North American ECA

I have previously commented on the relatively limited impact a Great Lakes ECA would have on the air quality. I also disagreed with the statement contained in the proposal to IMO that emissions from land based sources had been addressed in Canada and the USA, before addressing marine emissions.

Here is the opening paragraph from "Sulphur Dioxide Controls for Small Utility Boilers" in the most recent "EM" magazine from the Air & Waste Management Association:

"There are more than 420 coal-fired boilers in the United States with capacities from 50 to 300 megawatts (MW) that currently are not equipped with a selective catalytic reduction (SCR) system, for NOx control, a flue gas desulfurization system, or a mercury control system. Many of these boilers, which collectively represent almost 60 gigawatts (GW) of installed capacity, are difficult to retrofit for deep emission reductions, because of space constraints or unfavorable economics of scale. Considering many boilers are over 50 years old, they are increasingly vulnerable to retirement in the face of progressively more stringent environmental regulations."

The installed capacity of these coal fired boilers is equivalent to the total installed power of 10,000 ships with 6MW (8,000HP) installed power! These power stations can meet the Clean Air Act by burning LS coal with S-content of 0.6-1.0%.

With the EPA proposed rulemaking Great Lakes ships will have to burn LS distillate, while some 420 power stations in the USA burn coal without SOx scrubbing!