Statement: Working toward bringing new alternative fuels onto the river
Given the importance of alternative, low carbon fuels in the future of maritime and UK decarbonisation, the PLA Harbour Master, Vessel Surveyor and Environment teams have been undertaking a preliminary review of current regulations, directions and policies to identify any current barriers to adoptions. This work will be ongoing as technology and fuel knowledge improves in the maritime sector in coming years and has not been concluded at the moment.
Due to a large amount of enquiries and our continuing review, we have decided to publish our current considerations (as of August 2021), to help operators and infrastructure owners make their own plans.
International regulations and guidance in the form of the IGF Code, supported by classification rules currently cover LNG as a fuel, and interim guidelines from the IMO also cover ethyl/methyl alcohols (methanol). Interim guidance for the use of fuel cells is at an advanced stage of discussion at the IMO, however this will not cover the fuels to be used in the fuel cells. Battery systems are covered by Classification society rules. Ship designs electing to use hydrogen or ammonia will need to undergo a rigorous risk-based design process administered by a Class society before use in the Port of London.
There is currently no specific, local restriction on the alternative technologies used in the vessel for propulsion or the adoptions of new fuels in the vessels to make use of the technology.
Providing the technology meets the requirements of the relevant codes, guidance and requirements of existing legislation it can be coded for you.
If it requires an exemption from the PLA or MCA Surveyors, advice and approval must be sought of the PLA Harbour Master for its use in the Thames for commercial purposes (as defined by the Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 1998). Approval or exemptions will be considered by the PLA on a case by case basis.
While some of the codes of practice do not specifically refer to alternative fuels, some specifically relate to ICE or fuel based knowledge and operational requirements. It would be expected that the operation would appropriately train staff (including any certification requirements), implement safety protocols and notify the PLA of any requirements for the purposes of emergency response under existing requirements of the Port Safety Code.
Storage and Carriage
The PLA has identified that in international, national and its own regulatory framework places some restrictions of certain emerging fuels that are considered dangerous cargos and goods. The local restrictions are placed for the Thames in terms of amount and geographical constraints, but can be considered with agreed and evidenced measures for example risk assessment and passage planning.
The PLA will be continuing to undertake a full review of the framework that is in its control, with a view to facilitate decarbonisation and use of alternative fuels safely and is working with other regulatory colleagues to share learning and align guidance. There are similar but more advanced learnings for other actions like shore power. The PLA is committed to undertake this work prior to 2023, but if any operator requires advise before this time, the PLA can only provide preliminary considerations, and subject to some uncertainty. Operators are requested to use this advice at their own risk as the work may reveal other considerations as the PLA is also learning and exploring this space. Advice sought requiring offices to provide preliminary thoughts may also be subject to charge, as the PLA resources will be in addition to the work already undertaken.
It should be noted that the PLA is guided by international and national port regulatory frameworks and not able to extend beyond these. Also shore side bunkering of these fuels is likely to be in other regulatory controls and not necessarily of the PLA’s, although we encourage the use of the river for carriage as much as possible.
Cathryn Spain, Senior Harbour Master
Tom Parham, Marine Surveyor
Tanya Ferry, Head of Environment
Date August 2021