Closed consultation

Domestic maritime decarbonisation: the course to net zero emissions – summary of responses

Updated 20 July 2023

Executive summary

Context

Transport is the largest contributor to the UK’s domestic greenhouse gas (GHG) emissions. While shipping is generally a relatively carbon-efficient mode for transporting freight, UK domestic maritime vessels represented around 5% of the UK’s domestic transport greenhouse gas (GHG) emissions in 2021. This was more than domestic rail and bus emissions combined. It is, therefore, crucial that the government and the UK maritime sector have a credible plan to decarbonise the sector.

In July 2021, the government published the transport decarbonisation plan, which set out the commitments and actions needed to decarbonise the UK transport system including maritime. The plan included a commitment to refresh the clean maritime plan and to establish, following public consultation, an ambitious ‘course to zero’ of indicative targets for the domestic maritime sector.

In July 2022, we published a consultation to gather evidence on the proposed pathway to decarbonisation, the barriers to achieving this, and potential economic and regulatory interventions. The consultation explored the technical, operational and policy options available for government to accelerate decarbonisation in this sector, to achieve net zero by no later than 2050, or earlier if possible.

This document is a summary of responses received to each of the 22 questions and does not represent the government’s position or offer a formal response to the evidence given. Additionally, the government has not conducted a full analytical review of the evidence provided, so is not commenting on the accuracy of the evidence provided.

We plan to publish a refresh of the clean maritime plan in late 2023. This will be the formal government response to this consultation, in which we will include indicative decarbonisation targets for the domestic maritime sector and details of the policies and interventions required to support this transition to net zero.

Respondents

The consultation received 55 responses, varying from general comments and feedback about the government’s approach to maritime decarbonisation, to detailed evidence relating to each of the consultation questions.

Of those responses, 5 were submitted as the views of the individual respondent (9% of total responses) and 50 responses were submitted on behalf of an organisation to reflect their collective view (91% of total responses). The breakdown of the types of organisations that responded can be below:

• academics: 5
• ports and harbour authorities: 6
• public bodies: 3
• energy companies: 3
• non-governmental organisations (NGOs): 4
• technologies: 6
• consultancies: 3
• maritime operators, governing bodies and trade unions: 6
• trade bodies: 14

The 5 individuals who shared feedback in response to this consultation highlighted their close working relationship with the maritime sector.

Summary of responses

The course to zero consultation had 3 overarching aims, which were to:

• seek views and evidence on the optimal pathway to net zero emissions in 2050, including where there is scope to accelerate decarbonisation

• gather productive feedback about the remaining barriers to maritime decarbonisation

• collect views on the various additional policy options which could be employed to address these barriers, building on the government’s current approach.

Respondents offered a range of views and perspectives on these objectives.

Pathway to net zero

We received a range of positive responses discussing the overall pathway to net zero. A significant proportion of respondents were positive about the overall level of ambition and feasibility associated with the net zero strategy pathway. Other respondents commented that the trajectory was not ambitious enough and a small minority questioned the age of the data used for the analysis behind the pathways.

Respondents believed that increasing the uptake of alternative fuels was the best way to reduce emissions and offered a range of evidence in support of different fuel types. Hydrogen and ammonia fuels received the most support, with liquefied natural gas (LNG) receiving mixed views from respondents.

Barriers to maritime decarbonisation

In response to a question on potential barriers, the most common themes highlighted were economic and structural barriers. These included inadequate access to the capital investment required to decarbonise, by retrofitting existing vessels or purchasing new zero emission vessels. Government support to unlock additional funding routes was raised as a requirement to incentivise decarbonisation, with the lack of private sector investment acting as a barrier government could support the sector in addressing. The future availability of infrastructure for new alternative fuels was another common theme in responses.

Respondents also reported that they would like to see greater alignment between government departments, as well as greater government and industry collaboration. They felt that there was limited collaboration between government departments with a stake in decarbonisation, as well as limited space for the maritime industry input.

Additional policy options

Respondents provided many solutions that could address barriers and support decarbonisation. A prominent theme was the need for a fuel standard to regulate the carbon intensity of fuels. Respondents suggested that this may help drive decarbonisation within the sector, as low carbon fuels are seen as the best way to achieve zero emissions.

Respondents also highlighted the benefit of regulatory alignment with international partners, such as the European Union (EU) and International Maritime Organization (IMO). In particular, the EU was seen as a key international partner for respondents, as the UK and EU markets were seen as deeply connected.

The sector also suggested sub-sectors for which the emissions may be easier to abate. While there was no consensus from respondents as to these areas, the ferry sector and workboats serving offshore wind, oil and gas installations received the most responses highlighting these as having the most potential to act as first movers.

Most respondents also expressed support for the energy efficiency measures that were proposed within the consultation, highlighting a range of technologies and operational changes that could lead to the improved efficiency of vessels.

Respondents also suggested additional regulation, for example, relating to the governance of inland waterways and the safety of alternate fuels.

Q1: The net zero strategy pathway for the domestic maritime sector

1. What is your feedback on the overall ambition and feasibility of the net zero strategy pathway for domestic maritime vessel emissions?

The consultation presented the key evidence and analysis of the UK’s domestic maritime sector, which was used in the government’s net zero strategy, including the net zero strategy pathway for domestic maritime. It also examined the wider implications of this pathway and seeks further evidence to help refine this pathway. It was recognised that analysis of this nature is subject to significant uncertainty and that this is an area where the available evidence continues to evolve at pace. So, a key objective of this consultation was to capture feedback on the analysis that has been completed to date on the net zero strategy pathway for domestic maritime. Question 1 received 46 responses.

Overall feedback

15 respondents (33% of those who responded to this question) provided positive feedback on the overall level of ambition and feasibility associated with the net zero strategy pathway for domestic maritime vessel emissions. 6 respondents (13%) responded with a generally negative view of the pathway on the basis that the trajectory was not ambitious enough. One respondent stated explicitly that the low level of ambition in the short-term limited the feasibility of such a trajectory. 21 respondents (46%) either expressed a neutral perspective about the ambition and feasibility of this trajectory or did not respond directly to this aspect of the question. 4 respondents (8%) rejected the pathway given, based on concerns about the underlying data and analysis used in this modelling.

Opportunities to accelerate decarbonisation

Respondents offered a range of sectors within maritime that would be best suited to decarbonisation at pace.

Some respondents identified the domestic ferry industry as the subsector with significant potential for rapid decarbonisation, suggesting that the domestic ferry industry accounts for a higher proportion of emissions than the number of vessels in this subsector. Therefore, any progress made here would have a significant impact on reducing domestic maritime emissions.

The offshore wind sector was also identified as having significant potential for accelerating decarbonisation, according to the respondents. There is already an existing initiative in place to accelerate decarbonisation in the sector (Operation Zero). However, there may be room for further acceleration to create a fully green sector for electrical generation. Respondents also suggested that a similar strategy could be applied to vessels that support oil rigs, as they are not significantly different from those serving offshore wind.

Leisure boats on inland waterways were also identified as potential areas for decarbonisation. Respondents highlighted that these vessels tend to use short journeys at slower speeds and require less power to operate so could potentially be retrofitted to battery propulsion systems.

Harder to abate sub-sectors

The 2 sub-sectors that were identified as the most challenging to decarbonise were vessels that operate on inland waterways and the fisheries sector.

Respondents explained that vessels that operate on inland waterways have long lifespans of over 20 years, which means that any newly built vessels will still be in use near to 2050 and could continue to emit if there is no short-term change. Furthermore, the economic barriers to decarbonisation in these sectors are particularly high.

The fisheries subsector was also identified by respondents as a challenging area to decarbonise since the fishing industry is composed of numerous small businesses for which fuel represents a significant expense. Because of this, there is already an incentive to decarbonise. Any new fuels that are not cost-competitive with traditional fuels could inadvertently have a negative impact on this sub-sector.

Technological barriers to reaching zero emissions

Respondents were asked to identify barriers to achieving zero emissions in the maritime sector, including economic, regulatory and technological factors. The choice of fuel for the maritime sector was identified as the most significant technological barrier. Developing new, zero-emission, propulsion systems that can provide the necessary power for ships to operate is another significant technological challenge facing the maritime sector.

The lack of infrastructure to support zero-emission propulsion systems was also highlighted as a challenge. For example, the production, storage and distribution of hydrogen fuel is still in its infancy and there are relatively few ports equipped to handle ships powered by electricity or other low-carbon fuels. Therefore, even if ships are retrofitted with zero-emission technologies, they may not have access to the necessary fuelling infrastructure to operate effectively.

Other comments

Respondents provided comments on the net zero strategy pathway described in the consultation. There was significant feedback that the net zero strategy pathway indicated little decarbonisation prior to 2035. The responses also flagged that indicative targets would not push the sector to decarbonise at the pace required, with mandatory targets being a better alternative. In addition to this, it was suggested that those subsectors that have the possibility of decarbonising quickest could have more ambitious targets.

Regulations were also discussed in the consultation responses. Respondents suggested that regulations are slow to react to change, leading to the risk that they cannot match the speed of change that is required to decarbonise the sector.

Respondents pointed out that the maritime sector not only contributes to GHG emissions, but also other pollutants and emissions such as nitrogen oxides (NOx) and sulfur oxides (SOx). For instance, ammonia, a fuel regularly suggested as an alternative fuel for maritime, is zero carbon but can emit large amounts of other pollutants. Any new fuels should look to limit emissions of these to improve air quality in coastal communities and around ports.

Q2: The role of alternative fuels and energies in maritime decarbonisation

2. What role do you think the following alternative fuels and energies may play in decarbonising domestic maritime sector vessels (within your subsector, if appropriate)? What evidence do you have to support this opinion?

The consultation presented analysis of how the use of alternative low-emission fuels by UK domestic maritime vessels is estimated to evolve between 2020 and 2050 under the central net zero strategy pathway and discussed the caveats and uncertainty associated with this analysis. Question 2 invited views on what role various fuels and energies were likely to play in decarbonising the domestic maritime sector and received 40 responses.

Low-carbon hydrogen and low-carbon hydrogen-derived fuels

Most of the 31 (78%) respondents that expressed a positive view of hydrogen and its derived fuels considered green hydrogen as a clean and safe fuel for the maritime sector. However, respondents expressed concerns about the cost and scalability of green hydrogen, as well as its energy density, which may limit its use to shorter journeys and smaller vessels. Respondents preferred hydrogen-derived fuels, like ammonia, for longer journeys due to their higher energy density. However, ammonia’s toxicity and particulate emissions may pose risks to its suitability for sensitive waterways.

Electricity and battery technologies

Electricity and battery technologies were mostly seen as positive, with 25 respondents (63%) giving positive views and 3 (8%) respondents giving negative views. Most respondents regarded electricity and battery technologies positively, particularly for shorter journeys and smaller vessels. Responders noted that larger vessels may face challenges due to the low-energy density of batteries, compared to traditional fuels and the need for stable battery integration. However, batteries are a proven technology with improving energy density and longevity and can be used in hybrid propulsion with other zero-emission systems, making retrofitting of vessels more viable.

Onboard renewables

Onboard renewables had 13 respondents (33%) providing a positive view and 4 (10%) providing a more negative view. These responders suggested that onboard renewables have the dual benefit of charging batteries and providing propulsion. They are better suited for smaller vessels with lower power demand but may require large amounts of space. Wind alone can provide around 30% of a ship’s propulsion. Solar power may have lower potential than wind for domestic and near UK routes due to weather conditions.

Nuclear power

Nuclear power had fewer responses than other fuels, with only 6 (15%) respondents giving positive feedback and 3 (8%) providing negative feedback. These respondents noted that nuclear power is a proven zero-carbon source, but faces negative public perception and challenges regarding spent fuel storage. Nuclear power is more economically feasible for newly built vessels than retrofitting older ones.

Biofuels

Biofuels saw overall positive feedback with 13 (33%) respondents giving positive views, and 8 (20%) giving negative views. Biofuels are primarily seen by respondents as transition fuels but can reduce emissions up to 90% and are useful for smaller, less frequently used vessels. It was suggested by respondents that first-generation biofuels have limited impact on greenhouse gas (GHG) emissions and impact land use and biodiversity. However, second-generation biofuels use waste parts of crops so do not have the same negative effects. Algae biofuels are also in development.

Liquefied natural gas

Liquefied natural gas (LNG) saw mixed feedback from respondents with 8 (20%) giving positive feedback and 7 (18%) giving negative feedback. LNG is seen as a transition fuel for larger vessels that can reduce GHG emissions by around 23% and is considered safe to use. However, respondents raised concerns about how it’s produced from methane, a powerful GHG that breaks down into carbon dioxide. The World Bank recommends no further public policies for LNG usage due to its GHG impact and there are concerns about other pollutants and limited bunkering facilities.

Other fuels and energies

Other synthetic fuels: there were 2 (5%) respondents who provided favourable views on this fuel type as it has similar energy densities to traditional fuels.

Carbon capture and storage: a further 2 (5%) respondents raised the possibility of adding carbon capture and storage to vessels.

Q3: The role of energy efficiency and energy-saving technologies in maritime decarbonisation

3. What value do you think different efficiency and energy-saving measures could have in helping to achieve domestic maritime vessel decarbonisation?

The consultation provided analysis of the effectiveness of various energy efficiency and saving measures. This included energy efficiency technologies, design features and operational interventions that could be incorporated onboard a vessel to reduce fuel use. The consultation offered respondents the opportunity to share views on which energy efficiency measures were the most appropriate and effective for a given vessel type, sub-sector or operational profile. Question 3 received 32 responses.

Most respondents expressed a positive view about the potential of energy efficiency measures, both in terms of reducing emissions in the short-term, as well as facilitating the transition to low and zero carbon fuels. 15 respondents (47%) highlighted this specifically. Only 2 respondents reported that such measures may have a limited impact on the domestic maritime sector and the switch to low and zero carbon fuels was much more important.

A wide variety of energy efficiency measures were described by respondents with varying views about their applicability and efficacy.

Incorporating energy-saving technologies and designs

Respondents highlighted benefits from the following:

• improved hull designs and air lubrication measures
• adopting electric and hybrid systems, as electric powertrains were overall more fuel efficient and easier to replace and upgrade
• incorporating integrated heat recovery systems
• engine derating and tuning
• propeller pitch adjustments and boss cap fins
• rudder configurations
• LED lighting
• autonomy
• shore power
• carbon capture and storage (CCS) technologies

Making operational changes to increase fuel efficiency

Respondents highlighted the benefits of:

• new data collection and interrogation systems to optimise voyages
• weather routing software to optimise voyage times and reduce fuel use
• slow steaming. However, 2 respondents urged caution regarding interventions on vessel speed
• efficient port planning
• dredging canals, rivers, and harbour or port entrances to reduce drag effects on vessels and associated fuel use
• effective biofouling management and hull scrubbing in the regular operation of vessels
• changes to the rules on continuous cruising on the inland waterways

Q4: Supporting technological transitions

4. How should the technological transitions required to decarbonise the domestic maritime sector best be supported? What evidence do you have to help refine our understanding in this area?

The course to zero consultation discussed the technological and operational changes required to achieve the net zero strategy pathway. Question 4 gave respondents the opportunity to share their views on how the technological transitions needed to achieve decarbonisation should be supported. It also asked for views on what these technological transitions were. Question 4 received 41 responses.

Necessary technological transitions

Respondents suggested that a successful transition to a decarbonised maritime sector would require:

• developing low-carbon fuel production centres and a new network of bunkering and charging infrastructure and/or bunker barges
• the production of new vessels able to run on low and zero emission fuels
• widespread retrofit of vessels to achieve emissions reductions. However, this is unlikely to be cost-effective, although it may be critical to achieve decarbonisation
• the adoption of short-term transitional fuels. However, these could be a ‘dead end’, inhibiting the progress of decarbonisation in the long term and leading to stranded assets
• the adoption of energy efficiency and saving measures in the short term with sustained investment in low and zero carbon solutions throughout
• decarbonisation first among smaller vessels
• better understanding of storage considerations for alternative fuels, batteries and fuel cells

Supporting technological transitions

To support the technological transition, respondents suggested:

• the government should provide clear plans to support the development of maritime infrastructure
• generic ‘incentives’ to support various changes needed to facilitate decarbonisation
• further research and development (R&D) funding on a larger financial scale
• the government should provide support for retrofit projects
• clarity on policy and regulatory outcomes
• using the emissions trading scheme and Renewable Transport Fuel Obligation (RTFO) as the primary mechanism to support technological transitions
• supporting small and medium-sized enterprises (SMEs) based in the UK and ensuring that the supply chain to support decarbonisation was UK based to boost economic prospects and resilience

Q5: The costs and benefits of maritime decarbonisation

5. Are you able to provide any additional evidence on the costs and benefits associated with decarbonising UK domestic maritime vessels?

The consultation published evidence relating to the costs and benefits of meeting the net zero strategy pathway for domestic maritime. It invited respondents to share any additional evidence that they had on the costs and benefits of decarbonising the domestic maritime sector in question 5, which received 29 responses. A range of additional benefits and costs were noted by respondents, with some giving more detailed evidence to support their views.

Additional evidence on costs

Respondents offered quantitative evidence on the additional costs of decarbonisation. One respondent reported that retrofitting an inland waterway cruiser would cost about £150,000, including the capital costs associated with the vessel, as well as the required infrastructure and labour costs. Another respondent reported that a hybrid or battery-electric vessel generally costs twice as much as a traditional diesel-powered vessel in the leisure sector. One respondent noted that for larger sea and ocean-going vessels, an ammonia-powered engine would also cost roughly twice that of a traditional fossil-fuel engine. Another respondent noted that even more efficient diesel engines can cost 30% to 40% more than older models. In terms of fuel costs, one respondent reported that the cost of electricity generated via their hydrogen fuel cell was about 15 times higher than the current market alternative. Regarding the broader costs of decarbonising the maritime sector, the biggest investment needed would be on land-based infrastructure, with one respondent noting that these costs could represent around 90% of all investment costs.

Further evidence of additional costs includes that:

• decarbonisation would likely result in an increase in capital and operational expenditure, at least initially across the maritime sector
• there is an expectation that vessel capital expenditure costs would be higher than the figures given in the consultation, at least in the short-term
• costs of fuel to support decarbonisation should decrease in cost over time, rather than increase
• training staff on new technologies has not been reflected in the original cost estimations
• differences in regulations across regions may incur additional costs
• decarbonisation might affect the connectivity of island communities
• the additional cost to the fishing sector could reduce catches, which could impact global food security and create other costs across the economy
• certain vessels may become uneconomic to operate

Additional evidence on benefits

• economic advantages gained by being a first mover or frontrunner in this area
• improve export opportunities, jobs and boost local economies in the UK
• improved air quality associated with the decarbonisation of the sector
• reduction in noise and wildlife disturbance
• electric drivetrains on vessels required less maintenance and provided increased reliability
• reputational benefits for organisations that move first to decarbonise

Q6: Setting decarbonisation targets for the maritime sector

6. How should intermediary, indicative decarbonisation targets for UK domestic maritime sector vessel emissions be formulated?

The consultation outlined the commitment the Department for Transport (DfT) has to provide intermediary, indicative decarbonisation targets for the domestic maritime sector, as set out in the transport decarbonisation plan. The plan specified that these decarbonisation targets would be set from 2030 onwards, leading to full decarbonisation as soon as feasible. The course to zero consultation then discussed a range of options for how these targets might be set and offered respondents the opportunity to provide feedback on this topic. Question 6 received 30 responses.

Types of decarbonisation targets

Respondents expressed a wide range of positive views regarding the type of targets and metrics that would be the most impactful in helping to set the domestic maritime sector on its trajectory towards full decarbonisation. The most popular suggestion was for targets to be focused on overall GHG emissions reductions from the domestic maritime sector over time, potentially expressed in percentages. Five respondents (17%) recommended this approach. The next most popular suggestion was for targets to be set around the future prohibition of new non-zero emission vessels. This is likely in reference to ongoing work relating to the possible phase-out of new non-zero emission vessels consultation, another commitment in the transport decarbonisation plan. Three respondents (10%) recommended this approach and 2 respondents offered 2030 and 2035 as a reasonable date for this target.

Further respondent suggestions for targets include those:

• based on the number of, or percentage of, new zero emission vessels within the domestic maritime sector over time
• that focused on the rate of, or percentage of, retrofit vessels over time
• that are sector-based around the use of renewable fuels of a non-biological origin and low carbon fuels within the sector
• that concern vessel energy efficiency and saving measures, or overall vessel carbon intensity for the operational GHG intensity of fuels used in the domestic maritime sector and for supply or production of low or zero carbon fuels for the domestic maritime sector

Timelines for decarbonisation targets

Six respondents (20%) explicitly discussed the optimal timelines and interval periods for decarbonisation targets in their responses. Four of these respondents (13%) expressed a preference for any decarbonisation targets to be set on a 5-year basis, aligning with the existing timetable of UK Carbon Budgets. One of these 4 respondents noted that such intervals would provide opportunities to reassess and adjust the planned trajectory where necessary.

Subjects of decarbonisation targets

A range of views was expressed about who should be the subject of any decarbonisation targets for the domestic maritime sector and whether targets should be universal or sub-sector specific. Of those that responded to this question, 7 respondents (23%) said that targets should be sub-sector specific, rather than blanket targets. This was the most common response, with most other respondents not offering a view. Respondents argued for consideration of:

• the ability of the sub-sector to comply
• the age of vessels within the sub-sector
• the cost of replacement or retrofit
• their cost to earnings ratio
• engineering challenges when setting targets

However, other respondent called for all targets to be applied consistently across the domestic maritime sector, and proportionately, to avoid burdening one sub-sector.

Other design considerations

Respondents made recommendations for the government to consider when setting decarbonisation targets for the domestic maritime sector. Some suggested science-based targets with supporting evidence, credible monitoring systems for GHG emissions and stringent, ambitious goals in line with Paris Agreement goals. Clarity on emissions coverage and the course to zero trajectory were also requested.

Respondents suggested that any decarbonisation targets in the domestic maritime sector should be connected to funding opportunities. There were calls for short-term policy levers to be used to protect long-term infrastructure projects from economic shocks in the energy market. It was recommended that targets should be supported by a scrappage scheme, supported by infrastructure mandates or that port fees could be adapted to incentivise retrofit of vessel in accordance with any targets that are set.

Overcoming the barriers to decarbonisation: summary of responses

Q7: Barriers to decarbonisation for the maritime sector

7. What are the most significant barriers to domestic maritime decarbonisation at scale (if appropriate, within your subsector)?

The consultation discussed research that was published alongside the 2019 clean maritime plan which examined the barriers to decarbonisation in the maritime sector. This research, as set out in the consultation, catalogued barriers to decarbonisation within the following 5 categories:

• economic
• structural
• policy
• organisational
• behavioural

The consultation acknowledged that there may be additional barriers to decarbonisation that are not listed in the consultation. It then offered respondents the opportunity to share views on barriers to inhibiting the sector’s decarbonisation. Question 7 received 41 responses, with respondents invited to provide comment on the highest impact barriers.

Highest impact barriers: economic

Many respondents highlighted economic barriers as being among the most significant to decarbonisation for the maritime sector. Different views were offered about which economic barriers were the most significant, varying according to the sector or organisation type that submitted the response.

Twelve respondents (29%) highlighted the negative externalities barrier as one of the highest impact barriers to decarbonisation. This refers to the fact that, at present, maritime fuel prices do not reflect the costs of their GHG and air pollutant emissions. Four respondents (10%) highlighted the split incentives of ship owners and operators to invest. One respondent noted that domestic and roll-on, roll-off (Ro-Ros) ferries in the domestic maritime sector have fewer arrangements for alternative fuels and energies than their international counterparts. However, another respondent pointed out that there is ambiguity about which party should invest in supporting infrastructure, leading to a split incentive to invest, especially with regards to shore power.

Imperfect information on abatement options and between owners and charterers was flagged as the most significant barrier to decarbonisation by 90% of respondents. Additionally, the high cost of capital or lack of access to it was identified as another significant barrier by 36% of respondents, especially for smaller operators, ports, harbour authorities and technology providers. Three respondents cited funding, financial barriers and uneconomic proposals as significant barriers to decarbonisation, indicating that economic barriers are a high impact.

Highest impact barriers: structural

Several respondents cited structural barriers hindering decarbonisation in the maritime sector. Twelve respondents (29%) mentioned limitations in existing infrastructure, such as ports and refuelling, as well as onboard technologies. Small ports face difficulty in accommodating multiple fuel types due to limited space and lack of access to capital for new infrastructure. Retrofitting of vessels may not be possible at the required speed in some areas, with long life spans of vessels and insufficient funding or training to retrofit with new technologies.

As well as the physical infrastructure, respondents raised concerns about the speed at which retrofitting of vessels would be possible. For example, some areas of the UK may not have the capacity to retrofit vessels at the speed required to refit fleets by 2050, and the long-life spans of vessels mean they may not all be new builds by 2050. This may be down to the lack of funding in building capacity to retrofit vessels or a workforce that is not sufficiently trained to retrofit vessels with new technologies.

Highest impact barriers: policy and regulatory

Some respondents stressed the importance of policy and regulatory barriers to decarbonisation. Respondents cited the current lack of regulatory guidance from the government and the Maritime and Coastguard Agency (MCA), especially around the safety aspects of any new fuels and updated guidance on safety zones as examples of these barriers. They were concerned that regulators may take a conservative approach to any new fuel and innovations. It was reported that without any firm cross-government policy, it is unlikely private investment would be willing to take the risk of funding low carbon vessels. The current absence of policy and regulations means that operators are reluctant to invest in non-conventional vessels, as there is no guarantee that these will be compatible with any future policies or regulations.

Highest impact barriers: organisational

Other respondents highlighted organisational barriers in their response to this question. The most prominent of these was the inability of differing organisations to coordinate and align on new technologies and fuels, due to split incentives and the different needs from different operators. Respondents were concerned that there may be competing objectives between vessel owners, operators and those that would be providing new fuels. Respondents noted that operators may not own the vessels they run and would not be responsible for retrofitting them, but could bear the costs of not making changes. In similar situations, some operators run life-line ferry services that see them fined for not delivering services – this would prohibit any retrofitting of vessels as there is an additional cost to taking vessels out of service.

Other respondents raised that training and certification are simply not up to speed with upcoming technologies. Respondents suggested that staff may not feel confident in their ability to work with emerging technologies and new fuel types. Organisations will need to ensure that they have put sufficient resource into ensuring staff have the required skills to safely operate vessels.

Highest impact barriers: behavioural

Respondents cited a range of behavioural barriers as significant factors inhibiting decarbonisation, with many seeing decarbonisation as ‘expensive’ and ‘difficult’. Respondents noted that the industry might fail to see the costs of not taking action, either in terms of cost to business as a result of climate change or lost revenue and market share when not reacting to changing market conditions.

Highest impact barriers: other

Some respondents cited barriers that were not listed in the consultation or the original research paper on barriers to decarbonisation. These included:

• the availability of technical solutions to complex machinery involved in the sector, such as the many moving parts in a fishing vessel

• the growth of supply chains and logistics associated with new zero carbon fuels

• that scaling up of production and storage of these fuels is likely to come at a cost the sector may not be able to afford, or be unwilling to risk

• the challenges of providing infrastructure at ports for multiple different fuel types

Q8 and Q9: International maritime decarbonisation efforts

8. Which international policies, programmes and initiatives do you expect will have the most impact on how the UK’s domestic maritime sector decarbonises?

9. What do you think are the key lessons from international policies, programmes and initiatives that we should consider in our approach to decarbonising the UK domestic maritime sector?

The consultation acknowledged the international context of the maritime sector and catalogues the many efforts to decarbonise the sector through international regulations, regional policies and ambitious national programmes from around the world. The consultation asked respondents to share their views on which policies, programmes and initiatives from around the world may have the highest impact on how the UK’s domestic maritime sector decarbonises (question 8). It also offered respondents the opportunity to share views on which key lessons from these policies UK government should consider in its approach to decarbonising the domestic maritime sector (question 9).

Question 8 received 27 responses. The policies respondents considered to be of the highest impact on the UK’s domestic maritime sector are set out as follows.

High-impact international policies, programmes and initiatives

Respondents listed various international policies, programmes and initiatives that could greatly impact the UK’s decarbonisation of the maritime sector. The impact of EU policies was cited as having the most significant impact, particularly with the launch of the Fit for 55 policy in July 2021. For context, this policy includes measures for decarbonisation across sectors. It covers transport as well as expanding the EU Emissions Trading System (ETS) to shipping and reducing emissions allowances at a faster rate.

Additionally, the EU has removed tax exemptions on heavy fuels used in the maritime industry and is working to finalise the proposed FuelEU Maritime Initiative that will introduce a standard to ensure ships reduce the amount of greenhouse gases (GHGs) in their energy use by up to 80% by 2050. This proposal would also impact UK shipping as targets would apply to 50% of the energy used on external voyages travelling to and from the EU.

As well as the policies implemented by the EU, it is expected that EU standards will have a high impact on the UK domestic maritime sector. The markets of the EU and UK are deeply connected and operators looking to use vessels in both would need to conform with EU standards.

International agreements at the International Maritime Organization (IMO) will impact the UK maritime sector’s decarbonisation. The IMO has recognised the need to strengthen the ambitions of its initial greenhouse gas reduction strategy, when it is revised in July 2023, beyond a 50% emissions reduction by 2050 target that was agreed in 2018.

Where international organisations direct funding for R&D is likely to drive the UK’s domestic decarbonisation. Innovations and increases in economies of scale will make decarbonisation more affordable within the UK, as well as provide a source of funding that is seen as a barrier to decarbonisation.

Question 9 received 25 responses. The key lessons from various international policies, programmes and initiatives which respondents highlighted follow.

Key lessons: regulatory alignment with regional and international bodies

Seven respondents (28%) highlighted the benefit of taking an international approach to decarbonising the UK’s maritime sector ensuring alignment with wider regulatory regimes, such as the EU or IMO regulatory regimes. One respondent cited the UK’s RTFO programme as a helpful lesson, contending that its success was premised on underlying EU directives that were in force in the UK at the time and had promoted land transport decarbonisation across Europe.

Respondents highlighted the importance of aligning UK policies with international initiatives, specifically the IMO, and urged flexibility in policies to adapt to future regulations to avoid duplication and ensure full alignment. It was noted that this approach can prevent harm to the domestic maritime sector and protect UK businesses on the international stage. Additionally, the impact of UK policies on the fishing industry could affect its international competitiveness and potentially lead to lower-quality imports.

Some respondents recommended aligning with the EU or IMO for competitiveness and a level playing field, while others suggested this approach due to the EU’s high ambition of decarbonisation in the Fit for 55.

Further insight from respondents suggested:

• matching EU GHG mandates and inclusion of domestic shipping in the ETS to accelerate decarbonisation
• remaining in the EU Horizon Europe program to lead in ship decarbonisation R&D
• following the lead of the EU with policies such as the ETS, Ocean Fund, FuelEU Maritime, Renewable Energy – Recast to 2030 (RED II), which support research, innovative technologies and marine environment protection
• alignment and simplicity where sensible, noting that it is important to individually assess each policy before incorporating international regulations into the UK’s domestic regulatory regime

Key lessons: emulating high climate ambition countries

Responses also highlighted a range of programmes and initiatives from countries demonstrating high ambition in tackling climate change, which could be considered in the UK’s approach to decarbonising the domestic maritime sector.

Respondents highlighted East Asia’s influence on international shipping and its efforts towards decarbonisation. They suggested working together to achieve common goals, such as the United Nations sustainable development goals and the Maritime Singapore Decarbonisation Blueprint, which sets emissions reduction targets and promotes the use of low and zero-carbon maritime fuels.

Respondents recommended that the UK establish an organisation similar to Singapore’s newly announced Global Centre for Maritime Decarbonisation. This should be part of a new Advanced Propulsion Centre for Marine. They also noted that South Korea is investing US$870 million by 2030 in eco-friendly shipping technology development projects, including constructing more than 10 ships that demonstrate emission reduction through LNG bunkering and mixed fuel propulsion.

Several respondents highlighted the pioneering efforts of European countries in maritime decarbonisation. Norway and the Netherlands were specifically mentioned for their work on local ferries and inland waterways respectively. Norway’s Green Shipping Programme, Enova, Innovation Norway and NOx fund schemes were deemed useful initiatives, and Norway’s approach to decarbonising short-range ferries was recommended for the UK to emulate. Respondents suggested that successful initiatives are based on stakeholder engagement and coordination, which can overcome concerns about commercially sensitive information.

Key lessons: embracing the UK’s individuality and climate leading potential

Six respondents (25%) emphasised the UK’s potential to lead the way in decarbonisation and act as a global climate leader. Four of these suggested that the UK should not rely solely on the IMO or EU for regulations and policies but should engage with international groups and develop green corridors. They recommended that the UK should strive to outperform other countries in its progress towards decarbonisation. Other respondents emphasised the importance of prioritising support for the green energy transition and suggested that setting domestic targets can be a more effective approach than agreeing on international measures.

Other key lessons

Respondents shared broad lessons for the UK in decarbonising its domestic maritime sector. They suggested a holistic ‘energy perspective’ instead of a ‘fuel-focus’ or a maritime view, seeing regulations as opportunities to lower costs. In their view, collaboration between industries and strategic NGOs is critical, as learned from previous fuel transitions such as LNG. Respondents also emphasised the need for a collaborative approach between land and sea. Lastly, one respondent urged early action on decarbonisation to achieve net zero by 2050.

Q10: Economic intervention

10. Are there any additional interventions targeting economic barriers that the government could explore introducing to complement and enhance our current approach in the short, medium and long term?

The consultation outlined the UK government’s commitments to economic interventions for maritime decarbonisation, such as the £206 million research and development programme by the UK Shipping Office for Reducing Emissions (UK SHORE) and the potential inclusion of domestic maritime in the UK Emissions Trading Scheme (UK-ETS). Question 10 invited respondents to give their views on tailored interventions and specifically asked for suggestions on economic interventions to support decarbonisation within existing commitments and received 32 responses.

Respondents suggested various economic interventions, such as new financial products, tax incentives and underwriting market finance to increase investment confidence and improve the sector’s access to finance. They also suggested further government spending on R&D and sustained financial support for operating costs on new alternative fuels or energies.

However, there were diverse views on the preferred economic measures and separation between short, medium or long term interventions. There was widespread support for the government to provide sustained financial support through various mechanisms for sector decarbonisation. A comprehensive list of suggestions follows.

Focus on interventions targeting economic barriers

Various views were presented on the government’s priority target for economic intervention related to economic barriers. These views are:

• greater economic support for developing green corridors
• increased support for low-carbon renewable or environmentally friendly fuels
• funding for electrification of inland waterways
• funding for a national steering group for UK ports to share best practices
• additional regulations or measures to support economic interventions, such as an integrated approach to fuel demand and supply, and the simplification of regulations for renewable energy production
• expansion of the Environmental Ship Index beyond the Port of London Authority to encourage cleaner and greener vessels

Research and development funding

Two respondents preferred existing technology over R&D funding while another suggested more support for R&D on smaller vessels. One respondent wanted funding focused on combustion tech and engine efficiency, as well as incentives for uptake. Another suggested government-funded studies on UK port infrastructure and energy demand. Lastly, a respondent called for co-investment in green propulsion technology R&D and infrastructure deployment at ports and waterways.

Government grants, subsidies, loans and guarantees

Two respondents called for government subsidies and grants to support decarbonisation efforts while two others suggested offering low-interest loans to the domestic maritime industry. Two respondents recommended grants and loans as part of a scrappage scheme. One respondent suggested offering discounts for green ships, including reduced berth fees and harbour dues. Another respondent proposed ‘plug-in’ grants for small boats. One respondent called for a national framework and funding for shore power, while 2 respondents suggested the government underwrites market finance or offers guarantees to encourage private sector investment in the sector.

Tax incentives and contracts for difference approaches

One respondent highlighted the need for more financial products while another called for tax incentives and improved access to finance. Another respondent suggested tax relief to incentivise investment in new infrastructure and make low carbon fuels cost-competitive with fossil fuels and a lower VAT rate for electric propulsion systems.

Adjusting marine fuel taxation was suggested as an opportunity to accelerate decarbonisation while capital funding for shore power and removing taxes on shore power electricity were also recommended. Another respondent proposed contracts for difference (CfD) approaches to alternative fuel production and use, funded by ETS revenue. Finally, one respondent suggested CfD approaches or RTFO-type incentives for wind-assisted technologies for original engine manufacturers (OEMs).

Q13 and Q14: Regulatory intervention

13. Are you aware of any domestic or international regulatory measures that you think currently discourage progress toward maritime decarbonisation and should be reviewed by the government?

14. Which regulatory interventions do you think the government should support in the short, medium and long term to help accelerate decarbonisation and complement existing plans and proposals?

The consultation discussed the range of regulations that could be implemented to support maritime decarbonisation.

The consultation provided respondents with the opportunity to feedback on which existing regulations may be having an adverse effect on decarbonisation (question 13) and which regulatory interventions would be preferable in the short, medium, and long-term (question 14).

Question 13 received 23 responses. Three respondents (13%) were not aware of any regulations discouraging decarbonisation. However, 10 (44%) felt that certain regulations inhibited decarbonisation, such as the IMO’s energy efficiency and carbon intensity indicator regulations, and planned EU regulations like FuelEU Maritime and Alternative Fuel Infrastructure Regulations (AFIR). A respondent believed these regulations would encourage the use of LNG and fossil-fuel-based methanol, hindering decarbonisation efforts in the long term. This respondent proposed that relief from fuel duty and the National policy statement for UK ports should be revised to promote decarbonisation commitments.

Four respondents noted the lack of incentives and support for wind propulsion and hydrotreated vegetable oil (HVO) technologies in the maritime sector, while 2 respondents mentioned the impact of the UK’s Renewable Transport Fuel Obligation (RTFO) on decarbonisation efforts, including the exclusion of certain fuels from the scheme.

Additionally, 2 respondents mentioned regulations hindering decarbonisation efforts. One cited the lack of safety standards for new fuels and energies, such as ammonia, with the sector relying only on the International Code of Safety for Ship using Gases or other Low-flashpoint Fuels (IGF). The other noted that the UK not adopting international regulations was inhibiting decarbonisation for their subsector, using the example of the standard for small craft electric propulsion developed 6 years ago in partnership with representatives from the United States Coast Guard and the Norwegian and Canadian maritime authorities.

Ten respondents (43.5%) did not mention any specific regulation discouraging decarbonisation, but highlighted risks where regulation or lack of regulation could hinder decarbonisation or where it could be used better to encourage it. Examples provided by respondents included:

• the Canal and Rivers Trusts changing licensing rules to limit diesel boats per year or alter continuous cruising rules to encourage decarbonisation of inland waterway vessels
• a warning that unique UK regulations could create confusion and adverse impacts for operators attempting to decarbonise
• the view that current regulations were too vague or inadequate to facilitate progress towards decarbonising the sector
• new regulations are too slow in being established, domestically or internationally and do not cover all new fuels and technologies for decarbonisation. For example, hydrogen is an area where the lack of regulation or slow development of safety standards was inhibiting innovation
• the IMO’s carbon intensity indicator (CII) regulations could result in more vessels being demanded due to slow steaming
• targeting the highest emitters rather than applying regulatory measures based on gross tonnage thresholds, as the current use of green taxonomy could incentivise the construction of vessels that can use lower-carbon fuels but do not

Question 14 asked respondents to share their views on which regulatory interventions the government should be focusing on in the short, medium and long term. It received 30 responses. For those respondents who were specific about the timing and choreography of various regulatory interventions, there were mixed views on which measures should be introduced at which stage.

Respondents suggested short-term regulatory interventions to make zero-emission fuels competitive with traditional fuels. These interventions included expanding the UK-ETS, changing the UK monitoring, reporting and verification scheme (UK MRV) and regulations to increase traditional fuel costs. Respondents also proposed linking freeport status to a commitment to become a zero-emission port. Additionally, respondents wanted the UK to align with and push for higher standards and ambition at the IMO.

In the medium term, the key intervention raised by respondents was linked to fuels. Interventions that could lead to increased demand for fuels would benefit the sector and would incentivise an increase in supply. This could be done by a commitment to phase out vessels that use traditional fuels over alternative fuels. As the usage of these new fuels grows, there will need to be regulations around the safe handling of them by crews. Longer-term interventions focused on further costs of using traditional fuels and not engaging with decarbonisation.

Additionally, respondents suggested additional regulatory measures including granting more power to harbour authorities to develop infrastructure for alternative fuels and increase bunkering capabilities, increasing levies on traditional fuels, providing financial incentives for wind propulsion and carbon capture and storage technologies, including inland waterways in any emission charge zones and expanding the Emission Control Zone around the UK coastline.

Q11, Q12 and Q15: Regulatory proposals

11. What are the potential benefits and impacts associated with mandating or incentivising the incorporation of energy efficiency and energy-saving measures on board domestic maritime vessels, where possible?

The consultation explored how energy efficiency and energy-saving measures may help to unlock decarbonisation in the domestic maritime sector. Energy efficiency and saving measures could encompass anything from vessel optimisation to operational and voyage improvements. Question 11 received 29 responses. Nine (31%) expressed a generally positive view about the potential for this kind of intervention, 14 (48%) expressed a neutral stance and 6 (21%) expressed a mostly negative view of this sort of policy.

Within those responses, the following possible benefits and impacts were highlighted:

Potential benefits

• energy efficiency and saving measures
• mandate would reduce greenhouse gas (GHG) by up to a third
• regulating energy-saving measures would reduce fuel costs for operators
• reduction of air pollution
• UK could be a global leader in research and development (R&D) and decarbonisation technology
• change the mindset of operators towards optimisation as the default position
• a mandate applied according to vessel size or type with a technology-neutral approach that helped operators select the most effective low-cost options
• applying a carbon price would likely have the same positive impact on the take-up of energy efficiency measures

Possible impacts

• mandates specific to the UK might negatively impact businesses and isolate the UK, pushing businesses elsewhere
• efficiency measures are complicated and hard to generalise. This makes energy efficiency and saving measures difficult to mandate
• overcomplicate the decision-making process
• limit innovation and undermine technological neutrality
• older vessels being used for longer to avoid regulations if the mandate applied to new vessels only

12. What are the potential benefits and impacts of developing a zero-emission capability standard either as a mandate or incentive for new ships? What do you think is a reasonable definition of zero-emission capability?

The consultation explored a range of specific regulatory interventions that could be implemented to support or accelerate decarbonisation in the domestic maritime sector.

This included the potential benefits and impacts of developing a zero-emission capability standard. The consultation set out a range of interpretations of ‘zero-emission capability standard’ and how this might best be implemented. Question 12 received 26 responses. Of those who responded, 9 (35%) were generally supportive of this idea. Eleven (42%) expressed an overall neutral stance on this issue and 6 (23%) expressed a negative view.

Within those responses, the following possible benefits and impacts were highlighted:

Potential benefits

• signal to industry giving companies objectives to meet and encouraging the necessary investments
• lead to future-proofing of vessels and savings
• ensures that all vessels meet the same standards, regardless of which flag they fly
• improvements of environmental conditions that such a measure would secure, including better living standards in port areas and beyond

Respondents offered a range of views on how zero emissions capability could be interpreted as a standard. For example, by providing evidence of how the vessel could be retrofitted in the future to enable zero emission technology or to include the ability to run on a low carbon fuel or be retrofitted in the least costly manner. Other respondents called for:

• zero emission capability to represent the actual possibility to combust a low or zero carbon fuel rather than have the option to retrofit a ship in the future when technology becomes cheaper and available
• zero emissions capable should represent zero emissions over the entire lifecycle of the vessel and its fuels
• zero emissions of pollutants as well as GHGs
• a zero emission capable standard that is defined in legislation and target vessel operation rather than vessel design
• alignment with international standards agreed upon at the IMO

Possible impacts

• this could give methanol an advantage over ammonia as the former has already proved to be commercially viable
• limited impact on how vessels are designed unless agreed at the IMO as most vessels are designed and built outside the UK
• high standards might render UK shipyards uncompetitive
• mandate may encourage exits from the industry
• prescriptive regulation of this nature can hinder innovation and decarbonisation
• by defining zero emission capability, it is possible that designs may converge on low-cost options that are technologically flawed
• without proven mature technologies to deliver net-zero, zero emission capability may be hard to achieve

Other policy considerations

Several respondents offered views on other policy considerations to be reviewed either before implementing such a measure or suggesting alternative ways to achieve similar objectives. They include:

• the need for a clear explanation of what is being asked to reach ‘zero-emission capable’ status
• that 2025 was too early for the introduction of any standard of this kind
• the question of whether the standard would apply only to vessels constructed in UK or to those operating in UK waters or that are UK flagged
• that standards could be applied regionally, or route-by-route, to create zero emission marine pockets across the UK
• that standards should not inadvertently risk having a damaging impact on the inland waterways sector and the wider communities that they benefit
• that government should consider providing full grandfathering rights or security against future penalty for early adopters
• the need to introduce any zero emissions capability measure as an incentive rather than a mandate
• that government should provide guidance on designing new vessels
• that developing a zero emission capability standard is likely to be difficult and create many technical issues that government may not be best placed to resolve

15. What are the potential benefits and impacts of mandating the carbon intensity of fuels and energies used in the domestic maritime sector?

The consultation discussed some of the potential benefits and impacts of mandating the carbon intensity of fuels and energies used in the domestic maritime sector. Question 15 received 24 responses. Those who responded to the question were broadly supportive of this kind of measure. Fourteen (58%) respondents were positive overall about the opportunities associated with this kind of policy, 9 (38%) were neutral and only 1 respondent (4%) was emphatically opposed to such a measure.

Within those responses, the following possible benefits and impacts were highlighted:

Potential benefits

• provide long-term clarity and certainty
• help to drive deployment of low and zero carbon fuels
• create a level playing field, encouraging a uniform approach that would support the scalability of new fuels and technologies
• standardisation of alternative fuels and technologies, promote their adoption and deliver cost efficiencies
• drive the UK to become a pioneer and major exporter in this area
• improved environmental conditions and living standards in port areas
• increase the cost of fossil fuels, making them less attractive to operators
• easier than regulating the carbon intensity of vessels and the relative simplicity of this approach was another benefit

For such a measure to be most effective, respondents recommended a range of considerations that ought to be incorporated into any policy. This included the need for clear labelling and certification around sustainability criteria and carbon intensity. Further suggestions can be found below:

• overall GHG emissions reduction basis, using a ‘well-to-wake’ lifecycle analysis
• carbon intensity calculated by carbon dioxide (CO2) emissions (in grams) per megajoule (MJ) of fuel
• inclusion of air pollutants in a fuels standard
• regulation needed to encourage innovation and development beyond the limits of existing technology

Possible risks

• inadvertently encourage the use of fuels with production methods that can be damaging to the ecosystem, such as HVO and biofuel
• encourage the uptake of fuels that are derived from or blended with fossil fuels, such as LNG
• if UK measures do not align with regional or international regulations, this could create challenges for scalability
• a fuel carbon intensity measure might not capture the CO2 reductions that can be achieved from energy efficiency measures and onboard propulsion technologies such as wind power
• a fuel mandate should not be implemented before the requisite fuels and technologies are available on the market
• costs for operators and consumers

Q16 and Q17: The government’s role in connecting, coordinating and supporting decarbonisation in the maritime sector

16. What more can the government do to help convene the maritime industry, connect coordinate and support its collaborative efforts to decarbonise the sector?

The consultation examined how the UK government could better bring the maritime industry and wider private sector together to ensure that the necessary coordination and collaboration are in place to support decarbonisation. This included the possibility of developing a maritime-focused fuel strategy to support the rollout of alternative energies and fuels at ports and via other bunkering facilities. It also included discussion about the role of government and private sector in supporting infrastructure development.

This question received 29 responses that proposed several options for how government could better connect, convene and coordinate the sector’s decarbonisation efforts. Some respondents agreed that the government should play a role in coordinating the maritime sector’s efforts to decarbonise, helping to convene operators, ports, agents and intermediaries, as well as original equipment manufacturers (OEMs), naval architects, marine fuel producers and distributors.

Respondents also noted the importance of ensuring that regulators, finance and legal representatives were included in any ongoing dialogue to support the investment needed in new technologies and infrastructure. Six respondents (21%) shared a view that in setting a clear policy direction, providing targets and regulatory certainty, the government would encourage collaboration across maritime and wider sectors.

Other suggestions for how government could better connect, convene and coordinate the sector’s decarbonisation efforts include:

• a plan for port energy supply across the UK, including consideration of production, storage, distribution and connections with the wider energy network
• greater government support of regional clusters, which could provide the critical mass of demand and coordination needed to support the development of new infrastructure
• establishment of regional collectives, guided by a national steering board, when it came to developing new infrastructure at ports to support maritime decarbonisation
• creation of an energy demand model for the maritime sector to support the rollout of requisite infrastructure, taking a systems approach to supply and demand across modes, sectors and the UK
• greater joined up working across government, the establishment of an infrastructure fund with a national framework to support these efforts, alongside promoting strategic private-public partnerships to help establish new infrastructure
• government organising and attending shared events with industry to promote collaboration
• produce and provide a live interactive product on maritime decarbonisation technology options
• a government-led technology forecast or strategy to create a shared vision to rally and plan around
• a forum to discuss decarbonisation equivalent to the Jet Zero Council

These responses are also relevant in response to question 17 and have been considered in the government’s review of responses.

17. Does government have a role in providing advice or greater clarity on the technology and investment options for the domestic fleet?

The consultation investigated what role the government should play, if at all, in providing advice or greater clarity on the technology and investment options for the domestic fleet. This included exploring whether the government’s current commitment to technology neutrality presented a barrier to decarbonisation for the maritime sector.

Thirty responses were received to question 17. Of these, 17 (57%) were positive about whether government could helpfully play an active role, 6 (20%) took a negative view and the remaining 7 (23%) did not take a strong position either way or responded with alternative comments, taking a broad view of the question.

Generally, respondents who supported government’s advisory role believed that it would aid fuel suppliers in understanding future requirements and avoid wasting time on options that won’t be adopted. Suggestions included sub-sector-specific guidance on decarbonisation and government-produced independent advice and assessments on new technologies and their GHG emissions.

Those who opposed the idea of government providing advisory services stated that, in their view, it is government’s role to set policy direction and implement supportive measures. They believed that this would be sufficient to encourage private-sector investment and innovation. Some felt that the maritime industry is better placed than government to make decisions about technology options due to their practical expertise.

Those who were neutral on the topic provided other comments, such as:

• economic and infrastructure costs, rather than lack of clarity on solutions, were the primary barriers to decarbonisation in their maritime subsector, so government advice on technology options may not have a significant impact
• classification societies were providing the best available advice
• NGOs, specialised agencies and consultant firms were also offering helpful guidance

Ten respondents referred specifically to the government’s current stance of technology neutrality with 3 (30%) stating that it presented as a barrier to decarbonisation or might do so. Respondents cited examples of the government’s current stance on technology neutrality, such as the lack of position on biofuels, which some felt could lead to wasting time and resources on technologies or fuels that are not the right options. Technological neutrality was also seen as a barrier by some respondents due to the impact it may have on producing and deploying low and zero carbon fuels, and the need for clarity to allow fuel providers to begin planning within the required timescales. In certain subsectors with lower fuel consumption, respondents emphasised the importance of clarity from the government or industry on technology pathways.

Seven respondents (70%) who referred specifically to the issue of technology neutrality stated that they did not believe this presented a barrier to decarbonisation for the sector. Two of the 7 respondents acknowledged that the government’s technology-neutral stance has not been a barrier so far, but infrastructure development would require the government to prioritise certain technologies. Other comments suggested that the market should decide on technology options based on qualified applications for specific operations. Some respondents agreed that government should provide targets and support the sector in reaching them through commercial incentives and safety standards. The uncertainty around technological solutions was cited as a reason for technological neutrality. One respondent suggested that the government should commission independent evaluations to learn what works and share the information widely to facilitate decision-making.

Q18: Disincentivising contractual behaviours that discourage decarbonisation

18. Should the government explore options to disincentivise contractual behaviours that create a barrier to decarbonisation? How should government approach this?

The consultation explored the possibility of government intervening to disincentivise contractual behaviours in the maritime sector that may be creating a barrier to decarbonisation. The example given in the consultation was that of late arrival charges, which may discourage operators from ‘slow steaming’, one method of reducing energy consumption and, therefore, GHG emissions.

Twenty-four responses were received to this question. Of these, 13 (54%) confirmed that the government should explore options to disincentivise contractual behaviours that are creating a barrier to decarbonisation. Some respondents suggested that the government could intervene in licenses and subsidies for fossil fuel production or tackle split incentives between charter parties. Others recommended that government should request that vessels track their lifetime emissions or use measures such as the Poseidon Principles to encourage decarbonisation.

However, 5 respondents (21%) took a negative view of the government exploring such options. These respondents felt that government intervention would be difficult to apply uniformly and could have negative unintended consequences. They suggested that the government should focus on deregulation or providing incentives and other supportive policies instead. One of these respondents argued that intervening in this area could be counterproductive to efficiency, safety and the viability of certain routes and trades.

Six respondents did not offer a strong view either way and focused their responses on issues not directly related to this question. Some felt that the question was unclear, or they were not aware of any such contractual behaviours, or that this did not apply to their sub-sector. Others advocated for further supportive research and development.

Q19 and Q20: Encouraging consumer investment in maritime decarbonisation and reviewing the monitoring, reporting and verification (MRV) system

19. How do you think the UK’s MRV system could be improved to help support public and consumer engagement with maritime decarbonisation?

The consultation described the introduction of the UK’s own MRV regime for recording CO2 emissions from vessels over 5,000 gross tonnes (GT). It also detailed ways in which this MRV system could be amended to improve its functioning and to support efforts to decarbonise the sector. This included lowering the threshold for reporting from 5,000 GT to include smaller vessels.

Question 19 received 22 responses. Almost all responses were positive about the potential for emissions reporting to be used to build a reliable baseline understanding of the emissions from the domestic maritime sector and, when published, positively influence consumers and the public.

There were 3 respondents who underlined a range of risks associated with this approach. These included:

• growth in the regulatory or reporting burden might lead to increased road journeys in preference to domestic maritime journeys, at a higher cost to the environment
• depending on how any data is published, misinterpretation by the public could lead to complaints and protest action at ports over certain vessels
• the need to ensure that data supplied to the MRV system has sufficient integrity and uniformity in evaluation before data is published to ensure fairness and transparency

Most respondents favoured refining the UK’s MRV system to support decarbonisation efforts, which they suggested could incentivise better energy efficiency measures by operators and scale customer demand for alternative fuels.

Lowering the 5,000 GT threshold and including a wider range of vessel types, such as offshore service vessels, were options supported by respondents. Some suggested a new system to include canal and river craft, but one respondent noted that including fishing vessels would create a disproportionate administrative burden for smaller operators.

Other suggested options for refining the MRV system included extending the reporting period back to 2018, and reporting MRV data on a fuel type per voyage basis, enabling a better understanding of the costs and benefits of any given fuel in an operational context. Respondents suggested including methane, NOx and black carbon emissions in addition to CO2 emissions, and one respondent suggested reporting emissions from journeys between UK ports and ports in the European Economic Areas (EEA) in the MRV. Another respondent recommended reporting the level of direct and indirect renewable energy used on ships, generating demand for a wide range of applicable technologies.

Five respondents (23%) expressed a preference for any UK monitoring system to remain aligned with other reporting systems that operators may be obliged to use, such as the EU’s MRV regime and the IMO’s data collection system (DCS). This is to ensure a minimal administrative burden on operators. Two respondents expressed their preference to avoid duplication in reporting the same data to different systems where possible and offering exemptions in this case. Two respondents noted that the MRV system and data could be used positively in the development of carbon labelling similar to food miles labelling.

20. What role do you think the government should play in encouraging public engagement and consumer investment in maritime decarbonisation efforts?

The consultation set out a range of policy measures that the government could explore to encourage public and consumer engagement with efforts to decarbonise the maritime sector. This included publishing performance and environmental impact information relating to vessel journeys to encourage efforts by operators and their customers to decarbonise the sector. It also included discussion of the ways in which green taxonomy and eco-labelling could be used to encourage decarbonisation for vessels, in the form of certification, or for the goods they transport. Question 20 provided an opportunity for respondents to discuss these issues and propose methods by which government could most helpfully intervene.

Question 20 received 25 responses. Most responses supported the idea of government taking an active role in this area. Eight respondents (32%) specifically called for government to do more to educate the public on the value of the maritime sector and increase its visibility and the challenges around its decarbonisation. Two respondents stated or suggested that government may not be best placed to fulfil the role of encouraging consumer and public investment in the maritime sector and its decarbonisation. Instead, the government could work through organisations such as Maritime UK and Mari-UK when trying to reach a wider audience.

Respondents suggested various options for how government could support the decarbonisation of the maritime sector. Ideas included hosting national showcases, providing struggling businesses with successful investment ideas and encouraging energy efficiency. Respondents emphasised the government’s role as a commercially neutral arbiter, balancing evidence-based dialogue and encouraging moves towards decarbonisation.

Some respondents also suggested that support for domestic lifeline ferries and increasing the use of domestic canals and rivers by business and the public would increase visibility of the sector, which would then stimulate public engagement. Additionally, setting targets and a clear regulatory roadmap was seen as a way to stimulate public interest in decarbonisation.

Respondents suggested various ways for the government to increase consumer investment in maritime decarbonisation. They suggested the government could act as a guarantor, offer grants and provide research and development funding. Respondents also suggested implementing tax incentives, subsidising zero carbon routes and using the Enterprise Investment Scheme to support infrastructure build-out. Additionally, they referred to government-supported carbon and eco-labelling to engage consumers, and market-based measures to have a tangible impact on prices for the consumer.

Q21 and Q22: Final comments on maritime decarbonisation

21. Do you have any other comments to share with us, about any aspect of domestic maritime decarbonisation?

22. Do you have any other comments?

The consultation offered the opportunity for respondents to provide final comments about any aspect of domestic maritime decarbonisation or any other issue. Twenty-six respondents offered final comments about domestic maritime decarbonisation in response to question 21. We received 27 responses to question 22 offering general comments. Similar themes were raised about the responses to these questions, which are set out as follows.

The strategic context and taking an holistic approach to domestic maritime decarbonisation

Respondents recommended a systems approach to decarbonising the domestic maritime sector, emphasising the need for the DfT to consider wider energy and infrastructure needs and engage with relevant stakeholders across government, devolved administrations, local authorities and industry. They also highlighted the importance of considering air pollution issues and the potential for the UK to gain a first mover’s advantage in decarbonisation efforts rather than being disadvantaged by domestic regulations in a tiered regulatory system. Some respondents highlighted their support for the UK’s international efforts at the IMO to pursue agreement on universally applied measures.

The role of government, the maritime industry and wider private sector

Respondents welcomed the consultation and the government’s commitment to decarbonising the sector, stressing the role of government as a facilitator of collaboration and innovation and establishing targets and regulation where appropriate. They also noted the need for the government to appreciate the diversity of the domestic maritime sector and treat businesses accordingly.

Respondents would like the government to engage with a wider range of stakeholders including fishing, smaller vessel operators, SMEs working on marine engineering, technology development and the energy sector. They want to work closely with the government to set ambitious decarbonisation targets and provide a clear roadmap for the sector that is flexible and adaptable to future technological developments. Some respondents recommended that the government reviews the evidence base before setting intermediary decarbonisation targets, leads the way in decarbonising the domestic civilian fleet and takes an active role in supporting green maritime skills.

Developing our domestic maritime decarbonisation strategy

Respondents proposed measures beyond decarbonisation targets, including government support for regional clusters focused on maritime decarbonisation and increased investment from both government and private sector. They acknowledged that a range of technologies would be needed and suggested focusing on UK strengths within the maritime industry. They also called for incentives and improved access to capital for SMEs in the maritime sector and a need to move away from practices that inhibit development, such as just-in-time practices.

Next steps

We thank all respondents for their contributions to the course to zero consultation. We will thoroughly review the feedback received, incorporating it into our internal processes to inform the update of the clean maritime plan, which we hope to publish in late 2023.

The identification of suggestions within this document is not an indication that government will take them forward as policy proposals. Similarly, the absence of a suggestion from this report does not mean it will not be considered.

If you have any other feedback in the meantime, email maritimetdpconsultation@dft.gov.uk.

List of organisations that responded

Responses from individuals working in the maritime sector who did not categorically state that they were responding on behalf of an organisation have been recorded as responses from individuals rather than organisations and are, therefore, not listed here.

DfT received 5 responses to the course to zero consultation from individuals and 50 responses from organisations, as follows:

American Bureau of Shipping (ABS)

ASEA Brown Boveri (ABB)

Blue ESG

British Marine

British Maritime Technology Group Ltd (BMT)

Broads Authority

Canal and River Trust (CRT)

Cemex

Connected Places Catapault (CPC)

Dover Port

Energy Networks Association (ENA)

European Marine Energy Centre (EMEC)

Faculty of Science and Engineering, University of Plymouth

Further Fuel (FF)

GPS Marine

Hydrogen Afloat

Hydrogen UK

Imperial University

International Council on Clean Transportation Europe (ICCT)

International Windship Association (IWSA)

Liverpool City Region Combined Authority

Logistics UK

Marine Capital

Marine Management Organisation (MMO)

Maritime UK

National Federation of Fisherman’s Organisations (NFFO)

National Oceanography Centre (NOC)

Nautilus International

Northern Lighthouse Board

Ocean Infinity

Opportunity Green

Penine Energy Group Ltd

Port of London Authority

Royal Yachting Association (RYA)

RWE Renewables

Shell

Smart Green Shipping (SGS)

Society of Maritime Industries (SMI)

Southampton Marine and Maritime Institute (SMMI), University of Southampton

Tarmac

The Law Society of Scotland

Transport and Environment (T&E)

Tyndall Centre for Climate Change Research, University of Manchester

UK Chamber of Shipping (UKCoS)

UK Hydrogen and Fuel Cell Association (UKHFA)

UK Major Ports Group (UKMPG)

UK Petroleum Industry Association (UKPIA)

University Maritime Advisory Services (UMAS), University College London (UCL)

Warrenpoint Harbour Authority

Western Fish Producers’ Organisation (WFPO)