White paper

The International Maritime Organization’s proposed Arctic heavy fuel oil ban: Likely implications and opportunities for improvement

In February 2020, at the seventh session of the International Maritime Organization (IMO)’s Pollution Prevention and Response Sub-Committee, delegates agreed on draft text of a ban on the use and carriage for use of heavy fuel oil (HFO) in the Arctic. HFO is the bottom-of-the-barrel leftovers from the oil refining process, and the ban was spurred by a desire to protect the fragile Arctic region from the risk of HFO spills. The use and carriage of HFO has been banned in Antarctic waters since 2011.

While the ban would start to apply in July 2024, exemptions and waivers included in the draft text would allow some ships to use HFO until July 2029. To assess the impacts of these exemptions and waivers, the authors estimated how much HFO carriage, HFO use, and black carbon (BC) emissions would have been eliminated if the policy had been in place in 2019. This analysis assumed that all ships eligible for exemptions and waivers would use them, and that ships would not reflag or alter their routes to take advantage of the waivers clause. The analysis was based on 2019 terrestrial and satellite Automatic Identification System (AIS) data from exactEarth and ship technical characteristics information from IHS Markit.

Results show that the proposed ban would have eliminated only 30% of HFO carriage and 16% of HFO use in 2019, and this would have reduced BC emissions by only 5%, as shown in the bottom bar of the figure below. This is important because HFO use in the Arctic is increasing—it grew 75% between 2015 and 2019. As newer ships enter the Arctic fleet, especially oil tankers and bulk carriers, more ships will qualify for exemptions. Additionally, if ships reflag to Arctic states, more could qualify for waivers and the effectiveness of the ban would be further eroded.

Ahead of the 75th session of the IMO’s Marine Environment Protection Committee, which will be held virtually in November 2020, policymakers should consider how the proposal could be modified to ban a larger share of HFO carriage and use. For example, as the third row of the figure illustrates, doing away with exemptions and limiting waivers to internal waters (IW) and territorial seas (TS) would ban 70% of HFO carriage and 75% of HFO use, and would lower BC emissions by 22%. However, an HFO spill close to shore would result in larger direct impacts to Arctic coastlines and coastal communities. An HFO ban with no exemptions or waivers is the most protective.