Resolution 2025-08
WHEREAS, in 2010, the International Maritime Organization implemented emission standards for shipping, requiring cleaner burning fuel on shipping and cruise ships. A regulatory loophole was created allowing the use of exhaust gas scrubbers as an alternative compliance mechanism to burning cleaner fuel, and cruise ships began installing exhaust scrubbers in large numbers in 2015; and
WHEREAS, the exhaust scrubber loophole has resulted in a rapid uptake of the use of scrubber systems worldwide, with the number of scrubbers spiking from less than 200 worldwide in 2014 to over 7,400 at the start of 2025, threatening the marine and near-shore environment; and
WHEREAS, scrubber systems produce large volumes of hot, acidic, and toxic wastewater pollution that would not be produced if cleaner burning fuel was used. Heavy fuel oil and exhaust scrubber use is not necessary for the operation or the safety of ocean-going vessels and is used for a marginal cost savings when readily available cleaner lower-sulfur distillate fuel could be used instead; and
WHEREAS, scrubber wastewater is produced as a result of the “washing” of high-sulfur heavy fuel oil exhaust, which captures numerous other pollutants, including heavy metals, unburned oil (polycyclic aromatic hydrocarbons – PAHs), nitrates, and nitrites. Exhaust scrubbers effectively transfer pollutants from the exhaust of dirty heavy fuel oil into a discharge that poisons the waters, foods, and ways of life for coastal communities; and
WHEREAS, studies suggest that the combined toxicity of the metals and PAHs in scrubber wastewater can be significantly greater than the toxicity of the metals or PAHs on their own with a “more-than-additive” co-toxicity. Other research has found that scrubber water could not be diluted enough to find a No Observed Effect Concentration with impacts to reproduction and development of marine organisms found at the lowest concentrations tested; and
WHEREAS, the use of exhaust scrubbers and heavy fuel oil has been shown to increase the emissions of particulates and black carbon into air as compared with using lower-sulfur distillate fuel instead. Additionally, the use of scrubbers encourages the continued use of heavy fuel oil increasing the risk of harmful persistent fuel spill risks, which pose an extremely difficult spill clean up problem, particularly in colder northern waters; and
WHEREAS, large ocean-going vessels successfully avoid using heavy fuel oil and scrubbers while operating in the waters of National Marine Sanctuaries, within 24 miles of the State of California coastline, and within the Arctic Circle to comply with the International Maritime Organization’s ban on heavy fuel oil; and
WHEREAS, the implementation of such policies show no negative impact on the thriving shipping and cruise industries in said regions. Numerous similar policies have successfully been enacted globally.
NOW, THEREFORE, BE IT RESOLVED that the National Wildlife Federation, at its annual meeting assembled June 3-6, 2025 in Minneapolis, Minnesota, calls on the shipping and cruise ship industries to end the use of heavy fuel oil and exhaust gas scrubbers immediately; and
BE IT FURTHER RESOLVED that the National Wildlife Federation calls on the International Maritime Organization to end the practice of allowing the use of exhaust scrubbers to meet sulfur emissions goals worldwide and in Emission Control Areas; and
BE IT FINALLY RESOLVED that the National Wildlife Federation calls on local, state, and federal governments to prohibit the use of heavy fuel oil and exhaust scrubbers systems.