Call for evidence on shore power: Implementing maritime commitments in the Transport Decarbonisation Plan, response form

Introduction 
Thank you for responding. Your views will assist in gathering information on different aspects of supporting the deployment of shore power in the UK and will be used to inform future policy development. 
Please fill in all relevant sections of this form, providing evidence where possible, and email it to: MaritimeTDPConsultation@dft.gov.uk.
Alternatively send by post to: 
Call for evidence on shore power 
Maritime Environment, Technology and International Division, Maritime Directorate,  
Department for Transport, Zone 1-5, Floor 4, 
Great Minster House, 
33 Horseferry Road, 
London, SW1P 4DR 
 
Closing date is 25 April 2022.
Confidentiality and data protection  
The Department for Transport (DfT) is carrying out this call for evidence to gather views on shore power in the UK. This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the Controller for this information. 

As part of this consultation we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions. We’re also asking for information about your organisation, if you represent one, to better understand your relationship with the issue.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. You can view it at https://www.gov.uk/government/organisations/department-for-transport/about/personal-information-charter.

Your information will be kept securely on a secure IT system within the department and destroyed within 12 months after the consultation process has been completed. 

You 
1.	
Name:
Email:

Your contact details (used for contact purposes only):

2.	Are you responding:

As an individual?
On behalf of a business?
On behalf of another organisation?

Business Organisation
3.	What is the name of your organisation?

4.	
0 – 49 people
50 – 249 people
250 or more people 

How many people does your organisation represent?

5.	What industry or sector is your organisation from?
Shipping 
Ports 
Cruise 
Ferry 
Transport 
Technology
Manufacturing 
Infrastructure 
Energy 
Academia 
Government (if so, specific which)
Other (please specify)

6.	Where is your organisation based? (please specify town, region and country).

7.	What is your role in the organisation? (Please state your role).

Purpose of this call for evidence 
The Transport Decarbonisation Plan includes a commitment to consult on how government can support the wider deployment of shore power, including consideration of regulatory interventions, for both vessels and ports, that could drive deployment as we transition to a net zero world, and bring forward appropriate measures. 

This consultation process began in October 2021 with the launch of an industry-led task and finish group in partnership with the Clean Maritime Council, to provide initial advice to the Department for Transport on their proposals to support the uptake of shore power, ahead of wider public consultation. The Clean Maritime Council is a strategic advisory body bringing together leading figures from the maritime industry, academia, and government.  

This initial engagement with industry identified limitations in the evidence base available to government, so this call for evidence does not identify a preferred approach on proposals to support shore power.  

More information is needed, for example, on the scale of vessel emissions at berth, the actual potential of shore power alongside other technologies in reducing emissions, the barriers to the commercial take-up of shore power and the impact of potential solutions to enable the roll out of this technology.  

Shore power policy options will be developed in cooperation with Devolved Administrations. Further evidence and engagement are needed to review the impact of options on devolved competencies. It should be noted that policy areas of relevance to ports as well as environment policies are devolved in Scotland, Wales, and Northern Ireland. This has led to environment regimes in each of the four nations that are in some respects distinct. Whilst the main legislation which provides for UK shipping including pollution is reserved, some competences concerning maritime transport are devolved e.g. in Scotland. 

This call for evidence builds on the work of the industry-led task and finish group and considers a range of policy options, explored in increasing levels of ambition, to gather further evidence on their impact and implications.  

Responses to this call for evidence will help to inform further policy development work, as part of the 2023 refresh of the Clean Maritime Plan. Any specific policy options will be subject to further consultation accompanied by impact assessment, informed by the findings of this call for evidence. 

Shore power 
Shore power is one of the available technologies to reduce vessels emissions at berth. Also known as cold ironing, shore power is the provision of shoreside electrical power to a vessel at berth while its main and auxiliary engines are shut down. When a vessel docks, it no longer needs energy for propulsion but may still be a large consumer of energy. Onboard generators are still running when in port to supply the domestic loads of the vessel (e.g. lighting, galleys, air-conditioning, etc.), resulting in air pollutant as well as greenhouse gas (GHG) emissions. Rather than letting on-board generators produce the necessary electricity, this can be provided through a standardised onshore interface while the vessel is at berth. 

Shore power benefits 
The National Policy Statement for Ports incorporates guidance on the provision for shoreside power in section 5.7 (air quality and emissions). For example, paragraph 5.7.13 states that "All proposals should either include reasonable advance provisions (such as ducting and spaces for sub-stations) to allow the possibility of future provision of cold-ironing infrastructure, or give reasons as to why it would not be economically and environmentally worthwhile to make such provision”. 

Shore power has the potential, alongside other measures, to contribute to a reduction in GHG emissions from the maritime sector. This potential will further increase as the national electricity grid decarbonises. Government-commissioned research estimates that without any further policy intervention, the total annual electricity demand at UK ports could rise from 20 GWh in 2016 to around 250 GWh by around 2050, largely driven by the demand for shore power from container vessels. In contrast, under a scenario in which there are very ambitious assumptions about maritime electrification, this research estimates that annual electrical demand at UK ports could rise to over 4000 GWh by around 2050, predominantly driven by demand for electric propulsion, but with demand for shore-side power also expected to increase significantly. 

Further research commissioned by the government concludes that “the total share of a ship’s energy demand that can be met through shore power is small”, therefore other solutions are likely to have a greater overall contribution to reducing GHG emissions. This research adds that “there are significant potential benefits from shore power for controlling air pollution emissions when ships are in port and close to centres of population where impacts of those emissions may be greatest”. In addition, related research identifies that the use of shore power as opposed to auxiliary engines will reduce, emissions, noise and vibrations from vessels at berth, improving working conditions in ports. 

By helping to address the sector’s environmental impacts, the increased use of shore power would help to future proof jobs in the UK maritime sector. In 2017, it is estimated that maritime directly supported around 220,000 jobs in the UK. In addition, the increased use of shore power has the potential to directly support UK jobs in the markets for relevant technologies. Research commissioned by the Government concluded that the UK has “some basis for competitive advantage” in the market for low carbon shore power technologies, including “several manufacturers of relevant electrical equipment”, and a “strong basis for competitive advantage” in the related markets for onboard batteries and electric propulsion. 

Whilst the available evidence suggests that shore power can lead to significant reductions in air pollutant emissions from ships whilst they are at berth, it would not address all sources of emissions. For example, there would continue to be emissions from the use of boilers, which are “used on board larger vessels for heating and hot water production”. In addition, ships would still produce emissions when manoeuvring within ports. For these reasons, shore power is only one of the measures that the government is supporting to reduce maritime emissions. Other interventions include incentivising the supply of alternative marine fuels through the Renewable Transport Fuel Obligation, exploring the role of economic instruments, funding for feasibility studies and technology trials allocated via the Clean Maritime Demonstration Competition, and other maritime commitments in the Transport Decarbonisation Plan. 

Crucially, the scale of the total impact on UK GHG and air pollutant emissions from the use of shore power at UK ports is currently subject to uncertainty and is expected to be influenced by a range of factors. These include the type of marine fuel that would be used, the energy efficiency of the vessels calling at UK ports, and how the electricity that is used is generated. Consequently, it is expected that the impact on emissions will change over time as both the maritime sector and the electricity sector decarbonise. For example, research commissioned by the government suggests that “alternative low emission fuels will be essential to achieve the ambitions for zero emission shipping, particularly beyond 2030”20. In addition, the available evidence suggests that the benefits from reducing air pollution will also be influenced by the location of ports21. More analytical work is therefore required to assess the benefits of a significant take-up of shore power in the UK and how these could vary under different scenarios. 

Although the provision of shore power has been a proven process for twenty years, its deployment in the UK remains very limited. Apart from the presence of shore power infrastructure at the Royal Navy base at Portsmouth, only two UK ports are equipped with shore power facilities, Orkney and Southampton22. Industry analysis illustrates that the international picture is different, as local circumstances contribute to the conditions for greater adoption of this technology23.  
 
Shore power costs 
There are several different costs associated with the use of shore power, including the costs to vessels of fitting the necessary equipment to make use of shore power, and the investment required within ports to enable this. Further costs will also be incurred when upgrading existing port electricity network connections. 

For vessels, investments may include “a cable reel, connection boxes, switchgear, transformer and control panel” according to research commissioned by the government. The available evidence suggests that investment costs vary between different types and sizes of vessel25, and that retrofitting existing ships with the required equipment can be significantly more expensive than incorporating it into new builds.  

The use of shore power will also impact on the operational costs of vessels. Whether the use of shore power will increase or decrease operational costs will depend on the relative prices of electricity and the maritime fuel that would otherwise be used by the vessel. Fuel prices fluctuate over time due to market conditions. Relative prices of electricity and marine fuels will also be influenced by the wider policy landscape, and the potential for any future changes in pricing or regulatory policy. In addition, relative prices will be impacted by changes in the type of maritime fuel that would otherwise be used. For example, in situations where expensive low carbon fuels would otherwise need to be used by vessels in the future, the use of shore power has the potential to decrease operating costs when vessels are at berth. 

Research commissioned by the government suggests that investments required on land may include “substations, switchgear and power connections”, as well as “power network reinforcement or local generation if the port is in a poorly connected location”. The available evidence suggests that the total cost of investments required within ports can vary significantly. In addition, research commissioned by the government suggests that the costs of any enhancements required to the power network “are likely to be very context specific”29. For example, costs would be much higher “if a new substation were needed or if large-scale reinforcements were needed”.
 
The available evidence suggests that the costs of a significant rollout of shore power in the UK are currently subject to significant uncertainty such as the circumstances of different ports and different scenarios for how the fuels used by ships in UK ports could evolve in the future. More analytical work is required to fully assess the costs of a significant rollout of shore power in the UK and how these costs could vary under different circumstances. 

Barriers and market failures 
Research undertaken by both industry and government has highlighted significant existing barriers to the uptake of shore power. These include the cost of infrastructure (both in ports and for electricity network connections) and a lack of evidence about long term levels of demand from vessels31. These barriers include, but are not limited to: 

•	Negative externalities. At present, maritime fuel prices do not reflect the costs of their greenhouse gas and air pollutant emissions. This means that there is currently a suboptimal incentive for investment in emission reduction options, including shore power. 
•	High capital costs, especially upfront costs for ports. Upfront costs for ports can be split between (1) capital costs for installing infrastructure inside the port and (2) costs for connecting to the electricity network, including upgrading the existing port network connection such as building new substations. Government-commissioned research suggests that the cost of upgrading electricity connections is subject to uncertainty as this is “very context specific”. In some locations where the capital costs associated with electricity network connections are particularly high, solutions such as renewable generation and storage might help to reduce costs. It should also be noted that the contribution currently required by connecting customers to network connection upgrades varies between the electricity transmission and distribution networks. For distribution networks the independent energy regulator, Ofgem, has proposed that the costs of network reinforcement required to accommodate demand connections be socialised. Currently, a proportion of these costs is recovered from the connecting customer. Any changes would take effect from April 2023. In addition, the GB electricity network is separate from the Northern Ireland electricity network and connection costs may be recovered differently in Northern Ireland, for example Ofgem’s proposed changes would only apply in GB.  
•	The cost of electricity. Aside from the cost of upgrading connections to the electricity network, the price of electricity compared to conventional marine fuels is often raised by industry as another key barrier to the commercial take-up of shore power. Of the 25 IEA countries reporting industrial electricity prices in 2020, the UK had the third highest after Japan and Germany. For comparison, during the same period Norway had the lowest price.  
•	Split incentives to invest and co-ordination failures between ports and the shipping industry. Ports are unlikely to invest in shore power infrastructure until the demand can be credibly demonstrated. At the same time, shipping operators are unlikely to invest in shore power solutions (e.g. retrofit) as well as other zero emission solutions if the necessary infrastructure is not readily available across ports. Split incentives to invest between ship owners and charters may also be a further impediment.  
•	Imperfect information on abatement options. For example, ports might not have access to information that would allow them to make an informed decision about whether ensuring sufficient electricity provision from their port to support shore power or electrified ships is likely to be a worthwhile investment.  
•	Limitations in regulatory frameworks. A basic framework for shore power is available in UK legislation as part of the Alternative Fuels Infrastructure Regulations 2017. Regulation 4 (shore-side electricity for seagoing ships) provides that “A statutory harbour authority which operates a shore-side electricity supply installation for seagoing ships which is deployed or renewed after 17th November 2017 must ensure that the installation complies with the requirements set out in paragraph 4 of the Schedule”. Paragraph 4 of the Schedule then provides that “Shore-side electricity supply installations for seagoing ships, including the design, installation and testing of the systems, must comply with the technical specifications of the IEC/ISO/IEEE 80005-1 standard”. A review of the Alternative Fuels Infrastructure Regulations is ongoing. Progress has been limited at the IMO, mostly limited to the safety aspects of shore power. By comparison, the EU directive 2014/94/EU mandates EU ports to install shore power by the end of 2025, but it also specifies that this is required only unless costs are higher than benefits and there’s no demand. 
•	Project complexity (e.g. planning regulation). The infrastructure requirements of certain shore power projects make them challenging, especially for small ports which might not have immediate access to the necessary skills. For instance, the process of obtaining development consent and land rights is led by the port but is likely to involve both the relevant electricity network operator and the port. This would involve public consultation, assessment of environmental impacts, etc. 
•	Low vessel demand for shore power. This is the result of the combined impact of the barriers set out above. The available evidence suggests that retrofitting vessels is more expensive than buying new vessels already equipped with shore power facilities, despite existing vessels having a lower lifespan compared to new ones. Also, the less time a vessel spends at berth, the less likely some operators are to prioritise retrofitting vessels for shore power against measures to reduce emissions whilst the vessel is at sea (e.g. alternative propulsion methods). However, industry suggested that there are front runners in the usage of shore power e.g. cruise and container lines. 

Questions. Please provide evidence to support your response. 
8.	Can you provide any evidence to quantify the current level of GHG and air pollutant emissions from vessels at berth in UK ports? Please disaggregate this information as much as possible (e.g. to cover different ports and vessel types and operational and idle vessels). 

9.	In your opinion, which technologies and fuels can contribute to reducing vessel emissions at berth and what are their costs, benefits and level of technology readiness? Please include both on-board and land side technologies (e.g. storage) where relevant.  

10.	In your opinion, what impact would shore power have in reducing emissions at berth for (a) different vessel types and (b) different locations in the UK? Could shore power have any other positive or negative environmental impacts (e.g. any impacts on marine pollution)? Please quantify and disaggregate your responses as much as possible.  

11.	In your opinion, what are the key (a) barriers and (b) incentives for ship owner, ship operators and ports to invest in shore power? 

12.	Can you provide estimates of the costs and benefits for any current or future shore power projects in the UK, including emission savings, costs of infrastructure at ports and costs of any upgrades to existing network connections and any reinforcements required to the electricity network? If possible, please provide estimates of cost recovery periods for these projects and estimates of the associated increases in electricity demand?  

13.	Can you provide estimates of the total overall costs and benefits if shore power is taken-up commercially at scale across the UK, including the overall emission savings and electricity demand? Please disaggregate these estimates across different locations, if possible? 

14.	Are you aware of any shore power installation projects underway in the UK? If so, please provide as much detail as possible? 

Options explored as part of this consultation 
An industry-led Task and Finish Group, in partnership with the Clean Maritime Council47, proposed potential solutions to the above barriers. Membership of the group included representatives from: the British Ports Association, the UK Major Ports Group, the UK Chamber of Shipping, the National Grid, the Energy Network Association, Innovate UK, Shell, Wightlink, Red Funnel, University College London and the University of Strathclyde. 

The options explored in this call for evidence are grouped below. 

•	Exploring the potential of government’s coordinating function. For example, commissioning research, producing guidance for port operators on planning and energy network requirements, and facilitating collaborations across the sector as well as information sharing. This could also include exploring other potential measures to unlock private investment. 

•	Exploring the potential of government mandates through regulation. This could include requiring vessels and ports to report on the usage of shore power, requiring vessels to use shore power when in port, and requiring ports to install shore power infrastructure.

•	Exploring the potential of market-based measures. This could include economic instruments based on the “polluter pays principle48”, to incentivise the adoption of shore power by vessel and port operators.  

Exploring the potential of the government’s coordinating function 

One option to address the issue of imperfect information on abatement options across market players and the inherent complexity of shore power projects would be to produce guidance for port operators concerning planning as well as energy network requirements for the installation of shore power infrastructure. Such guidance could be delivered in cooperation between the Department for Transport, the Department for Levelling Up, Housing and Communities (DLUHC), the Department for Business, Energy and Industrial Strategy (BEIS) and network operators. 

Questions. Please provide evidence to support your response. 
15.	 Do you think Government coordinated guidance would be a helpful tool for ports and other operators to navigate the complexity of shore power projects? If so, which topics should be included to maximise the value of such a document?   

We recognise that coordination failures can represent a barrier to the take-up of shore power. We therefore invite innovative ideas on how government could intervene to facilitate collaboration across the sector, for instance building on experience in other transport modes or recent initiatives like the Clean Maritime Demonstration Competition. Government could facilitate collaborative work between multiple stakeholders, for instance enabling the formation of industry consortia or facilitating information sharing across the sector, enabling opportunities to share learning and build momentum across shore power projects in the UK.
 
Questions. Please provide evidence to support your response. 
16.	In your opinion, how could government’s coordinating function be deployed to accelerate collaboration across the maritime sector to facilitate shore power projects? Can you please provide examples?  

Innovative commercial finance models might play a part in unlocking private investment, providing ports with greater certainty should they decide to invest in shore power infrastructure. These might play a role in offsetting uncertainties in vessel demand for shore power infrastructure. We are interested in ideas on how such measures could be structured. 

Questions. Please provide evidence to support your response. 
17.	In your opinion, does future revenue uncertainty represent a significant barrier to investment in infrastructure for shore power? Please explain your answer. 

18.	Can you provide examples of innovative commercial finance models that might help de-risk port investment in shore power infrastructure? Please include as much detail as possible. 

The current gap in evidence for the costs and benefits associated with shore power could be filled through further research to understand what it would cost ports to install shore power, the costs of upgrading electricity distributional networks, the costs to ships of fitting shore power, and the impact that this would have on emissions.  

Questions. Please provide evidence to support your response. 

19.	 Do you have any other views on the potential of Government’s coordinating function in supporting the uptake of shore power?

20.	 Do you have any other views on the potential of Government’s coordinating function in supporting the uptake of shore power?   

Exploring the potential of government mandates through regulation 
Government could proactively impose regulatory requirements on both ports and shipping operators. Such mandates could provide policy clarity while helping solve the issues of failures of coordination between ports and ship operators and split incentives to invest between charterers and ship owners. A range of potential interventions are set out below. 

A requirement for vessels and ports to report on the usage of shore power, where available, could address the lack of information on shore power in the market, providing ports with evidence on the possible scale of shore power demand, and ship operators with evidence on the availability of shore power connections now and potentially in the future, enabling investment to take place. This could also provide government with evidence that could be helpful for designing future regulations and could provide a clear signal to industry on potential utilisation. 
A mandate requiring ships to use shore power when at berth could, in theory, help provide more certainty concerning emission abatement and the usage of relevant infrastructure and could address the barrier presented by low vessel demand. Such mandate could only apply to those vessels that are “shore power capable”. 

Questions. Please provide evidence to support your response. 
21.	In your view, what would the impacts of a mandate on vessels to use shore power while at berth be on (a) ship owners (b) ship operators (c) UK ports and (d) the wider UK economy?  

22.	Do you think that any mandate on vessels to use shore power while at berth in the UK should be accompanied by a mandate on ports to install the related shore power infrastructure? Please explain your answer. 

A requirement for UK ports to install shore power infrastructure would also be subject to the issue of a lack of evidence on impacts. This measure is currently being implemented in mainland Europe, based on EU directive 2014/94/EU which requires EU ports to install shore power facilities by the end of 2025 “unless there is no demand and the costs are disproportionate to the benefits, including environmental benefits”. The package of proposals presented by the EU Commission on 14 July 2021 – the “Fit for 55 package” – includes binding targets for, among other things, shore power supply for ships at ports. However, concerns have been raised by ports about the additional costs relating to rolling out infrastructure.  

Questions. Please provide evidence to support your response. 
23.	In your view, what would the impacts of a mandate on port operators to install shore power infrastructure be on (a) ship owners (b) ship operators (c) UK ports, (d) energy network operators, and (e) the wider UK economy?  

 

We are not clear about the merit of considering a mandate on vessel operators to ensure that vessels are “shore power capable”. First, we are not sure whether such a mandate would incentivise the usage of shore power on the part of vessels. Also, it is not clear how this mandate could be implemented in UK legislation, as shipping design is mandated by the IMO’s Energy Efficiency Design Index. Even if that was possible, industry have suggested that it would be difficult to mandate design criteria to vessel manufacturers as vessels are bespoke. Industry also suggested that, if applied to domestic manufacturers, a design mandate might risk putting UK designed vessels and yards at a disadvantage against international competition. 
 
Questions. Please provide evidence to support your response. 
24.	In your view, what would the impacts of a mandate that all vessels are “shore power capable” by design be on (a) ship owners (b) ship operators (c) UK ports and (d) the wider UK economy?  

  

25.	Do you have any other views on the potential implications of Government mandates, or any other regulatory intervention, to support the take-up of shore power? Please include evidence where possible, including references to international case studies where relevant. 

 

We do not currently have access to a well-developed evidence base concerning the impacts of implementing any of these mandates for ports and vessel operators. 

Exploring the potential of market-based measures 
Market-based measures are a type of economic instrument. Economic instruments can play a valuable role in enabling the efficient achievement of targets and supporting the transition to zero emission shipping. Crucially, economic instruments are very context specific and there is no single design that can easily be replicated from one context to another. The outcomes and impacts of an economic instrument are very dependent on the design and context in which they are implemented, so careful analysis of options would be necessary to inform policy makers’ decisions. 

When deciding on the most appropriate economic instruments and their more detailed design, several important and related issues will need to be considered. These include distributional issues in terms of differential impacts on sub-sectors within the shipping industry; potential costs to businesses; the economic, environmental and social benefits that could be achieved, including the opportunity to incentivise new low emission innovations; implications for trade- flows and competitiveness; differences in impacts across geographies; the international context in which the domestic economic instrument is implemented; and the cost of the economic instrument to the public purse.  
Furthermore, the design of the instrument should consider how to manage the following trade-offs:
 
•	Encouraging behaviour to ensure short-term compliance as well as alignment with longer-term aims.  

•	Providing incentives to change behaviour to reduce emissions, while also being mindful of the cost implications for sub-sectors within the shipping or other industries and consumers; and 
 
•	Ensuring appropriate monitoring and compliance while also balancing data requirements and associated verification or administrative costs. 

Some industry suggestions referred to the potential of market-based measures to support the uptake of shore power. By placing a price on these emissions, economic instruments could be one of the options to strengthen the incentive for ship operators to reduce their emissions while at berth. The Transport Decarbonisation Plan committed the government to further investigate the use of economic instruments to drive maritime decarbonisation. This call for evidence is part of that ongoing work.
 
Questions. Please provide evidence to support your response. 
26.	Are you aware of economic instruments deployed internationally to address emissions at berth? If so, please provide details, including their cost and environmental impacts.  

27.	In your view, how could similar economic instruments be used in the UK to address emissions at berth? What would the impacts be on (a) ship owners (b) ship operators (c) UK ports and (d) the wider UK economy?  

 

Wider questions. Please provide evidence to support your response. 
28.	In your view, which alternative levers, including economic instruments, would support the commercial take-up of shore power in the UK? Please provide as much detail as possible, including on potential impacts. 

29.	In your opinion, what uptake of shore power do you expect in the UK between now and 2050, in the absence of further Government intervention?   

30.	Do you have any other information or evidence that you would like to submit as part of your consultation response? 

Next steps 
A summary of responses will be published within three months of the call for evidence ending. These responses will be used to inform further policy development and future consultation on specific proposals to support the uptake of shore power. Pending the results of this consultation process, we will announce a set of interventions to support the uptake of shore power in the UK as part of the refresh of the Clean Maritime Plan in 2023. Paper copies will be available on request.  
If you have questions about his consultation please contact: MaritimeTDPConsultation@dft.gov.uk 

Final Comments
Any other comments?