Deadline near on rule that drives up cost of living, makes state less competitive

January 1, 1970

A federal ruling that imposes strict air emission standards on marine traffic in much of Alaska would drive up the cost of living for 90 percent of Alaskans and add another $100 million to the cost of operating cruise ships in the state.

“If Alaskans don’t speak out, this rule will dearly cost all Alaskans as 90 percent of all consumer goods come through the Port of Anchorage,” said John Binkley, president of the Alaska Cruise Association (ACA).

“It also will seriously affect the competitiveness of Alaska as a premier tourism destination.”

The deadline to comment on the ruling, which is designed to apply in areas where ambient air quality is a serious risk to public health, is September 28.

In October 2008, the International Maritime Organization (IMO) under the United Nations adopted new standards to reduce marine vessel emissions. The standards include general limits on the maximum sulfur content of fuel and nitrogen oxides emissions that apply to ships. The IMO also adopted much more stringent standards for specially designated areas called Emission Control Areas (ECA).

Last April the U.S. and Canada submitted their selections to be designated as ECAs. These areas include Southeast and Southcentral Alaska, but not Southwest Alaska.

Justification for the U.S. portion of the ECA was based upon emission inventories and modeling on ambient air quality. The modeling was specifically targeted to determine the impact of ship emissions on human health.

No modeling was done in Alaska and there is no scientific study or evidence that demonstrates Alaska’s coastal communities have an ambient air problem as a result of marine vessels. In fact, the air sampling that has been done clearly shows that Alaska does not have a ship emission air problem.

Here is what the American Lung Association says about Anchorage’s air: “Currently, Anchorage and the surrounding areas are considered well within the ambient air quality standards for sulfur dioxide, ground level ozone, and nitrogen dioxide.”

The Department of Environmental Conservation hired a contractor to monitor air quality in downtown Juneau in 2000 and 2001. “Data from these monitors indicated that concentrations of measured air pollutants were appreciably below the State and national air quality standards in both 2000 and 2001. Since these standards are developed to protect health and welfare, ADEC concluded that air pollutant concentrations in Juneau would not result in adverse effects on health and welfare.”

The Environmental Protection Agency (EPA) admits that it has no evidence to include Alaska. “Essentially, we don’t have all our science done to make the compelling case,” they have stated.

The IMO also requires all ECA applications to consider the cost to implement the new standards and the economic impact to local communities. The EPA failed to study the economic impacts Alaska’s economy and local communities.

In their cost analysis, the EPA concluded large passenger vessels would incur an additional $7 per passenger/day cost to pay for the new standards. An ACA analysis puts the additional cost much higher, between $15 and 18 per passenger/day. A $15 per passenger/day increase would add $100 million to the cost of operating in Alaska for ACA member lines.

The difference comes from the length of time ships would spend in the ECA. When ships leave Los Angeles or Ft. Lauderdale,
they quickly travel outside the ECA. However, Alaska cruises remain within the ECA boundaries their entire trip and the ACA
estimates that two-thirds of all costs within North America will be attributable to Alaska cruises.

“Given there was no modeling done for Alaska, no consistent application within our state, and no analysis of the negative
impact on our economy, I ask for your help,” Binkley said.