IBIA comment on Arctic HFO ban: Voluntary measures could reduce harmful emissions prior to ban taking effect

IBIA comment on Arctic HFO ban: Voluntary measures could reduce harmful emissions prior to ban taking effect

A prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters is on course for entry into force on 1 July, 2024. There are, however, exemptions for ships with fuel tanks protected by double hulls, and waivers for ships flying the flag of countries with a coastline bordering on Arctic, that will allow these ships to continue to use and carry HFO for use until 1 July, 2029.

This has angered environmental organisations which have warned that exemptions and waivers will apply to most ships. Combined with expected growth in shipping activity in the Artic, this could cause both the use and carriage of HFO in the region to increase significantly until the middle of 2029.

The 75th session of the IMO’s Marine Environment Protection Committee approved draft amendments to MARPOL Annex I to incorporate a prohibition on the use and carriage for use as fuel of HFO by ships in Arctic waters. It is expected to be adopted by MEPC 76, which is scheduled to meet in June 2021.

Very low sulphur fuel oil (VLSFO) produced to meet the IMO 2020 0.50% sulphur limit may still be regarded as HFO as any product with density at 15°C higher than 900 kg/m3 or kinematic viscosity at 50°C higher than 180 mm2/s will be defined as HFO according to the MARPOL Annex I regulation.

Prior to approving the draft regulatory change, MEPC 75 discussed a submission by FOEI, Greenpeace International, WWF, Pacific Environment and CSC urging the Committee to strike out exemptions and waivers so that the prohibition can take full effect from 1 July, 2024.

Their paper, MEPC 75/10/7, was one of the very few submissions to MEPC 75 which was allowed to be introduced. Due to time constraints, most papers were not introduced, but taken as pre-read before discission. Their paper highlighted the risk of HFO spills in the sensitive Arctic environment, and several of the co-sponsors made statements about the harmful impact of black carbon emissions on the region’s diminishing sea ice cover.

Member states who spoke at MEPC 75 nevertheless supported the draft prohibition, including the exemptions and waivers up until 1 July, 2029, recognising that the text was already an intensely negotiated and carefully balanced compromise.

Toward the end of the 35 minutes discussion on the HFO prohibition in the Arctic, IBIA’s Director and IMO Representative, Unni Einemo, made the following statement to MEPC 75:

We have a short intervention. It’s simply some practical considerations. We know that part of the reasoning behind the prohibition on the use and carriage for use of heavy fuel oil by ships in Arctic waters is to reduce black carbon emissions. As we know, the exact factors behind black carbon emissions are complex to determine. However, studies do indicate a significant general reduction when ships use distillates instead of HFO.

There has, therefore, been calls for a voluntary shift to distillates for ships operating in the Arctic, prior to the prohibition entering into force. In practice, this is entirely feasible. Ships have already been using mainly distillates in emission control areas since 2015.

In light of the impact black carbon emission in the Arctic can have on climate change, a voluntary shift to distillates, or other fuels and technology solutions that can significantly reduce black carbon emission for ships operating in the Arctic should clearly be recommended. Moreover, we are confident that the bunker supply industry can meet the demand requirements.

IBIA believes it makes sense to encourage voluntarily steps to reduce black carbon emissions in the Arctic as part of global efforts to fight climate change. Black carbon, or soot, absorbs light and heat and causes snow and ice to melt faster, and with less snow and ice to reflect solar radiation, the warming process accelerates.

IBIA checked the 4th IMO GHG study prior to MEPC 75 and made some enquiries with its authors about black carbon emission factors. In short, the study suggests that overall, engine type is a bigger factor than the fuel type in determining black carbon (BC) emissions, because 4-stroke engines emit so much more BC than 2-stroke engines.

The study indicates that a 4-stroke engine using MGO emits more BC than a 2-stroke engine using HFO. However, both engine types emit less BC when using MGO compared to HFO, and the reduction is particularly pronounced for 2-stroke engines.

As IBIA already stated at the seventh session of IMO’s Sub-Committee on Pollution Prevention and Response in February this year, the shift to very low sulphur fuel oil (VLSFO) meeting the 0.50% sulphur limit has likely already helped to reduce overall black carbon emissions from international shipping.

VLSFOs are typically less aromatic than the high sulphur fuel oils they have replaced, and hence likely to emit less BC during combustion than HSFO. However, if switching to distillates can reduce black carbon emission even further, it is a practical step that should be within easy reach. Methanol and LNG are even better for reducing black carbon emissions, but as they are low-flashpoint fuels it isn’t a quick and easy change to make, as it requires ships to meet specific safety design criteria.

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