Submitted by FOEI, Greenpeace International, WWF, Pacific Environment and CSC
In response to document MEPC 75/10/Add.1, the co-sponsors raise concerns about the impact and effectiveness of the draft prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters. Recently published work indicates that only 30% of HFO carriage and 16% of HFO use would be banned when the regulation comes into effect, and that it is likely that the amount of HFO carried and used in the Arctic will increase following the ban taking effect. In addition, further concerns are expressed regarding the draft regulation and its impact on the Arctic environment. The co-sponsors invite the Committee to take into account the information provided and to consider modifying the proposed draft amendment to MARPOL Annex I (i.e. new draft regulation 43A) in order to approve a meaningful prohibition on the use and carriage for use as fuel of heavy fuel oil by ships in Arctic waters.
MEPC 75/10/7: Comments on document MEPC 75/10/Add.1, paragraph 3.5 on draft amendments to MARPOL Annex I to incorporate a prohibition on the use and carriage for use as fuel of heavy fuel oil by ships in Arctic waters