Clean Arctic Alliance response
to draft law on amendments to the Environmental Protection Act on Svalbard 15 June 2001 no. 79 (Svalbard Environment Act)
The Clean Arctic Alliance (CAA) is a coalition of 21 not-for-profit organizations (including Norwegian NGOs Bellona and WWF-Norway), based in Arctic and Arctic-observer countries, with a demonstrable interest in the conservation of Arctic ecosystems, communities and wildlife and committed to securing a clean Arctic. The Clean Arctic Alliance’s “HFO Free Arctic” campaign is focused on delivering a ban on the use and carriage of heavy fuel oil (HFO) as fuel for ships operating in Arctic waters. This campaign is increasingly positioned within the wider climate crisis discussion regarding the importance of reducing black carbon emissions from shipping affecting the Arctic, as well as reducing the likelihood of a devastating HFO spill. The Alliance also advocates on related issues such as the use of scrubbers to reduce sulphur oxide (SOx) emissions from Arctic shipping and other impacts of ships operating in the Arctic, for example, underwater noise.
The Clean Arctic Alliance wishes to respond to the element of the draft law on amendments to the Environmental Protection Act on Svalbard 15 June 2001 that addresses the proposal for a ban on the use of heavy oil in the territorial waters of Svalbard.
As a first step towards alternative non-fossil fuels and propulsion systems, the Clean Arctic Alliance welcomes the Ministry of Climate and Environment’s proposals for amendments to section 82 of the Svalbard Environment Act to prohibit the use of petroleum-based fuels, by maritime traffic other than natural gas or marine gas oil throughout Svalbard’s territorial waters. The Clean Arctic Alliance notes that this amendment will not only eliminate the risks associated with a spill of HFO in Svalbard’s territorial waters, but it will also result in a reduction in black carbon emissions benefitting both the local communities on Svalbard and also reducing shipping-sourced black carbon impacts in the Arctic.
In February 2018, Norway along with seven other International Maritime Organization (IMO) Member States submitted a proposal for an Arctic-wide heavy fuel oil use and carriage ban, recognising that “a single HFO spill could have devastating and lasting effects on fragile Arctic marine and coastal environments. In addition, Arctic shipping is projected to continue to rise, thus increasing the risk of a spill. For these reasons, the ban on HFO should be implemented as soon as possible, and any delay in implementation of the ban by eligible ships should be short-lived.”
Yet, in November 2020, the IMO Marine Environment Protection Committee approved a draft text for the Arctic HFO regulation which will not be fully effective for close to a decade. If adopted later this year, this regulation will only start to prohibit the use and carriage of HFO as fuel in July 2024, yet because it includes exemptions for ships with protected fuel tanks and waivers for Arctic coastal state flagged vessels, most ships will be able to continue to carry and use HFO until July 2029.
The Clean Arctic Alliance is disappointed that the decision by IMO Members, to approve a draft Arctic HFO Regulation including exemptions for vessels with protected fuel tanks and the possibility of waivers, means that not only will HFO continue to be used and carried on board ships in the Arctic throughout the 2020s but that the levels of HFO being used and carried are likely to continue to rise as they have in recent years. This means that the amount of HFO used and carried on an annual basis, ahead of the ban becoming fully effective, will likely be greater than the amount in use today or in 2024. when the Arctic HFO ban takes effect.
The Clean Arctic Alliance commends Norway’s leadership in consulting on a proposal for a comprehensive ban on HFO use in the territorial waters of Svalbard.
Clean Arctic Alliance
E: sian.prior@HFOFreeArctic.org
www.HFOFreeArctic.org
The Clean Arctic Alliance: 90 North Unit | The Altai Project | Alaska Wilderness League | Bellona | Clean Air Task Force | Green Transition Denmark | ECODES |Environmental Investigation Agency | European Climate Foundation | Friends of the Earth US | Greenpeace | Icelandic Nature Conservation Association | International Cryosphere Climate Initiative | Nature And Biodiversity Conservation Union | Ocean Conservancy | Pacific Environment | Seas At Risk | Stand.earth | Surfrider Foundation Europe | Transport & Environment | WWF
Campaigning to ban heavy fuel oil (HFO) from Arctic shipping www.HFOfrearctic.org
to draft law on amendments to the Environmental Protection Act on Svalbard 15 June 2001 no. 79 (Svalbard Environment Act)
The Clean Arctic Alliance (CAA) is a coalition of 21 not-for-profit organizations (including Norwegian NGOs Bellona and WWF-Norway), based in Arctic and Arctic-observer countries, with a demonstrable interest in the conservation of Arctic ecosystems, communities and wildlife and committed to securing a clean Arctic. The Clean Arctic Alliance’s “HFO Free Arctic” campaign is focused on delivering a ban on the use and carriage of heavy fuel oil (HFO) as fuel for ships operating in Arctic waters. This campaign is increasingly positioned within the wider climate crisis discussion regarding the importance of reducing black carbon emissions from shipping affecting the Arctic, as well as reducing the likelihood of a devastating HFO spill. The Alliance also advocates on related issues such as the use of scrubbers to reduce sulphur oxide (SOx) emissions from Arctic shipping and other impacts of ships operating in the Arctic, for example, underwater noise.
The Clean Arctic Alliance wishes to respond to the element of the draft law on amendments to the Environmental Protection Act on Svalbard 15 June 2001 that addresses the proposal for a ban on the use of heavy oil in the territorial waters of Svalbard.
As a first step towards alternative non-fossil fuels and propulsion systems, the Clean Arctic Alliance welcomes the Ministry of Climate and Environment’s proposals for amendments to section 82 of the Svalbard Environment Act to prohibit the use of petroleum-based fuels, by maritime traffic other than natural gas or marine gas oil throughout Svalbard’s territorial waters. The Clean Arctic Alliance notes that this amendment will not only eliminate the risks associated with a spill of HFO in Svalbard’s territorial waters, but it will also result in a reduction in black carbon emissions benefitting both the local communities on Svalbard and also reducing shipping-sourced black carbon impacts in the Arctic.
In February 2018, Norway along with seven other International Maritime Organization (IMO) Member States submitted a proposal for an Arctic-wide heavy fuel oil use and carriage ban, recognising that “a single HFO spill could have devastating and lasting effects on fragile Arctic marine and coastal environments. In addition, Arctic shipping is projected to continue to rise, thus increasing the risk of a spill. For these reasons, the ban on HFO should be implemented as soon as possible, and any delay in implementation of the ban by eligible ships should be short-lived.”
Yet, in November 2020, the IMO Marine Environment Protection Committee approved a draft text for the Arctic HFO regulation which will not be fully effective for close to a decade. If adopted later this year, this regulation will only start to prohibit the use and carriage of HFO as fuel in July 2024, yet because it includes exemptions for ships with protected fuel tanks and waivers for Arctic coastal state flagged vessels, most ships will be able to continue to carry and use HFO until July 2029.
The Clean Arctic Alliance is disappointed that the decision by IMO Members, to approve a draft Arctic HFO Regulation including exemptions for vessels with protected fuel tanks and the possibility of waivers, means that not only will HFO continue to be used and carried on board ships in the Arctic throughout the 2020s but that the levels of HFO being used and carried are likely to continue to rise as they have in recent years. This means that the amount of HFO used and carried on an annual basis, ahead of the ban becoming fully effective, will likely be greater than the amount in use today or in 2024. when the Arctic HFO ban takes effect.
The Clean Arctic Alliance commends Norway’s leadership in consulting on a proposal for a comprehensive ban on HFO use in the territorial waters of Svalbard.
Clean Arctic Alliance
E: sian.prior@HFOFreeArctic.org
www.HFOFreeArctic.org
The Clean Arctic Alliance: 90 North Unit | The Altai Project | Alaska Wilderness League | Bellona | Clean Air Task Force | Green Transition Denmark | ECODES |Environmental Investigation Agency | European Climate Foundation | Friends of the Earth US | Greenpeace | Icelandic Nature Conservation Association | International Cryosphere Climate Initiative | Nature And Biodiversity Conservation Union | Ocean Conservancy | Pacific Environment | Seas At Risk | Stand.earth | Surfrider Foundation Europe | Transport & Environment | WWF
Campaigning to ban heavy fuel oil (HFO) from Arctic shipping www.HFOfrearctic.org