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Documenting our Progress

International Maritime Organization (IMO) Position Paper

Inuit Circumpolar Council (ICC) – version November 22, 2023

The International Maritime Organization (IMO) is a United Nations agency responsible for regulating international shipping. It serves as the foundation for global shipping rules and has 175 member states, 66 Intergovernmental Organizations (IGOs), and 85 Non-Governmental Organizations (NGOs).Shipping is a global business that crosses state waters and because of this the IMO aims to provide a regulatory level playing field for vessel rules and operations. To ensure comprehensive shipping rules in state waters, states often advocate for global rules at the IMO. Participation at the IMO is essential for achieving state safety and environmental protection goals.The United Nations Convention of the Law of the Sea (UNCLOS) mandates that state pollution regulations cannot be lower than IMO regulations. UNCLOS also designates jurisdiction over state waters: 12 nautical miles being the state territorial sea with a high degree of state control and a 200 nautical miles exclusive economic zone where states have reduced jurisdiction.Within this global shipping regulatory framework is the UN Declaration of the Rights of Indigenous Peoples and the sovereignty, land claims, harvest rights, and self-determination of Inuit. A permanent Inuit voice at the IMO is essential to ensure Inuit rights are respected and maintained into the future, and that Inuit are able to influence ongoing rule setting to safeguard their waters and embed Inuit rights.

Inuit rely on marine wildlife for their physical sustenance and culture and in turn, they are the stewards of the Arctic marine environment and dependent on ensuring its long-term health and sustainability. Inuit cultural practices are inextricably linked to the sea, sea ice and coastlines of Inuit Nunaat, the Inuit homeland, and from this link arises the foundational existence of Indigenous Knowledge and values. Thus the importance of safeguarding the Arctic marine region, which maintains culture, knowledge and values, and the future of Inuit. Therefore, Inuit must be central to all decision-making and governance regarding the Arctic Ocean, from the community level to the United Nations. This includes ICC work at the IMO. ICC envisions a future of progress and equity within the maritime industry, guided by Indigenous Knowledge and critical goals and timelines.

Our Aspirations

ICC Full Consultative Status by 2025^[1]

In November 2021, ICC received provisional NGO consultative status at the IMO becoming the first Indigenous Peoples organization to have been granted such status. In the summer of 2023, the IMO Council reviewed this provisional status and renewed it for two more years. ICC is now working strategically to ensure permanent status in 2025. The IMO’s decisions have a significant impact on shipping in and around Inuit communities^[2]. Having an Inuit voice at the IMO table ensures that Inuit rights are represented and listened to. Looking ahead to 2030, the goal is to see multiple Indigenous Peoples and groups attaining full observer status at the IMO. This will empower all Indigenous Peoples to contribute their invaluable perspectives and insights towards the decision-making process and holistic marine governance.

Ensure the Utilization of Indigenous Knowledge, and Implementation of UNDRIP

Inuit Circumpolar Council has a vision that Indigenous Knowledge^[3] is utilized in all areas of IMO’s work by 2030. This will be supported by a strategy for implementing the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). The success of this vision has already been demonstrated as the revised underwater noise reduction guidelines for ships now include specific mention of operating conditions in Inuit Nunaat and the need to account for and include Indigenous Knowledge. Additionally, a special communication on reducing underwater noise in Inuit Nunaat waters was sent to all IMO members in the fall of 2023 (MEPC.1-CIRC.907). ICC played a crucial role in making this happen and will use this success to leverage similar changes throughout IMO conventions and regulations such as the Polar Code. The Polar Code, which Inuit were not originally engaged in, is an IMO set of regulations which covers design, construction, equipment, operations, training, search and rescue and environmental protection relevant to ships operating in polar waters. The revision of the Polar Code^[4] is envisioned to be a key IMO instrument to more comprehensively include Inuit perspectives, Indigenous Knowledge, its boundaries including all of Inuit Nunaat, and updated Arctic ecosystem safeguards and safety standards.

GHG reduction strategy anchored in an Equitable Transition Framework placing Indigenous Peoples at its heart

ICC is committed to supporting a fully decarbonized shipping sector^[5] and a greenhouse gas (GHG) reduction strategy that is based on an Equitable Transition Framework. This framework must prioritize the needs of Small Island Developing States (SIDS), Least Developed Countries (LDCs), and Indigenous Peoples, and include financial support to help these nations transition to more sustainable and low carbon economies. ICC’s goal is to support a significant 50% reduction in GHG emissions by 2030 and full decarbonization of the shipping sector by 2040. To achieve this, ICC proposes integrating wind propulsion into the majority of new ship constructions and advocating for energy efficiency improvements which rapidly reduce emissions. ICC also emphasizes the importance of complying with the ban on heavy fuel oil (HFO) by 2024, with a global ban in place by 2030. Lastly, ICC envisions by 2030 an elimination of black carbon^[6] from shipping, a type of particulate matter that is emitted in the exhaust of engines. This particulate matter is known to speed up the melting of ice and snow when deposited on their surfaces. Additionally, the particles absorb heat and sunlight, which warms up the air surrounding the area where the emissions occur and acidifies the ocean as its deposits accumulate in the ocean floor.

Eliminate scrubber and greywater pollution^[7] entirely by 2030, focusing on halving underwater radiated noise by the same year, prioritizing the Arctic region

Eliminating the use of scrubbers on ships, which discharge harmful and toxic effluent^[8] into the ocean, is crucial for Inuit health and food security. Pollution from shipping can affect ocean biodiversity and risk damaging important resources for Inuit.

ICC envisions halving underwater radiated noise (URN) by 2030 from ships, with a particular emphasis on the Arctic region. URN is acoustic pollution from ships which interferes with the communication, foraging, and reproduction of wildlife on which many Inuit communities depend. Additionally, ICC recognizes the positive impact of speed reduction on noise and GHG emissions. By reducing the speed of ships worldwide, an impressive 50% reduction in GHG emissions can be achieved, as well as reductions in underwater noise and the risk of vessel whale strikes.

Finally, phasing out liquefied natural gas (LNG) as a marine fuel is needed as quickly and intentionally as possible. LNG is a significant source of methane, which makes it an undesirable option for the maritime industry, especially in the Arctic region where the impacts of global warming are more pronounced.

Avoiding areas significant to Inuit use and mandatory measures to prevent the introduction of invasive species are key steps in minimizing shipping impact in Inuit Nunaat

It is crucial to avoid ship transits^[9] in sensitive, significant, and Inuit use areas to minimize the impact in Inuit Nunaat. The IMO’s Navigation Communication Search and Rescue (NCSR) committee recommends routing guidelines that standardize global ship transits. States propose changes to this committee, and new routes are added to vessel voyage charts. Examples of such measures are the Bering Strait Traffic Separation Scheme (TSS), Areas to be Avoided (ATBAs), and speed restrictions in the Inuvialuit Settlement Region. There is potential for many similar measures throughout Inuit Nunaat, like the Low Impact Shipping Corridors initiative in Canada.

Vessels can quickly spread invasive species from one ocean area to another through ballast water discharges and hull fouling. Ballast water is the intake of fresh or seawater into an empty ship to maintain stability and discharged into the water to load cargo. Hull fouling is the attachment of species to a ship’s hull that come unattached in foreign seas. The Ballast Water Convention (BWC), which came into force in 2017, mandates vessels to remove species/pathogens before discharge, and all ships must have treatment in place by 2024. The hull fouling guidelines were updated in 2011 to remove species and use anti-clinging paint, and they are currently being revised at the IMO. To minimize the spread of species, updated hull fouling guidelines should be mandatory, and there should be regular testing and monitoring of ballast water treatment systems with penalties for non-compliance. The D2 (exchange and treatment) standard should be maintained. Additionally, Arctic-specific guidelines for both ballast water use, and treatment and hull fouling are needed.

Conclusion and Next Steps

With an agreed mandate and vision, ICC engagement at the IMO will seek to:

Secure permanent representation at the IMO in 2025
Ensure utilization of Indigenous Knowledge in all areas of the IMO’s work
Call for climate strategies anchored in an Equitable Transition Framework placing Indigenous Peoples at its heart
Work to eliminate sources of pollution including underwater radiated noise and black carbon, reduce the spread of invasive species, and advocate for ship transits to avoid Inuit use and sensitive areas in Inuit Nunaat

^[1] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 38

^[2] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 9

^[3] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 29

^[4] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 38

^[5]Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 24

^[6] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 32

^[7] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 38

^[8] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 38

^[9] Inuit Circumpolar Council 2022 Ilulissat Declaration paragraph 38

The Inuit Circumpolar Council (ICC) is an Indigenous Peoples’ Organization (IPO), founded in 1977 to promote and celebrate the unity of 180,000 Inuit from Alaska (USA), Canada, Greenland, and Chukotka (Russia). ICC works to promote Inuit rights, safeguard the Arctic environment, and protect and promote the Inuit way of life. In regard to climate change, we believe that it is crucial for world leaders and governments to recognize, respect and fully implement the human rights of Inuit and all other Indigenous peoples across the globe.