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CLIA speaks out against emission rules

The Environmental Protection Agency (EPA) moved closer to finalizing new engine and fuel standards for the largest ocean-bound ships by sending the draft rules to the White House for review. If finalized, the rules would drive up the cost of living for 90 percent of Alaskans and add $100-$150 million per year to the cost of operating cruise ships in the state.

Alaska was joined by Hawaii in expressing concern with the proposed rules. In fact, governors from both states wrote to the EPA expressing concern over imposing such stringent and costly regulations without adequate scientific research or justification.

“While I understand and support reductions in fuel emissions, I would like Hawaii’s inclusion in the EPA’s proposed ECA (Emission Control Area) to be based on quantitative air quality and economic impact data. Until such time as the data is available, I would respectfully request the EPA delay implementation of the proposed rule,” Governor Lingle wrote.

CLIA expressed similar concerns in their comments to EPA. Here is part of their comments.

CLIA supports the public health goals of the proposed North America ECA and the intent of the proposed rule. However, we believe these goals should be implemented in such a way that recognizes the economic benefit of the North America cruise industry to the U.S. economy and those U.S. jobs which depend on this industry. We believe this can be accomplished by utilizing all of the tools that are available within MARPOL Annex VI and the Clean Air Act and ensuring that a proposed ECA is scientifically supported.

We have serious concerns with the geographic extent of the proposal and analysis of benefits as well as with some elements of the proposal and the impact analysis.

CLIA is of the view:

1. There remain significant concerns and questions regarding the fuel availability and pricing discussions as well as the overall economic impact not only on the maritime industry in general and cruise industry specifically, but also on other industries that will be competing for the finite amount of distillate fuel that is available from each barrel of crude stock.

2. While the projected health and social benefits appear to be favorable in so far as the climatological modeling and health benefits models are correct, we believe that a more accurate representation, at least for the long term model from 2020 to 2050, should be based on comparison to the expected .5% bunker oil sulfur content global cap expected effective in 2020. With this in mind, an analysis should be undertaken and the appropriate breadth of the ECA should be based on the correct analysis.

3. EPA has not adequately predicted the economic costs associated with this rulemaking.

4. Alaska and Hawaii should be excluded from the petition until such time as EPA has adequately and scientifically evaluated the need for inclusion of Alaska and Hawaii.

5. Viewing and analyzing air emissions from a holistic view (including factors for greenhouse gases) will be important. Thus far, all regulatory restrictions on pollutants have been done without consideration that reduction of one pollutant increases the production of another. The U.S. needs to join with the industry in developing solutions in a comprehensive rather than piecemeal approach.

6. Further development of Exhaust Gas Scrubbers (EGS) or other similar technology and the use of such technology should be encouraged and the manufacture, offer for sale and sale of residual fuels should not be prohibited for use with such proven technology.

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