Statement in Support of EPA Considering Alaska as Part of a

Marine Emission Control Area

Purpose: “…describe the adverse health and environmental impacts
caused by OGV emissions to U.S. populations, terrestrial and aquatic
ecosystems, critical habitats, water quality, and areas of cultural and
scientific significance. …”

“Our most pressing need is for information which highlights the
environmental effects nitrogen and sulfur deposition may have on
Alaska's sensitive ecosystems.  Specifically we are interested in any
information about the effects NOx, PM, and sulfur emissions have on
human health or regional haze/visibility.  Any other environmental
impacts associated with NOx, PM, or sulfur emissions would also be
helpful. .. 

What would an Emission Control Area (ECA) mean?

Fuel Sulfur Limits (to address SOx and PM)

March 2010:  10,000 ppm in ECAs

2012:  Global cap falls to 35,000 ppm

2015:  ECA cap falls to 1,000 ppm

2020:  Global cap falls to 5,000 ppm - subject to a review in 2018; if
review indicates fuel will not be available, the date defaults to 2025

Position:  The Alaska Department of Environmental Conservation (ADEC)
encourages EPA to consider including Alaska’s coastline, including
Southeastern and South-central Alaska, the Aleutian Chain, the Northwest
and North Slope coasts, in the implementation of an Emission Control
Area (ECA).   

Air quality values protected by a future ECA in Alaska include public
health, addressing the Regional Haze Rule and visibility concerns, plus
ecosystem integrity, resilience and protecting Alaska’s subsistence
based cultures.

Background: 

Two of Alaska’s three major population centers (Anchorage and Juneau)
are coastal, with economies linked to fishing, marine commerce, and
tourism.  Alaska’s fishing industry and smaller population centers are
widely distributed along its coastline. With a warming climate and
changes in sea ice, the department anticipates increases in shipping
along the coasts of the Beaufort and Chukchi Sea.  Air pollution from
marine traffic can affect human populations both culturally and
economically; acid rain and runoff can adversely impact subsistence and
commercial food resources.  

Alaska Natives and rural Alaskans may have disproportionate exposure to
emissions from oceangoing vessels because of their heavy reliance on
subsistence foods and their proximity to marine traffic.  Alaska’s
Native children have higher rates of respiratory infections and other
lung ailments than other Alaskan children.  Both asthma and Respiratory
Syncytial Virus (RSV) are prevalent in Native, rural Alaskan children
and are of concern throughout rural Alaska. Though difficult to draw a
direct correlation between these health impacts and emissions from ocean
going vessels (OGVs), there are many communities located adjacent to the
shipping lanes in the Aleutians and in Southeast Alaska. Any effort to
reduce air quality emissions can potentially mitigate these health
concerns.

Impacts of Cruise Ship Sulfur Emissions in Alaska:

High sulfur emissions from cruise ships are visible as a blue haze that
hangs over Southeast Alaska towns frequented during the summertime. 
Periodically, this haze impacts the aesthetic quality of life for
locals, and ironically diminishes the views of Southeast Alaska for
tourists.  

ADEC estimated total sulfur oxide emissions from cruise ships during one
summer season using Juneau, Alaska as an example community. This
estimation did not include sulfur emissions from cruise ships underway,
only when in port, or “hotelling.”  From April 30 through September
27, 2008, there were 645 individual cruise ship visits to Juneau, or
nearly 4.3 visits a day on average.  When in port, cruise ships stayed
in Juneau’s harbor an average of 10.2 hours. Available data indicate
that one cruise ship can burn nearly 2 tons per hour of intermediate
fuel oil (IFO) 380, and nearly 0.5 tons per hour of marine diesel oil
(MDO) during hotelling. This equates to neatly 7,000 gallons of fuel
burned by one cruise ship in one hour. IFO 380 has a fuel sulfur content
of 2.5% or 25,000 parts per million (ppm); MDO has a fuel sulfur content
of 0.5% or 5,000 ppm. Based on these data, DEC estimated the total
sulfur oxide emissions from cruise ships hotelling in Juneau during one
summer season to be greater than 350 tons. These calculations suggest
that cruise ships are among the largest sources of sulfur oxide in
Alaska; aggregated sulfur oxide emissions in Juneau’s harbor are
larger than Cominco mine, large diesel electric utilities in remote
Alaska, and many of the North Slope oil and gas facilities.

Cruise ship traffic in southeast Alaska towns is on the rise, and
currently, there is no limit on the number of cruise ships that can
visit a port during any one day.  Currently, as many as six cruise ships
may visit Juneau per day, and Juneau is currently building additional
dock space to accommodate more cruise ships. These same cruise ships
then visit Skagway and Sitka on a daily basis.  On July 3rd, 2008, ADEC
staff witnessed a plume of visible cruise ship exhaust from nearly 3
nautical miles away as he approached  Skagway, Alaska (see Picture 1,
below).  As shown, this exhaust plume traversed the entire width of Lynn
Canal, the largest fjord in the world.  

Picture 1. Approaching Skagway on the Alaska State Ferry, July 3, 2008.

The following pictures were taken July 24, 2008 from West Juneau, on
Douglas Island, looking towards Juneau.  Weather conditions were fairly
typical this day with moderate winds blowing from the southeast, and
some light rain.  When the weather is humid, which is typical in Juneau,
cruise ship haze is more visible.

Pictures 2-4. Cruise Ship exhaust over Juneau, with Mt. Roberts in the
background. Alaska July 24, 2008.As the pictures show, the plumes from
each cruise ship comingle into a visible plume over Alaska’s capitol
city.  There were three cruise ships in Juneau when these pictures were
taken; this is below average.  On days when there are four or five
cruise ships, and other vessels in port, the plume is much more visible.
 

The last time air quality monitoring occurred in downtown Juneau was
nearly 8 years ago. The monitoring did not find violations of federal
sulfur oxide standards. At that time, PM2.5 was not monitored.  If
resources are available, ADEC is considering reinstating ambient
monitoring in downtown Juneau during the summer of 2009 to determine
current levels of PM2.5 and sulfur oxides.  This would provide updated
information on ambient air impacts from cruise ship emissions in the
port.

The most practical solution to the high levels of sulfur being emitted
into local communities from cruise ships in port is lowering sulfur in
the fuel burned by the cruise ships as part of a sulfur emission control
area (SECA). Using the same calculations as above and capping the sulfur
at 1% per the ECA requirements in 2010 reduces the tons per season of
sulfur emissions to a little over 300 tons. The 2015 cap of 0.1% sulfur
reduces the season sulfur oxides emissions to nearly 35 tons per year.
This is an impressive reduction. 

Regional Haze:

The visibility problems associated with high sulfur ship emissions
complicate Alaska’s ability to comply with the federal regional haze
rule. The regional haze rule establishes specific State Implementation
Plan (SIP) requirements and strategies for states to bring visibility in
designated Class I areas to natural conditions by 2064.  States must
develop long-term plans for reducing pollutant emissions that contribute
to visibility degradation and must establish interim goals aimed at
improving visibility in Class I areas. SIPs must address haze caused by
all sources of pollutants that impair visibility including haze caused
from smoke, vehicles, electric utility and industrial fuel burning, and
other activities that generate pollution.   Visibility in Alaska’s
Class I areas is impacted by uncontrollable sources of pollution, such
as wildfires, transport of pollutants from Europe and Asia, volcanic
activity, and sea salt deposition.  Fuel quality controls on mobile
sources, like marine shipping, are of paramount importance in addressing
regional haze impacts.  

Simeonof National Wildlife Refuge (NWR) and Tuxedni NWR are coastal
Class I areas of special concern for how to achieve visibility goals. 
The department believes that controlling emissions from ocean-going
vessels will be crucial to controlling regional haze in Alaska.  
Shipping and other port emissions from along the Pacific Coast have been
shown to contribute significantly to atmospheric aerosol concentrations
over large areas of the western United States (Xu et al. 2006; Dominguez
et al. 2008)).  Based on IMPROVE air monitoring, existing shipping
routes and modeled emissions along the Alaskan coast, ADEC believes
aerosols impact visibility at Alaska’s Class I areas. Figures 1 and 2
demonstrate that with even a cursory examination of Corbett’s work
(Corbett et al. 2006, 2007), we see major shipping lanes pass by
Simeonof NWR, a Class I area for regional haze purposes. 

Figure 1 (Corbett and Wang, 2006)

Figure 2 (Corbett et al. 2007)  

Anthropogenic sources of sulfur in the atmosphere typically dominate at
higher latitudes, 35-50 deg N (8% natural) and 50-65 deg (10% natural)
(Bates et al, 1992). Nevertheless, we have examined natural sources of
atmospheric sulfur near the Regional Haze Class I monitoring sites. 
Sulfate levels at Alaska IMPROVE sites are not correlated with volcanic
activity monitored by the Alaska Volcano Observatory, nor are they
correlated with sea salt which can sometimes be a significant source of
sulfur in coastal regions.  The sulfur dioxide from the Alaskan ports
emission inventory (Pechan, 2005) already exceeds that from the
permitted facilities in the Class I Area coastal counties. Ocean-going
shipping is not yet included in either inventory, but based on its
proximity to the Aleutian Archipelago, shipping will increase impacts
from the marine sector. 	

Evidence for elevated sulfate levels in pristine and remote areas of
Alaska 

Simeonof Class I area is located near the tip of the Alaska Peninsula
facing the Pacific Ocean. The nearest community is Sand Point nearly 60
miles to the north and with a population of around 900 people.  Sand
Point is home to an IMPROVE monitoring site in one of the most remote
areas in the United States. IMPROVE monitoring sites exist because of
regional haze rule requirements and have specific data collection
objectives and standards for use an. As such, IMPROVE monitoring sites
are reliable and comparable across different regions of the country.

The Sand Point/Simeonof IMPROVE monitoring site should be detecting
levels of sulfate that are very low.  However, sulfate levels detectable
at Simeonof are comparable to sulfate at IMPROVE sites in Redwood and
Point Reyes in the Lower 48. Denali and Glacier National Park IMPROVE
sites demonstrate LOWER levels of sulfate. Hawaii Volcanoes seems to
have a baseline lower than Simeonof, but has frequent spikes to much
higher levels which is consistent with volcanic activity. Not too
surprisingly, East Coast Class I areas (Acadia and Shenandoah) are much
higher. 

Why would Simeonof’s sulfate emissions be comparable to IMPROVE sites
much closer to major populations?  One potential explanation is volcanic
activity. The Aleutian Chain is home to many active volcanoes. The
signature of sulfate emissions from volcanic activity is episodic, with
steady levels interspersed with spikes of sulfate reflecting nearby
volcanic activity.  The levels seen at Simeonof, though indeed
influenced occasionally by nearby volcanoes, are consistently elevated
related to other Class I areas considering how remote the area is. 
Sulfate levels at Simeonof do not vary seasonally. Another explanation
is the IMPROVE site’s proximity to the Great Northern Shipping Route,
a commonly used shipping lane for cargo ships sailing from North America
to Asia.  See figure #2 for context. 

The regional haze rule has a number of requirements with which Alaska
must comply. States must develop long-term plans for reducing pollutant
emissions that contribute to visibility degradation and within the plans
establish goals aimed at improving visibility in Class I areas. The SIP
must address haze caused by all sources of pollutants that impair
visibility including haze caused from smoke, vehicles, electric utility
and industrial fuel burning, and other activities that generate
pollution. By 2064, visibility in Class I areas must reach background
levels. In the interim, goals of some percentage improvement in
visibility must be met. Of course, this presents a challenge in Alaska
which is already considered very close to “background”.  

Yet reduction of sulfate provides Alaska its most reasonable chance of
meeting regional haze requirements.  Monitoring at Sand Point shows
sulfate is a significant fraction of the total haze causing pollutants.
The other contributing emissions are, for the most part, uncontrollable.
(See “A Quick Look at Simeonof Class I Area Visibility” in Appendix
A at the end of this document). The data indicates that controlling
sulfates is the best option for meeting the required “glidepath”
goals.

Boreal and Arctic ecosystems are susceptible to damage from marine
emissions with potential subsequent impact on subsistence food
resources:

Industrial and naturally occurring aerosols cause ecological damage to
boreal and arctic ecosystems. Many reports, although not all, come from
industrial regions subject to a wider range of pollutants than solely
NOx and SOx.  Documented damage to northern ecosystems includes forest
and tundra defoliation, physiologic stress responses, changes in growth
rates, changes in biogeochemical cycling and soil deposition, changes in
species composition and life cycles, and large-scale changes in remotely
sensed land cover (Oppenheimer, 1989; Kryuchkov, 1993; Freedman et al.,
1990; Alexeyev, 1995; Rees and Williams, 1997; Virtanen et al., 2002;
Tutubalina and Rees, 1999, 2001; Savard et al., 2002; Addison et al.,
1984; Savard et al.,2004).  The effects of sulfur dioxide and other
sulfur compounds on vegetation, food webs, and ecosystem health have
also been widely documented for most other biogeographic regions.  

Three factors are of specific concern for Alaskan ecosystems: 

Lichens are important components of boreal, subarctic, and arctic
ecosystems, by anchoring food webs and influencing plant succession: 

Damage to lichen populations has widespread effects in Alaskan
ecosystems.   But, lichens are among the most sensitive organisms to
sulfur dioxide. Lichens are so sensitive they are frequently used as
biological indicators of sulfur pollution.  Examples, manuals, and
protocols for using lichens as bioindicators may be found at: 

 HYPERLINK "http://gis.nacse.org/lichenair/?page=reports"
http://gis.nacse.org/lichenair/?page=reports  (USDA Forest Service) and 
HYPERLINK "http://www.nhm.uio.no/botanisk/bot-mus/lav/sok_rll.htm"
http://www.nhm.uio.no/botanisk/bot-mus/lav/sok_rll.htm  (The
Bryologist).

A study conducted in areas within the Tongass National Forest in
Southeast Alaska found evidence of sulfur emission impacting lichen
communities. The study included specific efforts to determine patterns
of contaminant accumulation in lichens near downtown Juneau, on Mt.
Roberts (directly north of downtown Juneau), and at Greens Creek mining
facility on Admiralty Island (19 miles south of Juneau). Sulfur
exceeding Forest Service thresholds were found at all these sites, but
the Mt. Roberts results are particularly illuminating as the mountain
rises behind downtown Juneau and the docks where the cruise ships moor
(see pictures 2-4). Lichens from Mt. Roberts were above forest service
thresholds for sulfur at the 175, 600, and 910 foot levels (Dillman
2007). The authors conclude the main source of sulfur and nitrogen found
in lichens from Mt. Roberts is likely the burning of fossil fuels by
cruise ships and other vehicles and equipment in downtown Juneau.  

Lichen biodiversity and abundance have been inventoried at multiple
sites along the Alaska coast, including Class I Areas for regional haze,
National Parks, and National Forest lands (Talbot et al., 1992, 2000,
2001, 2002). The inventoried sites contain a wide variety of lichens
from the entire range of sulfur sensitivity, from those most susceptible
to sulfur dioxide to those less susceptible. Given the results of the
Forest Service study cited above and sensitivity of the lichen species
known to be present, we expect sulfur oxides emissions from marine
vessels to be already impacting coastal plant communities.

Subsistence Resources: 

Lichens are a particularly important food source for caribou, which in
turn are important to Alaskans as a subsistence food.  

One issue of concern and current research is the potential role damage
to lichens may be having on the Southern Alaska Peninsula Caribou Herd.
This herd’s range adjoins the Alaska coast near a major ocean-going
shipping route.  The Southern Alaska Peninsula Caribou Herd has been
decreasing in size, exhibiting both poor calf survival and low pregnancy
rates which are typically a sign of dietary stress (ADF&G, 2008; Manning
and Butler, 2007; Valkenburg and Keech, 2002).  The herd is now being
managed by predator control and a complete hunting ban, including a ban
on subsistence. There are few, if any, remaining options for management
of this herd. One area of ongoing attention is the food base for this
herd, including lichen where available. If regulation of marine fuels
could potentially enhance lichen biomass in the area, it would
contribute in turn to maintenance of an important subsistence resource
for local human populations.

Subsistence hunting and plant gathering activities by Native and
non-Native Alaskans include use of a wide range of marine and land-based
resources along Alaska’s coasts.  Air pollution affects these
resources in several ways.  Contaminants accumulate in the foods
themselves, and air pollution damages and changes ecosystems, making
food resources less available (Shannon, 1999).

Ecosystem resilience: 

Other areas of concern with marine shipping emissions are impacts on
ecosystems already stressed through climate change and potential for
acid rain in remote areas lacking current monitoring.

Climate change is serious in Alaska. Changes in temperatures, storm
activity, and sea ice stress Alaska Native and rural community abilities
to anticipate and adapt to changes in subsistence resources. How is it
affecting coastal ecosystems?  Alaskan ecosystems are already
disproportionately affected by climate change, with many indicators of
ecosystem stress present.  These indicators include melting permafrost,
declines in annual growth of dominant tree species, changes in shrub and
tree distributions, expanding pest outbreaks, increased methane efflux
from forests and wetlands.  Multiple stresses on ecosystems typically
act synergistically (Chapin et al. 2006, 2008; Arctic Climate Impact
Assessment, 2004; US Global Change Research Program, National Assessment
Synthesis Team.  2000).

Some Alaskan natural areas, such as Lake Clark National Park and
Preserve, have been identified as particularly susceptible to acid
deposition because of poor buffering capability of aquatic ecosystems.
Sources for airborne contamination in the Lake Clark region include
emissions from offshore oil/gas development in Cook Inlet, coal
extraction at the Beluga coal field, and international transport from
Asia and Europe (National Park Service, 2006). It may at some point be
possible to quantify how much sulfate from marine traffic is reaching
Alaska’s Class I areas and this national park (Dominguez et al.,
2008).

Participation in a marine ECA would diminish at least one of these many
stressors on Alaska’s ecosystems and would be one more protection for
maintaining Alaska’s ecosystems and the cultures that depend on them.



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Appendix A:

A quick look at Simeonof Class I Area Visibility: 

The regulatory requirement under the Regional Haze Rule is to improve
visibility on the worst days from 18.56 deciviews (dv) to 15.7 dv by
2064.  This is not a huge amount, but the control options are few.

How does sulfate affect visibility at Simeonoff?  This plot of light
extinction due to sulfate (Y-axis) against date (X-axis) shows that best
days (B) and worst days (W) have very different amounts of sulfate.

 

 

4.  If we take out the emission sources that we can’t control (sea
salt, organic carbon associated with wildfires, coarse mass (on a
coastal island, think silt), we get the plot below.  Of the controllable
aerosols, sulfate (in yellow) is the most important.  Controlling
sulfate is probably the best way, perhaps the only way, to improve
visibility at Simeonof.  

 

Image and data sources: 

Visibility Information Exchange Web System (VIEWS), Annual summary
tools: Composition
http://vista.cira.colostate.edu/dev/web/AnnualSummarydev/Composition.asp
x

Interagency Monitoring of Protected Visual Environments (IMPROVE), Air
Monitoring Data.   http://vista.cira.colostate.edu/improve/Data/data.htm

[File\pathname]	

[File\pathname]	

Skagway is located in this  fjord.

Simeonof

