The Shipping Industry’s Pollution Problem Part I: Low-Hanging Fruit

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By Adam Sarvana, DC Bureau

Part I in the four-part series No Safe Harbor about the shipping industry’s emissions problems

The shipping industry is an invisible and nearly unregulated environmental disaster, and if you haven’t heard much about its poor record, you’re not alone. Compared to power plants, cars and even commercial aviation, shipping has drawn little scrutiny ─ it gets few mentions in the media, and activist groups tend to focus their attention elsewhere. Seen as little more than an expensive tourist option or a humdrum conveyor of goods, the modern sea vessel is a mystery to the average person, either a love boat or a floating tractor trailer. If there were no pirates or seasick honeymooners, the shipping industry would barely register in the public consciousness.

This invisibility is unfortunate, because toxic shipping emissions bring about the premature deaths of thousands of people living near ports every year. Worldwide, cargo shipping pumps out more carbon dioxide (CO2) annually than the United Kingdom (UK).

Most commercial ships are powered by a thick brew of sulfur and sludge called bunker fuel with a deserved reputation as one of the dirtiest energy sources on earth, even among industry representatives. Bryan Wood-Thomas, the vice president for environmental policy at the World Shipping Council (WSC), which represents many of the biggest shipping companies (including Møller-Mærsk, the world’s largest) in Washington, D.C., called bunker fuel “the residual crap that comes out of [oil] refineries.” It is so thick, he said, that “if you put a chunk on your desk, it would keep a three-dimensional shape.” Engineers need to liquefy it through super-heating before putting it into a ship’s fuel lines because it would otherwise clog them.

The high sulfur content of this fuel, which leads to sulfur-heavy emissions, is only one danger. Ships are prodigious emitters of several so-called criteria pollutants, those that are most heavily regulated under the Clean Air Act because they are the most dangerous to human health, including fine particulate matter (PM2.5), nitrogen oxides (NOx) and sulfur oxides (SOx), the last of which not only harms lungs but can lead to acid rainfall.

In addition to these risks, many observers (including some industry representatives) consider shipping a low-hanging fruit in the battle against global warming. Arctic shipping lanes can mean a quick melting death for polar sea ice thanks to emissions of black carbon, a sooty residue that absorbs heat and settles on anything it touches. As David Marshall, an activist with the Clean Air Task Force, somewhat casually put it in an interview for this article, “If the Greenland ice shelf collapses, we’re looking at significant sea rise.”

Why has the issue not received more attention? It’s a tricky question to answer. Unlike oil companies, which have invested millions of dollars and years of effort to deflect attention from global warming research, shippers can sit back and let the environmental conversation pass them by.

“The industry knows it’s under-regulated, and they keep a low profile,” said Sarah Burt of the environmental law firm Earthjustice, which has sued the Environmental Protection Agency (EPA) over its failure to regulate shipping emissions. “When it does get attention it’s at specific ports, at the local level, not at the national level. … The industry has managed to lay low. There’s no smoking gun that you can point to and say, ‘This is the reason’” for a lack of regulation.

John Kaltenstein of the activist group Friends of the Earth agreed, noting,

“A lot of areas [of the country] feel like they’re not affected by port communities. It’s a selective issue.”

Indeed, during a Feb. 14, 2008, hearing on a proposal to more strictly regulate ships in U.S. waters, on which more later, Sen. David Vitter (R-La.) remarked that stronger rules would only be appropriate for “areas such as California that really have an air quality problem,” as opposed to nationwide rules that, he said, would put the country at a competitive disadvantage.

The idea that only a few ports here and there should be concerned about the industry’s health impacts is unarguably incorrect. Wood-Thomas did not always work for the WSC ─ before holding his current position, he was the associate director of EPA’s Office of Transportation and Air Quality as well as a key Bush administration negotiator on environmental treaties. Testifying before Vitter and other lawmakers at last year’s hearing, still working for the government at the time, Wood-Thomas said,

“Currently more than 40 U.S. ports are located in non-attainment areas [that exceed existing health standards] for ozone or fine particulates or both. However, the problem is not limited to port areas alone. Santa Barbara County, which has no commercial ports, estimates that by 2020, 67 percent of its NOx inventory will come from shipping traffic transiting the California coast, although the extent to which these emissions reach land depends on wind and weather patterns. … [Shipping] engines are massive in scale and they represent a significant source of NOx emissions with studies estimating emissions as 18 percent or higher of total NOx emissions worldwide.”

However, not only is there no push to examine shipping more closely, there is little reason to think someone will pick up the slack in the future. For activists, endangered species tend to make for better fundraising materials than pictures of cargo containers or rusty ocean liners. For government researchers, there’s little incentive to study a problem that no one is pushing to fix ─ air quality experts, without some political mandate to put their time and energy into such research, have little reason to spend precious days or weeks mapping dockside pollution dispersal patterns. As for the general population, shipping is the opposite of a sexy topic. The word conjures up images of big, slow freighters laden with hundreds of identical crates, steaming from point A to point B, trudging along like relics of a bygone era.

Nothing could be further from the truth. Shipping has burst onto the global economic landscape as the preeminent means of moving goods wherever they need to go. According to a general information document published online by the International Maritime Organization (IMO), the industry’s global governing body responsible for regulating shipping pollution under the Kyoto Protocol,

“It is generally accepted that more than 90 per cent of global trade is carried by sea. Throughout the last century the shipping industry has seen a general trend of increases in total trade volume. … [A]lthough the growth in seaborne trade was tempered by the Asian financial crisis of the late 1990s, there was a healthy growth in maritime trade since 1993.”

According to the organization, world shipping output grew by 3.6 percent in 2005 and another 4 per cent in 2006. Especially poignant is the recent explosion of shipping in developing economies: India registered “an impressive” 9.2 percent shipping volume increase in 2006, and China “continued its strong performance of recent years” with 10.7 percent growth.

Based on this ever-expanding volume of overseas trade, governments and international organizations have occasionally conducted studies and issued reports, only to find that, indeed, more environmental regulation is needed.

They have also found that no one has been keeping accurate records, government agencies have been asleep at the switch, getting reliable information is nearly impossible, and putting hard numbers to the problem is going to be difficult for years to come. An April report prepared for the IMO’s Marine Environmental Protection Committee (MEPC) found, for instance, that “statistical data presently available are likely to under-report the consumption of marine fuel,” and also noted difficulties in establishing any sort of baseline estimate for global shipping’s greenhouse gas emissions.

What little reliable information can be gleaned from the mass of estimates, best guesses and informed speculation paints a troubling picture.

According to a pioneering 2007 study by James J. Corbett and others published in Environmental Science & Technology, shipping-related emissions of particulate matter contribute to approximately 60,000 premature cardiopulmonary and lung cancer deaths each year, mostly in coastal regions along major trade routes. In a 2007 rulemaking announcement, the EPA published estimates that worldwide shipping in 2001 emitted more than 54,000 tons of PM2.5, as much as 117 power plants, and approximately 745,000 tons of NOx, equivalent to about 800 million modern automobiles. That number is not a typo ─ the global fleet of approximately 90,000 ships really is that dirty.

These health impacts will only get worse. As the EPA wrote in March,

“Without further action, by 2030, NOx emissions from ships are projected to more than double, growing to 2.1 million tons a year while annual PM2.5 emissions are expected to almost triple to 170,000 tons.”

NOx is of particular concern because it can react with other particles in the atmosphere to form ozone, yet another criteria pollutant, which creates smog and leads to asthma and respiratory infections. The industry knows all this: Bill Box, a representative of the International Association of Independent Tanker Owners, was quoted in a 2007 article in the UK Independent as saying, “Shipping has not yet been regulated and for politicians it is the last low-hanging fruit.” Wood-Thomas admitted in an interview for this article, “The ability of ships to become more efficient is very real.”

The few attempts to address the issue domestically have failed, and not just at the EPA level.

In May 2007, a bill labeled S. 1499 was introduced by six senators, including Environment and Public Works Committee Chairwoman Barbara Boxer (D-Calif.) and then-Sen. Hillary Clinton (D-N.Y.), that would have cut the sulfur limit in fuels to 1,000 ppm for any vessel within 200 miles of the West Coast and “within such distance of the East or Gulf coast or the shoreline of the Great Lakes or St. Lawrence Seaway as EPA determines to be appropriate.” The bill, which represented a significant step beyond anything the IMO had ever proposed, even passed the Environment and Public Works Committee unscathed, marking a strong congressional push to address an issue with almost no public visibility. Then-Rep. Hilda Solis (D-Calif.), now Secretary of Labor, introduced an identical companion bill with 23 cosponsors, including current House Energy and Commerce Committee Chairman Henry Waxman. There seemed to be every chance for action.

Then, unaccountably, the matter was dropped. The Senate bill was never brought for a full vote, and the House bill never moved out of the energy committee’s clean air panel. A call to Boxer’s office to ask about whether the issue will be revived was not returned, and calls to the six Representatives from California districts on the House Energy and Commerce Committee were similarly unfruitful. A staffer for one of the six, Rep. Lois Capps, suggested that Rep. Sam Farr (D-Calif.) has been active on the issue, despite his not being on the relevant committee; Tom Mentzer, a Farr staffer, subsequently e-mailed, “We really don’t have anything to do with the shipping industry. It may be argued that HR 21, our comprehensive ocean management bill, could touch on the periphery of the issue, but it’s not something that has come up in that realm.”

The main global effort to address this ever-growing toxic cloud is the International Convention on the Prevention of Pollution from Ships, commonly referred to as MARPOL. When it was first written in 1973, it concerned itself with wastewater disposal and other better understood shipping issues ─ emissions controls were not even contemplated until 1997, when Annex VI of the treaty (“Regulations for the Prevention of Air Pollution from Ships”) was prepared. Under the annex’s terms, it would not go into effect until one year after it was ratified by at least 15 countries representing at least 50 percent of the world’s shipping tonnage, a requirement that was only met in 2004 when Samoa finally joined Bahamas, Bangladesh, Barbados, Denmark, Germany, Greece, Liberia, Marshall Islands, Norway, Panama, Singapore, Spain, Sweden and Vanuatu as signatories. Combined, the countries accounted for 54.57 percent of shipping tonnage, barely enough to squeak past the post.

The air control protocol went into effect May 19, 2005, setting abstrusely conveyed limits on NOx emissions from ships built on or after Jan. 1, 2000, as a function of a ship’s engine type. The original rules also limited the sulfur content of fuel to 45,000 parts per million (ppm) or 4.5 percent of total composition, a weak figure when compared to the current global shipping average of 27,000 ppm. The October 2008 rewrite reduced the sulfur content limit to 35,000 ppm, still well above the average. As a contrast, California currently mandates that diesel fuel, even that used by long-haul truckers, have no more than 15 ppm. (That standard is set to go nationwide in 2010.)

For international shipping, a 5,000 ppm standard will not take effect until at least 2020 under MARPOL, and could be postponed to 2025 based on the results of a 2018 feasibility study. Ships that don’t or can’t meet the sulfur content restriction can install scrubbers on their exhaust pipes as long as their emissions do not exceed 6 g/kW-h. The sulfur content rule is also meant indirectly to reduce PM2.5 emissions ─ there is no explicit particulate matter limit.

The Annex created a process by which countries can request the designation of a special emissions control area (ECA), either for SOx and PM2.5 or NOx or all of the above together, inside which the limits are at least strict enough to have real teeth. An ECA extends approximately 200 miles from a petitioning country’s border, which has already meant the designation of the entire Baltic and North Seas as control areas. Currently, inside a sulfur ECA, fuel cannot contain more than 10,000 ppm of sulfur, and inside a nitrogen ECA the emissions limits for each engine type are strengthened fivefold from the original (pre-rewrite) standards.

Taken altogether, “complicated” would be a charitable description, which may be one reason nobody is watching.

(Originally published at


See also:

The Shipping Industry’s Pollution Problem Part II: A Lack of Authority

The Shipping Industry’s Pollution Problem Part III: Off The Hook

California Fights Shipping Pollution As International Shippers Push Back

(Photos: / CC BY 2.0)