air pollution?

According to an EPA-reviewed study, a cruise ship idling at berth for 10 hours, using 0.1% sulphur level fuel, emits 28,904 grams of SO2 which is the equivalent of 34,409 trucks idling for the same time period.

In the 2022 cruise season, ships were berthed in Victoria for 2223.5 hours, equivalent to 7,650,952 tractor-trailers idling and 6.42 metric tonnes of SO2.

Do cruise ships have a history of polluting the local air?

It appears so.  Air quality has been monitored in James Bay since 2006 and indicated increased sulphur dioxide (SO2) levels during the cruise seasons.  In 2011, a single SO2 monitor was placed in James Bay by the Ministry of Environment.  As soon as the monitor was in place, SO2 levels almost halved as the cruise lines moved the most polluting ships off the Alaska route. 

What are current air emission standards for ships?

In 2012, the North American Emissions Control Area (ECA) Agreement required ships to reduce sulphur dioxide emissions to 0.1% levels.  In 2020, the International Marine Organization (IMO) mandated that ships meet emission levels of 0.5% globally. 

Cruise ships bound for Victoria have to meet the 0.1% standard when they are within the North American Emission Control Area - which includes Victoria. They must meet the 0.5% global requirement in Canadian waters outside of the ECA.

What was the intent of mandating lower sulphur air emissions standards?

The intent of IMO and ECA regulations was to reduce air pollution by having ships switch to use low sulphur marine gas oil (MGO) rather than cheaper heavy fuel oil (HFO). However, the IMO allows the use of Exhaust Gas Cleaning Systems (EGCS), also known as scrubbers, to comply with their regulations. Since the introduction of these regulations, the majority of cruise ships have installed scrubbers to continue to use cheaper heavy fuel oil.

What are scrubbers?

Ship scrubbers use seawater or freshwater to remove sulphur and other contaminants from a ship’s exhaust when heavy oil fuel is used - thus reducing emissions released into the air to comply with international SO2 air emission regulations. Scrubber wash water is often released directly into the marine environment and discharges contain pollutants such as metals, hydrocarbons, and acids. Scrubbers turn air pollution into ocean pollution.

Do scrubbers eliminate air pollution?

No. They are effective at reducing sulphur emissions, but do not eliminate air pollution.  Researchers at the International Council for Clean Transportation found that “even with scrubbers, ships will continue to emit air and climate pollution emissions such as particulate matter, sulfur oxides, nitrogen oxides, black carbon and carbon dioxide.”

The use of scrubbers with heavy fuel oil in Emission Control Areas exacerbate air quality concerns in areas designated by the IMO to be safeguarded from such impacts. Scrubbers also do not mitigate GHG emissions.

Do scrubbers increase ocean pollution?

It appears so. Contaminants in scrubber discharge wash water include metals, hydrocarbons, sulfurous and nitrous acids, and turbidity that can contribute to long-term contaminant loading to the marine environment, especially in ecologically vulnerable and sensitive areas such as coastal waters, semi enclosed seas and ports and harbours.

A 2019 Port of Vancouver modeling study showed that scrubber wash water discharge in Burrard Inlet could result in concentrations of metals that exceed federal and provincial thresholds set for the protection of marine aquatic life. The port banned scrubber discharges at berth and at anchorage in 2022 and is evaluating additional restrictions.

How have other countries reacted to the use of scrubbers?

Many governments and ports around the world have restricted or banned the use of scrubbers, including California, Norway, China, Saudi Arabia, Portugal, Sweden, Malaysia, Dublin, Seattle. 

What about Canada?

In Canada, five of Canada’s seventeen federal port authorities, have restricted scrubber use in their ports, including Vancouver and Prince Rupert. 

From November 2024 to January 2025, Transport Canada conducted consultation on vessels using scrubber systems in Canadian waters.  The results have not yet been released.

Environment and Climate Change Canada conducts ongoing research and investigations on scrubber use in Canada.  In 2023-24, fourteen of the inspections conducted in the Pacific and Yukon Region were directly related to cruise ship discharges, including scrubber wash water.  No further information on the outcome of these investigations is currently available as the matter is ongoing.

What is the most effective way to reduce air pollution?

IMO guidelines set no limits on any air pollutant other than SO2. Scrubbers tend to meet SO2 limits, however, they are not as effective at reducing other air pollutants. Currently, the most effective way to reduce air pollution is the use of low sulphur marine gas oil.

What about shore power?

Shore power is a ship-at-berth solution only. It reduces harmful air emissions and GHG emissions while cruise ships are docked. However, shore power does not address air pollution while ships are transiting and maneuvering in our harbour and beyond.

Does Victoria have shore power?

No. The installation of shore power at Ogden Point has been discussed for many years.

In April 2023, the Province of British Columbia announced a $9 million contribution towards detailed engineering designs for shore power at Ogden Point.

In 2024, the GVHA reported that a business case was presented to the Board in June 2024. Cost and complexities were identified as key challenges. They are exploring the potential of emerging technologies. That could include barges carrying large batteries that could be recharged electrically or use of a lower carbon fuel to recharge them. A Hydro interconnectivity study was expected to be presented to their Board in June 2025.

In February 2025, the federal government announced that it is providing $22.5 million for shore power at Ogden Point. A February 11, 2025 Times Colonist stated that “It won’t happen immediately. The Greater Victoria Harbour Authority is carrying out a business planning process for the project that includes speaking to B.C. Hydro and cruise lines about their power needs… It is too soon to set a target date for shore power or to announce the project’s total cost…”  Ogden Point to get $22.5 million for shore power - Victoria Times Colonist

In 2019, installing shore power at Ogden Point was estimated to cost about $24.8 million.  So far, the provincial and federal governments have contributed $31.5 million towards shore power, with no target date in sight. It is unknown how much the City of Victoria would have to contribute to infrastructure costs to bring shore power to Ogden Point.  It is also unknown how much the cruise lines would contribute.

Who should pay for shore power?

Fair Sailing advocates for cruise industry-funded installation (no use of taxpayer money) and maintenance of shore power in Victoria with mandatory use or infrastructure contribution fees by all ships, as data from other ports show that many ships do not connect to shore power, even when it is available.

Most ports that have received provincial or federal shore power funding provide essential trade and cargo services.  Odgen Point does not. It is essentially a cruise ship terminal.

It is unclear how much the cruise industry would be willing to contribute to shore power in Victoria. At the July 2022 CRD Board meeting, the former CEO of the GVHA announced that a significant member of the cruise line industry had committed support for the payment structure on how cruise lines will pay for the installation of shore power. No details have been released.

A fee of $10 for 1 million cruise passengers a year could raise $30 million in three years to pay for shore power installation.

Do cruise ships connect to shore power in other ports?

Even if cruise ships are shore power capable, many choose not to connect as shown in Vancouver and Seattle. California now mandates use and Seattle will in 2027.

In Victoria, the majority of cruise ships arrive after 7 pm and leave at midnight. It is estimated that ships must continue running engines for up to three hours total during shore power connect/disconnect procedures, so compliance for ships berthing for less than 5 hours is uncertain and may allow not enough time for passengers to disembark and return to the ship.

What conditions would be required for shore power to work in Victoria?

There are three conditions for shore power to be a successful local at berth solution: ship capability, port mandates to use and/or pay for the infrastructure, and scheduling to maximize access/hook up.

What about greenhouse gas emissions?

According to a study commissioned by the Greater Victoria Harbour Authority society, GHG emissions from terminal activities accounted for 3.3% of the City’s annual GHG emissions in 2018. Cruise emissions accounted for 96.3% of all emissions at the Victoria Cruise Ship Terminal.

From 2010 to 2018, Victoria Cruise Ship Terminal GHG emissions increased 19.1%. Since then, the total hoteling time at the terminal, when ships are docked but running generators, has increased as more cruise ships visit the port.

When three cruise ships are in port, their hourly GHG emission rate is equivalent to 45% of the City of Victoria’s hourly emission rate (based on Synergy’s 2018 study).

In addition, cruise tourism generates GHG emissions from taxis, highway style buses (which idle for long periods at the site), large industrial waste trucks, and landfilling.

In 2021, Canada signed the Clydebank Declaration as part of COP26 to support the establishment of green shipping corridors that reduce greenhouse gas emissions from ships.  The goal is to establish zero emissions maritime routes between two or more ports; however, participation and commitments are voluntary.

Air Pollution or Ocean Pollution?

Air pollution and ocean pollution have become interconnected with the use of scrubbers.  Scrubbers reduce SO2 air emissions.  However, using scrubbers in connection with heavy fuel oil increase atmospheric emission of particulate matter, black carbon, and carbon dioxide relative to using lower sulphur fuels.  A recent study by Environment and Climate Change Canada found that ships with scrubbers emit 104 percent more black carbon, or soot, than ships without.  Currently, the most effective way to reduce air and ocean pollution is to use low sulphur marine gas fuel.