A ban on the use and carriage of heavy fuel oil (HFO) in the Arctic is looking increasingly likely.
In addition, we may see proposals to regulate black carbon in the not too distant future that could have a big impact on ships operating
in Arctic waters, as they will likely be more restrictive than mainstream ship emission control measures.
In 2010, the IMO’s Marine Environment Protection Committee (MEPC) was informed that although marine vessels emit only around 2% of total global BC, the release of BC emissions in northern shipping routes affecting the Arctic is particularly damaging and magnifies their impact. In July 2011, the 62nd session (MEPC 62) agreed to initiate work to control BC emissions.
Progress has been slow, held up several IMO member states that have been questioning the scientific basis for regulating BC from shipping.
But as glaciers and Arctic sea ice have been receding at an alarming rate, opening up the region for more shipping activity, in particular the use of the Northern Sea Route (NSR), pressure to regulate BC has continued to grow.
Consideration of the issue was on the agenda at the fourth session of the Sub-Committee on Pollution Prevention and Response (PPR 4), which met at IMO’s headquarters in mid-January this year. PPR 4 had several documents and information papers submitted on the subject, mainly relating to the results of studies undertaken on the accuracy and practicality of various BC measurement methods, as well as observations about which factors contribute to BC emissions.
The workplan for this item, as defined by MEPC 62, calls for developing a definition; identifying the most appropriate measurement method(s) for international shipping; and investigating appropriate control measures. The Bond et al. definition for BC was approved by MEPC 68 in 2015, but much work remains on the rest.
PPR 4 agreed that it would need an extension on the target date for completion of the current workplan from 2017 to 2019, and that intersessional work will be required even to meet this new target date. It will seek to finalize identification of the most appropriate method(s) for measurement of black carbon at PPR 5 (2018).
Discussions on BC showed divergence on opinions as to whether it
is premature to begin to investigate control measures before appropriate measurement methods have been fully agreed.
Some think this is premature as they fear it will lead to legislation before the merit of control measures has been proven, however, the door has been left open for proposals to allow progress on this third element of the workplan.
Any potential future control measures are only expected to be adopted for ships operating in or near the Arctic, as that is where BC emissions can have the most dramatic impact on global warming.
Observations & future predictions Studies suggest there is good correlation between several measurements methods that are part
of the current measurement protocol for voluntary data collection studies on BC emissions from ships, but even one method that has not been showing good correlation and is deemed impractical by most that assessed it has as yet not been excluded.
Most measurements have been done in laboratories.
Doing measurements during actual operations is challenging
and it seems many external factors have an impact on the result.
Fuel type has an impact on BC emissions, but the study results are not fully conclusive and overall it appears that engine load is a bigger factor. Reduced sulphur content reduced the overall PM emissions, but not necessarily the BC emission according to one study presented to PPR 4, with variable engine loads creating variable results between fuels of 0.10%, 0.50% and 2.50% sulphur content.
Studies are missing on BC emissions from low speed engines, and studies on the impact of using 0.50% sulphur fuel are as yet limited. Looking ahead, and reading the signals from discussions at PPR 4, we may see a push toward requiring ships in the Arctic to use only very clean distillate fuels combined with particulate filter technology, or LNG, and exclude the use of scrubbers combined with HFO as an acceptable control measure.
To date, such particulate filter technology has not been practical to use on larger ship types. Any such decisions will only be taken in the next stage of the IMO’s work on controlling the impact on the Arctic of BC emissions. Before then, there must be reliable measurement methods in place as well as more research to understand exactly which factors cause the worst BC emissions, and how these can best be controlled.
However, sooty emissions are not the only concern. Environmental NGOs have been pushing for a ban on the use and carriage of HFO in the Arctic, to reflect the one in the Antarctic, to prevent HFO spills in these very sensitive eco-systems. That push has now received the full support of the European Parliament, which in March this year adopted a resolution on the Arctic. MEPs called on the Commission and the Member States “to actively facilitate the ban on the use of heavy fuel oil (HFO) and carriage as ship fuel in vessels navigating the Arctic seas through MARPOL of IMO” as part of an integrated European Union policy for the Arctic.” Should this not prove feasible at international level, the Commission should come up with rules to prohibit the use and carriage of HFO for vessels calling at EU ports,” MEPs said. The Clean Arctic Alliance, which counts many environmental NGOs among its members, believes that a ban on HFO in the Arctic can be achieved by 2020 if governments and business demand action by the IMO.
If this were to reflect the HFO ban in the Antarctic, it would require an amendment to Annex I of MARPOL to extend it to the Arctic.
A reduction of BC emissions would be a positive side effect, but would it be enough? Ships operating on distillates also emit soot, and at some specific engine loads they may even be worse offenders than ships burning HFO.
If the IMO agrees that BC emissions need to be reduced effectively, amendments to Annex VI of MARPOL may also be required, but identifying and agreeing on the appropriate control measures would likely take longer than adopting an HFO carriage ban under Annex I.
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