Environmental Permitting

EPA and USCG Flexible on Ship Emissions Options

These new technologies are required for ships covered by the International Marine Organization’s (IMO) amended regulations known as Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL), which designated specified “portions of U.S., Canadian and French waters as an Emission Control Area (ECA).” In the United States, the ECA and Annex VI are implemented via regulations adopted under the Act to Prevent Pollution from Ships (APPS).

The goal of the ECA is to reduce ships’ emissions of nitrogen oxides (NOx), sulfur oxides (SOx), and fine particulate matter (PM-2.5) in coastal waters of North America. According to the EPA, by 2020, compliance with the ECA will reduce NOx emissions by 320,000 tons (23 percent), SOx by 920,000 tons (86 percent), and PM-2.5 by 90,000 tons (74 percent). Without the ECA emissions limits, the EPA estimated that by 2030, “NOx emissions would more than double … while annual PM-2.5 emissions would be expected to almost triple…” The North American ECA “extends up to 200 nautical miles from coasts of the United States, Canada and the French territories,” including portions of Alaska, Hawaii, and the U.S. Caribbean.

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In a letter to one of the world’s largest vacation cruise lines, the EPA and the USCG reached an agreement in principle concerning the company’s proposal for a trial program that will “exempt 32 (of its) ships from the fuel sulfur requirements of the North American ECAs,” which mandate that ships use more costly lower-sulfur fuel (1,000 ppm), or, as an alternative, “equip their vessels with exhaust gas cleaning devices (“scrubbers”)” to remove sulfur emissions.

The cruise line’s trial program will develop and install scrubber systems “that will meet or exceed sulfur emission levels” on 32 of its vessels operating in the North American ECA. According to the EPA, the new emissions control systems will “combine the use of SOx scrubbers with diesel particulate filters–thus combining technologies well known in the power plant and automotive sectors, but not previously used  on a marine vessel.”

The trial program will run in phases and will be performed in dry dock beginning with 9 ships in 2014, 16 ships in 2015, and 7 ships in 2016. In addition, during the exemption period, the company will use “shore power or marine gas oil with a fuel content no greater than 0.1 percent” while at berth.

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The costs to industry for meeting the lower emissions requirements under the ECA will be “on par” with similar costs for land-based sources, according to the EPA. “We estimate the total costs of improving the emissions of ships operating in the ECA from current performance (2010) to ECA standards will be approximately $3.2 billion in 2020.” The EPA estimates economic impacts of compliance to be “modest,” with an increase of approximately 3 percent (or about $18 for a 20-foot container) for a vessel operating in the ECA on a route of 1,700 miles.

The EPA anticipates significant health and welfare benefits resulting from the lower emissions to include improved air quality in coastal zones as well as “hundreds of miles inland  to reach nonattainment areas such as Nevada, Tennessee and Pennsylvania.” Moreover, the EPA concludes that improved air quality will result in “preventing between 5,000 and 14,000 premature deaths, 3,800 emergency room visits, and 4,900,000 cases of acute respiratory symptoms in 2020.”

The EPA and the USCG will continue discussions with other marine companies to develop similar technologies within the flexibility established by the North American ECA and MARPOL Appendix VI.

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