EMEC ZAS0006

Written evidence submitted by the European Marine Energy Centre Limited (EMEC)

Executive Summary

This response is led by EMEC and has been drafted in collaboration with local industry partners and public sector partners Orcades Marine, Highlands and Islands Airports Limited (HIAL) – Kirkwall Airport, Loganair, Northlink Ferries, and the Orkney Islands Council (OIC). Our collective response was informed by a two-hour collaborative workshop addressing relevant questions, followed by a collective review of the final submission. Although it expands beyond the recommended submission length, it reflects the views of 6 key stakeholders, and we hope it will effectively inform the Committee’s inquiry.

EMEC and partners welcome the opportunity to respond to this timely consultation.  By way of summary:

• In Orkney, we are developing highly experienced personnel across organisations in the space of zero emissions aircraft and vessels. This includes research, development and demonstration (R&D&D) centres such as EMEC, commercial companies such as Loganair and infrastructural service providers such as Kirkwall Airport, run by HIAL, as well as Orkney Ferries, Northlink Ferries or Orcades Marine, hence extending our reach across the value chain.

• Zero emission aircraft is closer to commercialisation than zero emission vessels. There is a risk that a focus on Sustainable Aviation Fuels (SAFs) clouds the value of zero emission domestic flights. In the maritime sector, retrofitting and demonstration at scale for domestic fleets will drive decarbonisation.
• People are key to driving decarbonisation of both sectors. Without the training, skills and confidence in the workforce, these technologies will not reach commercialisation.
• Hydrogen is an obvious, and pertinent overlap between the decarbonisation of both aviation and the maritime sector. There is a need to standardise operational requirements for this fuel source as soon as possible. There is in addition, a need to ensure regulators provide appropriate flexibility within regulations for pilot demonstration projects of these technologies.
• We welcome the focus on ‘green’ hydrogen for transport decarbonisation, including in aviation and maritime and would encourage greater clarity on targets. This is particularly relevant for island and coastal areas such as Orkney, given the vast wind, wave and tidal energy resources to hand – creating opportunities for such territories to become clean energy and green hydrogen hubs while responding to decarbonisation needs. Given the level of expertise to hand, we urge further engagement on the opportunity for Orkney to become one of the UK’s innovation hubs in the green transport space.
• There is a clear just transition argument in the decarbonisation of these two sectors which respondents fear the government could overlook. The Orkney Islands are clean aviation and shipping pioneers within the UK, are setting up a hydrogen ecosystem and will undergo a renewable energy development revolution over the coming decade which will provide vast amounts of power to the UK. In this context, it is critical to understand that both shipping and aviation provide lifeline services to these islands which cannot be replaced. There is a real risk that policies are urban-centric instead of recognising specific needs, risks and realities of different territories. It is hence necessary that policies take contexts such as that of Orkney and the opportunities they bring, into consideration.

We would welcome the opportunity to meet with the Committee to discuss our submission. In the meantime, should you have any questions, please do not hesitate to contact Neil Kermode, Managing Director.

Introduction

EMEC was founded in 2003 in Orkney, Scotland and is the only accredited wave and tidal test centre for marine renewable energy in the world.  More marine energy devices have been tested at EMEC than at any other single site in the world: EMEC has hosted 20 wave and tidal energy clients (with 32 marine energy devices) spanning 11 countries.

Today we’re also pioneering the development of a green hydrogen economy in Orkney, having set up a hydrogen electrolysis plant onshore in 2016, next to our tidal energy substation. With the ability to use locally produced hydrogen to decarbonise across a range of power heat and transport applications, Orkney has become a leading example of a developing hydrogen economy. EMEC support and actively collaborate on hydrogen research projects and offers a demonstration site for new hydrogen technologies. Most recently EMEC’s project involvement has focussed on hydrogen demonstration in the maritime and aviation sectors, supporting the decarbonisation of lifeline transport services. 

• How close are zero carbon fuels to commercialisation for aviation / shipping? 

Aviation

Zero carbon aircraft solutions, with a focus on battery electric and hydrogen/fuel cell technologies are in fact close to commercialisation and are already being demonstrated successfully. Examples in which respondents are involved include the recent successful milestone achieved by the Sustainable Aviation Test Environment (SATE) project, where partner Ampaire was recently the first to fly a low-emission, hybrid-electric aircraft in Scotland on a potential airline route[1]; or the HyFlyer I project which achieved successful completion of the world’s first hydrogen fuel cell powered flight involving a commercial-sized aircraft[2]. Certification and approval of these technologies are expected by industry within a decade, and for domestic flights, zero emission technologies like these are considered more commercially viable in the near term than decarbonisation through SAFs.

Zero emission technologies for domestic-scale flights are not facing technical barriers. Rather, the certification of alternatively fuelled aircraft frames has been slow. Commercial factors around the market pricing of alternative fuels are also currently prohibitive. However, industry partners see a five-to-ten-year window for these products to be fully commercialised.

Given the weight of batteries, battery-electric technologies are likely to be quite limited, although there is value in continuing to support their demonstration at such early stages. Hydrogen is thus predicted to be the primary technological solution, especially once economically viable (even beyond SAFs). Both hydrogen combustion engines and hydrogen fuel cells are being developed, with applications in mind in providing power for aircraft propulsion, as well as for auxiliary power units. Fuel cells are heavier than conventional combustion engines, yet they are more efficient, and they are truly zero emission. Early-stage innovation projects undertaken in the last few years have focused on deploying small fuel cells, up to ~500 kW in scale, for the purposes of providing power for passenger aircraft with fewer than 10 seats. However, research projects underway now are looking at fuel cells up to 10 MW in scale, which would be appropriate to provide the power required for a turboprop aircraft with up to 70 seats. This demonstrates the pace at which these technologies are nearing commercialisation.

Shipping

In contrast to aviation, shipping is noticeably further away from commercialisation, despite a relevant amount of R&D and demonstration projects in the sector. The primary barrier that the maritime sector is facing is with regulation, and particularly, a highly conservative approach from regulatory bodies in the face of innovative projects. This is, however, not just a UK-driven problem. Global regulation in the maritime space is restrictive, and other countries such as Belgium and Norway are known to be facing similar challenges. In this context, respondents welcome the creation of UK SHORE, as announced in the Transport Decarbonisation Plan[3].

Commercial viability of zero emission shipping, as with other technologies, heavily depends on deployment of projects at scale. Projects such as HyDIME, led by Ferguson Marine in collaboration with EMEC, ULEMCo and HSSMI, have studied commercial viabilities of zero carbon shipping technologies and of the usability of hydrogen as a fuel. The partnership evaluated the technical feasibility of converting a diesel ferry to operate with a hydrogen-diesel dual fuel auxiliary power engine system, in order to reduce ferry emissions. First-of-a-kind real world testing of this system on board a Shapinsay-Kirkwall ferry was anticipated for the project, however challenges associated with inflexibilities in regulation in the marine environment limited the scope of possible project activities to ancillary exercises. This project exposed flaws in the translation of learning from the terrestrial to the marine regulatory environment and the slow development rate of the controlling frameworks.

Hydrogen Europe’s Maritime Decarbonisation Position Paper highlighted that a ship’s lifetime is around 30 years, and that ~50% of ships in operation worldwide are around 15 years old[4]. This gives many in the sector around 15 years to develop commercially viable, zero carbon solutions. Fleet renewal will then determine the ships and their emissions for the next ~30 years, potentially locking vessel owners and operators in high-emission systems which is why acting now is necessary. Simultaneously, retrofitting of vessels will be essential to increase commercial viability of zero carbon ships while decarbonising the existing fleet, given that entirely re-building vessel fleets would create an incredible amount of waste and embodied emissions. We recommend the UK assess the lifespan state of our current domestic fleet as well as of international opportunities for fleet decarbonisation.

The industry requires three critical elements to drive the commercialisation of zero emission shipping in the timescales required. Firstly, standards and regulation must be revisited with urgency, at international and national levels to ensure cohesion. Where relevant, regulatory bodies must be supported in legislation and in resource to meet the challenges of evolving. Likewise, however, those bodies must also seek to be flexible and proactive in adapting to facilitate innovation while upholding stringent safety standards. They must introduce an element of flexibility for testing and demonstration purposes. Otherwise, we will never be able to learn about these new systems and develop learnings around their functionality, management and safety dimensions for future standards to be defined. This could look like a regulatory sandbox of some sort, as highlighted in the UK’s hydrogen and innovation strategies, and is essential for these technologies to develop. Given partners responding to this consultation are in the supply chain, R&D and demonstration spaces in the industry, we would welcome further engagement on this topic.

Secondly, the industry has an opportunity to drive domestic innovation for adoption of truly zero emission vessel technologies in the shorter term – and policy needs to recognise and drive this effectively. The Transport Decarbonisation Plan highlighted the potential of domestic fleet decarbonisation, but there is a risk that policy continues to delegate the responsibility of action to the IMO. The Department for Transport are almost wholly competent with regards to shorter-range operation vessels, creating a clear opportunity for national focus and breakthrough. Meanwhile, transitional fuels will play a role at an international level, though international progress will clearly be slower.

Thirdly, the shipping sector requires demonstration projects that can escalate to industrial scale, to understand and ultimately lower costs. We recommend the government takes a tailored approach to grant funding and competition subsidy schemes to drive the commercialisation of different technologies.

• How effective will the Jet Zero Council be in catalysing zero emissions technologies? 

Aviation

While the Jet Zero Council (JZC) is a welcomed initiative, we must stress our concern with regards to SAF fuels versus zero-emission flight options. The JZC has two focused delivery Groups: on zero emission flight and sustainable aviation fuels (SAFs)[5]. In practice, however, the Jet Zero Council is fundamentally focussed on SAF given most operational emissions arise from long-haul, international flights, as outlined above. Nonetheless, this might not be the appropriate path for domestic emissions reductions.

It is understandable that the council should focus on the bulk of emissions, but not to the detriment of existing, zero emission technologies. We recommend that the Zero Emission Flight Working Group gain weight within the JZC to discuss domestic flight decarbonisation. We suggest that the JZC look at regional connectivity and the broader benefits stemming from this – particularly the role for aviation in economic development for peripheral and island locations, alongside regional emissions reductions. A top-down, national emissions focus will be driving solely SAF, and this will increase costs while potentially precluding the adoption of zero emission alternatives.

• What role should transitional fuels such as alternative hydrocarbon fuels play? 

Aviation

It is likely that transitional fuels, such as alternative hydrocarbons and SAFs, support the decarbonisation of medium to long haul aviation. Biofuels could provide a potential 90% lifecycle emissions reduction and are currently available commercially. However, under current market conditions they are three to four times more expensive than conventional jet fuel. Therefore, the barrier to more widespread adoption of biofuels is market-based rather than technical. The UK government is currently consulting on a SAF mandate, which will require the incorporation of a proportion of biofuel in fuel blends.

We would like to note that the 10% of national emissions referred to within the consultation document, of which 7% pertain to aviation, arise almost exclusively from international aviation, at 7%, as specified in the Committee on Climate Change’s Net Zero Technical Report, 2010[6]. This report further states that in 2017 GHG emissions from departing international flights made up the vast majority (96%) of UK aviation emissions, while domestic flights made up 4% of aviation emissions[7].

This is not to say domestic flights need not be decarbonised. However, we are therefore concerned about the bulking together of long-haul aviation decarbonisation requirements with those of shorter distance, regional routes. While transitional fuels have a role to play in long-haul aviation to reduce operational emissions in the near term while zero emission solutions progress, it is unclear whether this is the same process required for short distance flights. Industry partners like Loganair argue that they do not see a need in short haul aviation for this transitional support. There is a risk that a focus on transitional fuels for the whole of aviation clouds the efforts and proximity to commercialisation of truly zero carbon aviation solutions like hydrogen and battery electric flights for short flights. This could create economic and technical difficulties in the development of regional aircraft carriers. Policies with regards to aviation decarbonisation should distinguish between the needs of domestic, short-distance flights, versus long-haul decarbonisation, as should policy support mechanisms for innovation and deployment in these arenas.

In addition, there is a risk that a focus on transitional fuels to meet overarching aviation decarbonisation targets, including domestic decarbonisation (to consult on a 2040 target[8]) will lead to a high, and unnecessary cost to consumers. Particularly for islanded regions this impact would be highly detrimental. The cost of airline travel is noticeably higher than across the rest of the nation, even with subsidisation for residents. More importantly, airline and maritime travel for island residents is a lifeline service to connect to the rest of the country and world. A drastic increase in price for consumers would therefore put island communities in particular risk and at a high, distributional disadvantage. This is in juxtaposition to the fact that island territories, in particular Orkney, are leading the charge in low-carbon aviation innovation and demonstration through projects such as SATE and HyFlyer I & II. To ensure a just transition across the board, while supporting levelling up (instead of increasing inequalities), energy transition and climate change mitigation policies must take these contexts into consideration.

Specifically, in the Orkney and island contexts more widely, hydrogen has an edge as a more viable fuel than electricity or SAFs, likely providing a solution for inter-island flights up to perhaps turboprop routes within the decade. It also creates socio-economic development opportunities for these territories.

Hydrogen powered inter-island aircrafts offer wide opportunities to the aviation ecosystem and supply chain. The Orkney islands have vast tidal, wave and wind resources, the latter onshore and offshore, which create a noticeable opportunity for hydrogen production. Since 2013, the Orkney Islands are producing over 100% of their electricity demand through renewable energy. In the aviation space, at present, it is very expensive to refuel aircrafts in Kirkwall airport due to the need to import fuels. Therefore, operators try to minimise fuel uplifts at outstations generally, because it is cheaper to uplift centrally where fuel costs are lower – a highly inefficient use of time and fuel, with greater emissions, which creates a vicious circle. A hydrogen-based aircraft fleet would create a new dynamic, given that it is likely that gaseous hydrogen production will in fact be cheaper in Orkney rather than elsewhere. Increasing industrial efficiency, while creating levelling-up opportunities for the islands.

Shipping

Innovation in decarbonisation is at an earlier stage in shipping, so transitional fuels have a greater role to play across the industry.

To begin with, there is a coherent role for Liquified Natural Gas (LNG) in the transition for larger vessels, as they move from high emitting fuels to the predicted green ammonia. It is likely that ammonia offers a better technical alternative to hydrogen for use in larger tankers and cruise ships, albeit with its own unique challenges around onboard storage and additional processing during production.

On the other hand, however, LNG makes less sense for smaller vessels serving domestic routes, or for inland shipping. For these vessels, we should already be looking to move to zero emission alternatives, as some demonstration projects such as HySEAS III are aiming to do. Transitional fuels are less relevant in these applications.

• What new technologies are there to reduce emissions from aircraft / shipping vessels and how close to commercialisation are they?  

Aviation

Technology-focused solutions for aircraft propulsion are covered in questions above.

In addition to technology focused solutions, the government and this committee should review the entire operational value chain of relevant to these industries. For example, there are an array of existing, commercial technologies that could contribute to the decarbonisation of airport ground operations in the aviation sector. The Civil Aviation Authority has been criticised for being inflexible with regards to what can and cannot be done within an air-side environment, in terms of the adoption of zero emission solutions. Ground operations as a key part of the aviation industry’s value chain and a contributor to emissions which have been overlooked in aviation so far. From airport vehicles to baggage carts, land-side generators and auxiliary power to aircraft systems, a whole-systems perspective of the industry’s emissions and operational chain could be transformational across airports and the sector more widely.

Shipping

There are a variety of new technologies to reduce emissions from shipping, which are being widely developed and trialled by some of the largest commercial operators. Examples of these include CMB Technology and their Hydrotug programme, or Kawasaki and Wartsila working on hydrogen ammonia and methane R&D. 

Hydrogen and fuel cell technologies have been demonstrated but continue to be at test and demonstration phase, remaining expensive. As examples, there is currently a vessel running on a fuel cell in San Francisco, and an inland river ferry in Hamburg also running on a fuel cell. It should be noted that current fuel cells under testing are significantly smaller (factors of 10) than the required power for trans-continental shipping. Technical issues in scaling-up fuel cells should be tackled via two mechanisms: the provision of further research, development and importantly, demonstration support, and through addressing regulatory challenges to test and demonstrate new fuel cells, as these inflexibilities also preclude more widespread adoption. To date, the Maritime and Coastguard Agency has been reluctant to provide approvals for use of hydrogen and fuel cells in vessels. 

Storing appropriate volumes of hydrogen ashore to fuel vessels when they are alongside is a challenge due to the low volumetric energy density of hydrogen as a gas. Liquification is being considered as a means of improving this as liquid hydrogen is much higher in energy density by volume. However, liquification is energy intensive (consuming approximately 15% of the energy of the hydrogen), and its low temperature would require the roll out of specialist infrastructure in harbour settings. Other means of storing and transporting hydrogen are being investigated, including the use of solid-state metal hydrides and liquid organic hydrogen carriers. Both are expected to facilitate more efficient hydrogen handling in the future. 

In terms of commercialisation, ammonia holds great potential as an energy carrier, once the hurdle of scaling up green hydrogen production is crossed. It can be handled as a liquid at temperatures much nearer to room temperature. In addition, because it has been transported on ships for years already, the logistics of its transportation are simpler and better understood than of hydrogen gas.

Another key dimension to the types of fuels and their role in shipping will be the adaptation and conversion of existing port infrastructure to meet new fleets’ needs. This specifically means the provision of electrical shoring equipment at quay side as well providing adequate bunkering facilities. This has been highlighted in the UK’s Transport Decarbonisation Plan, as well as in Hydrogen Europe’s policy paper on “How Hydrogen can help decarbonise the maritime sector” published in June 2021[9]. Importantly, port infrastructures offer an opportunity to tackle the chicken and egg dilemma in this sector through the supply value chain, given that the transformation to zero-emission vessels must be coordinated with port infrastructure repurposing and adaptation. An opportunity to begin to achieve transition is through large-scale zero-emission demonstration projects which will begin to put appropriate infrastructure in place, next to where it will be used in the medium to long-term, while further de-risking infrastructures and future investment.

We would also like to highlight that a primary issue in shipping is that training and certification are simply not up to speed with upcoming technologies. Staff need to feel confident in their knowledge and ability to manage and operate low-emission vessels and fuels, upholding stringent health and safety standards. A key pathway to increase efficiency of technology commercialisation is therefore to keep a people-focus in mind, and increase skilling within the sector, designing appropriate courses for instance in the hydrogen or fuel cell space. Orkney is trying to take the lead in this area with respect to local skills and in fact Orkney College and Orkney Ferries, with support from EMEC, designed and delivered a world first hydrogen training for ferry operators in 2021[10]. 

• How should the Government’s net zero aviation strategy support UK industry in the development and uptake of technologies, fuels and infrastructure to deliver net zero shipping and aviation? 

We have addressed this question from a combined aviation-maritime perspective, focussing on cross-cutting themes.

Increased R&D

The strong focus in recent strategies on R&D for decarbonisation is welcomed. We would however like to stress the importance of ‘demonstration’ within the R&D process, which is critical to bridging the gap between research, development and commercialisation, known as the ‘valley of death’ for emerging technologies. We would like to highlight the opportunity presented by the Government’s net zero aviation strategy, the upcoming R&D Place and Net Zero strategies to drive forward the demonstration pillar of innovation. In places like Orkney, where EMEC has a track record of demonstration projects, there is an opportunity to drive technologies forward with local and international partners. Expertise gained from projects like HyDIME, HyFlyer I & II and SATE position us to drive forward the development and uptake of technologies, fuels and infrastructure to deliver net zero shipping and aviation.

In this vein, we welcome the ambition within the Transport Decarbonisation Plan[11] for maritime demonstration at scale in the 2020s, as well as the inclusion of maritime within the RTFO. We recommend the government take advantage of the innovation activities taking place in Orkney to create an innovation cluster where the expertise and value chain already exist.

Hydrogen

A critical element of overlap for these two hard-to-decarbonise, transport sectors, is no doubt hydrogen. We welcome the publication of the Hydrogen Strategy and the government’s clear focus on demonstration as the road to innovation. We would also like to highlight the government’s explicit recognition of the need for a supportive regulatory framework (p79), and the understanding that “first-of a kind hydrogen projects… may encounter unexpected regulatory barriers, for instance relating to safety, planning, licensing or access to end use markets (for example, different regulations and regulators for households versus industry, transport versus heat). Such unforeseen barriers can significantly hinder early project development and related innovation.”[12] Above, we have highlighted the critical risk presented by regulation and the opportunity for regulatory bodies to adapt to the needs of transforming and experimental industries. We look forward to seeing what proposals are put forward by the government in this arena.

The Hydrogen Strategy also highlighted a critical aspect that will positively impact both aviation and shipping in tandem: hydrogen training for staff across the sector. The people working in these sectors, their capabilities, knowledge and importantly levels of comfort and security handling these new technologies will be essential for the future industries’ success. We look forward to seeing government’s support for organisation across the shipping and aviation value chains, from commercial developers to management institutions such as ports or HIAL, to design, implement, and deploy appropriate training in hydrogen handling.

From a market-driven perspective, the development and demonstration of clean solutions for both aviation and shipping in unison will together drive increased need and demand for hydrogen, in turn enhancing production and stimulating the market. The aviation strategy therefore has a role to play in driving the uptake of truly zero emission, green hydrogen-based solutions, such as in the domestic flight space, which will simultaneously drive market demand for the fuel across the board. A key governmental role through these strategies is to provide appropriate signals that drive down costs.

Finally, given shipping and aviation will share fuels and technologies, policies such as the aviation strategy can drive forward standards and regulations that should be homogenised across industries. Common fuels, methods and standards are required, as well as the standardisation of certain fuel-adjacent infrastructures such as filling infrastructure and bunkering. Strategies must avoid creating regulatory siloes or effort duplication, instead identifying the consistencies between industries to ensure a common approach.

Avoid R&D siloes but beware of urban-centric policy making

From an overarching perspective, a key requirement is for the Government’s net zero aviation strategy to understand its fit within the wider UK future energy market. Individual sectors must be understood, in the same way that geographical differences across the nation do; but the net zero aviation strategy must fit within all the different pieces of the UK’s decarbonisation policy landscape, from the recently published Hydrogen Strategy and Innovation Strategy, the Transport Decarbonisation Plan, all the way to the UK’s Digitalisation Strategy and Road Transport Decarbonisation Action Plan. The way these different fuel sources are developed across modes of transport will impact different sectors and their subsequent development, so these cannot be considered in siloes.

Having said this, the UK government must take care not to fall into an urban-centric, hub creation approach where proximity leads to centralisation away from peripheral areas. The Innovation Strategy highlights through a levelling-up lens that there are still too few strong innovation clusters[13]. Both aviation and shipping present an opportunity to continue to invest in ongoing R&D&D in peripheral areas where there is already a knowledge economy around these technologies, a need to decarbonise and to continue to use them (given that in Orkney, switching to electric rail travel is simply not an option), and the relevant geographic space and infrastructure to continue to investigate them. The UK Government’s Decarbonising Transport Plan recognised the role that the Orkney Islands are playing as home to innovative hydrogen vessel projects[14]. We would welcome further engagement on how this region can become an innovation cluster in this field.

• What is the most equitable way to reduce aircraft passenger numbers (e.g. reforming air passenger duty and taxes, frequent flyer levies, bans on domestic flights where trains are available, restrictions on airport capacity)? Are there any policy mechanisms that could reduce our reliance on shipping? 

Aviation

From our perspective, this question is fundamentally wrong-headed. We would caution that it is designed from an urban-centric perspective, reflecting attitudes that air travel is optional. Air connectivity is essential for island communities – as stated above, there is no possibility to travel via electrified rail between Eday, an isle in Orkney, and Glasgow, for instance. An improved question would be to ask what the minimum level of connectivity is between certain places, such as Edinburgh and Kirkwall, to identify potentially inefficient routes.

Nonetheless, when aviation is a lifeline service, there will need to be available routes despite incomplete capacity. The emissions cost of running a route does not necessarily vary by passenger number either, when within capacity – which entails that limiting passenger numbers may simply be reflected in a higher cost for those who have no other choice but to fly. This applies not only to Orkney, but to other island and rural areas. Essential aviation services in these environments should be recognised as such.

Finally, we would like to reiterate the point that this question obviates the fact that truly zero emission flights are being tested in the Orkney Islands already, and that companies such as Loganair have a genuine ambition to deliver low to zero emission flights in the very near term, for inter-island flights at least. This highlights imperfections in the current approach to aviation. We would strongly recommend a nuanced approach that recognises the nearing availability of zero emissions flights to meet the needs of peripheral areas – thus passenger numbers would not have to be reduced per se. Policy should distinguish between aviation for leisure, and aviation routes that have a feasible travel route replacement, versus aviation for necessity. The UK is an island nation– and a great part of the UK is made up of island archipelagos. The government must recognise these regions and their different needs within their strategies, to avoid leaving people, territories and opportunities behind.

Shipping

From a shipping sector perspective, we assessed this question as: Are there any policy mechanisms that could reduce our reliance on shipping?

In the case of island territories such as Orkney, there is an important parallel between aviation and shipping: they both provide lifeline, essential services to our communities. They enable interisland connectivity and commutes, often the sole link between some of the further isles and avoiding potential depopulation; and these two transport modes also connect the archipelago to the wider UK and beyond. Therefore, it is particularly difficult to focus on policies that reduce consumer reliance on these modes of transport, versus in other parts of the nation where other options do exist.

Instead, and in similar vein to aviation, we would encourage the focus on fast and ambitious decarbonisation of vessels. We are encouraged by commitments in the Transport Decarbonisation Plan published in July, which highlighted firstly, place-based solutions, including encouraging local areas to identify their priorities (p40); and secondly, the aim to develop and deploy zero emission technology starting with small craft through demonstration at scale in the 2020s (p41)[15]. We also welcome the Plan’s commitment to genuinely ‘green’ hydrogen for transport decarbonisation, including in aviation and maritime[16]. This is particularly relevant for island and coastal nations such as Orkney, given the vast natural resources of wind, wave and tidal energy that we have to hand – creating great opportunities for territories to become clean energy, and green hydrogen hubs. In addition, we particularly look forward to the indicative domestic maritime decarbonisation targets said to be announced in 2022, and the UK Government’s ‘Course to Zero’ consultation, as specified in the government’s Transport Decarbonisation Plan[17].

Concluding Remarks

While we recognise that vessels and aircraft in territories such as Orkney may not account for a great proportion of emissions within the UK total, they result in individuals in Orkney having one of the highest carbon footprints across the UK. Not only this, but these two, hard to decarbonise sectors, are not an option for island citizens – they are an essential lifeline service. Combining this knowledge with the fact that world-leading, tangible innovation and demonstration of technologies, in air and water, are being demonstrated in the islands, this makes a compelling argument to consider the need to island-proof transport decarbonisation policies.

Finally – we must re-state the point that real, zero-emission aviation is tangibly close to delivery across these islands. The advancement of these technologies will create an exportable knowledge economy to the rest of the world, where the UK will be able to compete in zero-emission aircraft markets. The UK Government must therefore take care that a focus on SAF does not endanger our ability to progress these technologies and their benefits to UK regions. We require greater ambition with regards to zero emission domestic aviation, and we require clarity on targets with regards to domestic vessel decarbonisation now that ambition for zero emission domestic vessels has been stated.

As an island-based, cross-sector, experienced, and innovation-focused cluster, we would welcome representation in ongoing decarbonisation policy decisions-making processes.

September 2021