Dear Director-General Hololei,
Thank you for your note of 02 August responding to our earlier correspondence on ships’ black carbon emissions impacting the Arctic. As mentioned in my acknowledgement of 12 August, I would like to discuss further some of the comments concerning black carbon (BC) in future EU measures and am attaching a Clean Arctic Alliance note setting out our thinking on these issues.
As you will be aware, the Arctic is facing a severe crisis and the EU’s commitment to lead on zero emission Arctic shipping requires that action be taken immediately. The IMO committed to address the impact on the Arctic of ship BC emissions 12 years ago but has yet to produce any concrete regulations that will result in a reduction in these emissions. IMO’s Resolution MEPC 77 243 from last November calling for a voluntary switch to distillates was the first tangible step, and it is now imperative that this be converted into mandatory action at both IMO and EU level for BC emissions to be reduced across all shipping impacting the Arctic.
The Clean Arctic Alliance believes that the EU Fit for 55 package can be strengthened through the co-decision process in ways that ensure that the transition to cleaner fuels includes action in the first instance to address both HFO use and BC emissions. In the attached note, we highlight several opportunities for the EU/EC to take the lead both internationally and regionally on Arctic ship pollution as committed to in last October’s Communication (JOIN (2021) 27 final.
We would welcome the opportunity to discuss these issues in greater depth and as you suggested, I have contacted the members of the D1 team proposing that we meet in Brussels this month. We have a provisional date identified, so I am copying this note to Mr Oscislowski and Mr Batista, and to Ms Kopczynska. We will also be raising the issues in the attached note with the Climate, Environment and External Action Directorates.
Dr Sian Prior
Clean Arctic Alliance