Frequently Asked Questions

The Clean Arctic Alliance is a coalition of nonprofit organizations from around the world that is committed to protecting the Arctic from the hazards and risks posed by the use of heavy fuel oil (HFO). The goal of the Clean Arctic Alliance is to secure a legally binding phase out of the use of HFO as marine fuel in Arctic waters by 2020.

Member organizations of the Clean Arctic Alliance include the Alaska Wilderness League, Bellona, the Clean Air Task Force (CATF), the Danish Ecological Council (DEC), the Environmental Investigation Agency (EIA), Fundación Ecología y Desarrollo (ECODES), the European Climate Foundation (ECF), Friends of the Earth U.S. (FOE), Greenpeace, the Icelandic Nature Conservation Association (INCA), the Nature And Biodiversity Conservation Union (NABU), Ocean Conservancy, Pacific Environment (PE), Seas At Risk (SAR), Surfrider Foundation, Transport & Environment (T&E) and WWF.

The Clean Arctic Alliance is an international coalition with member organizations in Belgium, Canada, Denmark, Finland, France, Germany, Iceland, Netherlands, Norway, Russia, Spain, Sweden, the United Kingdom, and the United States.

At this time, the Clean Arctic Alliance urges the International Maritime Organization, the appropriate international body to regulate HFO, to adopt a legally binding provision to phase out the use of heavy fuel oil as marine fuel in Arctic waters by 2020.

No. In many cases shipping in the Arctic is an essential service. The Clean Arctic Alliance recognizes the importance of shipping to communities in the Arctic. For example, many communities living in the Arctic rely on an annual sealift of dry cargo including cleaning supplies, flour, sugar, and canned goods. For these reasons, the Clean Arctic Alliance is not seeking to ban shipping in the Arctic, but rather to ensure that the highest possible environmental and safety standards are adopted by all shipping sectors operating in the Arctic.

The Clean Arctic Alliance is making a distinction between the use and carriage of HFO as shipping fuel and the carriage of HFO as cargo, in recognition of the dependence of some Arctic communities on HFO for household use, including heating. However, in order to address the risks of an HFO spill in Arctic waters, the risks associated with the carriage of HFO as cargo must also be considered.

On a technical level, HFO, which is often referred to as “refinery residual,” is a complex group of hydrocarbon products that consist of the highly viscous and tar-like residues of the crude oil refining process.[1] Not all HFO is chemically uniform as its components are present in varying percentages depending on the crude oil from which the residuals have been derived as well as the nature of any other products (including diesel) added in order to improve pumping/flow, handling and combustion,or reduce the sulphur content of the fuel (a technique known as blending).[2] That being said, HFO typically includes bitumen, asphaltenes and long chain polycyclic aromatic hydrocarbons.[3] Mineral pollutants such as sulphur and heavy metals (vanadium, nickel etc.), derived from the baseload crude oil, may also be present in relatively high quantities.[4] In addition, refinery residues consist of “heavy” compounds that are less prone to evaporation and distillation. By their nature and definition such compounds are less prone to degradation in the environment and are thus recognized as environmentally persistent.[5] Given the significant differences in the quality and content of HFO products currently available in the market, Annex 1 of the International Convention for the Prevention of Pollution from Ships (MARPOL) defines residual fuel as “oils, other than crude oils, having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s.”

On a less technical level, HFO, which is the world’s dirtiest and most polluting ship fuel, is a tar-like residual waste from the oil refining process. As a result, marine transportation has been referred to as an incineration service for a waste product.[6] The combustion of HFO produces high levels of pollutants such as particulate matter, black carbon, sulphur oxide, nitrogen oxide, which have been linked to an increased risk of heart and lung disease as well as premature death. Black carbon is also a critical contributor to human-induced climate warming, especially in the Arctic.

[1] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 6 (2016).

[2] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 6 (2016).

[3] Vard Marine Inc., Fuel Alternatives for Arctic Shipping, Rev. 1, at 10 (2015), available at http://awsassets.wwf.ca/downloads/vard_313_000_01_fuel_alternatives_letter_final.pdf

[4] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 6 (2016).

[5] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 6 (2016).

[6] Vard Marine Inc., Fuel Alternatives for Arctic Shipping, Rev. 1, at 10 (2015), available at http://awsassets.wwf.ca/downloads/vard_313_000_01_fuel_alternatives_letter_final.pdf

Because HFO is the waste product of the crude oil refining process, it is relatively cheap, especially for larger vessels such as tankers, bulk carriers and container ships.[1] For example, while oil prices can change quickly, the price of a ton of HFO in October of 2016 was approximately $290.00 USD, while a ton of distillate fuel was $516.00 USD.[2]

[1] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 6 (2016).

[2] Ship and Bunker Prices, October 18, 2016, available at http://shipandbunker.com/prices/av.

There are numerous risks associated with the use of HFO in the Arctic including (1) threats to the food security, livelihoods and way of life of Arctic communities; (2) risks to the Arctic marine environment; (3) harmful emissions that negatively impact the local and global climate; and (4) emissions that are harmful to human health.

HFO threatens the food security, livelihood and way of life of Arctic communities:

Many indigenous people in the Arctic region depend on marine resources as a primary food source, use marine resources as a source of clothing and equipment, as material for handicrafts, and to support their limited commercial fishing, hunting, and ecotourism activities. An HFO spill in the Arctic would have devastating consequences on these communities and the resources they depend on for their nutritional, cultural, and economic needs.

HFO poses a risk to the Arctic marine environment:

In Arctic conditions, HFO is nearly impossible to clean up. Due to its high viscosity, HFO not only emulsifies on the ocean surface, but dispersants, which break down oil into smaller droplets that more readily mix with water, are also comparatively ineffective.[1] In addition, in conditions with 10 percent or more ice coverage, conventional booms and skimmers, which are typically used for containing and retrieving oil spills, are rendered ineffective. All of these technical complications are compounded by the natural difficulties posed by the Arctic, including navigational hazards such as sea ice, lack of infrastructure, heavy storms, high winds, and seasonal periods of 24-hour darkness.

In addition, HFO spills have acute and long-term consequences for marine life. The immediate effects of an HFO spill include hypothermia and death in seabirds and marine mammals as a result of HFO coating or sticking to their fur or feathers.[2] Aside from the devastating acute impacts an HFO spill will have on an ecosystem and marine wildlife, studies on the long-term impacts of an Arctic spill demonstrate that oil can remain within the affected area for more than a decade, impacting growth and reproductive rates of various species.[3] These impacts affect all levels of the fragile Arctic ecosystem, with larger predators like beluga whales being directly affected by coming into contact with the oil in water and sediments, and indirectly by consuming smaller contaminated prey.[4] A decade after a 2003 HFO spill in the Russian White Sea, hydrocarbon pollution in near shore water was still 22 times the Russian Maximum Permissible Contamination level (MPC), and many low trophic level species like flounder were still 10 times higher than MPC.[5] In this Russian example, the local population of beluga whales has declined, and have completely abandoned their traditional calving grounds in the area.[6]

Finally, HFO produces a considerable amount waste sludge. In fact, one to five percent of fuel volume consumed, must be discharged onshore, incinerated, or burned as fuel after further processing .[7] One study found that shipping within the Barents and Norwegian Seas produces 13,000 metric tons of fuel oil sludge a year[8], while the use of many alternative fuels, such as marine distillate fuels or LNG, does not result in any sludge residue.

HFO produces harmful emissions that negatively impact the global climate:

The use of HFO as fuel produces harmful and higher emissions of air pollutants, including sulphur oxide, nitrogen oxide, particulate matter, and black carbon (BC), than other marine fuels.[9] In particular, BC is a critical contributor to human-induced climate warming, especially in the Arctic.[10]

Black carbon influences the Arctic climate through two mechanisms. First, when black carbon is in the air, it directly warms the Arctic atmosphere by absorbing solar radiation that would otherwise have been reflected to space.[11] Second, when black carbon is deposited on light-colored surfaces, such as Arctic snow and ice, it reduces the amount of sunlight reflected back into space. This process results in the retention of heat and ultimately contributes to accelerated melting of Arctic snow and ice.[12] A recent study found that black carbon emitted from in-Arctic sources has five times the warming effect than black carbon emitted at mid-latitudes.[13]

HFO produces emissions that impact human health:

Emissions from shipping pose an acute and substantial risk to human health. In particular, pollutants such as particulate matter, BC, sulphur oxide and nitrogen oxide have been linked to an increased risk of heart and lung disease as well as premature death.

[1] PEW (2010). Oil spill prevention and response in the U.S. Arctic Ocean: unexamined risks, unacceptable consequences. Report commissioned by Pew Environment Group from Nuka Research and Planning Group LLC and Pearson Consulting LLC, 137 pp. and WWF (2009). Not so fast: some progress in technology, but U.S. still ill-prepared for offshore development. Report commissioned by WWF from Harvey Consulting LLC, 15pp.

[2] Arctic Council, Arctic Marine Shipping Assessment 2009 Report, at 139 (2009), available at http://www.pame.is/index.php/projects/arctic-marine-shipping/amsa.

[3] Peterson, C. H., Long-Term Ecosystem Response to the Exxon Valdez Oil Spill, 302 Science 5653, 
2082–2086 (2003), available at http://doi.org/10.1126/science.1084282.

[4] Andrianov, V.V. et al., Long-Term Environmental Impact of an Oil Spill in the Southern Part of Onega Bay, the White Sea, 42 Russian Journal of Marine Biology 3, 205–215  (2016).

[5] Andrianov, V.V. et al., Long-Term Environmental Impact of an Oil Spill in the Southern Part of Onega Bay, the White Sea, 42 Russian Journal of Marine Biology 3, 205–215  (2016).

[6] Andrianov, V.V. et al., Long-Term Environmental Impact of an Oil Spill in the Southern Part of Onega Bay, the White Sea, 42 Russian Journal of Marine Biology 3, 205–215  (2016).

[7] Arctic Council, Arctic Marine Shipping Assessment 2009 Report, at 139 (2009), available at http://www.pame.is/index.php/projects/arctic-marine-shipping/amsa.

[8] Arctic Council, Arctic Marine Shipping Assessment 2009 Report, at 139 (2009), available at http://www.pame.is/index.php/projects/arctic-marine-shipping/amsa.

[9] Arctic Monitoring and Assessment Programme (AMAP), Summary for Policy-Makers: Arctic Climate Issues 2015, Short-lived Climate Pollutants, at 9 (2015).

[10] Bond T. C. et al., Bounding the Role of Black Carbon in the Climate 
System: A scientific assessment, 118 Journal of Geophysical Research: Atmospheres 11, 5380- 5552 (2013).

[11] Arctic Monitoring and Assessment Programme (AMAP), AMAP Technical Report No. 4: The Impact of Black Carbon on Arctic Climate, at 45 (2011).

[12] Azzara, A., Minjares, R., and Rutherford, D., Needs and Opportunities to Reduce Black Carbon Emissions 
from Maritime Shipping, International Council on Clean Transportation (2015).

[13] Sand, M. et al., Arctic Surface Temperature Change to Emissions of Black Carbon Within Arctic or Midlatitudes, 118 Journal of Geophysical Research: Atmospheres 14 7788-7798 (2013).

Yes, there are restrictions on the use and/or carriage of HFO in both the Antarctic and the national parks in Svalbard, Norway.

Antarctica

In August of 2011, the International Maritime Organization adopted an amendment to the International Convention for the Prevention of Pollution from Ships (MARPOL) introducing a new chapter that eliminated the use and carriage of heavy grade oils on ships operating in the Antarctic area. The provisions of MARPOL, Annex I, Regulation 43 took effect on August 1, 2011. In 2014, following an incident where a fishing vessel sank in the Antarctic while carrying heavy grade oil in the vessel’s ballast tank, MARPOL, Annex I Regulation 43 was amended to prohibit “the carriage in bulk as cargo, use as ballast, or carriage and use as fuel” of HFO in the Antarctic area.” Ultimately, this means that ships traveling in the Antarctic cannot use HFO as fuel or carry HFO as cargo, with the exception of vessels engaged in securing the safety of ships or in a search-and-rescue operation.

Svalbard, Norway

In addition, an HFO ban in most protected areas of Svalbard, Norway has existed since 2007 and 2010. In particular, ships carrying HFO cannot sail in South Spitsbergen National Park, Forlandet National Park, North-West Spitsbergen National Park, Northeast Svalbard Nature Reserve and South Spitsbergen National Park. Although there used to be an exception for cruise lines visiting Magdalenefjorden and Ny-Ålesund, this exception was terminated in 2015.

 

In general, ships that operate on oil-based fuels use either HFO or a type of distillate fuel. Large commercial vessels, such as cargo ships, generally operate on HFO while smaller ships, such as tugs and fishing vessels, tend to operate on distillate fuels, such as marine diesel oil (MDO), marine gas oil (MGO), or even ultra-low sulfur diesel fuel (ULSD).[1] However, because of the 0.5% global fuel sulfur standard, which will enter into force in January of 2020, ships that currently operate on high-sulfur HFO may switch to desulfurized HFO fuel or blends of HFO and distillate fuels that comply with the 0.5% standard. Although low-sulfur HFO and HFO blends may be better in terms of sulphur oxide emissions, they may be just as harmful to the marine environment as high-sulfur HFO.

More specifically, in the Arctic, as defined by the International Maritime Organization (IMO), the top five ship classes by total HFO fuel on board (MT) in 2015 were bulk carriers (247,800 MT), container vessels (112,900 MT), oil tankers (110,600 MT), general cargo vessels (76,600 MT) and fishing vessels (76,200 MT).[2] For the U.S. Arctic, the top five ship classes by total HFO fuel onboard in 2015 were bulk carriers (42,000 MT), oil tankers (7,700 MT), fishing vessels (7,400 MT), service vessels (6,200 MT), and tugs (3,800 MT).[3] This data suggests that cargo vessels, which tend to have larger bunker fuel tanks than fishing vessels, service vessels, and tugs, account for most HFO fuel on board ships in the IMO Arctic. However, the relatively large number of fishing vessels operating in the Arctic makes them an important source of HFO fuel carried onboard ships as well.[4]

[1] Bryan Comer et al, Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 1 (2016).

[2] Bryan Comer et al, Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 6 (2016).

[3] Bryan Comer et al, Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 6 (2016).

[4] Bryan Comer et al, Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 6 (2016).

Although there are fewer ships operating on HFO than distillate in the Arctic, as defined by the International Maritime Organization, the quantity of fuel on board ships is dominated by HFO at a ratio of more than 3:1.[1] For example, in 2015, a total of 2086 ships traveled in the IMO Arctic, carrying 835,000 metric tons of HFO and 255,000 metric tons of distillate in their main bunker fuel tanks.[2] Although only 44% of the IMO Arctic fleet (925 ships) operated on HFO, these ships carried 76% of the mass of bunker fuel on board ships in the Arctic.[3] In addition, in 2015, 41% of the ships operating in the U.S. Arctic (73 out of 180 ships), but carried 77% of the mass of bunker fuel on board ships in that same area.[4]

[1] Bryan Comer et al., Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 1 (2016).

[2] Bryan Comer et al., Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 4 (2016).

[3] Bryan Comer et al., Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 4 (2016).

[4] Bryan Comer et al., Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 4 (2016).

Although there have been some questions about the effect of the global sulphur cap on the need to phase out the use of HFO in the Arctic, one of the central findings of a fuel availability study that was commissioned by the International Maritime Organization is that a sufficient supply of compliant fuel can be produced in 2020 using heavy fuel (residual) blends. In addition, in order to comply with the global sulphur cap, shipping companies can choose to install scrubbers, which are a diverse group of air pollution control devices used to reduce sulphur emissions. The primary reason a shipping company would choose to install scrubbers would be to allow the company to continue burning cheaper HFO. Given this information, we anticipate that HFO will continue to be used by ships operating in the Arctic without action by the IMO to phase out the use of HFO in the Arctic.

Although a spill of any type of oil can cause irreversible damage to the environment, the ultimate consequences and hazards of an oil spill largely depend on the properties of the specific oil. For example, distillate fuels, such as diesel, tend to evaporate and dissolve faster than HFO and do not emulsify on the ocean surface.[1]   Conversely, HFO demonstrates a strong tendency to solidify rapidly and form tar lumps in marine waters. This not only results in a significant increase in the volume of waste to be handled in the event of a spill, but also makes HFO more persistent in the environment.[2] For example, a study commissioned by the Arctic Council has established that while 90 percent of HFO remains in the ocean after 20 days, marine diesel can take as few as three days to disappear from the surface.[3]

Most liquid hydrocarbons, such as distillate fuel, tend to spread into a slick over the water surface.[4] This quality allows oil recovery teams to detect and track a spill through aerial observations. On the other hand, due to a deficiency of “lighter” compounds in HFO, there may be no sea surface sheen to aid in the detection of an HFO spill.[5]

Furthermore, HFO is not typically as buoyant as distillate fuel and may not float on the sea surface. The long-term consequences of sunken oil are highly complex, but can include the incorporation of oil in ocean and coastal sediments. Although the oil can remain buried for years, it does not always remain submerged. A good example of the challenges associated with buoyancy of an HFO spill is the Swedish vessel THUNTANK. In December of 1986, the THUNTANK ran aground in heavy weather and spilled HFO in the Baltic Sea. When the HFO was spilled, it was denser than the surrounding water and sank to the ocean floor. However, when the water temperature increased during the summer months, the oil warmed, became more fluid and buoyant, and ultimately resurfaced. The resurfaced HFO was repeatedly washed ashore during the summers of 1987, 1989, 1990 and 1991 causing the shoreline to be repeatedly coated in thick oil.

Overall, the THUNTANK spill demonstrates that an HFO spill can be incredibly difficult to clean-up, given the viscous nature of HFO as well as its persistence in the ocean and coastal environments.

[1] Det Norske Veritas, Heavy fuel in the Arctic (Phase 1),Report No./DNV Reg No.: 2011-0053/ 12RJ7IW-4 Rev 00, 2011-01-18, at 38 (2011).

[2] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 7 (2016).

[3] Det Norske Veritas, Heavy fuel in the Arctic (Phase 1),Report No./DNV Reg No.: 2011-0053/ 12RJ7IW-4 Rev 00, 2011-01-18, at 38-39 (2011).

[4] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 7 (2016).

[5] Deere-Jones, T., Ecological, Economic and Social Impacts of Marine/Coastal Spills of Fuel Oils (Refinery Residuals), at 7 (2016).

The Arctic is defined differently by various domestic and international organizations as well as legal agreements. Some common definitions of the Arctic include (1) the areas above the Arctic Circle (66° 32’N) and (2) areas delineated by the 10-degree isotherm (a line on a map connecting points having the same temperature at a given time or the same mean temperature for a given period). However, both the International Maritime Organization and the Arctic Council have different definitions of the Arctic as outlined below:

 The Arctic as defined by the International Maritime Organization

The International Maritime Organization defines Arctic waters as “those waters which are located north of a line extending from latitude 58°00’.0 N, longitude 042°00’.0 W to latitude 64°37’.0 N, longitude 035°27’.0 W and thence by a rhumb line to latitude 67°03’.9 N, longitude 026°33’.4 W and thence by a rhumb line to Sørkapp, Jan Mayen and by the southern shore of Jan Mayen to the Island of Bjørnøya and thence by a great circle line from the Island of Bjørnøya to Cap Kanin Nos and thence by the northern shore of the Asian continent eastward to the Bering Strait and thence from the Bering Strait westward to latitude 60° N as far as Il’pyrskiy and following the 60th North parallel eastward as far as and including Etolin Strait and thence by the northern shore of the North American continent as far south as latitude 60° N and thence eastward along parallel of latitude 60° N, to longitude 56°37’.1 W and thence to the latitude 58°00’.0 N, longitude 042°00’.0 W.”[1]

The Arctic as Defined by the Arctic Council

In addition to the International Maritime Organization definition of the Arctic, various Arctic Council bodies have established differing definitions for the Arctic. The Arctic Council is an intergovernmental forum that promotes the cooperation, coordination and interaction among the Arctic States, Arctic indigenous communities and other Arctic inhabitants on common Arctic issues. The definitions of the Arctic developed by various Arctic Council groups vary based on criteria that are relevant to each body’s respective concerns. For example, the Arctic Monitoring and Assessment Program (AMAP) has established a definition of the Arctic that incorporates numerous considerations including the Arctic Circle, political boundaries, vegetation boundaries, permafrost limits, and major oceanographic features.[2] With these criteria in mind, the Arctic region covered by AMAP includes terrestrial and marine areas north of the Arctic Circle (66°32’N), and north of 62°N in Asia and 60°N in North America, modified to include the marine areas north of the Aleutian chain, Hudson Bay, and parts of the North Atlantic Ocean including the Labrador Sea.

The Arctic Council’s Emergency Prevention, Preparedness and Response Working Group (EPPR), the Conservation of Arctic Flora and Fauna (CAFF) Working Group, and the Arctic Monitoring and Assessment Program (AMAP), all have different definitions of the Arctic as detailed in Figure 2.

[1] Resolution A.1024(26) Guidelines for Ships Operating in Polar Waters (December, 2, 2009).

[2] Arctic Monitoring and Assessment Programme, AMAP Assessment Report, Chapter 2: Physical/Geographical Characteristics of the Arctic (2011).

Studies estimate that overall shipping activity in the Arctic will increase by more than 50% between 2012 and 2050. This increase in shipping means that although shipping currently only accounts for about 5% of black carbon emissions in the Arctic, this number is expected to double by 2030 and quadruple by 2050 given current projections.[1] At the same time, the risks of an HFO spill will increase as a greater number of ships transit the Arctic for commercial or recreational purposes.

Specific instances of increased traffic include a recent announcement by the Chinese cargo-shipping company COSCO to send five ships through the Northern Sea Route in 2016. This is the largest number of COSCO ships that have ever transited the Northern Sea Route and after the company’s success during the 2016 Arctic-shipping season, it remains optimistic about the future of Arctic shipping.[2] South Korea has also recently used the Northern Sea Route to transport goods to Europe and South Korea’s Director of Shipping and Logistics at the Ministry of Oceans and Fisheries has stated that South Korea will “prepare for the coming era of the Northern Sea Route by training manpower to specialize in Arctic shipping, offering incentives to shipping lines, and strengthening co-operation with states along the route.”[3]

In addition to increases in cargo traffic, there have also been several new developments in regards to recreational shipping in the Arctic. In particular, during the summer of 2016, the Crystal Serenity made history as the first luxury cruise liner to sail through the remote Northwest Passage. Furthermore, Sven-Olof Lindblad, founder and CEO of Lindblad Expeditions, announced that there will be ten new expedition ships delivered for use in Arctic waters by 2019.[4] Sven-Olof Lindblad also estimates that tourists will be coming the Arctic “in a big wave.”[5]

Finally, it is important to note that hydrocarbon extraction projects in the Arctic are the main driver for increased shipping traffic along the Northern Sea Route. For example, in 2015, a total of 5.4 million tons of goods and project cargo were transported through the Northern Sea Route, which was up from about 4.0 million tons in 2014 and 3.9 million tons in 2013.[6] This increase in traffic was due in large part to construction of the Yamal liquefied natural gas (LNG) plant, which is located deep in the Russian Arctic.[7] This type of shipping traffic is only expected to increase in the coming years with additional development of Russian hydrocarbon projects.

[1] Arctic Monitoring and Assessment Programme (AMAP), Summary for Policy-Makers: Arctic Climate Issues 2015, Short-lived Climate Pollutants, at 7 (2015).

[2] Atle Staalesen, COSCO sends five vessels through Northern Sea Route, The Barents Observer (October 10, 2016), available at: http://thebarentsobserver.com/en/arctic-industry-and-energy/2016/10/cosco-sends-five-vessels-through-northern-sea-route

[3] Xiaolin Zeng, More South Korean shipping lines eye Northern Sea Route, HIS Fairplay (July 19, 2016), available at: http://fairplay.ihs.com/commerce/article/4271961/more-south-korean-shipping-lines-eye-northern-sea-route

[4] Thomas Nilsen, Be prepared, mass tourism is coming like lemmings, The Independent Barents Observer (October 8, 2016), available at: http://thebarentsobserver.com/en/industry-and-energy/2016/10/be-prepared-mass-tourism-coming-lemmings

[5] Thomas Nilsen, Be prepared, mass tourism is coming like lemmings, The Independent Barents Observer (October 8, 2016), available at: http://thebarentsobserver.com/en/industry-and-energy/2016/10/be-prepared-mass-tourism-coming-lemmings

[6] Bjørn Gunnarsson, Further Development of the Northern Sea Route, The Maritime Executive (February 18, 2016), available at:http://www.maritime-executive.com/editorials/future-development-of-the-northern-sea-route

[7] Bjørn Gunnarsson, Further Development of the Northern Sea Route, The Maritime Executive (February 18, 2016),a vailable at: http://www.maritime-executive.com/editorials/future-development-of-the-northern-sea-route

Black carbon, which is the strongest light-absorbing component of particulate matter, is a critical contributor to human-induced climate warming, especially in the Arctic.  Black carbon primarily influences the Arctic climate through two different mechanisms. First, when black carbon is in the air, it directly warms the Arctic atmosphere by absorbing solar radiation that would otherwise have been reflected to space.[1] Second, when black carbon is deposited on light-colored surfaces, such as Arctic snow and ice, it reduces the amount of sunlight reflected back into space. This process results in the retention of heat and ultimately contributes to accelerated melting of Arctic snow and ice. In fact, a recent study found that black carbon emitted from in-Arctic sources has five times the warming effect than black carbon emitted at mid-latitudes.[2] A primary reason for this is that a much higher fraction of within-Arctic black carbon emissions deposit on snow and sea ice than mid-latitude emissions.

In addition, black carbon is unique in that it typically only remains airborne for approximately a week, depending on weather conditions.[3] This short-term nature of black carbon emissions is important for several reasons.  First, because black carbon only stays airborne for a short period of time, black carbon concentrations are highest close to the source. For this reason it is important to not only consider the percentage of black carbon emissions from individual sources, but also the location of the emissions.  For example, even though black carbon emissions from the shipping sector only account for a small percentage of the emissions in the Arctic region, black carbon emissions from ships traveling through or near to Arctic sea ice are likely to have a greater effect per unit of emission those from land-based sources.[4]  Second, given the short lifetime of black carbon in the atmosphere, reducing black carbon emissions will have a more immediate effect on the warming of the Arctic than long-term air pollutants.

[1]  Arctic Monitoring and Assessment Programme (AMAP), AMAP Technical Report No. 4: The Impact of Black Carbon on Arctic Climate, at 60 (2011).

[2] Sand, M. et al., Arctic Surface Temperature Change to Emissions of Black Carbon Within Arctic or Midlatitudes, 118 Journal of Geophysical Research: Atmospheres 14, 7788-7798 (2013).

[3] Arctic Monitoring and Assessment Programme (AMAP), Summary for Policy-Makers: Arctic Climate Issues 2015, Short-lived Climate Pollutants, at 4 (2015).

[4] See Arctic Monitoring and Assessment Programme (AMAP), AMAP Technical Report No. 4: The Impact of Black Carbon on Arctic Climate, at 60 (2011).

 

Before detailing the potential solutions for mitigating the risks associated with the use of HFO in the Arctic, it is important to highlight that HFO is either used as marine fuel for ships traveling through Arctic waters or is carried on ships as cargo. HFO cargo is typically either delivered to communities to heat homes and power equipment, or is simply transported through the Arctic on oil tankers.

The following section will detail the potential mitigations measures to (1) address the risks posed by the use and carriage of HFO as marine fuel; and (2) address the risks associated with the carriage of HFO as cargo.

Addressing the Risks Posed by the Use and Carriage of HFO As Marine Fuel

Phasing Out the Use of HFO as Marine Fuel in the Arctic

Phasing out the use and carriage of HFO for marine fuel in Arctic waters is the simplest and most direct way to mitigate the risks of HFO use as marine fuel in Arctic waters. In particular, prohibiting the use and carriage of HFO as marine fuel would be a significant step in reducing the risks from HFO spill impacts. Estimate figures for 2015 from the International Council on Clean Transportation indicate that the quantity of fuel onboard ships is dominated by HFO at a ratio of more than 3:1.[1] Reducing the amount of HFO on board ships traveling through the Arctic would be a big step in reducing the risks of an HFO spill in such a vulnerable environment.

In addition, while Arctic vessel traffic and corresponding emissions of black carbon are projected to increase in the near and mid-term,[2] black carbon emissions in some parts of the Arctic from land-based sources are already declining or are expected to fall due to stricter regulations,[3] increasing the relative importance of addressing emissions from shipping. Switching from HFO fuel to alternative fuel, such as low-sulphur distillate fuel, is expected to reduce black carbon emission levels by an average of 30 percent.[4] Furthermore, the high sulphur content of HFO prevents the use of diesel particulate filters (DPFs) that are estimated to remove 80-90% of black carbon emissions.[5]

Overall, because a phase out of the use of HFO as marine fuel would address both the risks of an HFO spill as well as reduce black carbon emissions from Arctic shipping, it is the current focus on the Clean Arctic Alliance.

Arctic Emission Control Area (ECA)

The International Maritime Organization could also consider the implementation of an emission control area (ECA) in some or all of Arctic waters. Introducing an Arctic ECA could allow for stricter requirements for air emissions of SOx, NOx and particulate matter, including a requirement for the maximum sulphur content in fuels to be no more than 0.1%. This type of measure would address local Arctic pollution problems in areas with higher background concentrations of pollutants and vulnerability to pollution load, while simultaneously reducing black carbon emissions and negative health impacts.

However, an Arctic ECA would not on its own address the risks of spills and impacts on ecosystems and wildlife, including the threat to the food security of local indigenous people. Therefore, in order for the ECA to be an effective mitigation measure, it would need to be accompanied by companion measures, such as limiting or eliminating the use of scrubbers in order to minimize the risk of an HFO spill or being coupled with a particularly sensitive area as described below. Additionally, an Arctic ECA alone does not typically require a particular type of fuel to be used, so any fuel meeting the sulphur limits could be compliant, including low sulphur heavy fuel oils and heavy fuel oils with the use of scrubbers. Therefore, an Arctic ECA would not reduce the need for oil pollution preparedness and response teams to be able to respond to an HFO spill and may not address black carbon emissions as effectively as other measures.

Addressing the Risks Associated with the Carriage of HFO as Cargo

Prohibiting the Carriage of HFO as Cargo

Although prohibiting the carriage of HFO as cargo would eliminate the risk of an HFO spill from shipping, due to the dependence of some local communities on HFO for household use, as well as existing hydrocarbon activity in the region, a more tailored approach to address the carriage of HFO as cargo in the Arctic may be necessary.

Designation of Areas to be Avoided (ATBA) and Other Routing Measures

To reduce the risk of an HFO spill in Arctic waters, the designation of specific routing measures, such as two-way traffic routes and areas to be avoided (ATBA), around hazardous areas or sensitive marine habitats should be considered. Because the majority of the Arctic is poorly charted,[6] established routes could decrease incidents such as ship groundings, collisions with other vessels, ice, or subsistence users, etc. For example, established routes that direct vessel traffic, such as traffic separation schemes, recommended tracks or two-way routes, could be created in more adequately charted, safer-to-navigate areas. This type of well-defined route will be critical in areas of the Arctic where the risks of these incidents are high, such as in the 53-mile wide Bering Strait, and it could be possible to monitor vessels closely in such areas and require mandatory reporting.

In addition, ABTAs, which typically exist in areas of known or potential hazards, as well as in areas of heightened ecological significance,[7] could complement traffic routes or exist independently of other routing measures. ATBA designations have already been delineated in the U.S. Arctic near the Aleutian Islands “in order to reduce the risk of a marine casualty and resulting pollution and damage to the environment.”[8] At the March 2015 meeting of the International Maritime Organization Maritime Safety Committee’s Navigation, Communications and Search and Rescue (NCSR) Sub-Committee, the United States’ proposal made in NCSR 2/3/5 emphasized the benefits of several ATBAs to help reduce the risk of shipping accidents, as they impose a safe distance between ships and shoreline. This, in turn, protects habitat from an HFO spill caused by grounding and provides additional time to mount a response to maritime emergencies. However, routing measures and ATBAs, although extremely useful in the mitigation of HFO spills, do not directly address the impacts of emissions from ships.

Designation of a Particularly Sensitive Sea Area/Areas

The designation of one or more Arctic particularly sensitive sea areas (PSSA) could be another option for mitigating the risk of carriage of HFO as cargo in the Arctic. A PSSA could include a suite of other protection measures such as ATBAs, ship routing schemes, mandatory reporting for vessels carrying HFO cargoes, mandatory no anchoring areas to further address the risk of an HFO spill in specific areas, identification of places of refuge, and/or restrictions or controls on emissions. For example, the Western European Waters PSSA requires mandatory reporting for single hull tankers carrying heavy grades of fuel oil.

Alternatively, a network of smaller Arctic PSSAs could be established to protect key habitat areas, each including a ban on use of HFO as part of its association protective measures. While this approach would be less comprehensive, it could allow for more tailored approach to each location. AMAP has identified a total of 97 areas, within the AMAP definition of the Arctic, that meet the established criteria for a PSSA, including critical habitat for marine mammals such as the beluga whale.[9] A network of Arctic PSSAs could also include portions of the Arctic High Seas. A 2011 report produced for the Arctic Council recommended that a core “sea ice area” of habitat could be protected under this approach.[10]

However, there are also drawbacks to addressing the risks of HFO use through PSSA designation. While protective measures can offer a suite of management measures to address multiple shipping impacts, enforcement of specific protective measures can lag behind the designation of a PSSA.[11]

[1] Bryan Comer et al., Heavy Fuel Oil Use in Arctic Shipping in 2015, International Council of Clean Transportation, 1 (2016).

[2] Arctic Monitoring and Assessment Programme (AMAP), Summary for Policy-Makers: Arctic Climate Issues 2015, Short-lived Climate Pollutants, at 7 (2015).

[3] U.S. Environmental Protection Agency,  Report to Congress on Black Carbon, at 177 (2012).

[4] Lack, D. A. and Corbett, J. J., Black Carbon from Ships: A Review of the Effects of Ship Speed, Fuel Quality and Exhuast Gas Scrubbing, 12 Atmos. Chem. Phys. 9, 3985-4000 (2012).

[5] Azzara, A., Minjares, R., and Rutherford, D., Needs and Opportunities to Reduce Black Carbon Emissions 
from Maritime Shipping, International Council on Clean Transportation (2015).

[6] Arctic Monitoring and Assessment Programme (AMAP), Black carbon and ozone as Arctic climate forcers (2015).

[7] International Maritime Organization, Ships’ Routeing (2013).

[8] International Maritime Organization, Routing Measures Other Than Traffic Separation Schemes,SN.1/Circ.331 (2015), available at: file:///Users/lianajames/Downloads/sn.1-circ.331%20-%20routeing%20measures%20other%20than%20traffic%20separation%20schemes%20(secretariat).pdf

[9] Arctic Monitoring and Assessment Programme (AMAP), Identification of Arctic marine areas of heightened ecological and cultural significance: Arctic Marine Shipping Assessment (AMSA) IIC (2013).

[10] Det Norske Veritas, Heavy fuel in the Arctic (Phase 2), No./Report No.: 2013-1542-16G8ZQC-5/1, at 33 (2013).

[11] Guan, S., Vessel-Source Pollution Prevention in Particularly Sensitive Sea Areas, Water Resource and Environmental Protection (2011).

Yes. Many ships can switch easily and immediately to using distillate fuels without significant alterations to the ship. Not only can engines that use HFO burn distillate fuel, but this shift would also allow for the possibility of installing efficient particulate filters, which can dramatically reduce black carbon emissions (by over 90%).

In addition, more and more ships, including container ships and cruise ships, are being built to run on liquefied natural gas (LNG), which produces approximately 25% less carbon dioxide (CO2) emissions than conventional marine fuels such as HFO. However, LNG also produces significant amounts of methane, a potent climate forcer that traps 86 times more heat in the atmosphere than the same amount of CO2 over a 20-year time period [1]. For this reason, there are substantial concerns that a shift to LNG will not reduce the shipping sectors impact on the global climate and on the Arctic.

Overall it is likely that future fuel/propulsion power sources for Arctic shipping will consist of a mix of fuel types and power sources. Ultimately it is critical that the shipping sector transition away from fossil fuels. Likely future fuels for shipping include ammonia, hydrogen, along with electric propulsion for smaller vessels [2].

[1] International Council on Clean Transportation, The climate implications of using LNG as a marine fuel, Jan 28, 2020  https://theicct.org/publications/climate-impacts-LNG-marine-fuel-2020

[2] Transport and Environment: Beyond Fossil Fuels: The Case for the Arctic, October 2017

https://www.hfofreearctic.org/wp-content/uploads/2020/02/Beyond-fossil-fuels-in-the-Arctic_TE.pdf

Yes, Hurtigruten, a Norwegian cruise line, and Arctia, a Finnish state-owned company responsible for operating a Finnish icebreaker fleet, support a ban on the carriage and use of HFO as fuel in Arctic waters.^[1]  In addition, the Association of Arctic Expedition Cruise Operators (AECO) has confirmed its support for a ban on the carriage and use of HFO as fuel in the Arctic.

There are also a number of industry associations, including Danish Shipping and the Norwegian Shipowners Association, that support a ban on just the use of HFO as fuel in the Arctic. This means that although ships would be prohibited from burning HFO as fuel when transiting Arctic waters, ships could continue to carry HFO as bunkers for use as fuel outside of Arctic waters. While this type of restriction would substantially help reducing some of the harmful emissions associated with burning HFO, it would have a very limited effect on the risk of an HFO spill. For this reason, the Clean Arctic Alliance believes that this level of support simply does not go far enough. The Clean Arctic Coalition will continue to identify other shipping and cargo companies that choose not to use HFO in the Arctic and support the use and carriage ban of HFO as fuel in Arctic waters.

^[1] See Thomas Nilsen, Hurtigruten CEO Calls for a Size Limit on Arctic Cruises,” The Independent Barents Observer, (August 22, 2016), available at: http://thebarentsobserver.com/en/2016/08/hurtigruten-ceo-encourages-limit-size-arctic-cruise-vessels; and Ship & Bunker, Duel-Duel Icebreakers Polaris Enters Service in Finland (November 3, 2016), available at: http://shipandbunker.com/news/world/272494-dual-fuel-icebreaker-polaris-enters-service-in-finland

 

Yes. Several counties have spoken out in favor of a phase out of the use of HFO in the Arctic. Just recently at the Arctic Circle Assembly 2017, Finland’s Minister for Foreign Trade confirmed that a ban on HFO in the Arctic was the top priority for Finland while they Chair the Arctic Council. Venstre, the Danish Liberal Party, has previously announced its support for a ban on the use of HFO in the Arctic, while Norway, Sweden, France, Germany and the Netherlands have indicated support for an HFO phase out in the Arctic for a number of years. Finally, at the International Maritime Organization’s (IMO) Marine Environment Protection Committee (MEPC 71), the Czech Republic, Denmark, Estonia, France, Poland, Russia, Singapore, Spain and Sweden supported a proposal by Canada, Finland, Germany, Iceland, the Netherlands, Norway and the U.S. calling for work to begin on mitigating the risks of use and carriage of heavy fuel oil (HFO) as fuel by ships in the Arctic.

While it is possible for Arctic nations to individually phase out the use of HFO in their national waters, or even to agree to a regional phase-out by their own flagged ships, a comprehensive phase out on the use of HFO, that would have to be applied by all international shipping, must come from the International Maritime Organization (IMO), a specialized agency within the United Nations body responsible for improving maritime safety and preventing pollution from ships.

In July of 2017, the International Maritime Organization’s (IMO) Marine Environmental Protection Committee (MEPC), accepted a proposal submitted by Canada, Finland, Germany, Iceland, the Netherlands, Norway and the United States to begin work on mitigating the risks of the use and carriage of HFO as fuel by ships in the Arctic.

Now that the IMO is formally considering this important issue, the IMO has requested that interested member states submit concrete proposals for measures to reduce the risks of HFO to the upcoming MEPC meeting in April of 2018. Over the course of the next two years, IMO member states will thoroughly consider the issue and ultimately reach a decision on how best to mitigate the risks associated with the use of HFO in the Arctic.

The CAA will be attendance at all upcoming IMO meetings in which the use of HFO in the Arctic is considered and will strongly advocate for a ban of the use and carriage of HFO as fuel in Arctic waters.

 

Any phase out of the use of HFO as marine fuel in the Arctic on the international level would require an amendment to the International Convention for the Prevention of Pollution from Ships (MARPOL), which is the primary international law covering the prevention of pollution of the marine environment by ships. Agreed measures are then incorporated into domestic law.

Phasing out the use of HFO as marine fuel in Arctic waters can be most easily accomplished by amending MARPOL Annex I, which sets forth regulations that are designed to minimize pollution from ships. Currently, MARPOL Annex I, Regulation 43 prohibits the carriage of HFO in bulk as cargo or ballast and the carriage and use of HFO as fuel in the Antarctic. The International Maritime Organization could adopt a similar amendment to MARPOL Annex I prohibiting the use of HFO as marine fuel in the Arctic.