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Rich Kassel’s Blog

EPA Finalizes Rule on Ship Pollution: A Welcome Holiday Gift for Clean Air

Rich Kassel

Posted December 22, 2009

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Back in August, I wrote about an EPA proposal to reduce ship emissions.  Today, EPA has finalized this rule.  Here’s my quick take on why this new rule is important, what it will mean once it’s implemented, and the key next steps on ship pollution to watch out for.

The rule will cover the largest, dirtiest diesels that power the ocean-going vessels (OGVs) at our ports, such as oil tankers, container-carrying cargo ships, and large cruise vessels (regulated as "Category 3" engines because of their size, i.e., those with per-cylinder displacement at or above 30 liters). 

This rule is a critical piece of a multi-part strategy to reduce ship pollution off our coasts and at our ports.  Due to the complexities of how ships are governed at the international level, this rule will only cover the U.S.-flagged ships at our ports and off our coasts.  But it’s a key step towards getting international approval of a comparable rule for all ships, U.S.- and foreign-flagged, at the March 2010 meeting of the International Maritime Organization (IMO) in London.

Here’s the background: 

Over the past few years, EPA joined with the Coast Guard, the State Department, and a diverse set of other governmental, industry and nongovernmental stakeholders (including NRDC) to advocate for a stronger global commitment to reducing ship emissions worldwide. 

It was the correct next step for an EPA that had aggressively targeted every other source of mobile diesel emissions over the past decade. (see, e.g., EPA’s rules for trucks and buses, farm, construction, and other nonroad diesel engines, and locomotives and marine-diesel engines).

In late 2008, this resulted in a new global pact to reduce ship emissions (for those readers interested in the minutiae, the agreement is codified in amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (a/k/a "MARPOL” in the shipping world)).  The new Annex VI amendments include a provision that allows individual countries to create special "Emission Control Areas" to accelerate the reduction of ship pollution off their coast lines. 

In March, the Obama administration proposed the creation of a joint US/Canada Emission Control Area (ECA) pursuant to this provision.  Under this ECA proposal, ships within 200 nautical miles of our coastlines will use fuel that has 98 percent less sulfur than in current OGV fuel, and will cut their smog-forming nitrogen oxides (NOx) emissions by 80 percent and their cancer-causing particulate soot (PM) emissions by 85 percent, starting in 2015.

This proposal is critically important because air pollution from large ships is expected to grow rapidly as port traffic increases.  By 2030, the ECA strategy is expected to reduce annual emissions of nitrogen oxides (NOx) from large marine diesel engines by about 1.2 million tons and particulate matter (PM) emissions by about 143,000 tons. Cutting those NOx and PM emissions by 80  and 85 percent, respectively, will be necessary for communities downwind of our ports and for states that are chronically battling dirty air.

The health benefits of these emissions reductions will be substantial.  In fact, EPA estimates that, by 2030, between 13,000 and 33,000 premature deaths and between $110 and $280 billion in health costs will be avoided annually.  As with all the other EPA diesel rules over the past decade, these benefits will far, far, far exceed the expected implementation costs—at a ratio of at least 30:1. 

Frankly, it is hard to find a better deal in the public health world.

Plus, there are significant climate benefits too.  Scientists are increasingly pointing to black carbon emissions as a key issue in the acceleration of melting sea and glacial ice, especially in the Arctic region and key mountain ranges that supply drinking water to billions of people around the world like the Himalayas and the Rockies.  Unlike carbon dioxide and other greenhouse gases, black carbon emissions are very short-term in duration – they last only a few weeks in the atmosphere.  In other words, cutting black carbon emissions today creates global warming benefits almost immediately—creating some breathing room to allow the longer-term strategies to cut greenhouse gas emissions time to take effect. 

The soot particles from the world’s ocean-going ships have a core that is largely composed of black carbon.  So, in addition to the health benefits listed above, cutting ship pollution creates a short-term climate benefit almost immediately.  In this week of important climate news, a commitment to cutting ship pollution would be an added bonus.

What does EPA’s new rule have to do with all of this? 

As I wrote in August, EPA’s rule covers all US-flagged ships, just in case the IMO fails to support the US/Canada ECA proposal.  Obviously, given the global nature of shipping, we need the IMO-sanctioned ECA to really solve the ship pollution problem off our coasts because most large ships at our ports carry foreign flags.  Nevertheless, this EPA rule for US-flagged ships will send a strong signal to the global shipping industry that the US intends to act swiftly to cut this pollution from the ships under its jurisdiction.  Doing so should help encourage the IMO to adopt a globally-recognized ECA, rather than a more limited US-only approach.

One caveat worth noting:  earlier this fall, a group of 13 steamships that operate on the Great Lakes convinced Congress to add a budget rider that restricted EPA’s ability to enforce the proposed pollution cuts against their vessels.  More recently, some steamship operators off the Alaskan and northwest coasts have been advocating for a similar carve-out.  Hopefully, dealing with these niche operators (less than one percent or less of emissions) won’t lead to extra trouble at the IMO meeting in March, just as the existence of a few remaining Model T Fords never stood in the way of EPA's world-class Tier 2 emission standards for cars.

The bottom line:  EPA’s rule is strong, and is a welcome holiday present to anybody who cares about clean air.

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