IMO makes ‘insufficient progress’ on slashing black carbon emissions from Arctic shipping

The International Maritime Organization (IMO) has agreed new guidance on best practices for cutting black carbon emissions from ships operating in or near the Arctic.

Meeting from February 19 to 23, 2024 at IMO Headquarters in London, IMO’s Sub-Committee on Pollution Prevention and Response (PPR 11) made progress in the following areas, to be submitted to the Marine Environment Protection Committee for approval this March (MEPC 81) and October (MEPC 82).

The Sub-Committe also agreed on draft guidelines on mitigation measures to reduce risks of use and carriage for use of heavy fuel oil (HFO) as fuel by ships in Arctic waters.

Black carbon emissions in the Arctic

The Sub-Committee agreed on draft guidance on best practices to assist ship operators/companies in their efforts to reduce Black Carbon emissions from their ships operating in or near the Arctic.

Black Carbon is a distinct type of carbonaceous material, formed only in flames during combustion of carbon-based fuels. It is a short-lived climate pollutant, produced by the incomplete burning of fossil fuels, with an impact more than three thousand times that of CO2 over a 20-year period. It makes up around one-fifth of international shipping’s climate impact. 

Several goal‑based control measures have been recommended for all ships, including the following guidance for ship operators or companies:

• As an initial step, to conduct an initial inventory of Black Carbon sources and undertake Black Carbon emission measurements from those sources (marine diesel engines);
• Consider setting a voluntary Black Carbon emission reduction target threshold;
• Identify and consider what practices and/or control measures are available to the ship which could be implemented to achieve the set reduction target threshold;
• Develop a Black Carbon management plan, including periodic monitoring for managing and ensuring success in reduction efforts.

In addition, the Sub-Committee agreed on draft guidelines for measuring, monitoring and reporting Black Carbon emissions, which will help with collecting data to support the development of recommendations and regulations to reduce the impact of Black Carbon emissions on the Arctic environment.

The guidance on best practices and guidelines for measuring, monitoring and reporting will be submitted for adoption at MEPC 82.

Use and carriage of heavy fuel oil in Arctic waters

The draft guidelines for reducing risks of use and carriage for use of HFO as fuel by ships in Arctic waters will be submitted to MEPC 82 for approval.

The guidelines cover navigational measures; ship operation; HFO bunkering; communication; enhancement of HFO spill preparedness, early detection and response; and familiarization, training and drills.

Regulation 43A of MARPOL Annex I, which introduces a prohibition on the use and carriage for use as fuel of HFO by ships in Arctic waters, takes effect on July 1, 2024. Ships which meet certain construction standards with regard to oil fuel tank protection will need to comply on and after July 1, 2029. A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party’s sovereignty or jurisdiction, up to July 1, 2029.

The guidelines contain recommendations that can be applied to ships not covered by the prohibition in regulation 43A of MARPOL Annex I.

The PPR 11 meeting also agreed guidelines on controlling nitrogen oxide emissions, developing local contingency plans for spills or pollution involving oil or hazardous and noxious substances and the safe transport of plastic pellets at sea.

Clean Arctic Alliance: Progress made but IMO fails to act on black carbon emissions, despite credible and direct pathway

At the PPR 11 meeting, the Clean Arctic Alliance called on the IMO to urgently adopt a mandatory regulation requiring ships to move to distillate fuels while operating in and near the Arctic, and for the maritime sector to follow a 2021 IMO resolution above 60 degrees north.

In addition, the alliance called on the international shipping sector to now implement the new guidance to protect the Arctic from black carbon emissions from shipping.

“While PPR11 made some progress this week – agreeing guidance on best practise on black carbon control measures as well as emissions measurement, monitoring, and reporting, and also commencing an open discussion on the issue of fuel quality and aromaticity – the IMO is still failing to act on reducing black carbon emissions despite a switch to cleaner fuels being identified over a decade ago,” Sian Prior, Lead Advisor to the Clean Arctic Alliance, said.

“A clear and credible path has already been identified – the IMO must now adopt a mandatory regulation requiring ships to move to distillate fuels while operating in and near to the Arctic.”

“During the meeting, some IMO member states agreed that recommendatory action would not be sufficient and stronger action was required – but then failed to push hard enough to achieve that action. Due to this ongoing travesty – with of emissions of a potent short-lived climate pollutant remaining unregulated – the Clean Arctic Alliance calls on the shipping sector to follow the IMO Resolution agreed in 2021 to voluntarily switch to distillate fuels to protect the Arctic, and to apply the guidance finalised during PPR11,” Prior added.

“We call on IMO member states to now turn the 2021 resolution into a regulation as an interim measure – switching to distillate fuels is a clear way forward in one of the world’s most climate vulnerable regions. Not only can it be achieved quickly, it will also ensure that black carbon emissions are rapidly reduced between 50% – 80% (depending on the engine and other variables), until work to develop a polar fuel standard can be concluded,” Prior concluded.

PPR 11: Scrubbers, HFO mitigation measures

During PPR 11, many IMO member states acknowledged that the discharge of scrubber wastewater is an environmental hazard and supported the regulation of scrubbers on a regional basis. Regrettably, there was no consensus between those that support a ban or regulation, those that support regulation but have no wish to penalize shipowners that have installed scrubbers, and those that have yet to be convinced that regulation is required.

As a result, PPR could only encourage member states and interested parties including NGOs to bring proposals to PPR 12 in 2025.

“While shipping industry and oil industry parties claimed that scrubbers are ‘OK’, several member states and environmental groups countered this old and tired narrative, which is based on the 20th century myth that ‘the solution to pollution is dilution’”, Eelco Leemans, Technical Advisor to the Clean Arctic Alliance, said.

“We are now seeing increasing support from IMO member states for regulation of scrubbers, particularly in coastal waters and sensitive areas such as the Arctic. The IMO’s failure to identify next steps means that it has in effect given the green light for countries to implement restrictions, while many states have given a red light to the use of scrubbers in their waters.”

With regard to guidelines on mitigation measures to reduce the risks of using and carrying for use of HFO in Arctic waters, the IMO has also been criticized for inaction.

“More important than agreeing these guidelines is the need for ships still using HFO in the Arctic to switch to cleaner alternative fuels, when the deadline prohibiting the use and carriage for use of HFO by ships operating in Arctic waters takes effect from 1 July 2024,” Andrew Dumbrille, Strategic and Technical Advisor to the Clean Arctic Alliance, pointed out.

“Regrettably, as some ships will continue to use HFO under an exemption or waiver until 1 July 2029, the Clean Arctic Alliance is calling for shipping companies to take responsibility for their environmental impact by making better fuel choices. Not only will this reduce the risks of a HFO spill in the Arctic but it will also reduce black carbon emissions too – a win-win situation which tackles both the climate and biodiversity crises together. Prioritising measures which are at the intersection of planetary threats should be a high priority for the IMO and its member states.”

In a context where black carbon emissions have doubled in IMO Arctic between 2015 and 2021, this infographic by Clean Arctic Alliance depicts how this harmful pollutant for the environment, the climate, and people, could be controlled and regulated. It also looks at the geographic scope for measures so impact from shipping can be reduced and emissions in and near the Arctic are also addressed and makes recommendations for action for IMO Member States.

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