IMO sets clear pathway for future black carbon regulation

The Clean Arctic Alliance today welcomed progress by the International Maritime Organization’s Marine Environment Protection Committee (IMO, MEPC 82) towards regulation of black carbon emissions from Arctic shipping, but lamented the UN body’s “kicking down the road” any decision regarding rules for scrubber use in the region.

“With the IMO finally looking set to regulate black carbon emissions from black carbon - which will greatly lower the impact of the shipping sector on Arctic sea and glaciers - member states must now agree on which fuels are appropriate for use in the Arctic, so that robust rules can be put in place”, said Dr Sian Prior, Lead Advisor to the Clean Arctic Alliance.

“Many countries made clear their increased and wide-spread support for the regulation of black carbon emissions during MEPC 82, however their challenge now is to agree how best to ban the use of unsuitable highly polluting fuels, e.g. residual fuels currently being used in the Arctic which produce high levels of black carbon - especially as global shipping seeks to decarbonize - and draft an IMO regulation for adoption”, she added.

Note: residual fuels are fuels derived from the leftovers of refinery process, including bunker fuels such as heavy fuel oil. They can only be used today in association with a scrubber, but are also blended with lighter fuels to form fuels low in sulphur but which still produce high levels of black carbon. See more about black carbon below.

Emission Control Areas
During MEPC 82, IMO member states adopted final amendments for regulations designating Canadian Arctic waters and the Norwegian Sea as emission control areas - sea areas with stricter controls on fuel use and pollution from shipping. Both ECAs will limit air pollutants of SOx, NOx and Particulate Matter with the co-benefit of reducing associated black carbon emissions, encouraging shipping operators to switch to using cleaner fuel. In addition, Portugal presented the results of environmental and socio-economic studies which provide the necessary arguments for designating another ECA which could stretch from Portuguese waters in the south to the coast of Greenland in the north, which is anticipated to come forward in 2025.

“We welcome the adoption of new Emission Control Areas (ECAs) in Canada’s Arctic waters and the Norwegian Sea, and we now look forward to a new proposal for an Atlantic ECA which would bring further reductions in NOx, SOx, and particulate matter being submitted for approval in early 2025”, said Carolina Silva, Shipping Policy Officer at ZERO. “It is paramount to keep the momentum around Emission Control Areas as effective tools to curb these harmful emissions from shipping, including black carbon, in particularly sensitive areas and regions such as the Arctic.”

“We are pleased to see the full engagement of all north Atlantic countries and territories in the process, from Portugal to Iceland and Greenland, and to see that everything is on schedule for a new proposal next year. We hope for a cleaner and colder Arctic as soon as possible", added Kåre Press-Kristensen from Green Global Future.

“Now we need the US to follow Norway and Canada’s lead and create an Arctic ECA in its Alaskan waters”, said Andrew Dumbrille, North American Advisor to the Clean Arctic Alliance. “This would create a North American wide ECA to fully protect these waters from the impacts of climate pollutants such as black carbon. What’s ultimately needed is an Arctic wide ECA, across all Arctic states, to comprehensively reduce air pollution for the entire Arctic.”

• Infographic: Emission Control Areas – Reducing Air Pollution From Shipping
• MEPC 81/11: Proposal to designate Canadian Arctic waters as an emission control area for nitrogen oxides, sulphur oxides and particulate matter
• MEPC 81/11/1: Proposal to designate the Norwegian Sea as an Emission Control Area for Nitrogen Oxide

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Scrubbers:
Unlike the progress made on black carbon and emission control areas, during MEPC 82 the IMO failed to deliver progress on the international regulation of scrubbers or scrubber discharges. Scientists recently announced that we have passed the planetary boundary for ocean acidification and the Arctic is acidifying faster than the global ocean, yet all discussion was yet again postponed, with further consideration of the use of scrubbers and regulation of discharge water from scrubbers now tabled for 2025.

The consequence is that worldwide, around 5000 ships will continue pumping over ten gigatons of acidic and toxic scrubber water into the ocean, including into protected areas and critical wildlife habitats.

“The IMO’s lack of action on scrubbers is frustrating - fortunately some governments and ports have recently taken action to ban the discharge of scrubber waste in their coastal and port waters, including most recently Sweden and Denmark”, said Eelco Leemans, Clean Arctic Alliance Technical Advisor. “But we need action to ban the dumping of scrubber waste in important wildlife habitats and marine protected areas, and a total ban on the use of scrubbers in the Arctic.”

• Infographic: Why We Need to Ban Scrubbers on Ships & Why the Use of Scrubbers to Limit Air Pollution is Flawed
• Op-ed on Scrubbers: The shipping industry’s greenwashing deception
• MEPC 82/5: Legal analysis on exhaust gas cleaning systems as an alternative compliance mechanism under MARPOL Annex VI from an air quality impact perspective
• MEPC 82/5/4: Air Pollution Prevention: EGCS pollution in Pacific Canada: investigation of Canada

Carbon Intensity Indicator
“It is essential that IMO member states embrace ambitious climate action and properly resource and pick up the pace of negotiations if the IMO is to ensure that shipping’s climate pollution peaks and reduces in line with its 2023 GHG strategy, thus curbing the sector’s contribution to the worst impacts of climate breakdown and the Arctic climate crisis”, said Prior.

“The Clean Arctic Alliance is concerned at the lack of urgency around strengthening the IMO’s energy efficiency measure. Failure to maximise the efficiency of the shipping sector immediately through a strengthened carbon intensity indicator (CII) threatens the IMO’s goal of cutting emissions by 30% by 2030.

Infographic: Why the IMO and international shipping needs a strong revised Carbon Intensity Indicator (CII)

Underwater Noise:
With respect to addressing the impact of underwater noise from shipping, there was good progress. A proposed Action Plan was agreed and an experience building phase (EBP) based on the revised IMO guidelines adopted last year is on track to build knowledge and set the foundation for potential mandatory measures in the future.

Infographic: Underwater Noise From Ships

Biodiversity crisis:
This week the IMO also endorsed the Kunming-Montreal Global Biodiversity Framework (GBF). The GBF is a landmark agreement that was adopted in December 2022 to reverse biodiversity loss. CAA is proposing a high level task force be created which would elevate the global threats of biodiversity loss and marine pollution to the same level of urgency as climate heating. The task force would be charged with creating a co-benefits action plan to make urgent progress on addressing shipping’s contribution to the triple planetary crisis.

About Black Carbon and the Arctic
In a paper submitted to the meeting (MEPC 82/5/2*: Regulating Black Carbon emissions from international shipping impacting the Arctic) NGOs called on IMO Member States to consider the development of a new regulation for inclusion in MARPOL Annex VI (the main international treaty addressing air pollution prevention requirements from ships) which would identify suitable polar fuels, for example distillate fuels, such DMA or DMZ, to deliver an immediate fuel-based reduction in black carbon emissions from international shipping impacting the Arctic. The paper develops the concept of "polar fuels" discussed at PPR 11 and sets out the fuel characteristics that would distinguish polar fuels from residual fuels and thus lead to fuel-based reductions in ship Black Carbon emissions if mandated for use in and near the Arctic.

Black carbon 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. Not only does it contribute to warming while in the atmosphere, black carbon accelerates melting if deposited onto snow and ice – hence it has a disproportionate impact when released in and near to the Arctic.

The melting snow and ice exposes darker areas of land and water and these dark patches then absorb further heat from the sun and the reflective capacity of the planet’s polar ice caps is severely reduced. More heat in the polar systems – results in increased melting. This is the loss of the albedo effect.

Declines in sea ice extent and volume are leading to a burgeoning social and environmental crisis in the Arctic, while cascading changes are impacting global climate and ocean circulation. Scientists have high confidence that processes are nearing points beyond which rapid and irreversible changes on the scale of multiple human generations are possible. Scientists say it is now too late to save summer Arctic sea ice, and research has shown that “preparations need to be made for the increased extreme weather across the northern hemisphere that is likely to occur as a result.”

Black carbon also has a negative impact on human health, and recent research has found black carbon particles in the body tissues of foetuses, following inhalation by pregnant mothers.

The need to reduce emissions of black carbon because of both the climate and health impacts has been long recognized. On land, considerable effort has been made to ban dirtier fuels in power stations, to install diesel particulate filters on land-based transport, and to improve the burning of dry wood – all to reduce emissions of black carbon and improve air quality. However, at sea the same efforts have not yet been made.