The International Council for the Exploration of the Sea (ICES), an impartial intergovernmental marine science organization whose purpose is to provide evidence on the state and sustainable use of the ocean, outlines many of these risks in documents MEPC 76/9/1 and MEPC 76/INF.5 (ICES). [...] In document MEPC 76/9/1, ICES recommends "…a complete transition to the use of cleaner low-sulphur fuels to avoid the use of scrubbers…" and provides facts to support this conclusion as follows: .1 "Scrubber discharge water is toxic to marine biota and has been shown to have lethal and sub-lethal effects on the marine zooplankton community"; .2 "Scrubbers discharge large amounts of metals and PAHs. [...] Document MEPC 79/5/3 (FOEI et al.) argues that the discharge of scrubber waste into the aquatic environment appears to be inconsistent with general and specific obligations of State Parties under the United Nations Convention on the Law of the Sea (UNCLOS), including those provided by Articles 192, 194, 195, 196, 211, 212 and 222. [...] Scrubber discharges also appear to be inconsistent with the body of international law which informs these articles, including the Convention on Biological Diversity, the United Nations Framework Convention on Climate Change (UNFCCC), and the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). [...] I:\MEPC\81\MEPC 81-5-4.docx MEPC 81/5/4 Page 4 Recommendations 11 On the basis of the information presented, the co-sponsors believe that scrubbers are not an acceptable alternative compliance method for regulation 14 of MARPOL Annex VI and urge the Committee to: .1 consider whether the use of scrubbers as an equivalent to low sulphur fuels is aligned with the duties outlined in regulation 4.4 of.
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