Consultation Outcome Report
Summary of consultee comments and government responses to them.
Section 1: Introduction
1.1 The Maritime and Coastguard Agency (MCA), an Executive Agency of the Department for Transport (DfT), carried out a public consultation on the draft Marine Guidance Note MGN 653(M) Electric Vehicles Onboard Passenger Ro-Ro Ferries, which ran from 25 October to 20 December 2021.
1.2 As increasing numbers of electric vehicles (EVs) are being transported on Roll-on/Roll-off Passenger (Ro-Pax) ferries there is a need to provide guidance on the safety aspects associated with their carriage. This includes, fire safety elements, electrical hazard risks, the increased risk from carriage of damaged EVs (accident recovery) and the safe charging of EVs aboard Ro-Pax vessels. The guidance as originally written focused on the charging of EVs on board which is the most novel aspect of the guidance. Further risks from EVs on Ro-Pax vessels were explored and the MGN gave guidance on how to manage these risks effectively. The MGN was developed following discussions with domestic Ro-Pax operators and in consultation with international marine authorities. It is expected that international legislation from the International Maritime Organisation (IMO) will be developed to advise or regulate on the carriage and charging of alternatively fuelled vessels in time, however UK guidance is required in the shorter-term to ensure the safety of Ro-Pax vessels, passengers, and crew.
1.3 The consultation generated some very detailed and strong responses. The robust responses offering constructive feedback are welcomed and through our engagement with stakeholders as part of this consultation and through other meetings we have made significant changes to the guidance.
1.4 This Report gives a high-level outline of the comments received from respondents. It does not seek to cover every individual comment received, but all comments received have been taken into consideration.
Section 2: Consultation
2.1 This consultation was carried out between 25 October and 20 December 2021. It can be found at: https://www.gov.uk/government/consultations/consultation-on-safety-of-electric-vehicles-on-passenger-ro-ro-ferries
2.2 Whilst the consultation was promulgated on GOV.UK for anyone who wished to read it and/or respond to it, and triggered notifications for anyone who is subscribed to receive such government notifications. These comprised a mixture of domestic passenger Vessel representative organisations, individual operators, government departments and other interested parties, included those contacted through working groups. All persons and organisations who had specifically requested notification were included. The MCA also made the consultation known through its Domestic Passenger Ship Safety groups, comprising government, industry and other interested parties, namely the Domestic Passenger Ship Safety Group (DPSSG) and the Domestic Passenger Ship Safety Ro-Ro Group (DPSSG Ro-Ro), and also representative bodies including the UK Chamber of Shipping.
Section 3: Consultation outcome
3.1. The government’s proposals were described in the consultation document, which then posed seven generic questions and offered a free comment box for respondents to provide detail and other thoughts they had on the content of the proposed guidance. Much of the feedback was generated as part of industry consultation session such as the UK Chamber of Shipping Dangerous Goods Working Group and the National Maritime Operational Health and Safety Committee. The feedback received can be split into eight general categories where the responders have challenged the proposed guidance or provided alternative solutions that they wish the government to consider including as part of the guidance. A total of eleven responses were received from a mix of individuals, small and large organisations.
3.2.1 Charging of Electric Vehicles – General Provision
The guidance as first published contained guidance on what is seen as a minimum standard required for the provision of charging systems for EVs on board Ro-Ro vessels. The guidance, as it was originally conceived, was to act as a minimum standard for vessels offering charging facilities, but during its development and in response to pre-consultation feedback, guidance was added on damaged vehicle carriage (accident recovery, particularly from Islands) and fire-fighting provision for EVs.
3.2.2 Consultee comments
This was the most contentious part of the guidance with four respondents questioning the rationale for offering EV charging on Ro-Ro ferries due to environmental, safety and effectiveness concerns. Amongst the other respondents who were more accepting of the need for guidance there was a desire from three of them for the charging requirements to moved to later in the guidance and for the firefighting requirements for EVs to be the prime and foremost concern of any new guidance.
Six responses highlighted the issue of using traditionally fuelled ships’ engines to provide power to EVs and the carbon impact of this. Questions were raised by two responders over the value that could be offered to EV owners from charging onboard ships due to the short journey times on the majority of routes and proposed using charging infrastructure at the ports the vessels served instead. There was a concern from all responders that EV fires carried a substantial threat to the safety of the ship and that any action such as charging that may increase the risk of fire should be avoided.
One respondent was hostile to the provision of charging for EVs under any circumstances and was concerned about the carriage of EVs onboard ro-ro vessels at all.
Two respondents objected to the need to maintain a record of charging operations believing this to be unnecessary administration that is not an effective use of crew time as there would be limited benefit from a record of charging operations.
3.2.3 Government comments
The government is aware of the concerns raised around the provision of charging for EVs and the issues around carbon impact and agrees with the issue of charging aboard vessels from electricity generated by burning fuel oil. The advantages of using charging infrastructure at ports is clear with faster charging being available, lower risk of fire in vessels and more environmentally friendly sources of energy (from national grid supplied at least partly by renewables rather than vessels diesel engines) and is something that the MCA would recommend. In the future when more vessels are powered by alternative energy sources such as hydrogen, ammonia, electricity etc. the environmental argument for charging at ports will be reduced however the limited power available on board the ship will impact upon the availability of charging and the other issues noted above will remain.
The guidance was intended as a technical minimum standard should an operator chose to offer charging of EVs onboard, not as an endorsement of charging or to encourage vessel operators to offer charging facilities onboard. This will be made clearer in a redraft of the MGN with greater emphasis placed on the fire-safety aspects of carrying EVs over the charging aspects, and emphasis will be made on the environmental issues associated with charging from ship supply as well as the benefits from the use of shore-side infrastructure.
The minimum safety standard required for charging of EVs will remain in the guidance. Whilst there are no UK-flag vessels currently offering charging that the MCA is aware of, there are foreign flag vessels that serve UK ports that offer charging of EVs onboard. There are no IMO regulations that prohibit charging of EVs, and the government does not intend to introduce legislation that will hinder operators with UK-flag vessels. The government sees the issue of a guidance note with minimum safety standards as a compromise position that balances the needs for improved fire-safety whilst not hampering innovation and competitive positions for UK -flag vessels. The choice to provide charging facilities onboard is at the discretion of the vessel owner and provision of minimum safety standards is not a recommendation from the MCA to provide charging.
Three respondents stated that an EV is at greater risk of fire during charging this is based on the occurrence of fires during charging in other Lithium Ion (Li-Ion) battery applications and does not consider the smart capabilities of modern EV charging equipment, which communicate with the battery and will establish potential faults, current leakage, overheating etc and cease charging, thereby reducing fire risk. Research by the Research Institutes in Sweden (RISE) on the charging of EV in multi-story car parks stated that “Based on the findings from statistics and a literature review, there were no indications that charging of electric cars in parking garages would result in an increased probability of fire”[footnote 1]
Fully EV sales are estimated based on trade publications to account for 11 % of new car sales in 2021 and a further 7% were plug in hybrid vehicles. The official figures for 2021 are expected to be released by Department for Transport in May 2022 These numbers are significant increase on 2020 and this trend is likely to continue.
The guidance proposing that operators keep a record of charging operations has been reviewed and will be removed from the revised MGN.
3.3.1 Charging of Electric Vehicles – Technical Questions
The guidance includes technical details related to the safety ratings of any charging equipment that would be provided in the Ro-Ro spaces/vehicle decks. This includes safety ratings for the charging equipment, details of wiring arrangements and references to applicable standards, it is a combination of the current legislative requirements and additional recommended guidelines.
3.3.2 Consultee comments
Consultees responded to request clarification and to offer corrections or alternative solutions related to the technical aspects of the charging guidance, the main issues were related to the ingress protection (IP) rating of charging equipment, the safe type-ratings for use in explosive gas potential (EX) environments, the provision of cabling and the compatibility of charging equipment with different manufacturers EVs. Some respondents identified challenges with long trailing-cables from charging-stations to EVs.
3.3.3 Government comments
The government appreciates and is thankful for the engagement on this issue and will amend the MGN to reflect the comments received with respect to IP ratings and safe type-ratings requirements.
Two respondents requested that the MGN should be amended to allow vessels to use customer supplied cables for charging. The MCA would accept the use of customer supplied cables and will amend the MGN to reflect this as long as the cables are from a recognised manufacturer and are visibly free of damage.
Modern EVs and dedicated charging stations communicate to provide information on state of charge, battery-health, charge-rate and other parameters. This information can be used to provide early warning of potential battery fire risks and could be included as part of an automated alarm system which would stop charging and alert the crew to a potential issue.
The guidance was not clear enough that a dedicated charging area should be established, enhanced detection and fire extinguishing equipment could be provided in this area and this would be near to charging points to avoid long trailing cables. Increased space around vehicles could be provided in this area to reduce the potential of fire-spread, give more space to fit water spraying equipment and possibly fit fire-blankets etc.
3.4.1 Firefighting and Fire Detection
The guidance includes suggested practice for extinguishing and containing electric vehicle fire onboard ro-ro vessels. While there is no definitive fire fighting approach for electric vehicle fires the MCA offers suggested methods that will prevent the spread of fire and the loss of the vessel. Electric Vehicle fires are not more likely, and the fire intensity and energy release are not significantly greater than that of a traditionally fuelled vehicle however special care and attention should be paid to specific elements of firefighting and fire detection for electric vehicles.
3.4.2 Consultee comments
The guidance was welcomed by the eight respondents, but concerns were raised over the use of fire-blankets and the practicality of their use in a crowded Ro-Ro deck. Four respondents raised concerns over the lack of definitive procedures for firefighting in land-based EV fires pointing out that the approach taken by many fire services to let the vehicle fire burn-out is not practical in a ship environment. Two respondents raised concerns over the quantity of water required as well as its properties (fresh water or seawater) due to potential risks from use of seawater and how it is delivered (sprinkler, water mist system, hose stream etc.). Two other comments were made relating to water lances and the potential for electric shock from their use. Two responses provided proposals for the use of devices to supply water to the underside of vehicles so as to best provide the water to the battery which is the anticipated fire seat.
There were proposals from two respondents for the use of thermal-imaging cameras by fire-patrols to identify issues with EVs before smoke release as well as off-gas detectors to potentially identify the early onset of thermal runaway events. Two other respondents proposed the integration of closed-circuit television (CCTV) systems with thermal imaging technology to continuously monitor the Ro-Ro space for signs of overheating. Two operators suggested that the need for thermal imaging cameras for use by deck patrols is not required for carriage of EVs but would be proportional if charging is undertaken.
Six respondents requested that the firefighting and fire detection guidance become the main focus of the MGN as this is where operators and owners have the biggest concerns.
3.4.3 Government comments
The government welcomes the comments around firefighting and will redraft the MGN to reflect the focus on firefighting and fire detection requirements requested by industry.
The MCA are aware of the lack of definitive guidance and established methods for extinguishing EV fires for use by the fire services. However, the MCA has engaged with international forums including the ALBERO project[footnote 2] in Germany and Research Institutes Sweden (RISE) in Sweden to try and follow the best guidance available at this time.
The proposals for use of systems to provide cooling water to the underside of the electric vehicle through hose attachments and the like are welcome and will be included within the MCA’s revised guidance.
Fire-blankets are used by some operators (non-UK flagged) that currently offer charging. The issue with the use of fire blankets is that they can not be used once a battery-fire is established but can be used to provide a boundary and stop the fire spread where a potential issue is identified through use of thermal imaging cameras, detection of off-gases, from a charging system identifying a fault or can be used after an electric vehicle fire has been extinguished to reduce the risk of re-ignition, or fire spread post-ignition. Off gas detection is a developing field in Li-Ion battery fire detection and consideration must be given to the presence of other sources of gases on vessels carrying vehicles when considering the use of off-gas detectors. The MCA will clarify the potential uses for fire-blankets and the limited application for them in the revised MGN.
3.5.1 Guidance for carriage of Damaged Electric Vehicles
The carriage of damaged EVs was included in the guidance to provide some information on how to handle vehicles that have been damaged but still need to be carried on vessels, for example recovery of an accident damaged vehicle from an island with no other means of transporting vehicles than by sea.
The guidance is intended for both EVs that are propelled by their own power and those towed or carried by another vehicle. Some damage to EVs may increase the fire risk, and special provision should be made for them, and guidance as to when such vehicles, or at least when still containing damaged batteries, should not be carried.
3.5.2 Consultee comments
Three respondents identified the potential need to carry damaged EVs and were generally in agreement with the guidance provided however there were questions from all three over the crew’s responsibilities around identification and inspection, especially over the ability of the crew to be qualified to make a judgement on the damage to the vehicle and the potential risks.
It was proposed that damaged electric vehicles are treated as dangerous goods and carried on weather decks.
3.5.3 Government comments
The MCA agrees with the concerns raised by operators over the responsibilities of crews around identification and confirmation of battery disconnection and removal (if required) and will update the guidance to include this.
The proposal for the carriage of damaged EVs on weather decks is also welcomed by the MCA. Some operators question this logic due to the presence of other dangerous goods on weather decks. The MCA believes this can be managed by the operators if declarations and advance notice is provided of the intention to have damaged EVs on board so that carriage can be scheduled on suitable sailings.
From discussions with dangerous goods teams at MCA it has been established that vehicles on a car carrier cannot be formally categorised as dangerous goods and would not be treated as such by the MCA, however this could be required by the operator and be managed using their own developed procedures and processes over and above the regulatory requirements.
3.6.1 Declarations and Identification Challenges
Guidance for identification of EVs and advance declarations were not included in the draft MGN, and consideration of this would be helpful.
3.6.2 Consultee comments
The need for declaration and identification aids for EVs was highlighted by three of the operators who responded to the consultation. With the different firefighting requirements and potential different fire detection methods it is important that crew can easily identify EVs. Wing mirror hanging cards were identified as a possible solution. Operators also pointed out the benefits of declarations from EV owners to allow deck planning to position such vehicles near drenchers etc.
3.6.3 Government comments
The MCA had not included any guidance for declaration or identification in the draft MGN. The MCA agrees the benefits of including these and will update the guidance to include the need for identification and declarations of EVs to aid with fire detection and firefighting approach.
3.7.1 Guidance for Electric Vehicles other than cars (eg E-Bikes and E-Scooters or Light trucks and commercial vehicles)
The guidance focussed solely on cars and did not consider other electric vehicles either in the form of light trucks and commercial vehicles or smaller electric vehicles such as e-bikes and e-scooters.
3.7.2 Consultee comments
One of the consultation responses identified this gap in the guidance, while the respondent identifies that cars represent the greatest concern there still should be a comprehensive guidance covering all electric vehicles.
3.7.3 Government comments
The MCA has not included any guidance for EVs other than cars and recognises that more comprehensive guidance should be provided. The MCA will include guidance for other electric vehicles in the revised MGN.
3.8.1 Harmful gases and other hazardous chemicals in Electric Vehicle fires
The guidance included a note on the potential harmful gases and vapours that may be released during a Li-Ion battery fire but does not include specific information related to their hazards.
3.8.2 Consultee comments
One of consultation responses requested further information be provided on the particular hazards from the fire products of EVs, particularly the batteries (and any secondary products that may be generated during firefighting).
3.8.3 Government comments
The MCA will include some information on the main hazards from the gases and vapours in terms of toxicity and risk of combustion generated during an EV battery fire and firefighting activities in the revised MGN. This will only be a summary of the main hazards as a full exploration of these would run to several pages and dominate the body of the MGN which would reduce the effectiveness of the MGN in providing guidance for the firefighting and other challenges of EVs on ships.
3.9.1 Risks to crew in Electric Vehicle Firefighting/First Response
The guidance notes the need for personal protective equipment (PPE) to be worn by responders but does not specify the actual requirements.
3.9.2 Consultee comments
One consultation response claimed that the standard firefighting suit (as required by SOLAS) is not sufficient for firefighting of EVs, they expanded this to note that research from the RISE project in Sweden indicates that a fire suit with a secondary inner layer is required to offer the required protection. The respondent notes that this is also applicable to all vehicle fires (SOLAS suit not sufficient). The same respondent also notes research showing that the electric shock risk during firefighting of these vehicles is low (assuming charging operations have ceased).
3.9.3 Government comments
The MCA will provide more detail on the PPE required for EV firefighting. The MCA will advise that suits with a secondary layer may offer further protection but will not be required. The MCA will investigate the need for enhanced protection for Ro-Ro vessels beyond the SOLAS requirements for firefighting suits.
There was engagement in the responses across all areas of the guidance. The responses were generally supportive with ten of eleven responses engaging positively with the MCA issuing guidance related to EV fire safety and the emergency responses. Industry and seafarers acknowledge that this is a developing area and that this guidance will need to be updated as a better understanding is developed. It is anticipated that regulations will be introduced in time, lead from the IMO, to make legal changes to the legal requirements for Ro-Ro fire safety due to the increase in EV however industry is supportive of guidance being issued now.
The proposal which elicited the greatest amount of opposition was related to charging of EVs. There may have been a misconception that the MCA was advocating for operators to provide charging on their vessels. This is not the case and the guidance related to charging is provided only to ensure that a suitable level of safety is achieved if charging onboard is to be offered by operators. The MGN will be significantly updated to reflect this and put more emphasis on fire safety (which was the main concern of the industry respondents) and clarifies our position on charging of EVs
Not all respondents answered all the questions posed. All the comments received have been fully considered, and government is reviewing the guidance in the light of these comments.
Section 4: Next steps
4.1. The government will finalise the guidance with a view to publishing by Summer 2022.