Fifteen NGOs Petition Arctic Council on HFO
The Arctic Council, now under the chairmanship of the United States, is meeting this coming Monday through Wednesday in Stockholm to discuss protection of the marine environment, and 15 international NGOs are urging Ambassador David Balton of the U.S. State Department to take action on heavy fuel oil (HFO).
A continuing disconnect between research and political progress remains when it comes to the issue of heavy fuel oil and shipping in arctic waters, says Sue Libenson, Senior Arctic Program Officer for Pacific Environment. “The Arctic Council identified a spill of heavy fuel oil as the top threat posed by shipping to the arctic environment in its 2009 comprehensive Arctic Marine Shipping Assessment. Additional papers are expected to be submitted at this upcoming meeting.
“However, the Arctic Council has taken no action to advise the shipping industry to curtail its use and switch to cleaner fuels. Concerns include the risk of an oil spill, black carbon emissions which especially speed climate change in the Arctic and greenhouse gas emissions.”
The letter below has been sent to Ambassador David Balton of the U.S. State Department.
Re: U.S. Arctic Council Chairmanship and HFO use in Arctic shipping
Dear Amb. Balton:
The Arctic Council’s Protection of the Arctic Marine Environment (PAME) Working Group continues to cover the issue of heavy fuel oil (HFO) and shipping in the Arctic. As a follow-on to the HFO Phase I and Phase II reports by Det Norske Veritas for PAME, and in accordance with the PAME 2015-2017 Work Plan, a submission by the U.S. et al. describing spills or releases of HFO in the Arctic and consequent impacts was prepared for PAME II-2015. A revised version of this document is expected for PAME I-2016, along with a paper from Norway related to the HFO Phase III(B) project entitled “Possible hazards for engines and fuels systems using heavy fuel oil in cold climates.”
While these documents are helpful and informative, their submittals raise the question as to whether further information gathering and analysis is called for—or, whether, as we believe, persuasive and extensive evidence has been sufficiently put forward at both the Council and the IMO that militates in favor of action to cease the use of HFO by vessels in the Arctic.
The eight Arctic Council Member States and communities represented by the six indigenous Permanent Participant organizations have the most at stake on this important issue, and the time is ripe for regional leadership at the IMO to enact an HFO use ban in the Arctic.
We note that the Arctic Ocean Review Final Report, released in May 2013, remarks that PAME is undertaking a study on the environmental risks related to the use and carriage of HFO by vessels in the Arctic and “will identify options and make recommendations – including the possible adoption of new international regulations – to mitigate those risks.”
Two and a half years later we are still not at this stage, and it is unclear when any recommendations will be forthcoming.
In our opinion, HFO use in 2016 by vessels in Arctic marine waters is highly imprudent, for many reasons, including but not limited to the following. First, effectively cleaning up an HFO spill in Arctic ice-covered waters is impracticable, if not impossible. HFO has unique properties amongst ship fuels, as it emulsifies in water, whereas lighter distillates evaporate. This means that its total volume increases rapidly over a few days and spreads throughout the water column. Coupled with its viscosity and tendencies to sink and stick to anything it comes into contact with, cleanup effort becomes insurmountable.
This point should not be overlooked, and is underscored by recent events. The oil spill involving the tanker MV Nadezhda off Sakhalin Island occurred in waters free of ice and in close proximity to a port, yet response was still stymied by severe weather. If a similar event had taken place in the Bering Strait or comparably remote and under-equipped area, a timely response would likely have been infeasible. And even if it were eventually mounted, a cleanup attempt would have been minimally effective at best.
The problem is more acute in Arctic waters because of lower species diversity as well as reduced growth and reproduction rates for its biota. More damage can occur, more quickly and with longer lasting effects than in other climates.
Second, banning the use of HFO in the Arctic will reduce black carbon, a potent climate-forcing substance. Efforts to decrease short-lived climate forcers can complement global initiatives to ratchet down carbon dioxide emissions. The Council’s Framework for Action on black carbon acknowledges that black carbon has substantial impact on the Arctic and that its reduction contributes to global efforts to limit the increase in global average temperature to below two degrees Celsius above pre-industrial levels.
AMAP has determined that Arctic warming could be cut by 0.25C (0.5F) by 2025 through global reductions in black carbon (and co-emitted air pollutants). In addition, recently the prominent atmospheric scientist Veerabhadran Ramanathan and his co-author asserted that if we reduce black carbon emissions by 90 percent, as well as phase out HFCs and decrease methane emissions by 50 percent, expected global warming could be halved over the next 35 years.
Moreover, it should be noted that black carbon emissions from shipping are becoming more significant in the Arctic, with retreating sea ice due to climate change facilitating efforts to expand trade, exploit natural resources, and conduct tourism. A high-growth scenario for Arctic shipping even projects black carbon levels to exceed 2004 levels nearly fivefold by 2030 and over 18-fold by 2050.
Third, in comparison to other types of black carbon, “mitigation of diesel-engine sources offers the most confidence in reducing the near-term climate forcing.” Hence, focus on ship-source black carbon such as from HFO ought to be a priority.
Fourth, reducing black carbon by banning the use of HFO by vessels in the Arctic will not only aid in decreasing global and regional warming, but also mitigate impacts to air quality and public health.
Finally, in terms of procedure, a minor amendment to MARPOL Annex I is all that would be necessary to effect an HFO use ban for the Arctic. With concerted action by the Arctic states, under U.S. leadership, this could be achieved at the IMO in a relatively short amount of time. And precedent exists for this type of modification, as the IMO adopted a ban on the use (as well as carriage) of HFO by vessels in the Southern Ocean in 2010.
In conclusion, you have called the need to reduce black carbon emissions “urgent.” We agree with that sentiment. While national reduction goals for Arctic Council Member States and observers are, of course, important and laudable, the Council’s Framework for Action does not as yet address black carbon emissions from international shipping. This omission ought to be remedied, particularly in light of the current and anticipated contribution of Arctic shipping to regional black carbon levels.
Despite some positive steps taken by the IMO with the Polar Code, we believe that measures are desperately needed to reduce the environmental impacts from Arctic shipping and that a logical place to focus attention is vessel fuel quality. While less than one-third of the vessels that currently operate in the Arctic run on HFO, since these represent nearly all of the larger ships their fuel consumption constitutes about three-quarters of regional shipping fuel use.
The risks to the marine environment, the climate, and public health are too great to permit the continued use of HFO in Arctic shipping. Efforts to eliminate the use of HFO by ships in the Arctic therefore are timely and well-justified, and we ask for your leadership in bringing together Council Member States to recommend appropriate IMO action in the near term to this end.
We appreciate your attention to this letter.
Sincerely,
Sian Prior, Ph.D., Advisor, Antarctic and Southern Ocean Coalition
Melanie A. Smith, Director, Conservation Science, Audubon Alaska
Conrad G. Schneider, Advocacy Director, Clean Air Task Force
Karla Dutton, Director, Alaska Program, Defenders of Wildlife
Sarah Burt, Attorney, Earthjustice
Daniele Grabiel, Senior Policy Analyst, Environmental Investigation Agency
John Kaltenstein, Marine Policy Analyst, Friends of the Earth
Lisa Speer, Director, Int’l Oceans Program, NRDC
Andrew Hartsig, Director, Arctic Program, Ocean Conservancy
Michael Stocker, Executive Director, Ocean Conservation Research
Susan Murray, Deputy Vice President, Pacific Oceana
Kevin Harun, Director, Arctic Program, Pacific Environment
John Maggs, Senior Policy Advisor, Seas at Risk
Bill Hemmings, Director, Aviation and Shipping, Transport & Environment
Alexander Shestakov, Ph.D., Director, WWF Global Arctic Programme