Low carbon and environmental impact

A Strategic Environmental Assessment (SEA) will be carried out on the overall ICP to ensure that environmental and sustainability aspects are captured and considered in the development of policies and plans. The Scottish Government committed in the Climate Change Plan to 30% of the ferry fleet, owned by Scottish Government, to be low emission by 2032. Actions that can be taken by ferry operators in the shorter term are: reviewing operations to improve fuel efficiency; designing vessels that are more fuel-efficient by optimising hull design and utilising low emission technologies where possible; using electric power supplied from the shore when in port, especially overnight; and exploring use of batteries for small ferries either on their own or alongside normal engines (as a ‘hybrid’).

Around 140 respondents answered Question 14.

The most frequently raised points were that, while environmental issues may be important, they are not currently a top priority, or that a realistic approach be adopted to ensure that achieving targets on emissions does not come at the expense of ferry service provision. Ferry board, committee or group respondents were among those who argued that any environmental impacts associated with improved ferry services should be weighed against the potential impacts of island communities becoming unsustainable in the absence of reliable services.

Other general comments included that the Strategic Environmental Assessment (SEA) should capture a wide range of environmental issues in relation to ICP policies and proposals, and their reasonable alternatives, and that Scope 3 emissions should be captured to allow planning for their reduction.

Climate change and greenhouse gas emissions

The importance of reducing carbon emissions and moving to renewable energy sources were the most frequently identified issues for inclusion in the SEA. Although most comments focused on impacts in relation to travel by sea, emissions from aviation and construction activities associated with any fixed links were also highlighted. Some respondents noted opportunities to support sustainable travel choices, considered in more detail at Question 15.

A small number of respondents observed that the Scottish Government has recently abandoned its target of a 75% reduction in emissions by 2030 and that new plans and targets will need to be set.

Carbon emissions associated with vessel operation

It was noted that ferry operations contribute to greenhouse gas emissions, which contribute to climate change, and that this applies to both vessels while in operation and in port overnight.

With respect to decarbonisation of vessel operation, there were references to potential for use of renewable energy – both electricity and green hydrogen – as power sources, with scope to use locally-generated energy highlighted. However, issues were also raised with respect to whether ports have sufficient network capacity to facilitate the introduction of electrical vessels and constraints on grid capacity on some islands that could be further exacerbated by ferries using shore-based power. It was argued that if the electricity used to power ferries is generated using fossil fuels, the carbon footprint will be greater than that from continuing to use diesel.

Some respondents commented on proposed use of Liquid Natural Gas (LNG) as a more environmentally friendly alternative to diesel, including the need to consider the impact of methane emissions, and that any reduction in carbon emissions during operation seem likely to be offset by the current necessity for fuel to be transported by road tanker from southern England.

It was also argued that there should be consideration of the environmental impacts associated with the whole life of a ferry, including emissions during construction, operation and decommissioning.

Suggestions with respect to improving operational efficiency to reduce fuel use and hence carbon emissions are covered at Question 15.

Carbon emissions associated with port operations

Port operations were also identified as a potential source of carbon emissions that should be considered, for example in relation to any additional recharging or refuelling infrastructure that may be required, as well as in normal operation.

Carbon emissions associated with the whole journey of service users

A small number of respondents proposed that carbon emissions should be considered in terms of the full journey of passengers, rather than solely the ferry component. With respect to reducing emissions from road traffic, it was argued that active travel and use of public transport should be encouraged, and it was noted that moving freight from roads onto ferries would reduce overall carbon footprint.

Flood risk and coastal erosion

Impacts of climate change such as severe weather, sea-level rise, flooding and coastal erosion on transport infrastructure were highlighted, particularly with respect to the vulnerability of port infrastructure. It was noted that measures to enhance the resilience of ferry terminals and also airports and fixed links will be required.

Air quality

Local authority and regional transport partnership respondents were among those who suggested that the SEA should consider the ICP’s impacts on air quality, including with respect to ferry emissions, aviation exhaust and road traffic. In particular, it was noted that emissions from ferries can contribute to air pollution, with potentially negative impacts on both human health and the environment and that such impacts could be mitigated by measures including reducing the idling of engines in harbours use of cleaner fuels, and improved public transportation options.

Water quality

Local authority and regional transport partnership respondents also commented on issues related to water quality, including potential impacts on marine/coastal and freshwater environments. Ferries discharging wastewater, sewage, and other pollutants were cited as causing potential harm to marine ecosystems as were port infrastructure and fixed links with measures to minimise disturbance in sensitive marine environments, protect marine species, and mitigate risks of pollution or habitat destruction required. Ferry operations, port operations and fixed links were also seen as having potential to impact water resources and damage freshwater ecosystems, requiring measures to prevent water pollution, manage stormwater runoff, and protect aquatic habitats from contamination or degradation.

Noise

Impacts of nuisance noise from ferry engines and other port equipment on people who live near ferry terminals and ports were highlighted, as were noise and vibration arising from aviation activities and from road traffic. Measures to mitigate noise pollution could include sound barriers, acoustic insulation, and flight path optimisation.

Biodiversity

It was noted that ferry operations can impact marine biodiversity, both as a result of pollution and also by disturbing marine habitats. Impacts associated with port works should also be assessed – for example if they impact seagrass meadows. Measures to minimise disturbance to sensitive marine environments, protect marine species, and mitigate risks of pollution or habitat destruction should all be identified.

Waste management

Generation and disposal of waste and debris associated with ferry operations, aviation activities, and construction projects were suggested for inclusion in the SEA, requiring measures to promote waste reduction, recycling, and support for the circular economy as well as pollution prevention. Specific suggestions with respect to onboard catering included assessment of single use plastics and reduction of packaging.

Landscape and cultural heritage impacts

New infrastructure developments should also be assessed in terms of potential impacts on land use patterns and on natural landscapes, with consideration of measures to minimise visual impacts and preserve scenic vistas. Consideration should also be given to potential effects on cultural heritage and the historic environment.

Cumulative impacts

Potential cumulative impacts were highlighted – both the impacts of current and future ferry operations in a given area, and the broader cumulative effects of multiple projects and activities on the environment. How individual projects interact with each other and with other developments should be assessed to understand their combined environmental impact.

Other suggestions

Other subjects that respondents suggested should be captured in the SEA included:

• Impacts of increased connectivity on tourism.

The needs of disabled people, to avoid inadvertently disadvantaging disabled people who rely on private car travel.

Around 115 respondents answered Question 15, with a small number stating that they had no suggestions, or felt existing actions are sufficient.

A public body respondent suggested that how providers calculate and report their carbon emissions could be considered, as transparency will help to inform consumer behaviour and drive providers to act in meeting consumer demand. Imposing emissions standards could also provide incentives for ferry operators to adopt cleaner technologies and practices.

Improved operational efficiency

A local authority respondent commented on the consultation paper’s reference to reviewing operations to improve fuel efficiency, noting that optimising vessel speed was one of the measures operators could take to minimise fuel consumption and reduce emissions, and that both NorthLink and CalMac ferries could make significant fuel savings by running more slowly. However, other local authority respondents emphasised that reducing vessel speed to cut emissions would not be welcomed by ferry users who generally seek as fast a journey as possible, or that efforts to reduce emissions should not impact either the reliability of services, or the timetable for introduction of replacement vessels.

Other respondents suggested that replacing an ageing fleet with newer vessels that use cleaner fuels or are more energy efficient by design would deliver reduced carbon emissions. However, it was also argued that, since a reliable service is critical to island communities, there should be an initial focus on proven technologies.

Further suggestions in terms of improving operational efficiency included:

• Making best use of fuel by optimising available capacity including by use of flexible fare structures, and improved planning of timetables to minimise empty runs.
• Reviewing suitability of vessels for routes, so that new vessels are not over-specified.
• Where possible, basing vessel crews on shore, providing scope to reduce both vessel carbon emissions and the size of vessel needed.
• Completion of various port infrastructure projects, for example at Ardrossan Harbour.
• Operating services over the shortest possible route – for example Ardrossan to Brodick rather than Troon to Brodick. It was argued that transporting a vehicle on a sea-going vehicle ferry produces several times more CO₂ than a vehicle travelling under its own power by road, so reducing the length of a ferry passage reduces CO₂

Offsetting carbon emissions was also suggested – for example by supporting community tree planting initiatives, thereby also contributing to Scottish Government tree planting targets.

Cleaner fuels

In terms of cleaner fuels, the most frequent reference was to electric or battery power for vessels with some respondents adding that this would be suitable for smaller vessels or for shorter routes. Provision of additional, back-up generators was also proposed and that, while these would need to run on diesel at present, they should have the capacity to use e-fuels in the future. It was also suggested that there should be investment in shore power infrastructure to allow to vessels to plug in and use electricity while berthed, and that port power supplies, including for terminal buildings should come from renewable sources.

Investment in local energy generation was suggested and also that a ferry operator could accelerate plans for renewable energy across islands by being a customer, or that there could be potential for co-location of renewable energy generation and ferry services. With respect to how electricity could be generated, there were references to wind, wave and tidal power.

In terms of other potential fuels, hydrogen and hydrogen fuel cells were the most frequently referenced, although LNG, biofuels and hybrid systems were also mentioned. It was noted that Orkney Ferries’ MV Shapinsay has already been retrofitted to allow injection of small quantities of hydrogen into the marine diesel on which it runs, but that existing regulations do not allow hydrogen to be used during operation as a passenger vessel.

Vessel design and size

Suggestions in relation to vessel design included that more efficient engines, lighter materials, alternative hull designs (including catamarans and e-foilers as technology develops) and, potentially, wind power devices such as rotor sails and other modern sail power could reduce carbon emissions. Maintenance requirements for components could also be considered.

With respect to size, it was argued both that there could be larger vessels that need to make fewer crossings and smaller vessels operating more frequent services. A local authority respondent suggested that smaller, electric vessels could open up accessibility in coastal communities and provide opportunities for regional boat builders.

It was also noted that the Scottish Government’s target of 30% of the ferry fleet being low emission by 2032 does not take account of vessel size and will not equate to a proportionate reduction in emissions across the fleet if achieved entirely by replacing small vessels.

Freight

With respect to carbon emissions associated with freight, it was suggested that there are opportunities to reduce road haulage miles by transferring road freight to sea – for example by providing direct sea-freight services between islands and mainland ports that are closer to large population/business centres, such as Islay to Troon. It was argued that transferring more road freight to sea could not only reduce the carbon footprint, but also bring added revenue and reduce subsidy levels.

A small number of respondents cited knock-on benefits of improved freight transport or lower transport costs in overall reduction in carbon emissions – for example, the ability of renewables developers to transport their equipment to island communities or transport of building materials to islands to support the transition to more energy efficient housing and heating.

Electric vehicles

Respondents raised a number of actions that should be taken in relation to EVs including:

• Addressing concerns around the risk of EV fires on car decks.
• Providing EV charging points on board vessels and expanding charging facilities at terminals.
• Reducing fares for EVs.

Encouraging use of public transport and active travel

Better connectivity with other forms of public transport so that ferry passengers may choose not to travel with their own cars was the most frequent suggestion at Question 15, although it was also noted that effective, accessible public and active travel options on either side of the ferry journey would be required. The impact of low RET fares was also highlighted, with one Ferry Board, committee or group respondent reporting that, for Cumbrae, a combination of low RET fares and lack of mainland parking encourages too many visitors to bring their cars onto the island. RET fares are covered in detail at Question 16.

Respondents suggested:

• Incentives to encourage use of public transport without discouraging visitors to islands that rely on tourism.
• Improved active travel infrastructure on islands, including ferry terminal cycling infrastructure.
• Developing a regional/national MaaS system that co-ordinates all forms of transport.
• Scope for integrated ticketing.
• A discounted ticket for a combined public transport and ferry travel to incentivise sustainable travel journeys and seasonal or discounted tickets for foot passengers.
• Easier booking for bicycles, including priority over cars.
• Potential for passenger ferries in some locations.

Building fixed links

Finally, a number of respondents referenced fixed links, suggesting that these could or should replace ferry services and so reduce emissions in the longer term.