Those amendments were prepared by the seventh meeting of the Sub-Committee on Pollution Prevention and Response (PPR 7) that took place in February this year and form part of the document PPR 7/22/Add.1, specifically its Annex 12, which can be found on pages 79 and 80 of that linked document.
They prohibit “the use and carriage of [certain] oils” as fuel by ships “in Arctic waters, on and after 1 July 2024,” although this date extends to 1 July 2029 for ships with “protected fuel tanks”, which are tanks that are separated from the outer hull of the ship by at least 76cm.
In addition, an Arctic state that is party to the convention “may temporarily waive the requirements … of this regulation” for ships flying its flag while they are operating in its waters. This waiver is also available until 1 July 2029.
Speaking on Monday (16 November) during a webinar organised by the CAA, Dr Bryan Comer, senior marine researcher for the International Council for Clean Transportation (ICCT), said that MEPC must address these waivers “if the ban is to be effective”. He reminded attendees that when it was first mooted by eight IMO member states in 2018, their intention was that the ban would come into effect in 2021.
According to his assessment, the current proposal “would allow 74% of HFO-fuelled ships to keep using HFO in the Arctic” and would result in a reduction of HFO carried of just 30% and a cut in black carbon emissions of only 5%. It would be even less effective if ships operating in the region, but registered elsewhere, were to reflag to an Arctic state in order to claim a waiver, he added.
He outlined three alternatives to the proposed draft amendments. The first would allow waivers but get rid of the exemptions for protected fuel tanks. In this scenario, he said, 64% of HFO carriage would be banned, but only 29% of HFO use. The second option would also exclude exemptions and allow waivers only in internal waters and territorial seas. In that case, he said, 70% of HFO carriage would be banned and HFO use would be cut by 75%.
His final option was “to actually ban HFO,” reducing HFO carriage and use by 100% and black carbon emissions by 30%.
He urged MEPC to consider these options and said that, if it does decide to include exemptions or waivers, these must expire “well before 2029” and the ban should be implemented as soon as possible. “There’s really no reason to wait until July 2024 when IMO procedures would allow the ban to enter into force as early as 2023,” he said.
By far the largest flag state operating in Arctic waters is Russia and Dr Comer presented a graph showing that Russian-flagged ships account for two-thirds of Arctic HFO use. Of that fuel volume, only 3% would be banned under the proposed draft amendment, with the rest either exempt or waived.
Because of Russia’s dominance in the area, ShipInsight observed during the webinar’s Q&A that it held the key to unlocking any reforms and asked whether that was a realistic hope. Dr Sian Prior, lead adviser to the CAA, believes that it is. She said that Russia’s president has “indicated in conversations with the president of Finland that there is a need to reduce carbon emissions and to move away from oil-based fuels altogether in the Arctic.”
Her optimism was supported by Alexey Knizhikov, leader of WWF Russia’s Extractive Industry Programme. Joining the webinar to respond to ShipInsight, he said that “it’s not easy in Russia to switch to a new agenda in terms of safety” but reported that “month by month and year by year, we see more and more changes at the policy level.”
He said that “quite recently” Russia had adopted a “new Arctic strategy … to switch from oil-based fuels to alternatives” and reported that, in the country’s shipping sector, “we see more and more companies who operate in the Arctic starting to … switch from oil-based fuels.” He cited Sovcomflot and Norilsk Nickel as two leading companies making this change in strategy.
“Step by step we see more support for this switch,” he said, and he believes there are opportunities “to work on win-win strategies with Russian shipping companies in the Arctic.”