Global scrubber washwater discharges under IMO’s 2020 fuel sulfur limit
Vancouver’s new scrubber restrictions mean cleaner waters
In a win for British Columbia’s waters and wildlife, the Port of Vancouver recently made good on its promise to prohibit ships from dumping contaminated scrubber washwater while at berth and at anchor, effective March 1, 2022. We expect this rule will eliminate 88% of in-port scrubber discharges, as explained in ICCT’s public comments and illustrated in the figure below. Our earlier work found that 252 of the ships that operated within the port’s navigational jurisdiction in 2019 (before the pandemic) had scrubbers installed as of the end of 2020. Those ships would normally discharge 10.8 million tonnes (Mt) of washwater in port waters. Instead, the port’s ban would prevent 9.5 Mt of water pollution from these ships. That’s enough to fill the Vancouver Aquarium’s largest pool, which holds 4.5 million liters of water (1 million U.S. gallons), more than 2,000 times!
It’s hard to overstate how much good this ban will do by preventing ships from polluting port waters that are home to endangered marine life and which support an important ecosystem. Before these restrictions, the Port of Vancouver was the fourth most impacted port in the world in terms of washwater discharges within 1 nautical mile of the port. With these new restrictions, it likely isn’t even in the top 100.
The remaining ~12% of discharges from ships traveling at cruising speeds (9.4%) and maneuvering (2.3%), which today would amount to approximately 1.25 Mt, will continue to be discharged inside the port’s navigational jurisdiction. But those, too, will be eliminated when the port moves to phase two, when all washwater discharges will be prohibited. The implementation date for phase two is still undetermined.
In a blog post a couple of months ago, we urged the Vancouver Fraser Port Authority to close what seemed like a cruise-ship-sized loophole in the ban, and I’m happy to share that they did. Here’s the original text from the scrubber ban:
The discharge of wash water from exhaust gas cleaning systems (EGCS) from all fuel combustion machinery (excluding main engines) into the environment is not permitted while a vessel is at anchorage or at berth within the Port of Vancouver.
The issue stems from the part about main engines and is related to the unique setup of cruise ship engines. Rather than one large main engine and one or more auxiliary engines, most cruise ships use a set of smaller diesel engines for both electricity and propulsion. If you want to get all philosophical about it, all the engines are both main engines and auxiliary engines. Because of this, ICCT’s public comments suggested deleting the text “(excluding main engines)” to avoid any confusion. And as our blog post showed, cruise ships are responsible for more than half of the scrubber washwater discharges in the port, so it’s important to get it right.
The Port Authority considered our suggestion and landed on this final text that went into effect March 1, with the new language underlined and in green:
The discharge of wash water from exhaust gas cleaning systems (EGCS) from all fuel combustion machinery (excluding main engines in use for propulsion) into the environment is not permitted while a vessel is at anchorage or at berth within the Port of Vancouver.
This is much clearer. Deleting the word “main” makes it clear that a stationary ship cannot discharge washwater, even if the exhaust being scrubbed comes from a so-called main engine. Further, adding the words “in use for propulsion” makes it clear that once the ship arrives at anchor or at berth and stops moving, scrubber discharges are no longer allowed.
One of the other public comments (not from ICCT) had asked the Port Authority to delay implementing the ban until it conducted additional studies and an environmental risk assessment. In response, the Vancouver Fraser Port Authority justified implementing the restrictions starting March 1 by citing a scientific study it commissioned that “showed that the discharge of scrubber wash water could result in levels of certain contaminants – such as cadmium, copper, mercury, and nickel and of polycyclic aromatic hydrocarbons (PAHs) – that exceed thresholds set for the protection of aquatic life within our jurisdiction.” The Port Authority also explained that it is applying the precautionary principle, but I would argue that the science is clear: Scrubbers pollute the marine environment. Our report for Environment and Climate Change Canada contains literature showing that scrubbers of all types (open-loop, closed-loop, and hybrid) discharge washwater that is more acidic and turbid than the surrounding water and which contains nitrates as well as PAHs and heavy metals that accumulate in the environment. PAHs and heavy metals have been linked to cancers and reproductive disorders in marine mammals, including Southern Resident killer whales whose critical habitat overlaps with the Port of Vancouver’s boundaries.
Kudos to the Vancouver Fraser Port Authority for taking decisive action to protect the waters under its jurisdiction. We look forward to phase two, when all discharges will be banned, not just when ships are at anchor or at berth, and phase three, when even closed-loop scrubbers in zero-discharge mode will be prohibited. The full ban in phase three is presumably because Emission Control Area-compliant fuel results in fewer total air pollution emissions than scrubbers, as we found in our report for Environment and Climate Change Canada.
Lastly, there was more good news just yesterday, when the Vancouver City Council unanimously approved a motion that cited our work and requested that the British Columbia government advocate to the federal government about scrubbers “as part of a comprehensive BC Coastal Marine Strategy.” Among the goals are stronger environmental protections “to include preventative measures to stop scrubber dumping from ships.” Indeed, the Port of Vancouver’s restrictions could provide a roadmap for other ports in Canada, the United States, and elsewhere. With Vancouver out of the fourth spot, a look at the data from our global scrubber report shows that ports like Port Everglades and the Port of Miami in Florida, which typically have heavy cruise ship traffic, now rank ninth and tenth in the world in terms of scrubber washwater pollution. Additionally, the port in Juneau, Alaska is thirteenth. So, who will be next to ban scrubber discharges?