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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:
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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.

I. 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 
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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.

Skagway is 

located in 

this fjord.
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Pictures 2-4. Cruise Ship exhaust over Juneau, with Mt. Roberts in the background. Alaska July 24, 2008.
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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. 

II. 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. 
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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)
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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 
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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 

Simeonof
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“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.

III. 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: 

1. 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: 

http://gis.nacse.org/lichenair/?page=reports (USDA Forest Service) and 

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 
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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.

2. 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 
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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).

3. 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).
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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: 

1) 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.

2) 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.

3. If we look at all the aerosols affecting visibility at Simeonof, we see that sea salt, sulfate, organic carbon, coarse 

mass, and elemental carbon,(represented by different colors below), are important. Sulfate, coarse particulates (CM), 

elemental carbon (EC), and organic carbon (OMC) and sea salt all contribute to visibility impairment (Y-axis) at 

Simeonof. 
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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.aspx

Interagency Monitoring of Protected Visual Environments (IMPROVE), Air Monitoring Data. 

http://vista.cira.colostate.edu/improve/Data/data.htm