Monday, August 20, 2012

California air pollution control officers to Congress: don't fall for cruise ship dirty-air scam

August 6, 2012

The Honorable Peter T. King, Chairman
Committee on Homeland Security
United States House of Representatives
1011 Longworth House Office Building
Washington, D.C. 20515

The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
United States House of Representatives
H2-117 Ford House Office Building
Washington, D.C. 20515

Dear Chairman King and Ranking Member Thompson:

The California Air Pollution Control Officer Association (CAPCOA), representing the air pollution control officers from all 35 local and regional air districts in California, is dedicated to improving public health and providing clean air for all our residents.

I am writing to express CAPCOA’s opposition to the cruise industry’s proposal to amend the Coast Guard authorization bill, HR 5887, to allow ocean going vessel operators to participate in alternative “pilot projects” in lieu of compliance with the North American Emission Control Area (ECA) fuel requirements. This proposal would have substantial negative public health impacts for Californians.

California is a coastal state, with significant marine vessel traffic in our harbors and offshore. Over 80% of the state’s population is exposed to harmful ship emissions. Marine vessels are the largest source of sulfur oxide emissions in our state, and major emitters of particulate matter and oxides of nitrogen. These emissions are responsible for thousands of premature deaths annually in California.

CAPCOA has long advocated for measures to reduce marine vessel emissions. We have been strong supporters of the International Maritime Organization’s 2008 amendments to MARPOL’s Annex VI, which established the North American Emission Control Area (ECA). While we believed the 2008 ECA establishment was long overdue, today it is an essential complement to the California Air Resources Board’s (ARB) marine vessel regulations.

Allowing the pilot program as currently proposed in the cruise industry’s amendment will increase emissions and jeopardize public health. By allowing emissions averaging over a voyage, vessel emissions immediately offshore of California’s most densely-populated and polluted regions will increase, leading to greater health risks. Moreover, allowing ships to count emission reductions from port power and other coastal measures will effectively double-count reductions that would be occurring anyway and so would allow for even greater total emissions. Thus the proposed pilot, while ostensibly aimed at achieving equivalent emissions, will increase both overall emissions and specifically emissions in California’s most heavily impacted and populated regions.

The long-overdue ECA was finally established through a comprehensive process that included coordination with the shipping industry. The US Environmental Protection Agency (USEPA) has conclusively shown the technical feasibility and cost-effectiveness of the ECA, as well as its public health benefits. We join with our colleagues at both the USEPA and ARB in opposing this amendment proposed by the cruise industry, and urge you to do the same.
Sincerely,

Rick Martin
President
cc: The Honorable John Mica, Chairman
Committee on Transportation and Infrastructure
2187 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Nick Rahall
Ranking Member
Committee on Transportation and Infrastructure
2307 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Frank LoBiondo, Chairman
Subcommittee on Coast Guard and Maritime Transportation
2427 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Rick Larsen
Ranking Member
Subcommittee on Coast Guard and Maritime Transportation
U.S. House of Representatives
108 Cannon House Office Building
Washington, D.C. 20515
The Honorable Fred Upton, Chairman
Committee on Energy and Commerce
2183 Rayburn House Office Building
Washington, D.C. 20515
cc, continued:

The Honorable Henry Waxman
Ranking Member
Committee on Energy and Commerce
2204 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Dan Lungren, Member
Committee on Homeland Security
2313 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Loretta Sanchez, Member
Committee on Homeland Security
1114 Longworth House Office Building
Washington, D.C. 20515
The Honorable Laura Richardson, Member
Committee on Homeland Security
1330 Longworth House Office Building
Washington, D.C. 20515
The Honorable Janice Hahn, Member
Committee on Homeland Security
2400 Rayburn House Office Building
Washington, D.C. 20515
Elizabeth Adams
Deputy Director, Air Division
U.S. Environmental Protection Agency,
Region 9
75 Hawthorne Street
San Francisco, California 94105
Senator Diane Feinstein
United States Senate
331 Hart Senate Office Building
Washington, D.C. 20510
Senator Barbara Boxer
United States Senate
112 Hart Senate Office Building
Washington, D.C. 20510
Mary Nichols, Chairwoman
CARB
PO Box 2815
Sacramento, CA 95812

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