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. 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, 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, 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. 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.
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, 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, 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.” 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. 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.
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.
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