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SCR selective catalytic reduction
SECAT Sacramento Emergency Clean Air Transportation (program)
SO
2
sulfur dioxide
SO
x
sulfur oxides
SWPPP Stormwater Pollution Prevention Plan
TBT tributyltin
TERP Texas Emission Reduction Program
TMDL total maximum daily load
VOCs volatile organic compounds (similar to hydrocarbons and reactive
organic gases, as some regulatory agencies commonly use)
g/bhp-hr grams per brake horsepower-hour (a measure of the amount of a
pollutant per engine energy output)
g/kWh grams per kilowatt hour (a measure of the amount of a pollutant per
unit energy output)
lb/MW-hr pound per megawatt hour (a measure of the amount of a pollutant per
unit energy output)
ppm parts per million
tpd tons per day
v
Strategies to Clean Up U.S. Ports
M
arine ports in the United States are major hubs of economic activity and major
sources of pollution. Enormous ships with engines running on the dirtiest fuel
available, thousands of diesel truck visits per day, mile-long diesel locomotives
hauling cargo and other polluting equipment, and activities at marine ports cause an
array of environmental impacts that can seriously affect local communities and the
environment. These impacts range from increased risk of illness, such as respiratory
disease or cancer, to increases in regional smog, degradation of water quality, and the
blight of local communities and public lands.
Most major ports in the United States are undergoing expansions to accommodate
even greater cargo volumes. The growth of international trade has resulted in
corresponding rapid growth in the amount of goods being shipped by sea. Despite
the enormous growth within the marine shipping sector, most pollution prevention
efforts at the local, state, and federal level have focused on other pollution sources,
while the environmental impacts of ports have grown.
Marine ports are now among the most poorly regulated sources of pollution in the
United States. The result is that most U.S. ports are heavy polluters, releasing largely
unchecked quantities of health-endangering air and water pollution, causing noise
and light pollution that disrupts nearby communities, and harming marine habitats.
In March 2004, NRDC and CCA issued report cards for the 10 largest U.S. ports
on their efforts to control pollution—or lack of efforts to control pollution. In the
short time since the grades were issued, steps to reduce port pollution have already
been made. For example, the first container ship in the world plugged into shoreside
power at the Port of Los Angeles. This report discusses solutions to port pollution
problems and provides additional information on the health and environmental
impacts of port operations; an overview of policies governing U.S. marine ports;
and detailed analysis and technical recommendations to port operators, regulatory
agencies, and community-based environmental and health advocates.
AIR POLLUTION AND HEALTH IMPACTS FROM PORT OPERATIONS
The diesel engines at ports, which power ships, trucks, trains, and cargo-handling
equipment, create vast amounts of air pollution that affect the health of workers and
people living in nearby communities and contribute significantly to regional air
pollution. More than 30 human epidemiological studies have found that diesel
exhaust increases cancer risks, and a 2000 California study found that diesel exhaust
is responsible for 70 percent of the cancer risk from air pollution.
1
More recent studies
have linked diesel exhaust with asthma.
2
Major air pollutants from diesel engines at
ports that can affect human health include particulate matter (PM), volatile organic
compounds (VOCs), nitrogen oxides (NO
x
), and sulfur oxides (SO
x
).
The health effects of pollution from ports may include asthma, other respiratory
diseases, cardiovascular disease, lung cancer, and premature death. In children, these
pollutants have been linked with asthma and bronchitis, and high levels of the pol-
lutants have been associated with increases in school absenteeism and emergency
room visits. In fact, numerous studies have shown that children living near busy
vi
EXECUTIVE SUMMARY
HARBORING
POLLUTION
Strategies to
Clean Up U.S. Ports
August 2004
diesel trucking routes are more likely to suffer from decreased lung function, wheezing,
bronchitis, and allergies.
3,4,5
Many major ports operate virtually next door to residential neighborhoods, schools,
and playgrounds. Due to close proximity to ports, nearby communities face extraordi-
narily high health risks from associated air pollution. Many of these areas are low-
income communities of color, a fact that raises environmental justice concerns.
Although cars, power plants, and refineries are all large and well-known sources
of pollution, Figure E-1 demonstrates that the air pollution from ports rivals or
exceeds these sources. In the Los Angeles area, oceangoing ships, harbor tugs, and
commercial boats such as passenger ferries emit many times more smog-forming
pollutants than all power plants in the Southern California region combined.
6
And
the latest growth forecasts predicting trade to approximately triple by 2025 in the
Los Angeles region mean that smog-forming emissions and diesel particulate pollu-
tion could severely increase in an area already burdened by the worst air quality in the
nation. The larger contribution of port sources to air pollution can be attributed to the
fact that pollution from cars, power plants, and refineries is somewhat controlled,
whereas port pollution has continued to grow with almost no regulatory control.
Figure E-1 uses the Port of Los Angeles and the Port of New York and New Jersey
as examples because they are the largest ports on the West Coast and East Coast,
respectively. The Port of Virginia is comparable in size to other large ports such
as Savannah, Houston, and Seattle. Figure E-1 also highlights emissions of NO
x
and PM, because these pollutants are associated with very severe health impacts.
7
Despite very conservative assumptions used to calculate port emissions, ports out-
pollute some of the largest sources of harmful emissions, raising the question, Should
ports be regulated like other large sources of pollution?
vii
Strategies to Clean Up U.S. Ports
Sources: Seaports of the Americas, American Association of Port Authorities Directory (2002): 127. U.S. EPA, National Emission Trends, Average Annual
Emissions, All Criteria Pollutants, 1970–2001, August 13, 2003. Energy Information Administration, Petroleum Supply Annual 1982, Volume 1, DOE/EIA-
0340(82)/1 (June 1983, Washington, DC), pp. 97-103 and Petroleum Supply Annual 2000, Volume 1, DOE/EIA-0340(2000)/1 (Washington, DC, June 2001),
Table 40. Energy Information Administration, Form EIA-861, “Annual Electric Utility Report.” As posted at www.eia.doe.gov/cneaf/electricity/public/t01p01.txt,
U.S. Dept of Transportation, Federal Highway Administration, 2000 Highway Statistics, State Motor-Vehicle Registrations.
0.0
5.0
10.0
15.0
20.0
25.0
30.0
35.0
Port of
Los Angeles
Port of
NY/NJ
Port of
Virginia
One-Half
Million
Cars
Average
Power
Plant
Average
Refinery
Tons Per Day
NO
x
EMISSIONS
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
Port of
Los Angeles
Port of
NY/NJ
Port of
Virginia
One-Half
Million
Cars
Average
Power
Plant
Average
Refinery
Tons Per Day
PM
10
EMISSIONS
FIGURE E-1
Nitrogen Oxides (NO
x
) and Particulate Matter (PM
10
) Pollution from Ports Compared to Refineries, Power Plants, and Cars
WATER POLLUTION FROM PORT OPERATIONS
Port operations can cause significant damage to water quality—and subsequently
to marine life and ecosystems, as well as human health. These effects may include
bacterial and viral contamination of commercial fish and shellfish, depletion of
oxygen in water, and bioaccumulation of certain toxins in fish.
8
Major water quality
concerns at ports include wastewater and leaking of toxic substances from ships,
stormwater runoff, and dredging.
LAND USE PROBLEMS AT PORTS
The highly industrialized operations at ports are often in close proximity to residential
areas, creating nuisances and hazards for nearby communities. Ports have several
available options to avoid developing new terminals near residential areas. They
can develop property previously used in an industrial capacity, or they can increase
efficiency of land use at existing terminals. The land use patterns at U.S. ports suggest
much room for efficiency improvements. Of the 10 largest U.S. ports, even those that
are most efficient in terms of land use—Long Beach and Houston—are four times less
efficient than the Port of Singapore, a model of land use efficiency.
PORT COMMUNITY RELATIONS
Ports can be bad neighbors. In addition to the air and water pollution they create,
they can cause traffic jams and can be loud, ugly, and brightly lit at night. These
impacts range from simple annoyances to serious negative health effects. For
example, noise pollution has been linked to hearing impairment, hypertension
(high blood pressure), sleep deprivation, reduced performance, and even aggressive
behavior.
9
At ports bordering residential neighborhoods, bright lights at night and the
flashing lights of straddle carriers and forklifts can affect nearby residents, disrupting
biological rhythms and causing stress and irritation.
10,11
Ports can also be bad neighbors by ignoring residents of the communities living
next door, or making little or no effort to solicit community input into operational
decisions that will directly affect the life of the community and its residents. Many
U.S. ports have developed decidedly hostile relations with their neighbors, not only
because of the pollution the ports produce but also because they have consistently
ignored residents of nearby communities, refusing sometimes even to share critical
information about possible effects of port operations.
RECOMMENDATIONS
The fact-finding for this report revealed untenable situations in many communities
near ports: freeways and neighborhood streets overloaded with trucks, homes coated
with soot, soaring asthma rates, containers stacked high enough to create significant
neighborhood blight, piles of dredged sludge forming toxic islands, and prime
marine animal habitats gouged by channeling. The following are recommendations
viii
Harboring Pollution
to port operators and policymakers on how to clean up port operations. The recom-
mendations, and the problems they seek to address, are described in greater detail
throughout the report.
Recommendations for Ports
Ports must commit to protect local communities and the environment, not only
during expansions but also during regular operations. Following are suggested
measures used by select ports worldwide to successfully decrease impacts on local
communities and ecosystems. These measures should be employed at all container
ports to clean up their operations, and local activists should be aware of these options
to advocate for their implementation. Ports should consider the negotiation of new
or modified leases as an important opportunity to require a combination of the miti-
gation measures, such as the use of cleaner fuels and equipment.
Marine vessels
Clean up harbor craft, such as tugboats, through engine repower and retrofit programs.
Limit idling of oceangoing vessels and tugboats by providing electric power at docks
and requiring ships and tugboats to “plug in” to shoreside power while at berth.
Require ships, including oceangoing vessels, to use the cleanest grade of diesel fuel
possible, with a sulfur content of 15 to 2,000 parts per million.
Where possible, create incentives for, or otherwise promote the use of, emission
controls on oceangoing vessels.
Cargo-handling equipment
Retire equipment that is ten or more years old and replace it with the cleanest
available equipment and fuel choices, preferably alternative fuels.
Retrofit existing equipment less than ten years old to run on the best available
control technology, including diesel particulate filters (DPFs) with lean NO
x
catalysts
(LNCs) and, if not feasible, with diesel oxidation catalysts (DOCs).
Switch to cleaner diesel fuels, such as low-sulfur fuel with sulfur content less than
15 parts per million and diesel emulsions.
On-road trucks
Create incentive programs that encourage fleet modernization, the retirement of
older trucks, and their replacement with modern lower-emitting trucks.
Offer incentives for the installation of pollution controls, including DPFs with LNCs
or, if not feasible, with DOCs.
Make cleaner fuels, such as diesel emulsions or low-sulfur diesel, available to
off-site trucks.
Minimize truck idling by enforcing idling limits or by installing idle shutoff controls.
Locomotives
Repower or replace all switching locomotives that do not meet the Environmental
Protection Agency (EPA) Tier 0 Standards with electric-hybrid or alternative-fuel engines.
Install engine emissions controls where possible.
ix
Strategies to Clean Up U.S. Ports
Require automatic engine shutoff controls to minimize unnecessary idling.
Commit to using cleaner fuels, such as on-road grade diesel.
Stormwater management
Take principal responsibility, as the general permittee, for preparing a stormwater
pollution prevention plan for all terminals.
Provide guidance to all port tenants for development of model stormwater programs,
oversight and inspections of individual terminals to confirm implementation of an
acceptable program, and education and training of terminal staff.
Carefully document and analyze potential water pollution problems, water quality
monitoring, and best management practices for the prevention, control, and treat-
ment of stormwater runoff.
Other measures recommended include water quality programs; traffic mitiga-
tion; land use, light, and noise abatement; improved aesthetics; and other terminal
design features.
Recommendations for Policymakers
In addition to the mitigation measures ports should implement on their own, a
number of policy and regulatory actions are needed to protect human health and
the environment from the large, industrial, and high-polluting operations at marine
ports. Ordinarily, such activities would be subject to stringent regulation, but over-
sight of ports falls between the regulatory cracks, defeated by confusion over
jurisdictional authority and the ongoing efforts of a strong industry lobby. While a
patchwork of international, federal, state, and local rules apply to various pollution
sources at ports, most are weak and poorly enforced.
Marine vessels
The U.S. government should officially ratify MARPOL Annexes IV and VI (an interna-
tional treaty that prevents sewage pollution and sets emissions standards for ships) and
the Antifouling Systems Convention, which bans toxic chemical coatings on ship hulls.
The EPA should expedite efforts to establish the entire East, West, and Gulf coasts
as control zones subject to stricter emission standards under MARPOL VI.
The EPA should implement a graduated harbor fee system similar to a program in
Sweden that requires more polluting ships to pay higher fees upon entering a port.
The EPA should expedite implementation of stricter emission standards for all
marine vessels within two years.
States and regional authorities should create financial incentives for the cleanup
and replacement of older marine vessels.
States and regional authorities should require ships to plug in to shoreside power
while docked.
States should require that ships use low-sulfur diesel while in coastal waters and at
berth (until electric power is made available). In the absence of state action, regional
authorities should require this.
Regional authorities should monitor and enforce ship speed limits.
x
Harboring Pollution
On-road and nonroad vehicles
The EPA must follow through with full implementation of its 2007 emissions
standards for on-road, heavy-duty trucks; its 2008 emissions standards for nonroad
vehicles and equipment; and the related lower sulfur diesel requirements.
The EPA should adopt a series of diesel retrofit rules, similar to those proposed
in the California risk reduction program, to establish a cleanup schedule for existing
polluting diesel engines. In the absence of federal action, states or local authorities
should adopt these programs.
The EPA should set uniform federal idling limits for all diesel engines. In the
absence of federal action, states or local authorities should require idling limits.
States should provide incentive programs to reduce pollution from heavy-duty
diesel engines, similar to programs such as California’s Carl Moyer and Gateway
Cities; in the absence of state action, regional authorities should sponsor such programs.
Regional authorities should adopt fleet rules to clean up and require new, cleaner
purchases of all heavy-duty engines, similar to those in place in the Los Angeles area.
Inland cargo transport
The EPA and individual states should consider fees on each container entering
a port to provide funding for mitigation of the environmental impacts of moving
those containers.
The U.S. government should adopt and support a sustainable transportation
system program, similar to the European Union program, facilitating the shift of
cargo transport from more polluting modes (such as trucking) to cleaner locomotive
and barge transport.
Locomotives
The EPA should implement stricter emission standards for locomotives within
one year.
States and regional authorities should also create financial incentives for the
cleanup and replacement of older locomotives.
States should negotiate memorandums of understanding that create incentives
for cleaner locomotives. In the absence of state action, regional authorities should
pursue this.
Land use
Regional authorities should improve efforts to protect marine habitats from further
infill due to port developments.
Regional authorities should work together with local communities and marine
terminals to improve efficiency and land use and to minimize impacts of terminals
on local communities.
Community relations
Neighboring states should work together in coastal alliances to protect their marine
natural resources and to share information on programs and technologies, and they
xi
Strategies to Clean Up U.S. Ports
should work together to jointly shoulder the neglected responsibility to neighboring
communities and their surrounding environment.
Stormwater
The EPA should issue effluent guidelines to require a general baseline level of
pollutant reduction for port facilities, or for those pollutants typically found in
port runoff.
States should ensure that anti-degradation provisions of federal and state law are
fully implemented in stormwater permits.
States should give special attention to the development of total maximum daily
loads (TMDLs) for impaired waters around many ports.
Local governments should prioritize port facilities when designing inspection
protocols in conjunction with local regulatory programs and implementation of
municipal stormwater permits.
Oil spills
Congress should pass the Stop Oil Spills Act (H.R. 880) to accelerate the phase-in
of double-hulled tankers in U.S. waters by 2007.
Regional authorities should require ports to take steps to ensure that oil pollution
does not become part of runoff and that portwide oil-recycling programs are in place.
Ballast water
The U.S. Coast Guard should finalize mandatory national ballast water regulations
as quickly as possible, or no later than the expected summer 2004 completion date.
States should adopt ballast water regulations, similar to those in place in California
and Washington, that ensure a 200-mile buffer from the U.S. coast.
Waste discharge
The EPA must consider more stringent requirements on the dumping of wastes
containing oxygen-depleting nitrogen and phosphorous, as well as persistent toxic
compounds that continue to threaten marine life.
CONCLUSION
Based on our previous survey of 10 of the largest container ports in the United States,
not nearly enough is being done to alleviate the severe impacts of the highly polluting
shipping industry despite real and significant environmental and health impacts
associated with marine port operations. Ports should take internal measures to
reduce pollution caused by port activities. Likewise, regulatory agencies at the
federal, state, and local level must provide long overdue safeguards. Further, if port
expansions are to continue, all projects must be mitigated to the maximum extent
possible, efficiency must be improved, and current operations should be cleaned up.
xii
Harboring Pollution
HEALTH AND
ENVIRONMENTAL
EFFECTS OF
PORT
POLLUTION
T
he economic benefits of marine ports are typically accompanied by signifi-
cant environmental and public health problems. Hundreds of enormous
diesel-powered ships, millions of diesel trucks, and other polluting equipment
and activities at modern seaports cause an array of environmental degradations
that, when uncontrolled, can severely affect the health and quality of life of
residential communities, as well as marine and land-based wildlife throughout
aregion. Among the environmental harm caused by pollution from marine
ports are a significant increase in regional smog, contamination of nearby
bodies of water, introduction of destructive invasive species, increased cancer
and other health risks for nearby residents, and blight on local communities and
public lands.
The specific sources of these various environmental hazards from marine
ports are many. They include:
Car and truck traffic, including thousands of diesel trucks servicing each of the
major ports every day
Rail and commercial ship traffic
Cargo-handling equipment
Chemical storage and handling
Fueling of ships, trucks, trains, and cargo-handling equipment
Liquid discharges from ships
Painting and paint stripping
Ship breaking (dismantling)
Maintenance and repair of roads, rails, grounds, vessels, vehicles, and equipment
Channel dredging
1
Even though marine ports are often associated with heavy industrial activities, they
are usually situated in or very near residential communities or environmentally sensitive
estuaries. A variety of negative environmental consequences commonly result, including
1
CHAPTER 1
HARBORING
POLLUTION
Strategies to
Clean Up U.S. Ports
August 2004
Air pollution from port operations and construction activities, including smog and
toxic particulate pollution
Loss or degradation of wetlands; destruction of fisheries
Loss of habitat of local endangered species
Contamination from wastewater and stormwater discharges
Severe traffic congestion
Noise and light pollution
Loss of cultural resources
Contamination of soil and water from leaking storage tanks and pipelines
Air releases from chemical storage
Solid and hazardous waste generation and soil runoff and erosion
2
MARINE PORTS ARE MAJOR SOURCES OF AIR POLLUTION
Many of the dirtiest sources of air pollution are concentrated at marine ports, often
creating a veil of brown haze that carries with it all of the severe health effects of
industrial and urban air pollution. For example, marine ports attract hundreds of
enormous oceangoing ships and tugboats, which burn the dirtiest grade of diesel fuel
available. Cargo is moved around shipyards by fleets of highly polluting heavy-duty
equipment, and it is delivered and taken away from those shipyards by millions of
heavy-duty container trucks and locomotives, many of which were built well before
emission standards were even considered. These and other port-related sources
combine to rival the worst pollution from power plants and refineries, accounting
for large percentages of the statewide air pollution in major shipping states.
Air pollutants emitted from port-related activities adversely affect the health of
port workers, as well as residents of nearby communities, and contribute significantly
to regional air pollution problems. The major air pollutants related to port activities
that can affect human health include nitrogen oxides (NO
x
), sulfur oxides (SO
x
),
ozone (O
3
) particulate matter (PM), diesel exhaust, and volatile organic compounds
(VOCs). Other pollutants from port operations—such as carbon monoxide (CO),
formaldehyde, heavy metals, dioxins, and even pesticides used to fumigate produce—
can also be problematic.
Health Effects from Diesel Exhaust
The vast majority of equipment employed at ports today runs on diesel fuel, emitting
a toxic brew of particles, vapors, and gases, including NO
x
, VOCs, and SO
x
.
3
In
addition to the pollutants just listed, diesel exhaust contains an estimated total
of 450 different compounds, about 40 of which are listed by the California Environ-
mental Protection Agency as toxic air contaminants with negative effects on health
and the environment.
4
Airway Irritation and Allergies from Diesel Exhaust
Many studies have shown that
diesel exhaust can irritate the nose, sinuses, throat, and eyes and damage the lower
airways. Studies of people exposed to diesel exhaust have documented eye and nose
2
Harboring Pollution
Cargo is moved
around shipyards
by fleets of highly
polluting heavy-duty
equipment, and it
is delivered and taken
away from those ship-
yards by millions of
heavy-duty container
trucks and locomotives,
many of which were
built well before
emission standards
were even considered.
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