Contrary to the narrative of pristine ecosystems across Alaska, it’s actually federally legal for large vessels to dump smokestack washwater into the ocean. This is a fact many open loop scrubber-equipped cruise ships regularly take advantage of during tourism season. Even while they sell tickets based on ecosystem health, they dump unburnt fuel and heavy metals into the living ocean despite known consequences to food systems, marine mammals and human health.
Discharges are regulated within 3 miles of coastline by the 2013 Vessel General Permit (VGP). When it comes to the cruise ships that come up to Alaska, the VGP puts limits on discharges of scrubber washwater — a cocktail of heavy metals, nitrates and carcinogenic polycyclic aromatic hydrocarbons (PAHs) that are regularly dumped into the ocean by cruise ships operating with open loop scrubbers.
Already pretty weak, these washwater regulations were violated over 400 times in 2023 and over 300 times in 2024 by cruise ships in Alaska waters. These numbers are according to a report by the Southeast Alaska Conservation Council (SEACC) who pulled data from the hundreds of self-reported Clean Water Act violations showing exceeding limits of PAHs, pH levels, and particulate matter in discharges.
“It may sound insignificant when you’re talking about micrograms per liter or obscure measures like nephelometric turbidity units, but studies show ships burning heavy fuel oil with some scrubber systems are discharging 90 cubic meters of polluted wastewater per megawatt hour or more than 27 million gallons over a 24 hour period,” Aaron Brakel, the clean water campaign manager at SEACC, said. “And negative impacts have been observed in marine life like urchin larvae at extremely low concentrations.”
A noncompliant day would be a day that a ship dumps concentrations of pollutants and acid beyond the regulated amounts — results being harmful fluctuations in ocean pH and turbidity. SEACC found 423 violation days in 2023 and 334 violation days in 2024 from cruise ships while in Alaska waters. Neither precise times nor locations are required in annual reports, but SEACC was able to see when violations occurred in Alaska waters by comparing reported violation days to vessel tracking data.
The biggest offender (unsurprising after their 2024 “F” environmental report card rating) was Carnival Corporation & Plc, the corporation who owns subsidiary companies Princess Cruise Lines, Holland America Cruise Lines, and Carnival Cruise Lines. In total, their ships were responsible for every single one of the 334 violation days in 2024 and 423 violation days in 2023. That’s 757 violation days, of which multiple violations can occur in a single day, in the course of just two years when their ships are only here for a few months during tourism season.
“Carnival is just unable to meet even the weak limits of the VGP,” Brakel said. “I would say they’re kind of a villain in this case. They have routinely violated the effluent limits, and they’ve done so since they started discharging.” Just 17 Carnival Corporation & Plc ships are responsible for the over 750 violation days.
The impacts of this scrubber washwater are well documented and have been points of major discussion at assembly meetings and town halls here in Juneau. Concern is mounting in the light of studies showing demonstrable links between contents of washwater and higher rates of intestinal cancers in belugas, immunosuppression in marine mammals, eutrophication, and disruptions to zooplankton at the base of the food chain. In humans, PAHs have been linked to endocrine disruption, disrupted cognitive development and cancer.
Linda Behnken, the executive director of the Alaska Longline Fishermen’s Association and lifelong commercial fisher, harbors concerns about these permit violations on Alaska’s commercial seafood industry.
“Our fisheries are so reliant on clean water, for the health of what we eat and what we catch and sell, but also for the market dependence on Alaska’s pristine waters (as a) market identity for Alaska seafood,” Behnken said.
Behnken has concerns that this scrubber washwater will eventually increase heavy metal concentration in fish beyond the point of sale and consumption.
“There’s a lot of uneasiness about what’s happening,” said Behnken. “We all eat a lot of fish – and a lot of people in our communities eat a lot of fish for subsistence or commercial harvest, and there’s just a lot of concern about what the impact (scrubber discharge is) having on people’s health, as well as on the market reputation for Alaska seafood.”
According to Brakel, accountability for these discharges is slim to none.
“Nobody is holding anybody to account in terms of the limits that are already in the permit from what we can tell,” Brakel said. “At the federal level there’s zero scrutiny, zero compliance, and apparently no follow up that is identifiable because (the cruise ships) keep missing this. It’s like the EPA … just stopped caring.”
The extent of the repercussions Carnival Corporation has faced in response to these VGP violations was a 2018 fine of $14,500 and an agreement to improve scrubbers and adjust ship operations to try to offset further violations. According to Brakel, the EPA actually loosened the regulations for just Carnival Corporation while in Alaskan waters. The impact being Carnival Corporation operates under more generous dumping regulations, which they still manage to regularly exceed.
“They’re taking up all this life that’s in the water, and they’re just absolutely bombarding it with this dirty, acidic exhaust. It’s worse than anything that we experience in terms of exhaust because this heavy fuel oil is so much dirtier than diesel and it’s the direct stuff straight out of the (exhaust) stack,” Brakel said. “The conclusion I’m taking is that even with these weak standards, the scrubbers aren’t working and they’re not meeting compliance.”
This September, the VIDA regulations within the CWA will once again change as the USCG publishes their final decisions on permissible incidental discharges into federal waters.
“I think we had these big pulp mills in Southeast and we lived for a long time with the impacts of those pulp mills on the air and the water, and then they shut down and we watched things clear out and clean up and life come back,” Behnken said. “Now we’re letting it all happen all over again from a different source, and it’s just sometimes hard for me to believe we don’t learn.”
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.
