Friday, January 17, 2025

The Scrubber Loophole in Alaska’s Cruise Industry

Concerns over Juneau’s relationship to the cruise ship industry have been on the rise in recent months. Between the Ship-Free Saturday campaign and the proposed West Douglas cruise port, many Southeast Alaskans are wondering if we might be crossing the line into overtourism.

Cruising has a large carbon footprint, one that’s eight times larger than a similar length land-based vacation according to the Friends of the Earth cruise ship report card. In 2015, in an effort to curb these emissions, the IMO capped maximum sulfur content in marine vessels — giving two options for vessels: burn cleaner and more expensive fuels or install exhaust scrubbers.

A scrubber runs seawater through a ship’s exhaust to extract sulfur, among other compounds. After being “scrubbed” of sulfur, the exhaust then has a lower sulfur content and can then be released into the air under IMO standards – a point the cruise ships have happily used to greenwash their services without sharing the full story.

“Basically the shipping industry was told to clean up its dirty fuel problem and instead they managed to get a loophole, which is the use of exhaust scrubbers,” said Aaron Brakel, the Clean Water Campaign manager at the Southeast Alaska Conservation Council. 

The scrubber option was given at a time when cleaner fuels were less available and more expensive than they are now. Cruise ship companies realized, however, that they could likely break even on the cost of installing scrubbers after just five years, and then not have to worry about ever paying an increased price for cleaner fuels. Fast forward to today and the use of scrubbers has helped companies negate their responsibility to cleaner operations.

The scrubber washwater, the mixed solution of sea water and exhaust contaminants, must go somewhere. In the case of the majority of large ships (larger than 1,000 passengers) that come to port in Juneau, it’s going directly into the ocean. Air pollution was swapped for water pollution, and is touted as an environmental success by many of these companies. 

“Instead of cleaner fuel, they’re now using this fundamentally unsound approach,” Brakel said.
“They’re taking this air pollution, and instead of burning cleaner fuel, they’re now just dumping this stuff straight into the water. It’s a serious problem, the studies were never done. They never did the due diligence to understand what the impacts to waters really would be around the world, and certainly they never did that work in Alaska.” 

It’s hard to overstate the environmental impact of these scrubbers. According to a Pacific Environment webinar on ending scrubbers, a single generator-and-scrubber-unit combination on a vessel can send an olympic-sized swimming pool’s worth of washwater into the ocean every hour, and, as Brakel states in the webinar, larger ships can have up to six generators on board. The amount of water getting polluted is alarming, and the acidic washwater contains metals, unburned oils and polycyclic aromatic hydrocarbons (PAHs) that are doing unknown harm to the living ocean system.

“The Inside Passage has served as the traditional highway, food system and vital resources hub for Tlingit, Haida and Tsimshian people for more than 10,000 years  — since time immemorial,” said Vivian Mork Yéilk’, an ethnobotanist and educator in Indigenous traditional foods and medicines. “It should be common sense that dumping scrubbed wastewater into the ocean is harmful to all living things.”

The EPA has not regulated scrubbers under the Clean Water Act, blaming a lack of data. Recently, however, Pacific Environment released a compiled document of 26 studies showing the adverse impacts of scrubber use. 

“Our food comes not just from the land, but from the ocean,” Mork said. “It’s absurd that those who claim to love this place are actively destroying it, especially when we have access to better fuels and advanced technologies that could prevent this harm. The cruise industry knows because the practice is banned in so many other places in the world. They are doing it on purpose to us. They know better and they’re not choosing better.”

A report by the Alaska Department of Environmental Conservation shows that every ship coming into Juneau with 1,000 or more passengers utilizes a scrubber system, and in 2023 two-thirds of the ships utilized an open-loop scrubber system, which means they are continuously discharging washwater into the ocean while operating. With more than 700 individual port calls to Juneau in 2023, the amount of scrubber discharge into the Inside Passage is absolutely monumental. It’s impossible to track, too, because reporting regulations don’t require ships to report the full scope of what or where they’re dumping, and the Ocean Ranger program that sent independent observers on board the vessels to track pollution was defunded in 2019. 

Proponents of scrubber technology defend this dumping with the idea that “dilution is the solution,” making the claim that proportionately speaking, concentrations of washwater in the ocean aren’t high enough to make any real difference. Recent studies, however, show this isn’t true: one shows that even a one-part-per-million ratio of washwater to clean ocean water has a negative impact on sea urchin, mussel and crustacean reproduction success rates. Another shows how PAHs and heavy metals, both present in the scrubber washwater, can bioaccumulate up the food chain and lead to cancer in marine mammals like killer whales. 

Despite claims about lack of published research and the blurred lines between state, federal and international waters, ports and nations around the world are taking actions against scrubbers. Currently there are 93 bans on scrubbers, with recent bans coming out of Denmark and Sweden. More than half of the bans in practice have been implemented by the port, suggesting that if change is going to be made in Alaska, it may be on Juneau as an individual port to make the first move. Right now, California is the only state in America with any type of scrubber regulation. Precedent is on Alaska’s side if we seek to do the same.

“When they come to Alaska waters,” Brakel said, “they need to stop burning the dirty fuel. We think that the DEC [Department of Environmental Conservation] has a place in this and the legislature probably needs to have a say.” 

Ships need to be required to burn the available, cleaner fuels. The exhaust from these fuels are cleaner than the exhaust being released from the current fuels, even after they’ve been scrubbed; thus mitigating the need for a scrubber to begin with.

“Everyone has a responsibility to care for the land in Alaska,” Mork said. “This stewardship extends to individuals, communities, cultures, cities, state, federal, and even businesses at every economic level.”

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Rachel Levy is a Juneau-based photojournalist whose work culminates at the intersections of environmental justice, arts and culture, and sustainable tourism. A 2022 graduate of Harvard University's Environmental Policy program, she is also the director of the award-winning documentary "Hidden in Plain Sight" that exposes the labor exploitation and colonial framework burdening Tanzania's safari industry.

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