Submitted by FOEI, WWF, Pacific Environment and CSC
This document draws attention to the likelihood that only 30 per cent of the heavy fuel oil (HFO) being carried in Arctic waters and 16 per cent of the HFO being used in Arctic waters will be prohibited from 1 July 2024 when the provisions of MARPOL Annex I regulation 43A take effect. The limited impact of the prohibition on the use and carriage of HFO is highlighted as being due to exemptions which would apply to 22 per cent of ships and the opportunity for Arctic coastal nations to issue waivers to up to 53 per cent of ships operating in the Arctic (based on 2019 Arctic shipping patterns). It proposes that regulation 43A be amended to increase its effectiveness in protecting the Arctic from HFO.