Program Update: Proposal of Emission
Control Area to Reduce Emissions
from Ships in the U.S. Caribbean
The United States has submitted a proposal to the International
Maritime Organization to designate an area off the coasts of Puerto
Rico and the U.S. Virgin Islands in which stringent international
emission controls would apply to engines and fuels on ships operating
in the area. When adopted, this control program would dramatically
reduce air pollution from ships and deliver substantial benefits to the
population of those U.S. territories, as well as to marine and terrestrial
ecosystems. This fact sheet contains an overview of the proposal.
Overview
The United States has proposed the designation of an Emission Control Area (EGA)
for specific portions of the coastal waters around Puerto Rico and the U.S. Virgin
Islands. This action would control the emission of nitrogen oxides (NOx), sulfur
oxides (SOx), and particulate matter (PM) from ships operating in the area, most of
which are flagged outside of the United States. These ships are significant contributors
to the Territories' emission inventories. The EGA is expected to reduce emissions of
NOx by 11,000 tons, PM2.5 by 3,300 tons, and SOx by 31,000 tons1 per year, which
is 27 percent, 86 percent, and 96 percent, respectively, below levels in 2020 absent
the EGA. The overall cost of the EGA is estimated at $70 million.
The International Maritime Organization (IMO) is a specialized United Nations
agency responsible for improving maritime safety and preventing pollution from
ships. The U.S. Environmental Protection Agency (EPA) is a member of the U.S.
delegation to the IMO and its Marine Environment Protection Committee (MEPC),
SEPA
1 The proposal to the IMO presented emission reductions in units of metric tones (MT): 10,000 MT
NOx, 3,000 MT PM2.5, and 28,000 MT SOx reduced.
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-10-041
August 2010
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The proposed EGA designation is the latest component of EPA's coordinated strategy to address
emissions from all ships that affect U.S. air quality. For more information about other compo'
nents of the strategy, including new Clean Air Act standards and the North American EGA,
please visit EPA's Ocean-going Vessels Web page at www.epa.gov/otaq/oceanvessels.htm.
The Proposed U.S. Caribbean EGA
The area of the proposed U.S. Caribbean EGA includes waters adjacent to coasts of the Com-
monwealth of Puerto Rico and the U.S. Virgin Islands. The northern and southern boundaries
of the proposed area would extend roughly 50 nautical miles (nm) and 40 nm, respectively, from
the territorial sea baseline of the main island of Puerto Rico. The western edge of the proposed
area would generally run north-south, about half way between the Puerto Rican island of Mona
and the west coast of the main island. The eastern edge of the proposed area would generally
run north-south, but extend eastward through the area between the U.S. Virgin Islands and the
British Virgin Islands and also eastward through the area between Saint Croix and Anguilla and
Saint Kitts. The proposed EGA is bounded such that it does not extend into marine areas subject
to the sovereignty, sovereign rights, or jurisdiction of any state other than the United States.
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Figure 1: Area Proposed for EGA Designation
The Need to Reduce Emissions from Engines on Ships
The large marine diesel engines on ships are significant contributors to the territories' emission
inventories. The largest vessels that operate in ports and waters of Puerto Rico and the U.S. Vir-
gin Islands typically have Category 3 marine diesel propulsion engines. These engines currently
use emission control technology that is comparable to that used by nonroad engines in the early
1990s. In addition, these large engines, as well as the smaller auxiliary engines installed on these
ships, are operated on fuel that can have a sulfur content of 30,000 ppm or more. As a result,
these ships generate significant emissions of fine particulate matter (PM2.5), NOx, and SOx
that cause adverse health effects and harm to public welfare, and contribute to visibility impair-
ment and other detrimental environmental impacts.
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a
There are well established links between NOx, SOx, ozone and PM exposure and asthma, and
the asthma mortality rate in Puerto Rico is 2.5 times higher than the rate in the continental
United States. Puerto Rico and the U.S. Virgin Islands are comprised of many highly sensitive
ecosystems that are already vulnerable and are threatened by pollution from ships. The depen-
dency of the islands' economies on marine transportation in combination with the physical and
human geography of the territories place these populations and environments at an elevated risk
from ship-related pollution.
The contribution of diesel engines to air pollution is expected to grow even more over the next
two decades. Designation of the proposed EGA would significantly reduce emissions from ships
and deliver substantial benefits to the local population, as well as to marine and terrestrial eco-
systems.
The U.S. Government's analysis for this proposal shows that in addition to exposure to emissions
from ships operating in local ports, populations of these islands are also exposed to emissions from
ships operating offshore, far beyond the boundaries of the proposed EGA. These port and offshore
emissions affect virtually all people living in Puerto Rico and the U.S. Virgin Islands.
Regulatory Announce
O J
Population Density
of Puerto Rico
(2000 Census)
Mayaguez
Port
'
Arecibo Port
San Juan Port
Fajardo Port
Culebras Port
Vieques Port
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Yabucoa Port
Guayanilla Port
Guayama Port
Figure 2: Ports and Populated Areas in Puerto Rico
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3 ZOOO - 4.99S- 2000 Population of
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Figure 3: Ports and Populated Areas in the U.S. Virgin Islands
Emission Control Area Standards
In October 2008, the International Maritime Organization (IMO) adopted stringent new
standards to control harmful exhaust emissions from the engines that power ships. The member
states of IMO agreed to amend Annex VI to the International Convention on the Prevention of
Pollution from Ships (MARPOL), adopting new tiers of NOx and fuel sulfur controls. The most
stringent of these new emission standards apply to ships operating in specially designated Emis-
sion Control Areas (EGAs):
• Beginning in 2015, fuel used by all vessels operating in these areas cannot exceed 0.1
percent fuel sulfur (1,000 ppm). This requirement is expected to reduce PM and SOx
emissions by more than 85 percent.
• Beginning in 2016, new engines on vessels operating in these areas must use emission
controls that achieve an 80 percent reduction in NOx emissions.
In most cases, ships already have the capability to store two or more fuels. However, to meet the
2015 requirement of 1,000 ppm fuel sulfur, some vessels may need to be modified for additional
distillate fuel storage capacity. As an alternative to using low sulfur fuel, ship operators may
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choose to equip their vessels with exhaust gas cleaning devices ("scrubbers"). In this case, the
scrubber extracts sulfur from the exhaust,
Costs
The costs of implementing and complying with the proposed EGA are expected to be reasonable
in comparison to the costs of achieving similar emissions reductions through additional controls
on land'based sources. We estimate the total costs of improving ship emissions from current
performance to EGA standards while operating in the proposed EGA will be approximately $70
million in 2020. The costs to reduce a ton of NOx, SOx and PM are estimated at $500, $1,000
and $10,000, respectively.2 In comparison, the 2007 heavy-duty highway truck rule cost $2,300
per ton for NOx and $15,000 per ton for PM. Improving current ship emission levels to EGA
standards is one of the most cost'effective measures available to obtain clean air benefits for
these islands.
The economic impacts of complying with the program on ships engaged in international trade
are expected to be modest. For example, the impact on the price of a cruise on a medium-sized
cruise ship that operates a route between the U.S. mainland and Puerto Rico is estimated to
increase by approximately US$0.60 per passenger per day for a 5-day cruise. This represents a
less than one percent increase in the price of such a cruise. Container ships operating in the pro-
posed EGA are expected to see a cost increase of less than one percent of the cost of transport of
a 20-foot container, or about $0.33 to $1.35 per unit, depending on the size of the ship and the
length of the route.
Benefits
Reducing ship emissions from today's performance to EGA standards would reduce local inven-
tories of NOx, SOx and PM2.5 in 2020 by approximately 11,000, 31,000 and 3,300 short tons,
respectively. The emission reductions that will occur as a result of applying EGA controls in
the proposed area would help reduce the damage to human health and the environment that is
caused by ship emissions and would help Puerto Rico and the U.S. Virgin Islands achieve and
maintain healthier ambient air quality. Designating this EGA would also help areas of environ-
mental and ecological significance begin to recover their natural balance.
Next Steps
IMO members are slated to consider our EGA proposal at the 61st session of the Marine Envi-
ronmental Protection Committee (MEPC 61), in London, beginning September 27, 2010. Final
action on the proposal may be taken by Parties to Annex VI (those who have ratified the treaty)
as early as MEPC 62, scheduled for summer 2011. Given the MARPOL amendment process and
the lead time specified in the regulations, an EGA adopted at MEPC 62 could enter into force as
early as 2014.
2 The proposal to the IMO presented cost effectiveness in units of US$ per metric tone ($/MT): $600/MT for
NOx, $l,100/MTfor SOx and $ll,000/MTforPM..
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Public Participation Opportunities
There will be a public meeting hosted by the U.S. Coast Guard in advance of MEPC 61, on
September 10, 2010, in Washington, DC. Members of the public interested in attending must
contact the meeting coordinator at least 7 days prior to the meeting. Additional details, in-
cluding the MEPC meeting agenda, can be found at the U.S. Coast Guard's IMO web page at
www. uscg. mil/imo/mepc/default. asp,
For More Information
You can access the U.S. proposal and related documents on EPA's Office of Transportation and
Air Quality web site at:
www.epa.gov/otaq/oceanvessels.htm
For additional information, please contact the Assessment and Standards Division at
Email: asdinfo@epa.gov
Phone: 734-214-4636
Mail:
Assessment and Standards Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
2000 Traverwood Dr.
Ann Arbor, MI 48105
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