I'm testifying at EPA's hearing today on its proposed regulation to reduce emissions from the largest, dirtiest diesels in our midst-the huge diesel engines (regulated as "Category 3" engines because of their size) that power the ocean-going vessels (OGVs) at our ports.  I haven't posted anything for awhile, but this is a topic that I've covered often in the past, so I'm updating Switchboard readers now.

As close readers of my posts know, I've worked closely with EPA staff over the past few years to craft a strategy to reduce OGV emissions.  Today, I will be happy to testify that I think the two-pronged strategy they've devised is a strong one. 

First, EPA has led the global shipping community to adopt a stronger global commitment to reducing ship emissions worldwide.  Last fall, the U.S. delegation to the International Maritime Organization secured a new global pact to reduce ship emissions, and to allow individual countries to create special "Emission Control Areas" to accelerate the reduction of ship emissions off their coast lines. 

In March, the Obama administration took advantage of this provision, and began the process of creating such a joint US/Canada Emission Control Area (ECA) within 200 miles of our coastlines. 

The IMO will vote on this proposal in March 2010 - and if it passes, ship emissions in the area 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.

Second, EPA has proposed similar restrictions for 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 both prongs to really solve the ship pollution problem.  But this EPA proposal for US-flagged ships sends a strong signal to the global shipping industry that the US intends to act swiftly to cut this emissions-and it should help encourage the IMO to adopt a globally-recognized ECA, rather than a more limited approach

Together, EPA's combined OGV strategy is critical to the health of our communities and our region's ability to meet its Clean Air Act requirements.  When today's proposal and the ECA designation are both finalized and fully implemented, the environmental and public health benefits of the combined OGV strategy will be substantial. 

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 cost of approximately 3.11 billion in 2030.  At a return on investment of at least 30:1, it is hard to find a better deal in the public health world.

With the nation engaging in a critical debate about rising health care costs and an aging population, avoiding these health impacts and costs is an urgent need.

Today's proposal is especially critical to the low-income communities and communities of color that exist just beyond the gates of our largest ports.  At our local port terminals in New York and New Jersey, nearby communities of Newark, Elizabeth, Brooklyn or Staten Island are hardest hit by port-related emissions.  This proposal will help bring some needed relief.

Here's why: the Port Authority of New York and New Jersey expects container volumes at its terminals to triple by 2020.  While the Port Authority is to be commended for convening many diverse stakeholders to create a "Clean Air Strategy" for the port, we know that only EPA can use its regulatory authority to require ship engines to be cleaner.  We can work together to retire old trucks, retrofit old switcher locomotives, to convince shippers to slow down as they enter New York Harbor, but the bottom line is that OGVs emit 47 percent of the NOx related to port activities in the region, and 62 percent of the PM2.5 related to port activities in the region.  We cannot meet our environmental goals for shipping in the region without cleaner ships.

The previous statistics underscore the importance of EPA's combined OGV strategy to New York, New Jersey, and all other states that are grappling with their upcoming Clean Air Act deadlines for ozone and particulate matter.  Even with cleaner cars, trucks, and other sources, far too many people continue to breathe air that fails to meet EPA's ambient air quality standards for these pollutants, and too many states already know that they will not be able to meet some of their upcoming State Implementation Plan requirements without additional regulatory help from EPA.

Reducing ship emissions is the right place for EPA to provide that help.  This is because OGV emissions are projected to grow dramatically-without the combined OGV strategy, NOx emissions from ships are projected to more than double, and PM emissions are expected to almost triple by 2030.  OGV emissions are also projected to grow in relation to other transportation sources, as cars, trucks, and other mobile sources get progressively cleaner during this period.  According to EPA, NOx emissions from OGVs will grow from about six percent of mobile source-related NOx in 2001 to 40 percent of this category in 2030.  Likewise, EPA estimates that PM2.5 from OGVs will grow from 10 percent of mobile source-related PM2.5 to 75 percent of this category of emissions in 2030. 

What's the bottom line?

EPA's approach is a strong one, and NRDC will be pleased to support it at today's hearing.