Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
chapter
[9 VAC 5 ‑ ]
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10/22/24  11:45 am
Commenter: Elizabeth Wilkins

To Protect Public Health and Ecosystems, I Support this Petition
 

As a marine biologist, I write to urge this board to carefully consider the potential harms of cruise ship pollution to Virginia’s coastal ecosystems and the public health of our citizens. Most cruise ships use a very dirty grade of so called “bunker fuel”, or Heavy Fuel Oil (HFO), which is a tarry sludge leftover from the crude oil refining process. Emission of toxic nitrogen oxides and sulfur oxides from the burning of HFOs is an ongoing serious threat to global human and environmental health, and an acute spill of this low-grade fuel would be disastrous in any marine environment.

 

In 2020, the IMO (International Maritime Organization) set new tougher standards for sulfur emissions, and subsequently the global shipping fleet is in the process of switching to lighter, cleaner fuels. But to save money, the cruise industry has chosen to use scrubbers or Exhaust Gas Cleaning Systems (EGCS) to reduce sulfur in the exhaust, rather than switch to more expensive fuels. The types of scrubbers used by most are open-loop systems and do not solve the pollution problem, they just transfer it from the air to the water, which becomes more acidic and laden with toxic PAHs and heavy metals. The problem may be worse in estuaries (such as the Chesapeake Bay) than in the open ocean, because scrubbers are known to be less effective in brackish waters. Coastal habitats and fisheries are acutely vulnerable to the effects of water pollution, and are of major economic and recreational importance to coastal communities.

 

https://theicct.org/publication/air-emissions-and-water-pollution-discharges-from-ships-with-scrubbers/

 

To summarize, environmental concerns include atmospheric pollution and ocean acidification, toxic discharges from open loop exhaust scrubbers (currently banned in 120 ports globally), and wastewater discharges. Fine particulates, residual sulfur oxides and nitrogen oxides

found in cruise ship exhaust can cause asthma, emphysema and cancer.

 

Cruise ship waste streams and accidental pollution incidents are increasing in proportion to the burgeoning growth of the industry, and the resulting public health and environmental issues are serious and complex. Please enact tougher cruise ship regulations for the good of the Commonwealth. The very real economic cost to human health, the seafood industry, and coastal ecosystems far outweighs the meager economic benefit of unregulated cruise traffic in our waters. For more detailed information, please visit https://protect-virginia.org/

 

CommentID: 228164