NEWS/EVENTS
News Articles
October 6, 2009
CLIA Comments on EPA’s Proposed Emissions Control Area;
Group Supports Goals and Suggests Modifications
Cruise Lines International Association this month submitted formal comments to the Environmental Protection Agency’s proposed rules that contains regulatory elements of a North America Emissions Control Area (ECA), extending 200 nautical miles seaward from the majority of the North American continent.
Cruise Lines International Association’s (CLIA’s) comments, which run to 11 pages and two annexes, question the Environmental Protection Agency’s (EPA’s) analysis of environmental and health benefits, in light of recent actions taken at the International Maritime Organization (IMO) to limit global sulfur content in fuel.
According to Gaye Stewart-Loudis, CLIA’s Director of Membership, CLIA’s comments expressed the industry’s support for the environmental and public health goals of the proposed ECA and offered recommendations for modifying the rule.
Excluded in the proposed area are the western and northern coastlines of Alaska.
“CLIA continues to work closely with the Northwest Cruise Association in coordinating industry efforts respecting this North America ECA proposed rule,” Stewart-Loudis stated.
According to a summary of CLIA’s comments, the organization believes that the IMO’s new limits on sulfur content in fuel would require reductions similar to those within the proposed ECA. CLIA cites industry calculations that 85 percent of the health and environmental benefits that EPA attributes to the proposed ECA will be met by the global sulfur content limits.
The comments also note that EPA’s 2020 base case does not include the IMO global Tier I or Tier II NOx control requirements, which go into effect prior to 2020, resulting in a significant overstatement of the NOx reduction benefits of the ECA.
EPA analysis did not take into account existing regulations in states such as California and the use of emissions reducing alternatives, such as shore power, again resulting in an overstatement of the end benefit, according to the summary of CLIA comments.
CLIA’s comments also point to the limited benefits of establishing a uniform 200-nautical-mile (nm) area.
“EPA’s proposal considers only the establishment of a uniform ECA to 200 nautical miles (nm) of shore,” the comment summary states. “Due to prevailing winds and climatic conditions, emission reductions at 200 nm will have less of a benefit on shore than emission reductions occurring much closer to the shore or within harbors.”
“Cost effectiveness calculations by ENVIRON show that the cost effectiveness of emission controls within 39 nm of shore are over 1,000 times greater than controls applied beyond 39 nm out to 200 nm,” the summary continues.
CLIA’s comments also question if the EPA’s proposal contains sufficient justification for including the Southeastern Alaska and Western Hawaii regions in the ECA.
“The proposal also excludes the Eastern Hawaii and Western Alaska regions,” the formal comments add. “No dispersion modeling results are presented to justify these decisions, and there is no information on the relative benefits of including (and disadvantages of excluding) these regions from the ECA.”
The formal comments also question EPA’s estimated cost for reduced sulfur fuel, required within the proposed ECA.
“EPA’s global market fuel price differential under the proposed rule (estimated at $145 per ton) is immaterial when the analysis concerns shipping that will trade almost exclusively within the ECA.”
“Instead, for this type of local impact, the analysis should be conducted utilizing historical spot market bunker pricing within the various geographic areas of the ECA,” CLIA notes. “CLIA analysis, for example, indicates a historical 10-year average price differential between distillate and residual fuel in the U.S. Northwest of approximately $230 per ton, almost twice the differential used by EPA.”
Anticipating that the proposed ECA will increase demand for distillate fuel, particularly in the North American market, CLIA’s comments point to new source air emission requirements for refiners, calling into question whether U.S. and Canadian refineries would invest in expanding production capacity for the marginal additional reduced-sulfur fuel market.
Given this scenario, CLIA expects fuels likely will be shipped to North America from other countries, increasing tanker ship emissions associated with fuel transport.
CLIA’s comments charge that “EPA sends mixed messages regarding the development of technology to achieve equivalent emissions reductions. CLIA encourages clarity and an open door policy that fosters innovation and the development of new technology to meet the emissions challenge.”
CLIA cites one of its members that is pioneering the testing and development of exhaust gas scrubber technology in a project with the U.S. and Canadian governments.
“Results to date show significant reductions in SOx and particulate matter emissions with the use of residual fuel,” the CLIA comments state.