruise Terminal 6 300% 6 300% 2 100% 0 0% Warnemünde Warnemünde Cruise Terminal Berth 7 12 7 6 5 Warnemünde Warnemünde Cruise Terminal Berth 8 14 140% 14 140% 2 20% 6 60% Wismar Unknown 1 7% 0 0% 1 7% 0 0% Page 86

8.4.2.3 Ports - Berths Local sewage storage / PRF Providers / Destination Sewage Table 66: Ports - Berths - Quantitative feedback Local storage / PRF Providers / Destination sewage Specific berth visited Local sewage storage available? Yes No How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? 0 Unknown 0 7 0 Unknown Aarhus Berth 129 0 3 0 Unknown Copenhagen Container terminal 266 2 0 0 Unknown Copenhagen Langelinie 0 15 0 Unknown Copenhagen Langelinie 008-021 0 0 0 Unknown Copenhagen Langelinie 19 0 0 0 Unknown Copenhagen Langelinie 33-54 0 0 1 Unknown Copenhagen Langelinie Berth C190 2 0 1 Municipal waste treatment system Copenhagen Langelinie Berth C192 0 4 1 Municipal waste treatment system Copenhagen Nordre Toldbod C177 0 3 1 Unknown Copenhagen Ocean Berth 3 6 3 Unknown Copenhagen Ocean Berth Terminal 1 C331 10 8 0 Unknown Copenhagen Ocean Berth Terminal 2 C332 0 1 1 Municipal waste treatment system Copenhagen Ocean Berth Terminal 3 C333 23 1 3 Municipal waste treatment system Copenhagen Unknown 1 1 3 Municipal waste treatment system Dover CT1 0 0 1 Municipal waste treatment system Fredericia Cruise Terminal Kastelkajen Berth 1-3 0 3 1 Municipal waste treatment system Gdansk Westerplatte 0 2 1 Municipal waste treatment system Gdynia Francuskie Berth 1 6 3 Municipal waste treatment system Gdynia Unknown 0 2 1 Municipal waste treatment system Gothenburg Inner Harbor Frihamnen 107 0 1 0 Unknown Gothenburg Outer Harbor Arendal 751-752 0 2 0 Unknown Gothenburg Unknown 0 1 1 Unknown Helsingborg At anchor 0 1 1 Unknown Helsingborg South Harbor 500 0 1 1 Unknown Helsinki Berth 3 8 0 Unknown Helsinki KatajaNokka Berth EKL 4 5 1 Municipal waste treatment system Helsinki Port Of Helsinki 0 1 1 Municipal waste treatment system Helsinki South Harbor ERA 0 1 0 Unknown Helsinki Unknown 0 1 1 Municipal waste treatment system Helsinki West Harbor 1 1 1 Municipal waste treatment system Helsinki West Harbor Melkki Berth LMA 3 16 1 Municipal waste treatment system Helsinki West Harbor Munkkisaari Berth 1 3 1 Municipal waste treatment system Helsinki West Harbor Munkkisaari Berth LHB 1 3 1 Municipal waste treatment system Helsinki West Harbor Munkkisaari Berth LHC 1 15 0 Unknown Helsinki West Harbor Ocean Berth LJ8 0 1 1 Municipal waste treatment system Helsinki West Harbour Melkki Berth LMA 1 0 1 Municipal waste treatment system Hundestad Traffikhaven 0 0 1 Municipal waste treatment system Karlskrona At anchor 0 1 1 Municipal waste treatment system Kiel Ostseekai LP 27 0 1 1 Municipal waste treatment system Kiel Ostseekai LP 28 0 2 1 Municipal waste treatment system Kiel Ostuferhafen 1 2 0 1 Municipal waste treatment system Klaipeda Berth 80 0 1 0 Unknown Klaipeda Cruise Terminal Berth 28-33 0 11 0 Unknown Klaipeda Cruise Terminal Berth 29 0 0 1 Municipal waste treatment system Klaipeda Cruise Terminal Berth 30-33 3 0 1 Municipal waste treatment system Klaipeda Klaipeda Cruise Terminal 0 1 1 Unknown Klaipeda PAX terminal 0 0 2 Unknown Lulea Unknown 0 0 1 Unknown Malmö Frihamnskajen No. 602 0 1 0 Unknown Mariehamn Berth 1-2 0 2 1 Municipal waste treatment system Mariehamn Unknown 0 1 0 Unknown Non Baltic Port (Oslo, Norway) Unknown 0 0 0 Unknown Page 87

Specific berth visited Local sewage storage available? Yes No How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Non Baltic Port (Stavanger, Norway) Unknown 0 0 0 Unknown Nynashamn At anchor 0 1 0 Unknown Nynashamn SeaWalk 0 6 1 Unknown Ornskoldsvik Unknown 0 0 0 Unknown Pori Unknown 0 1 0 Unknown Riga Krievu Salas Terminal 0 6 0 Unknown Riga Pasazieru Terminal 0 1 0 Unknown Riga Riga Terminal 0 1 0 Unknown Rønne At anchor 0 1 0 Unknown Rostock Rostock Berth 0 3 0 Unknown Rostock Rostock Cargo Port 0 1 1 Unknown Rostock Rostock P31 0 1 1 Unknown Skagen Cruise Berth 10 0 1 0 Unknown Skagen Cruise Berth 9 0 1 0 Unknown St Petersburg Berth 0 14 1 Municipal waste treatment system St Petersburg English Embankment 1 4 0 Unknown St Petersburg Lt Schmidt Embankment 0 3 0 Unknown St Petersburg Main Passenger Terminal, Berth B 0 1 2 Unknown St Petersburg Marine Façade 1 17 0 Unknown St Petersburg Marine Façade Terminal 1 Berth 6 3 1 1 Municipal waste treatment system St Petersburg Marine Façade Terminal 1 Berth 7 0 1 1 Municipal waste treatment system St Petersburg Marine Façade Terminal 2 Berth 5 0 1 1 Municipal waste treatment system St Petersburg Marine Façade Terminal 3 Berth 3 0 2 1 Unknown St Petersburg Marine Façade Terminal 4 Berth 1 0 10 1 Municipal waste treatment system Stockholm At anchor 1 0 1 Municipal waste treatment system Stockholm Berth 0 6 1 Municipal waste treatment system Stockholm Berth 523 0 1 1 Municipal waste treatment system Stockholm Frihamnen 4 3 2 Municipal waste treatment system Stockholm Frihamnen 634 0 6 1 Municipal waste treatment system Stockholm Frihamnen 638 0 1 0 Unknown Stockholm Frihamnen 650 1 4 1 Municipal waste treatment system Stockholm Ocean Berth 3 1 0 0 Unknown Stockholm Stadsgården 0 4 1 Municipal waste treatment system Stockholm Stadsgården 165/167 1 12 1 Municipal waste treatment system Stockholm Stadsgården 167 1 3 0 Unknown Stockholm Unknown 1 3 1 Municipal waste treatment system Stockholm Vartahamnen 0 3 1 Municipal waste treatment system Stockholm Vartahamnen 523 2 0 1 Municipal waste treatment system Tallinn Berth 0 6 1 Municipal waste treatment system Tallinn Berth 24 6 8 0 Unknown Tallinn Berth 24/25 0 7 1 Municipal waste treatment system Tallinn Berth 25 1 3 1 Municipal waste treatment system Tallinn Berth 26 8 1 1 Municipal waste treatment system Tallinn Berth 27 6 23 1 Municipal waste treatment system Tallinn East 0 2 1 Municipal waste treatment system Tallinn Unknown 0 1 0 Unknown Travemu nde Unknown 0 1 1 Municipal waste treatment system Umea Unknown 0 0 1 Municipal waste treatment system Visby Berth 7 0 3 1 Municipal waste treatment system Warnemünde Rostock Berth 5 0 0 Unknown Warnemünde Rostock Berth 41 0 0 2 Municipal waste treatment system Warnemünde Warnemünde 0 2 0 Unknown Warnemünde Warnemünde Cruise Terminal 0 10 0 Unknown Warnemünde Warnemünde Cruise Terminal Berth 7 8 7 1 Unknown Page 88

Specific berth visited Local sewage storage available? Yes No How many PRF providers can the ship select from? (maximum) According to that company or the treatment facility provider, where is the sewage taken/treated? Warnemünde Warnemünde Cruise Terminal Berth 8 1 17 0 Unknown Wismar Unknown 0 1 1 Municipal waste treatment system Page 89

8.5 Analysis of amendments and assumptions related to the exercise This chapter provides an analysis of necessary amendments and assumptions made. The information presented in this report and conclusions derived have been based on the possibilities and limitations provided by the reporting forms and information received from ports and ships. Moreover, it would be highly recommendable to further address these aspects in the approach to this exercise and the reporting forms in case this exercise would be repeated in some form in the future. This would considerably reduce the amount of time required to check, propose and amend the content of cells. Especially as erroneous content received usually is noticed in the analysing phase, after the specific section of the (Excel) model would already have been built. Section 8.5.1 addresses general aspects related to the process of the exercise. Section 8.5.2 addresses the assumptions made when drafting the reporting forms and amendments made to the responses received. 8.5.1 Aspects related to the exercise and process There has only been a reference included to the Marpol Annex IV legislation, but the regulations have not been included in detail. This project relies to a great extent on the dedication and knowledge of the person on board of the cruise ship and those in the ports completing the reporting forms. The reporting form unfortunately did not provide ship specific options to record their reasons for discharge at sea. As many cruise ships still had to discharge sewage at sea during the 2016 season, it would have been interesting to have included a standardised process to document the reasons. Both the questionnaires and the reporting forms were quite extensive and sometimes repetitive. Although this did support checking and correcting the data received, it also provided an additional administrative burden and may have confused people involved. Although ports and representative organisations have been contacted multiple times ahead of, during and after the exercise, only very few responses have been received from ports, reportedly mostly because it was considered an administrative burden. The full involvement of ports in the future is essential. The questions related to wastewaters (Sewage/BW, GW, mixed BW/GW and other) should be clearer distinguished in the reporting forms. The deadlines for companies (both ports and ships) to provide input and correct the input when required should be stricter maintained. Uncorrected information should be faster dismissed. 8.5.2 Assumptions and amendments made to the forms and responses received Cells in the excel file, provided to the external verifier, which are purple have been amended (e.g. format changed in accordance with other entries). General assessment: Date format (US vs EU), amended throughout the input received. Data lacking, completed where possible (e.g. based on general commenting sections). Information for worksheets has sometimes been copy-pasted leading to many cells with the same content for input for the same port on different dates. Page 90

Evaluation and assumptions made regarding Ship s Reporting Format Table 67: Evaluation and assumptions made regarding Ship s Reporting Format Reporting Format Name of Ship Baltic Port Name Berth/Pier/terminal Code or at anchor In case the Baltic Sea was entered between the previous port and the current port, when was the Baltic Sea entered? (Date) In case the Baltic Sea was entered between the previous port and the current port, when was the Baltic Sea entered? (Time) When was the vessel assigned to a specific berth? (Date) When was the vessel assigned to a specific berth? (Time) Is the current berth equal to the one assigned at first instance? ETA Estimated Time of Arrival at berth (Date) ETA Estimated Time of Arrival at berth (Time) ATA Actual Time of Arrival at berth (Date) ATA Actual Time of Arrival at berth (Time) ETD Estimated Time of Departure from berth (Date) ETD Estimated Time of Departure from berth (Time) Number of passengers on board when arriving Number of crew on board when arriving Implemented MEPC.1/Circ.644 - ANF (Advanced Notification Form) Implemented MEPC.1/Circ.645 - WDR (Waste Delivery Receipt) When was the ANF submitted to the current port? (Date) When was the ANF submitted to the current port? (Time) If submitted, did you receive confirmation that the PRF would be available on arrival? Estimate amount of sewage to be generated between notification and the current port Estimation of sewage to be delivered Maximum dedicated sewage storage capacity (notational total maximum capacity) Maximum dedicated sewage storage capacity (current trim-adjusted maximum capacity) Volume of Sewage (only greywater) on board when leaving previous port Volume of Sewage (only black water) on board when leaving previous port Volume of Sewage (mixed black and greywater) on board when leaving previous port Total volume of sewage on board when leaving previous port Assumptions and amendments include No amendments No amendments Descriptions aligned. Checked for consistency with time of departure and arrival and moved and deleted when appropriate. Amended from US to EU date format. Checked for consistency and amended when required. No amendments No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments No amendments No amendments No amendments No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments No amendments Definition sewage Definition sewage Unclear to the person completing this form whether this included e.g. ballast tanks and what definition of Sewage is used here. Should be aligned with the Capacity Plan and including some basic layout of the pumping and piping arrangement may be necessary. Unclear to the person completing this form whether this included e.g. ballast tanks and what the definition of Sewage is used here. May not be included in a next occasion. Definition sewage Definition sewage Definition sewage Definition sewage. Where possible, entries have been corrected to show the total volume of BW, GW and mixed BW and GW on board. Page 91

Reporting Format Assumptions and amendments include Volume of sewage discharged at sea after leaving previous port (black and grey water) Definition sewage. Also, Marpol Annex IV requirements unclear Should be have been in the following format:<4nm; <12 During discharge, what was the position of the vessel? nm. Input received differs significantly and has been aligned Was the sewage treated before discharge? No amendments Why was this sewage discharged? Definition sewage and link with the Marpol Annex IV requirements. Was the sewage discharged because of the safety of the ship? Definition sewage and definition of safety which was not provided. Unclear of this included treated sewage or not and what Did this volume of sewage discharged at sea consist of a the composition of the volume discharged was mixture of black and greywater? (BW/GW/mixed) Volume of Sewage (only greywater) on board when arriving at current port Definition sewage Volume of Sewage (only black water) on board when arriving at current port Definition sewage Volume of Sewage (mixed black and greywater) on board when arriving at current port Definition sewage Total volume of sewage on board when arriving at current port Definition sewage. Entries have been corrected to show the total volume of BW, GW and mixed BW and GW on board. A clear distinction needs to be maintained between the number of providers and for instance the amount of How many PRF providers can the ship select from? different types of PRFs. Also, a single Port may have different types of PRF s (tank truck, fixed or barge) and the mobile PRF s may have different providers of the tank trucks and barges. Name of company operating/providing the applied reception facility No amendments According to that company or the treatment facility provider, where is the sewage taken/treated? No amendments Name of the company providing the sewage treatment facility (if known) No amendments Local sewage storage available? Definition unclear The maximum capacity of local storage can fluctuate. It a) Capacity would be worthwhile to provide the opportunity to report that information. Sometimes unclear what PRF has actually been applied and 1) Type of PRF used: Tank car extensive analysis is required. Multiple entries (1,2,3) may have been completed. Moreover, the type of waste needs to be included per type of PRF. MARPOL standard connections fitted No amendments a) Total capacity available Amended to m3 b) Total pumping capacity Amended to m3/hr Sometimes unclear what PRF has actually been applied and 2) Type of PRF used: Barge extensive analysis is required. Multiple entries (1,2,3) may have been completed. Moreover, the type of waste needs to be included per type of PRF. MARPOL standard connections fitted No amendments a) Total capacity available Amended to m3 b) Total pumping capacity Amended to m3/hr Sometimes unclear what PRF has actually been applied and 3) Type of PRF used: Fixed Reception Point extensive analysis is required. Multiple entries (1,2,3) may have been completed. Moreover, the type of waste needs to be included per type of PRF. MARPOL standard connections fitted No amendments a) Total capacity available Amended to m3 b) Total pumping capacity Amended to m3/hr Does the cruise ship consider the fees disproportionately high such that they create a disincentive to utilize the PRFs? Note: very often completed. Links with definition of adequacy. Page 92

Reporting Format Start of discharging operation (Date) Start of discharging operation (Time) Pumping capacity applied Total volume of sewage (black, grey and mixed water) delivered to PRF in current port Did this volume of sewage delivered to PRF consist of a mixture of black and greywater? Completing discharging operation (Date) Completing discharging operation (Time) Was the volume of sewage discharged conform the wishes of the ship? Please elaborate on the foregoing answer Amount of sewage retained (black, grey and mixed water) on board when leaving current port How is the total costs of delivery calculated (the Cost Recovery System applied by the facility)? What was the total costs of delivery? When relevant: please indicate the problems encountered by using one of more of the following code letters (A) No facility available; (B) Undue delay; (C) Use of facility technically not possible; (D) Inconvenient location; (E) Vessel had to shift berth involving delay/cost; (F) Unreasonable charges for use of facilities; (G) Other (please specify under additional comments) Additional comments In your opinion, is the port facility properly accommodated to meet the needs of the ship? In case the cruise ships finds the PRF inadequate, has or will an inadequacy report (be) submitted to the Flag State? Next Port of Delivery (if known) ATD Actual Time of Departure of leaving berth (Date) ATD Actual Time of Departure of leaving berth (Time) In case the Baltic Sea was exited between the previous port and the current port, when was the Baltic Sea actual exited? (Date) In case the Baltic Sea was exited between the previous port and the current port, when was the Baltic Sea actual exited? (Time) Next Port Name ETA Estimated Time of Arrival at berth (Date) ETA Estimated Time of Arrival at berth (Time) Any other Comments 1 Any other Comments 2 Any other Comments 3 Assumptions and amendments include Amended from US to EU date format. Checked for consistency and amended when required. No amendments Checked for consistency (m3/hr) and Definition sewage Definition sewage Amended from US to EU date format No amendments Amended to yes/no format No amendments Definition sewage Various types of entries received Various types of entries received No amendments No amendments Amended to yes/no format Unclear if the person who completed the form considered this to be a hypothetical question or whether it considered the PRF to be inadequate. This question would need to be rephrased in future project. No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments Checked for consistency with time of departure and arrival and moved and deleted when appropriate. No amendments Amended from US to EU date format. Checked for consistency and amended when required. No amendments Note: very often completed Note: very often completed Added to include the information from various entries above. Page 93

8.5.3 Definition clockwise or counter clockwise The following table shows the order of ports in clockwise direction, if a next port of call has a lower number, the route is registered as counter clockwise. Table 68: Definition Clockwise approach Clockwise approach Clockwise approach Aarhus 1 Ventspils 17 Copenhagen 2 Klaipeda 18 Malmö 3 Kaliningrad 19 Bornholm 4 Gdansk 20 Rønne 4 Gdynia 21 Karlskrona 5 Szczecin 22 Kalmar 6 Sẃinoujsćie 22 Visby 7 Heiringsdorf 23 Stockholm 8 Stralsund 24 Mariehamn 9 Sassnitz 24 Turku 10 Wismar 25 Helsinki 11 Rostock 26 Kotka 12 Warnemünde 26 St Petersburg 13 Lu beck 27 Tallinn 14 Travemu nde 27 Saaremaa 15 Kiel 28 Veere 15 Holtenau 28 Riga 16 Flensburg 29 Ports excluded from this analysis These ports are located for instance at the entrance of the Baltic Sea Region (BSR) or at an island in the midst of the BSR. For that reason, it could not be specified whether a cruise ship would be following a clockwise or counter-clockwise itinerary. Therefore, these ports could not be included in this analysis: Aalborg, Fredericia, Gothenburg, Kalundborg, Hundested, Helsingborg, Helsingør, Lulea, Nynashamn, Örnsköldsvik, Pori, Kemi, Skagen, and Umea. Page 94

8.6 Baltic Sea map and ports and ships routing 8.6.1 Baltic Sea Map Figure 10: Baltic Sea map 8.6.2 Combinations of ports visited after one another Based on feedback received from the participating ships, the following overviews of ports visited after one another are drafted: Combinations of 2 ports visited after one another (section 8.6.2.1) Combinations of 3 ports visited after one another (section 8.6.2.2) The port of call before the current port was not a Baltic port (section 8.6.2.3) Page 95