United States and Maritime Shipping Emissions Policies

Term Paper 2016 27 Pages

Politics - Environmental Policy


Table of Content











The maritime freight industry is a major contributor to global greenhouse gas emissions. If current practices continue, experts predict that it will account for 17% of total emissions by 2050. Both the United States government and the International Maritime Organization have enacted strict regulations to promote the industry’s adoption of alternative sources of fuel in an effort to reduce the amount of sulfur oxides and other pollutants released from container ships. This research sought to connect whether or not the United States and International Maritime Organization sulfur fuel enforcements have allowed container ship companies to catalyze an industry-wide shift in shipping practices.

To answer my questions, I analyzed relevant container ship policies by the United States government within the last ten years as well as regulations in place by the International Maritime Organization specifically addressing sulfur level reduction. I then analyzed the archives of container ship companies in search of sustainability initiatives or alternative fuel adoption underway.

In gathering results, I found evidence suggesting the United States federal government has enacted sufficient standards in attempting to limit sulfur emissions from container ship engines within its coastlines. Additionally, I recognized that the International Maritime Organization is committed to reducing sulfur emissions in the fastest way possible by establishing Emission Control Areas in coastlines as well as instituting tight regulations to limit sulfur content in ship fuel. Third, reports show that the industry is struggling to adopt clean fuel, due to high market costs and demand, but have been able to meet the fuel standards through alternative and cheaper methods.

These results are applicable to only container ships or vessels of that size, as smaller vessels have different engine standards. Moreover, this research was concerned specifically with North American standards, meaning that the same results may not be found in other areas of the world. The research I conducted serves as insight for the public into a relatively unknown aspect of transportation-related environmental issues. It also functions as a platform upon which the dangers of human-caused climate change can be addressed.


In the current era of globalization, the maritime freight shipping industry is undergoing a major transition to more sustainable and environmentally viable practices. These new practices also attempt to maintain similar economic benefits to those under current operations. Many container ships operate with heavy fuel oil[1], which causes the ships to emit toxic chemicals like sulfur oxides and nitrogen oxides into the earth’s atmosphere. Currently global shipping accounts for 2 % of all greenhouse gas emissions. Studies show that if current practices remain unchecked, the industry’s contribution to greenhouse gas emissions will increase to 17% by 2050 and would result in an additional 200 thousand premature deaths if not addressed by 2020[2].

The purpose of this report is to analyze the efficacy of the United States government’s initiatives to reduce sulfur oxide and nitrogen oxide emissions in conjunction with international standards on global shipping. It intends to discuss how container ship companies can operate in an environmentally conscious manner, per U.S. and international standards, while maintaining economic success. These standards are beneficial in reducing sulfur oxides from the atmosphere. However, it is a challenge for container ship companies to keep pace with the new standards due to high market costs and low supply of clean ship fuel. This paper will also discuss the effectiveness of environmental standards by the United States to address emissions from container ship exhausts, the long-term impact of international agreements reducing sulfur emissions, and the methods container ship companies are adopting to comply with the global emission standards.


As the effects of climate change have rapidly encompassed the marine environment, the demand has grown for alternative green technology in major industries, including maritime freight shipping. Container ships are a vital component to the international trade economy. However, they are also responsible for emitting sulfur oxides and other pollutants into the earth’s atmosphere at a largely unchecked rate. While a lot more must be done, the United States commitments and regulations, with the oversight by the International Maritime Organization, and industry adaptation, have proved critical in reducing the effects of sulfur emissions from container ships.

With regard to the United States’ attention to combat sulfur fuel emissions, the National Oceanographic and Atmospheric Administration (NOAA) and the California Air Resources Board conducted a study on ships built in 2009 operating under California marine regulations that require container ships to switch to lower-sulfur bunker fuel within 24 miles of the California coast. The study found that low-sulfur bunker fuel cut sulfur emissions by 91%, and also lowered black-carbon emissions by 41% (Peckham, Jack 2011)[3]. Cutting these emissions has resulted in widespread health benefits for people living near shipping lanes. For example, the study noted that emissions reductions could prevent over eight thousand deaths as well as ease respiratory symptoms for another three million people per year for those living on the west coast (Peckham, Jack 2011). The study also reported that ships no longer emit the same amount of pollution as in the past, concluding that the California marine regulation is effective in reducing emissions.

In addressing the economic costs related to ship-caused air emissions, Kevin Gallagher explained how international trade by the United States is causing the rising levels of sulfur emissions and their contributed costs. Gallagher maintained that by obtaining an analysis of sulfur oxides and nitrogen oxides, policymakers at the federal level have the factual ammunition to pass regulations within the marine shipping sector. In his article, he showed that the costs range from $697 million to $3.7 billion between the years 1993 and 2001 (Gallagher 2005)[4]. Explaining the economic difference between sulfur oxides and nitrogen oxides, Gallagher maintained that simply switching fuel abates sulfur oxides. On the other hand, nitrogen oxides are more difficult to mitigate because doing so involves the need to change engine combustion technology. Dealing with nitrogen oxides in this way was more expensive, costing $2 billion between 1993 and 2001 (Gallagher 2005).

Gallagher also found that between 1977 and 1987, domestic cargo emissions increased by 24% and foreign cargo decreased by 18%. In contrast, between 1993 and 2001, foreign cargo emissions increased by 28% while domestic cargo had decreased by the same percentage (Gallagher 2005). Gallagher further reports that this shift is due to increased U.S. involvement in international trade agreements like the Uruguay Round[5]. Because of this trade agreement, data showed that the increase in international trade is responsible for $542 million in sulfur oxide emissions and $745 million in nitrogen oxide emissions (Gallagher 2005). Gallagher concluded that without active policy initiatives by the U.S. federal government, these reported costs will only go up.

In relation to the broader concept of sulfur emissions and international shipping, a study conducted by the Journal of the Air and Waste Management Association recorded the benefits of clean fuel usage within the Gulf of Mexico. The report found that the switching to marine gas oils[6] (MGO) significantly decreases sulfur oxide emissions, negative health symptoms, and ecological impacts within the designated North American Emission Control Area. The investigative team performed port emissions inventories on three ports in the U.S. and Mexico—Port of Houston, Port of Veracruz, and Port of Alta Mira. Results generated from the case studies found significant reductions in average sulfur dioxide concentrations from container ships within the North American Emission Control Area (Browning, L., et al., 2012)[7]. For example, data showed that “about 52,000 kg of sulfur deposition could be avoided to the reef and island network surrounding Veracruz if all vessels calling on the port were to move to a fuel switching regime within 24nm of shore” (Browning, L., et al., 2012).

In Plymouth, England, a team from the Penlee Point Atmospheric Observatory measured the count of atmospheric sulfur dioxide in the surrounding coastal area. In their study the team found that air from the southeast was heavily affected by emissions from ships in the English Channel. The International Maritime Organization ruled in January 2015 that Emission Control Areas like the English Channel require a tenfold reduction of maximum allowed sulfur in a ship’s fuel count to .1% (Yang, M., et al., 2016)[8]. Based off of the Emission Control Area regulation, as well as its findings, the Penlee Point team recommended a three-fold reduction in ship-emitted sulfur dioxide between 2014 and 2015 (Yang, M., et al., 2016). Results showed that most European ships complied with the IMO regulation, as approximately 70% ships in 2014 were already operating at emission levels below the 2015 cap (Yang, et al. 2016).

There are few scholarly articles about the sulfur fuel caps that were instituted by the IMO in October 2016. Thus, information regarding relevant and recent impacts to container ship industry comes from news articles. The .5% global sulfur cap was proposed in 2008, allowing shipping companies to adjust their ships’ fuel content. In 2014, in anticipation of the then-upcoming sulfur fuel cap, one such article from Marine Log in 2014 addressed the financial burdens of low-sulfur fuel and how they can negatively impact shipping companies beginning in 2015. There was a reported 50% potential increase in fuel costs as well as a rise in freight costs for ship operators in anticipation for the January 1, 2015 (Marine Log 2014)[9].

Additionally, an expert within the container shipping industry, Kevin Workman of APL Limited, argued that a shift to low-sulfur fuel oil would cost the industry $100 million. For example, one of the shipping giants, CMA CGM, stated that a switch to a Marine Diesel Fuel at .1% sulfur content would cost the company an additional $100 million annually (Marine Log 2014). Numerous parties cited in the article argue against low-sulfur fuel oil not only because of its financial consequences but also because of propulsion problems in the engines. From 2009 to 2013, a reported 336 propulsion loss incidents occurred off of the California coast, with 106 caused by fuel switching (Marine Log 2014).

In contrast to the Marine Log article, the Journal of Marine Science and Technology discussed the economic analyses of LNG operated container ships traveling on trans-oceanic voyages. The analysts compared LNG ships to traditional oil fuel ships operating with sulfur reduction systems by plotting graphs with hypothetical data and setting market prices. LNG fuel was calculated at $440 per cubic meter against heavy fuel oil’s $720 per ton[10] (Adachi, M., et al, 2014). Graphs showed that container ships with heavy fuel oil had a better-cost performance than an LNG ship. However, results showed a favorable market value for LNG[11] fuel over heavy fuel oil.

The study did acknowledge the challenges in constructing and operating trans-ocean LNG-fueled ships. Yet it reported a higher net present economic return from ships with LNG fuel than with oil fuel. Furthermore, the team concluded that LNG is both an environmentally and economically viable option, as it cancelled out the initial cost gap between an oil-fueled container ship and the LNG-fueled container ship (Adachi, M. et al 2014). This provides evidence to counter the central historical argument for shipping companies to continue using bunker oil, namely that they wouldn’t sacrifice their economic returns for the sake of transitioning to cleaner fuel.

Likewise in 2012, a study by a team at the University of California at Riverside proposed mitigation strategies for container ships—clean engines and clean fuels. Observing its data for a 2010 container ship, the team recognized that the overall in-use nitrogen emissions were below the Tier 1 certification and lower than the benchmark value use for conducting emission inventories. In other words, they found that a clean fuel switch at a regulated boundary would reap significant emissions benefits with concentrations of sulfur dioxide taking 55 minutes to reach steady state when switching from Marine Gas Oil to Heavy Fuel Oil (Khan, M., et al. 2012)[12]. The team then concluded that container ships travel up to 90% of the distance to the port on average if they change fuel at the regulated boundary. Moreover, they recommended an increased fuel switch boundary to fully benefit from a fuel change regulation that would, in turn, benefit the local populous living near ports.

Overall, this research paper will seek to build upon the findings from the primary and secondary sources by evaluating the contributions of the United States government, the International Maritime Organization, and the shipping industry. As discussed earlier in the literature review, countries are moving to adopt more environmentally efficient marine transportation operations. The continued collaborated effort among the aforementioned actors will shorten the necessary time to fully mitigate the long-term effects of sulfur emissions from container ships.


A. Environmental Protection Agency

The Environmental Protection Agency (EPA), which monitors the protection of human health and the environment, is the U.S. government’s primary body in enforcing maritime emission standards. The EPA classifies Sulfur Dioxide (SOx), as a primary pollutant. A primary pollutant is a gas that is directly emitted into the atmosphere from the source, like a ship’s exhaust. Nitrogen oxides (NOx) and particulate matter (PM) emissions are designated as secondary pollutants, which form in the atmosphere when primary pollutants react with other compounds[13].

In 2009, in an attempt to address sulfur fuel reduction in large container ships that affect U.S. air quality, the EPA set forth new emission standards called Standards for Control of Emissions from New Marine Compression-Ignition Engines at or Above 30 Liters per Cylinder. These standards combined the Clean Air Act standards and international standards established in MARPOL Annex VI[14]. This EPA regulation is expected to reduce annual emissions of nitrogen oxides (NOx) in the United States by 1.2 million tons by 2030[15].

In April 2010, the EPA stipulated that vessels could use other methods to reduce Sulfur Oxide emissions equal to those obtained by use of lower sulfur fuel. The EPA now also provides fuel availability relief provision for vessels with diesel engines on the Great Lakes and Saint Lawrence Seaway, a vital thoroughfare for Canadian and United States ports. Moreover, the ruling also amended the Clean Air Act for Category 3 engines, which include large marine diesel engines used by large oceangoing container ships, oil tankers, bulk carriers, and cruise ships. Three levels of Category 3 engine regulations, Tier I...III standards, were established over a length of twelve years to gradually phase out the use of sulfur in diesel engines.


[1] Heavy fuel oil is a type of crude oil used aboard oceangoing vessels. It comes from the bottom of oil barrels

[2] MarineLink. “Delay of Shipping SOx Law Could Endanger 200k Lives-Study.” Last modified October 12, 2016

[3] Peckham, J. “U.S. NOAA Study: Low-Sulfur Bunker Fuel Cuts Diesel Emissions Up to 90%.” Diesel Fuel News. Last modified September 19, 2011

[4] Gallagher, K. “International trade and air pollution: Estimating the economic cost of emissions from waterborne commerce vessels in the United States.” Journal of Environmental Management (2005): 99-103, accessed December 5, 2016, http://dx.doi.org/10.1016/j.jenvman.2005.02.012

[5] The Uruguay Round occurred as a multilateral trade discussion during the General Agreements on Tariffs and Trade (GATT) summit from 1986-1994)

[6] Marine gas oil is a distillate that does not have any traces of residual fuel. It is a general purpose fuel, usually found in engines smaller than 5 liters per cylinder

[7] Browning, L., Hartley, S., Bandemehr, A. “Demonstration of fuel switching oceangoing vessels in the Gulf of Mexico.” Journal of the Air & Waste Management Association (2012): 1093-1110, accessed December 4, 2016, http://proxy.lib.umich.edu/login?url=http://search.proquest.com.proxy.lib.umich.edu/docview/1467993830?accountid=14667

[8] Yang, M., Bell, TG, Hopkins F., et al. “Attribution of atmospheric sulfur dioxide over the English Channel to dimethyl sulfide and changing ship emissions.” Atmospheric Chemistry and Physics (2016): 4771-4783, accessed December 5, 2016, doi: 10.5194/acp-16-4771-2016

[9] Marine Log. “Rough waters ahead in 2015 for shipping: switching to low-sulfur fuel could present a number of challenges for ship operators.” Last modified 1 November 2014.

[10] Adachi, M., Kosaka, H., Fukuda, T. et al. “Economic analysis of trans-ocean LNG-fueled container ship.” Journal of Marine Science and Technology (2014): 470-478, accessed December 5, 2016, doi: 10.1007/s00773-014-0262-5

[11] Liquefied natural gas is a gas converted to liquid form for ease of transport. It is a clean fuel that has a significantly reduced sulfur content

[12] Khan, M., Giordano, M., Gutierrez, J. “Benefits of Two Mitigation Strategies for Container Vessels: Cleaner Engines and Cleaner Fuels.” Environmental Science and Technology (2012): 5049-5056, accessed December 6, 2016, doi: 10.1021/es2043646

[13] Acid rain is the most well-known secondary pollutant, which is caused by a reaction between sulfur oxides and water in the atmosphere

[14] MARPOL Annex VI was adopted in 1997 by the IMO and came into effect in 2005 to strengthen emission limits of sulfur oxides (SOx), nitrogen oxides (NOx), and ozone depleting substances (ODS)

[15] Appendix Figure A provides a timeline of major regulations from the EPA and the IMO that relate to sulfur emissions


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Title: United States and Maritime Shipping Emissions Policies