NOC ZAS0007

National Oceanography Centre submission to the Environmental Audit Committee’s inquiry into net zero aviation and shipping

1. The UK’s National Oceanography Centre (NOC) is one of the world’s leading oceanographic institutions with a remit to deliver research from the coast to the deep ocean. Our activities span numerous disciplines, from ocean physics to numerical modelling, marine biology, climate change, marine geophysics and technology innovation. We manage the UK’s national fleet of oceanographic research vessels and serve the needs of the UK’s marine science community through the National Marine Equipment Pool and the British Oceanographic Data Centre.

2. We welcome the opportunity to provide written evidence to the Environmental Audit Committee’s inquiry into net zero aviation and shipping. NOC has been leading Net Zero Oceanographic Capability (NZOC), a scoping project to inform UKRI’s planning for the future of low carbon oceanographic research. This project will report this autumn, so although the final report is not included in this response, many of the themes it tackles (notably future ships, the increasing use of autonomy in the marine sector, the realisation and impact of a digital ocean and future policy and regulation) are touched upon. NOC would be delighted to share the report in full with the Committee when published, and would be happy to provide oral evidence at any future session.

Executive summary

3. Decarbonising shipping is one of the most challenging of all the green-energy transitions, involving a simultaneous set of transformations ranging from ship and engine design to fuel production, storage and distribution infrastructures (most of which does not exist today) and much more besides.  The long asset lives of ships (30 years) mean carbon footprints can be locked in for many years from the point of design. 

4. NOC’s response will focus on the following five areas:

• Building, designing and operating zero emissions ships: Currently there is little practical direction for those building, designing and operating zero emissions or low emissions ships. We welcome the government’s idea to develop a UK Shipping Office for Reducing Emissions (UK-SHORE) and would like to see this made a firm commitment, with the intent to include stakeholders. NOC has offered expertise to the Department for Transport to help inform the work of such a grouping. The upgrade and replacement strategy for the UK’s fleet of publicly-owned vessels, including research vessels, presents a subset of UK flagged vessels that could be used to drive the technological development required to transition the marine sector to a zero/low emissions future operating model. With joined-up planning and investment in UK ship-building capability, there are 13 specialist UK vessels which will be at an age requiring replacement between now and 2035, presenting an unprecedented opportunity for a coordinated and integrated UK fleet design and build programme with potential benefits in areas such as; fleet wide cost savings (design, build and operation), cross organisational interoperability, adoption and integration of un-crewed ships and Marine Autonomous Systems (MAS), and benefits to UK industry through a coordinated approach to fleet design, build, and maintenance policies.
• Public procurement: Public procurement is identified as part of the innovation ecosystem[1]. In the time-window 2030-2040 it is likely that green shipping infrastructures (at sea and ashore) will not be at full maturity. Consequently, publicly procured specialist ships like research vessels will come at higher cost and technical risk. Present public procurement systems are averse both to higher costs and technical risk, but a raised risk appetite will be necessary to achieve the pace of the green energy transition for shipping. We recommend that UKRI, BEIS and other Government Departments give careful consideration to this, in determining their vessel replacement strategies.
• Regulatory framework: There is currently very little regulation of new fuels, although the International Maritime Organisation (IMO) has made some progress towards providing safety guidance on new and alternative fuels, and the Maritime and Coastguard Agency (MCA) intends to address the use of lithium batteries by workboats. The government must address how current legislation and regulation might inadvertently block new fuels options from becoming a reality. The Clean Maritime Plan (CMP), to be renewed and refreshed in 2022, must look at long term interventions and the regulatory framework behind them. Furthermore, work must be undertaken on an international level to ensure a patchwork of regulations across jurisdictions is not created. Similarly, the regulations pertaining to semi-autonomous and autonomous vessels is at a nascent stage.
• Investment in technology: Sustained investments must be made in new and emerging autonomous technologies, including in sensor development (another area where the UK is placed to take a lead role), battery technology, automation and the associated training for skilled operators, as small un-crewed sensing vessels become more common in the future, enabling some ocean sensing to be taken off research ships.
• Increasing ocean information availability per tonne of CO2 emitted: The ocean is a major carbon sink taking up about 25% of emissions but there is concern its efficiency as a carbon sink may decline (or even reverse) and little is known about its variability. Consequently, continuous global ocean sensing of ocean carbon uptake is essential to benchmark the emissions. The global commercial shipping fleet has an important role to play in this information gathering endeavour, along with specialist research ships and other autonomous sensing platforms. Consequently, during the shipping decarbonisation transition, every effort should be made to maximise the data return on these Essential Ocean Variables underpinning the scientific assessment of net carbon emissions, including ocean sinks.  Consideration should be given to incentives (e.g. through taxation or other environmental credits) that would encourage both commercial and publicly-owned vessels contributing the necessary marginal costs to vital ocean data gathering even whilst burning fossil fuel.

Building, designing and operating net zero shipping

5. We welcome the government’s idea to develop a UK Shipping Office for Reducing Emissions (UK-SHORE) - a dedicated unit within the Department for Transport aiming to “transform the UK into a global leader in the design and manufacturing of clean maritime technology”[2]. At present the government is committed to exploring the creation of such a body – we would like to see a firm commitment to establishing it, and have offered to play a role in providing expertise and support. At NOC, our NZOC programme will help inform net zero shipping – with particular work programmes around future ships and future policy and regulation being particularly pertinent to this inquiry.

6. Whilst yet to report formally, this NZOC review is likely to identify that the next generation of UK specialist ocean research ships in 2030-40 should be Zero Emissions Vessels, providing opportunities for a UK shipbuilding programme that could accelerate the UK’s take-up of new technology in the shipping sector and support the transitions needed across UK ports. Moves to replace the UK’s research ships with net zero vessels at the end of their current capabilities could act as a catalyst for the wider shipbuilding sector, helping to deliver the government’s aim to “be seen as a global exemplar in green maritime issues and will be a leading supplier of zero (and low) emission shipping technology[3]”.

7. Fuels such as green bio-fuel, green hydrogen, and green ammonia are likely to replace current fuels, and the next generation of ships are likely to be more automated. Such a shift will require a focus on addressing the right skills for this transition and the widespread availability of shore-side infrastructures for fuelling and maintaining green ships, including internationally.

Public procurement

8.     Public procurement can stimulate innovation and be used to develop opportunities for UK shipbuilding in respect of specialised publicly-procured vessels as referred to above. Consequently, the options for publicly procured research vessels in that window would be:

(i)                  build new fossil fuel ships which will run well into the 2060s, hardly compatible with green ambitions;

(ii)                 life-extend existing research ships and their CO2 emissions until green shipping is a less risky and less costly option, perhaps with carbon offsetting in the meantime;

(iii)               build new ‘low emissions ships’ burning transitional fuels like Liquid Natural Gas, but only saving about 20% CO2 emissions;

(iv)               embark on a strategy to try to do oceanography without research ships, hardly compatible with the UK as a global science superpower, especially when the deep-sea economic and geopolitical frontier will be a very prominent issue;

(v)                 take the bold step to be an ‘early adopter’ or ‘fast follower’ in Zero Emissions Ships. 

9. In order to go the route of Option (v) and for the UK to be an early adopter of Zero Emissions research ships, reformed public procurement criteria would be needed to enable it (or at least not present a barrier). This is because this option would almost inevitably entail a higher capital outlay, higher operating costs (green fuel prices and volumes needed given their lower energy density) and inherent technical innovation risk as well as increased operating risk (e.g. availability of green fuels and shore infrastructures) in the more remote regions off commercial shipping lanes where research ships operate. 

Regulatory framework

10. There is currently very little regulation of new fuels, although the International Maritime Organisation (IMO) has made some progress towards providing safety guidance on new and alternative fuels, and the Maritime and Coastguard Agency (MCA) intends to address the use of lithium batteries by workboats. The Clean Maritime Plan (CMP), to be renewed and refreshed in 2022, must look at long term interventions and the regulatory framework behind them. Furthermore, work must be undertaken on an international level to ensure a patchwork of regulations across jurisdictions is not created.

11. To achieve the zero emissions ambition, the timing of vessel replacements will need to account for the wider international context of the broader maritime energy transition that will be taking place, including consolidation around preferred propulsion technologies, fuels and the widespread availability of shore-side infrastructures for fuelling and maintaining green ships.

12. In order to support a shift to battery technologies, vastly more cobalt (as well as many other critical metals like lithium, rare-earths, and even copper) will be required for grid upgrades, energy storage, renewable energy harvesting, and electrification in general, to power the energy transition. NOC has warned that “unless new sources of cobalt (and other critical metals required to enable the energy transition) are found and brought on stream rapidly within a few (2-5) years, the UK and world together will be unable to reach anywhere near its carbon emissions pledges[4].” Deposits of such minerals can often be found on the sea bed, presenting a conundrum for policy-makers around the immediate needs of technology versus the impact on the natural environment. Mitigations for deep sea mining, such as moving projects away from vulnerable habitats and the use of new technologies to reduce sediment plumes, would require the appropriate regulatory frameworks.

Investment in technology

13. Marine autonomous sensing platforms provide the option to increase the necessary ocean sensing capacity without growing the size of the research vessel fleet. The Government Office for Science’s report “Foresight Future of the Sea” recommends that the UK should “identify and work with key sectors to create a long-term platform for UK businesses to capitalise on growing global opportunities for goods and services” including in the area of autonomy and robotics[5]. This would also include leading the “development of new regulation for emerging industries and technologies such as autonomous vehicles and deep-sea mining[6].”

14. We agree that “autonomy is likely to be the single most important marine technological development”, bringing with it a range of challenges, including a need for better sensors, improved battery technology, electric propulsion technology, data transfer and inter-device connectivity[7]. Autonomy will create huge opportunities around net zero operations at sea, with often smaller, lighter craft requiring lower power requirements than large manned vessels. NOC continues to work at the forefront of autonomy through our Marine Robotics Innovation Centre at Southampton, including on novel sensor technology and marinized batteries required to work in inhospitable environments, including at depth in the ocean and when facing severe and unpredictable weather events.

15. Un-crewed or autonomous systems still face a challenge in terms of their ability to comply with legislation due to a lack of clarity regarding the interpretation of terms such as ‘vessel’, ‘crewed’, ‘manned’ and ‘on board’. However, such issues are starting to be addressed in a number of fora, with the IMO and MCA leading such work. There is a risk that some coastal states may seek to limit access to their waters depending on their individual approach to net zero solutions. Uncrewed research vessels greater than 24m should be able to seek Diplomatic Clearance (DIPCLEAR) using established procedures in Part XIII of the United Nations Convention on the Law of the Sea (UNCLOS), however, there is no documented evidence of coastal state practice in this area.

16. NOC has been at the forefront of Maritime Autonomous Surface Ship (MASS) Regulation, hosting the Maritime Autonomous Systems Regulatory Working Group (MASRWG) conference in 2017 on the issue of MASS regulation and working as a key partner within the Maritime Autonomy Regulation Lab (MARLab) in the following years. Awarded by the Department for Business, Energy and Industrial Strategy’s (BEIS) Regulators’ Pioneer Fund, MARLab aimed to pioneer new ways of regulating the autonomous and smart shipping industries, and help them deliver innovative new technologies to the traditional maritime sector. Based at the Marine Robotics Innovation Centre, National Oceanography Centre at Southampton, MARLab provided a single point of contact between government, academia, and industry. The Project Advisory Board (PAB), set up and managed by NOC, concluded that no provisions in the Merchant Shipping Act expressly prohibit MASS operations, but that a number of provisions – such as definitions of master and seafarer, roles and responsibilities, manning levels, training, and remote operation facilities and requirements - are vague and require clarification[8].

Increasing ocean information availability per tonne of CO2 emitted

17. Almost no pathway to net zero can be achieved without CO2 removal from the atmosphere (the ‘net’ in ‘net zero’) which can be done by approaches such as biofuel production combined with Carbon Capture Utilization and Storage (CCUS) and enhancing natural carbon sinks.  The ocean is a major carbon sink taking up about 25% of emissions but there is concern its efficiency as a carbon sink may decline (or even reverse). Moreover, little is known about the natural variability of this natural sink, and especially for an altered ocean.

18. Consequently, continuous global ocean sensing of ocean carbon uptake is essential to benchmark the emissions.  The global commercial shipping fleet has an important role to play in this information gathering along with specialist research ships and other autonomous sensing platforms. 

19. Whilst the capital and operating costs of these vessels are already paid for, there are small marginal costs in procuring, installing, maintaining and processing and making available data from the necessary scientific instrumentation. Consequently, during the shipping decarbonisation transition, every effort should be made to maximise the data return on these Essential Ocean Variables underpinning the scientific assessment of net carbon emissions including ocean sinks. 

20. Consideration should therefore be given, working with HM Treasury, to what incentives might be possible (e.g. through taxation or other environmental credits) to encourage both commercial and publicly-owned vessels to contribute to vital ocean data gathering. This can be done through making vessels available and contributing to the marginal costs of installing and operating the necessary scientific equipment even whilst burning fossil fuel (on the grounds that a ship on passage from A to B gathering ocean carbon data is delivering some net global carbon budget assessment benefit for its CO2 emission foot print compared with one that is not).

Conclusion

21. Targeted investment supporting a clear strategy for enabling the net zero transition is essential. In some areas, we are likely skipping a generation of technology development in order to meet the necessary timeframes. That introduces multiple risks but also presents an opportunity to grow new skills within the workforce, position ports as hubs connecting people to a digital ocean and position the UK as a world leader. NOC has a role in leading the science that monitors how the oceans react to climate change and respond to efforts to reduce CO2 emissions. It also has expertise in key areas of technology that support this scientific endeavour, in addition to the broader transition required by the marine sector. It is positioned to support trials of new technology and prove their utility in some of the most extreme environments on earth.

22. We welcome the opportunity to play our part in moving to net zero – only by the right regulatory environment and investment by government, innovation by industry and coordinated focus across the whole marine sector, can net zero shipping be achieved. Furthermore, continual work at an international level is required to provide the right infrastructure to serve net zero fleets, the right skills to service them and the right regulatory frameworks to help sustain them. The Committee’s inquiry is an important step in setting out what short, medium and long-term changes are needed to make net zero shipping a reality.

September 2021