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1 INTRODUCTION

This article will analyze the implications regarding

the application of automation into activities

conducted out at sea, with a specific focus on

autonomous vehicles and their operations inside the

maritime dimension. Firstly, the paper will delve into

the history of automation and assess the current state

of affairs with regards to the infiltration of

autonomous vehicles into the maritime industry itself.

Secondly, the paper will examine the drivers of this

trend of infiltration by looking at its material benefits

and structural considerations presented to the

relevant stakeholders in accordance with changing

times. Thirdly, the paper will dissect some of the

above-mentioned drivers, before thereafter

contending that some of the benefits of autonomous

vehicles in the maritime dimension has been over-

stated, and that current technological developments

are not yet conducive for the introduction of full-

fledged automation out at sea. Fourthly, the paper

will discuss other nexuses that have the potential to

threaten the applicative practicality of autonomous

vehicles into the maritime dimension itself, such as

the role of the human element, as well as legal and

political complications. Fifthly, the paper will offer a

visual label by likening the implementation of

autonomous vehicles into the maritime dimension to

the concept of a low-hanging fruit, offering a

cautionary take that delineates some of the concerns

surrounding the infiltration of autonomous vehicles

into the maritime dimension.

Beware of the Low-Hanging Fruit – Autonomous

Vehicles in the Maritime Dimension

. Lim

S. Rajaratnam School of International Studie

s, Nanyang Technological University, Singapore

ABSTRACT: Autonomous vehicles have seen a meteoric rise in popularity amongst governments and

corporations looking to utilize technology for both economic and strategic gains, both on land and out at sea.

This paper focuses on the entrance of autonomous vehicles into the maritime dimension, examining the reasons

driving the burgeoning reputation of autonomous vehicles out at sea, before dissecting some of the myths

behind these reasons. The article will first assess three core reasons behind the rise in demand for autonomous

vehicles out at sea, before contending that the benefits of introducing autonomous vehicles out at sea have been

overblown, and that there are structural concerns and limitations that will hamstring the practicality of using

autonomous vehicles in the maritime domain. These concerns intersect with the domains of technological

maturity, maritime security, as well as international law, and that a presumptuous push for the widespread

implementation of autonomous vehicles in the maritime domain will increase the dangers faced by seafarers

out at sea, going against the natural progression of maritime operations.

http://www.transnav.eu

the

International Journal

on Marine Navigation

and Safety of

Sea Transportation

Volume 18

Number 3

September 2024

DOI: 10.12716/1001.18.03.1

622

2 A HISTORY OF VEHICLES

The first traces of automobiles go back to 1886, when

German Carl Benz patented and unveiled the Benz

Patent-Motorwagen, largely viewed as the world’s

first functional automobile and car. Benz’s creation

laid the foundations for a land-based revolution that

has transformed transportation methods around the

world, providing convenience to individuals while

increasing production efficiency, allowing

governments and industries to utilize automotive

technologies to drive economic growth on

unprecedented levels. Since then, despite a decade

characterized by meteoric technological developments

across a multitude of sectors, cars have largely

retained the overarching functional frameworks put

forth by Benz’s first patent – an engine mounted on

wheels for travel on-land, with its travel speed and

direction controlled by a human. However, recent

centuries have been marked by a rapid development

of autonomous technology, targeted to equip vehicles

with certain levels of autonomy, defined by the

United States’ (US) Department of Defense (DOD) as a

set of capabilities that enable a particular action done

by a particular system to be automatic, or, within

programmed boundaries, self-governing in nature [1].

These theoretical designs of autonomous technology

have already transitioned to practical application on

land, with Tesla’s development of Autopilot 2.0 as the

hallmark example of autonomous cars offering Full

Self-Driving (FSD) capabilities for users. States have

begun implementing domestic infrastructure

developments to allow for the unfettered operation of

autonomous land vehicles on their roads, and

conglomerates such as Apple and Google have also

re-directed resources towards the development of

Artificial Intelligence (AI), particularly with the

development of in-house mapping applications, in an

ambitious attempt to capture the autonomous vehicle

markets. With relevant stakeholders continuing the

incorporation of autonomous land vehicles into their

daily operations, market research experts have

forecasted the global autonomous vehicle market to

hit $2,796.33 billion in total value by 2032 [2].

3 AUTONOMY IN THE MARITIME DIMENSION

The most rudimentary definition of autonomy would

refer to either self-regulation or self-government,

essentially seeking to execute a particular task that

was previously performed by a human [3]. Porter

captures the essence of autonomous vehicles with a

simple one-liner – vehicles powered by autonomous

technologies, without needing human control [4].

While the “autonomous” terminology is often used

across different industries to represent different

things, a common classification that most invoke

specifically for vehicles, both on land and out at sea,

would be the Society of Automotive Engineers (SAE)

taxonomy for levels of driving automation, an

indicator which classifies automation levels from

Level Zero to Level Five [5].

Looking into the maritime dimension itself, it is

evident that automation has already infiltrated into

both the commercial and military sectors, with these

autonomous vehicles used for a variety of activities

ranging from traditional product transportation to

even marine science research. Furthermore, these

autonomous vehicles have also been identified for an

entire spectrum of uses such as oil spill removal,

cargo shipment testing, fish abundance estimation

surveying, and even for acts of terror [6] in recent

years. Prior to the rise of the above-mentioned

autonomous revolution in the past century, the

maritime industry had already seen widespread

usage of different variants of autonomous vehicles –

in particular, unmanned underwater vehicles (UUVs)

and remotely operated vehicles (ROVs). The

commercial potential of these variants was only

recognized after the discovery of offshore oil and gas

resources nestled in the bottom of the North Sea –

offshore corporations needed to develop automobiles

with the capabilities to operate in extreme depths of

the sea, while state militaries required these low-cost

assets to execute covert surveillance missions and

bottom-of-the-sea defense expeditions such as mine

planting [7]. In an era where stakeholders, both public

and private, prioritize the concept of value

maximization heavily, such dual-purpose assets have

become attractive propositions for governments and

institutions looking to increase the efficacy of their

monetary investments. This proliferation of

autonomous vehicles has continued with the changing

times, earmarked by the development of new variants

that possess operational capabilities on the surface of

the sea (unmanned surface vehicles – USVs / maritime

autonomous surface ships – MASSs) and in the air

(unmanned aerial vehicles – UAVs). Klein offers an

umbrella-level terminology that aims to capture all

the variants of autonomous vehicles in the maritime

dimension under its entire auspice – Maritime

Autonomous Vehicles (MAVs), defined as a variety of

vehicles that operate both above, below, as well as on

the surface of the ocean autonomously [8].

Delving deeper into MASSs and USVs, the

meteoric growth of the MAV industry has exceeded

all expectations, with industry bigwigs such as Rolls

Royce, Mitsui Lines and Kongsberg shelving out

significant resources into developing autonomous

ships for container transportation [9]. Militaries have

also identified the potential of MAVs in improving

maritime defense operations such as anti-submarine

warfare, with a specific focus on intelligence,

surveillance and reconnaissance (ISR) capabilities. The

United States of America (U.S.) Navy unveiled its

Unmanned Campaign Framework on March 2021, a

defense strategy aimed at fusing MAVs into its

maritime operations to expand its naval warfighting

capacity [10], while Japan announced plans to

transform 50% of its domestic vessel fleet to MAVs by

2040 [11]. Other Indo-Pacific countries such as Korea

and Australia have also unveiled plans to develop

MAVs, with renowned Israeli USV manufacturer Elbit

Systems announcing in 2021 its successful receiving of

contracts worth approximately $56 million to provide

USVs to an unnamed state navy in the Asia-Pacific

region [12]. It is evident that international arms

manufacturers have accurately identified the onset of

the autonomous revolution in the maritime industry,

thereafter attempting to jump onto this hype by

constructing and employing MAVs for a wide variety

of scientific, hydrographic, and military (both

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ISR/offensive) applications in a bid to capture

maximum economic gains [13].

4 MARITIME AUTONOMOUS REVOLUTION: THE

DRIVERS

Any discussions about the proliferation of

autonomous vehicles in the maritime industry has to

start with a profound appreciation of the drivers

behind the above-mentioned autonomous revolution

– these drivers are more often than not, multi-

directional in nature, and can be unpacked in terms of

both material benefits and structural limitations. A

survey conducted by the Institute of Marine

Engineering, Science & Technology pointed to the

primacy of corporations developing new technologies

– more than two-thirds of the surveyed industry

stakeholders pointed to technology providers as the

primary drivers of the autonomous revolution in the

maritime industry, while 44% of respondents

expressed support for the introduction of MAVs into

the shipping sector, compared to 33% who disagreed

[14]. The same survey also asked its participants about

the basis on which they would thereafter support the

adoption of MAVs in the shipping industry, and the

top three answer quoted were reduced operational

costs, enhanced safety and increased operational

efficiency [15]. Other less talked-about benefits would

include increased ecological and social sustainability,

as well as environmental advantages due to fuel

savings.

4.1 Driver #1: Cost Savings

Delving deeper into the primary benefits of

implementing MAVs into maritime operations,

predictive studies have forecasted that the

introduction of MAVs into commercial cargo schemes

would generate an 5-10% improvement in the ship’s

life cycle costs per vessel due to fuel efficiency

improvements and cost reductions from crew savings,

with this percentage potentially rising up to 22% per

transport unit [16]. Without the need for a living

human element in these MAVs, there would be

increased economic flexibility in terms of fuel

expenditures, labour costs and ship design in

particular, as MAV manufacturers can eliminate

considerations of building a living space for the on-

board crew. Resultantly, reducing the need for an on-

board human element would allow for an industry-

wide re-organization of manpower and the direct

cutting of operational overhead costs, generating

significant cost savings and longer vessel operation

hours. Over 80% of the world’s cargo transportation

goes through the sea, and the successful infusing of

MAVs as a reliable transportation system into current

commercial maritime transportation operations

would generate massive savings in cost for industry

stakeholders [17]. Furthermore, space can be

optimized and these MAVs can be designed to be

more streamlined and wind-resistant [18], which

would unlock significant amounts of untapped

potential as manufacturers can now develop lighter

and smaller vehicles, which would eliminate the need

for states and corporations to invest into

infrastructure building to aid the safe operations of

larger vessels (port building / sea depth

development), thereafter allowing manufacturers to

develop lighter vehicles that would reduce cost and

increase operational efficiency.

4.2 Driver #2: Enhancing Safety

The other primary benefits of MAVs commonly

touted by industry stakeholders is the enhancement of

safety – quantitative studies conducted by multiple

scholars contend that more than 80% of casualties

occurring inside the maritime industry can be

attributed to some form of human error [19], and the

view that human error is the main cause of vessel

collision is one held by a majority of stakeholders

inside the maritime industry itself [20]. The

introduction of MAVs would reduce the need for a

physical human element inside the vehicle, thereafter

eliminating human factors such as negligence, fatigue,

and non-compliance from safety calculations in its

entirety. A quantitative study of past accidents by

Wróbel et al concluded that the introduction of MAVs

that fulfil Lloyd’s Register Autonomy Level 5 (AL5)

scale requirements would significantly lower the

occurrence of maritime accidents [21]. More

importantly, MAVs’ most tangible safety benefit

comes in the form of increased human security, as the

removal of the on-board human element would

ensure that the operator is not put in danger during

the conduct of dangerous operations out at sea. The

U.S. Navy has already been conducting tests for

various USVs meant to conduct dangerous operations

out at sea such as mine and anti-submarine warfare

[22], with U.S. manufacturer Bollinger Shipyards

being awarded a US$122 million contract in 2022 to

produce MCM USVs for the U.S. Navy. The continued

development of MAVs would allow these vehicles to

extend their reach, enabling militaries to conduct

increasingly complex military operations deep in their

adversary’s anti-access zones without putting their

own forces in the path of harm, resultantly pushing

the boundaries of military missions in the maritime

sector [23]. Put simply, the removal of people from the

purported ‘line-of-fire’ would undoubtedly increase

human security and enhance the overall safety of

operations inside the maritime industry itself.

4.3 Driver #3: Structural Limitations

Another driver that is less-mentioned would be

structural limitations facing states and corporations

amidst an ever-changing global climate. With the 21st

century being characterized by COVID-19 and de-

globalization, many countries have been dealing with

internal domestic issues ranging from falling birth

rates to the slow digitalization of operations, and

stakeholders will be forced to constantly adjust its

social and economic infrastructures to meet the

requirements of the near future and beyond. Looking

at Singapore, many have discussed the onset of its

Silver Tsunami, with Singapore projected to be

classified as a super-aged society by 2030 according to

the United Nations’ (UN) classification, with more

than 20% of its population aged 65 and above [24].

Alongside the small island-state’s low fertility rates,

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the pool of national servicemen available has been

shrinking, and the Republic of Singapore Navy (RSN)

has attempted to optimize its operations to function

with leaner manpower through the development of its

own Maritime Security (MarSec) USV, which was

deployed out to Singapore waters for sea trials in end-

2021 [25]. This move can be characterized as

Singapore’s recognition of its domestic structural

constraints – these urban mobility challenges have

become the direct drivers pushing the RSN to adjust

its maritime operational structures to deal with the

city-state’s changing demographics. Furthermore, the

issue of changing social demographics is more acutely

felt inside the maritime industry due to the nature of

the work involved – labour in the maritime sector is

characterized by long periods at sea or off-shore,

monotonous and dangerous working conditions

(especially for the defence sector), and resultant

disruption to family life – the traditional requirement

to be out at sea for prolonged periods of time is

becoming an increasingly unpopular prospect for

younger generations of the workforce [26]. With

generational change-over also holding relevance for

the maritime sector, the push for MAVs is essentially

technological advancements seeking to replace

seafarers with an autonomous system that would

allow for work to be completed from the comforts of

the shore.

5 UNPACKING THE MYTHS: OVERBLOWN

CALCULATIONS

The appeal of MAVs is apparent to most – the

successful integration of autonomous vehicles into

military set-ups would directly eliminate the potential

risk of loss to human life in the conduct of dangerous

operations out at sea, and the possibility of

completing defence-related maritime operations such

as mine removal, as well as the ability to conduct

deep-water expeditions for marine scientific research

without putting the human element in harm’s way is

a tantalizing prospect for all relevant stakeholders in

the maritime industry. It is evident that the core tenets

of the above-discussed drivers of the autonomous

revolution in the maritime industry remain largely

valid, founded on assessments of logic. However, this

paper seeks to offer an alternative perspective – that

the calculation elements of cost savings and enhanced

safety/security has been overblown to a certain extent,

and an unpacking of myths is required for a proper

evaluation of the applicative practicality of

autonomous vehicles inside the maritime dimension

itself.

5.1 The Cost Fallacy

Firstly, the narrative of reduced cost certainly holds

validity – cost savings in the form of reduced

manpower costs and increased operational hours due

to flexibility in vehicle design cannot be ignored, and

while this spending was initially seen as sunk cost

industry-wide, the potential of MAVs to unlock this

element cannot be ignored, as industry stakeholders

seek to exploit these benefits. However, it is important

to note that there will definitely be an asymmetry of

benefit measurement inside the maritime industry

itself, as stakeholders in different sub-sectors will

undoubtedly have different cutting interests. While

labour shortages remain as one of the structural

constraints causing an accelerated push towards

MAVs, sub-sectors that have lesser labour cost

outputs would not find MAVs as attractive when

compared to sub-sectors with higher crew costs. The

application of MAVs into the maritime industry needs

to be put into perspective – sub-sectors that conduct

operations with shorter sea routes and smaller ships

(such as navies, intra-water border security etc) would

certainly see more potential in MAVs as compared to

sub-sectors that conduct daily operations with larger

ships, alongside longer routes cutting through the

open seas (container shipping, warship

manufacturing etc). Relevant players would need to

take a step back from the massive hype surrounding

automation, and to properly assess whether the

introduction of MAVs into their maritime operations

would be as value-worthy a choice as it seems at first.

The infusion of MAVs into maritime activities is not a

simplistic vessel-for-vessel replacement issue –

governments and industries would have to strengthen

port capabilities to provide the necessary

infrastructure for the docking of these MAVs, while

also ensuring that there are sufficient technological

coverages to prevent the MAVs from becoming

victims of cybersecurity attacks.

This raises the question of whether the

development of autonomous technology is truly

mature enough to support operations in the maritime

sector – countries have re-diverted significant

portions of its budget towards investing into

autonomous vehicles both on land and out at sea, yet

yielding notably mixed results. For example, the U.S.

Navy had invested nearly 17 years and $706 million of

taxpayer money into the development of the U.S.

Remote Multi-Mission Vehicle (RMMV), a UUV that

was designed by Lockheed Martin to find, classify

and remove mines from under water. However, the

RMMV’s reliability had failed to meet expectations

and it led to the U.S. Navy terminating purchases at

just ten units, down from its originally-planned 64, in

March 2016 [27], eventually scrapping the RMMV

project entirely inside the same year due to reliability

issues and communicative difficulties. Former U.S.

Senator John McCain criticized the RMMV project as

an indefensible failure, while noting that the cost per

system had risen throughout its development, yet

delivering little results [28]. While the U.S. Navy’s

failure here is just one heavily-publicized example of

a MAV developmental project that failed to live up to

its initial billings, this leads to further suspicion

regarding the cost savings of MAVs – while its

benefits are recognized, the path trodden by

stakeholders inside the maritime industry to achieve

automation via developing MAVs could possibly be,

similar to the RMMV, an extended and costly project

that would end as an wastage of significant resources

that could have been re-invested elsewhere for better

results.

Furthermore, the purported potential cost benefits

resulting from the removal of the human element

from maritime operations should also be relooked at –

multiple scholars have contended that the benefits of

removing the human element from the equation has

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been, to a large extent, overblown. There is

quantitative validity in benefits arising from the

exclusion of the living human element from vessel

operations – for example, it would remove the need

for sewage treatment plants on-board, thereafter

leading to reduction in infrastructure costs and

stronger profit margins due to increased operational

efficiency [29]. However, the removal of the human

element represents a basic task-transfer operation, as

the tasks previously performed by the on-board

human element would now fall into the hands of the

MAV operator back at shore. Of course, this argument

is founded on the level of autonomy that MAVs

eventually attain, but the crux of the issue remains: it

is functionally difficult to imagine a scenario where

MAV operations are able to achieve complete

autonomy without the requirement of any human

involvement, whether remote or physical. Human

supervision would likely still be required in the case

of an emergency, as the MAV’s controller would be

required to be on standby to take over control of the

MAV in a case of an emergency. The attempted

removal of the on-board human element via the

development of MAVs could lead to increased human

labour at shore or increased resource usage via

developing port infrastructures, and cost savings

would be resultantly minimal [30].

Another unintended consequence of the removal

of the human element is related to marine insurance,

and the development of MAVs will certainly lead to

seismic changes for the insurance industry for ships

and vessels. The official classification of MAVs

remains largely ambiguous at this point, and existing

frameworks in the marine insurance industry has not

listed clear guidelines for coverages related to ships

and vessels with autonomous technologies [31]. The

issue of liability assignment would be a tricky one for

the industry to solve, as the presence of the human

element allows for easier apportioning of fault – if a

collision out at sea occurs due to a technological

malfunction, it is difficult to identify where the

liability falls on, and the lack of the on-board human

element as a failsafe option could lead to a spike in

insurance costs for the maritime industry.

Another point to debunk the cost myth is related to

the manufacturing of MAVs itself – there are technical

infrastructural concerns that come with the designing

of a MAV that can reliably reproduce the functions of

a typical maritime vehicle out at sea. Building on the

previously-articulated arguments, industry experts

have contended that the potential saving in

manpower costs by reducing the crew members on-

board would simply be a transfer of these costs onto

the shore, and that this cost reduction would be

relatively inconsequential compared to the total

expenses required for the safe operation of the vehicle

[32]. Looking into the power sources of ships and

vessels, there is a widespread usage of lithium-ion

batteries to power their operations due to its higher

energy density than other battery options. However,

lithium-ion batteries have faced long-standing

criticism about safety issues due to the potential for

fire hazards, a risk that is ironically enough, amplified

out at sea, as these vehicles often operate directly

under the sun for extended periods of time. MAV

manufacturers have attempted to circumvent this via

designing vehicles powered by diesel or renewable

energy sources, and platforms using these sources

would be designed to exhaust their engines while

charging onboard batteries using solar power.

However, using diesel or renewable energy-powered

engines would require additional machinery-control

autonomy features to change operational speeds on

the fly, which adds a layer of complexity to MAV

manufacturing processes [33] – this resultant

complication could end up eating into any of the

‘saved costs’ while even threatening to potentially

create more infrastructure-related costs for the entire

maritime industry during the shipbuilding phase, as

well as the integration phase of MAVs into daily

operations.

5.2 The Safety Fallacy

Secondly, the narrative of enhanced safety and human

security also has obvious merits – the potential of

MAVs to remove the on-board human element from

harm’s way largely reduces the occurrence of

maritime accidents caused by human error and takes

the operator out of harm’s way when conducting

operations of a more intrusive and dangerous nature,

while unlocking the potential of MAVs to conduct

marine expeditions that were previously impossible

with a human on-board. However, the strength of this

narrative can be whittled down when connected to

the underlining argument of Section 5.1 – the removal

of the human element would be a simple transfer of

safety and security-related issues from the on-board

operator to the human element on-shore. The

development of MAVs largely hinges on their

automation levels and whether these vehicles are able

to reliably abide by laws governing the maritime

dimension (maritime traffic rules), as well as whether

they are able to perform the functions of a normal

vessel, as delineated by the International Maritime

Organization (IMO) and the UN Convention on the

Law of the Sea (UNCLOS). Removing the human

factor from ships and vessels without the full

assurance that autonomous technologies are able to

reproduce human functions could be a recipe for

disaster, with the example of internal fires and

explosions out at sea being relevant here – removing

the human element could equate to the removal of a

failsafe reactionary option in the case of serious

emergency, which could complicate matters out at sea

or even lead to more maritime accidents occurring

with the introduction of MAVs. Taking reference from

the IMO’s International Convention for the Safety of

Life at Sea (SOLAS), SOLAS requires periodically

unattended ships to have fixed local fire-fighting

systems with both automatic and manual release

capabilities [34], and putting the MAV’s fire-fighting

capabilities in the hands of an autonomous system

still seems like a distant possibility. Furthermore,

SOLAS Regulation 17-1 (that entered into force in July

2014) dictates that all ships are required to have plan

and procedures for the recovery of persons of waters

[35], and the removal of the human element could

hamstring the ability of vehicles out at sea to conduct

rescue operations on persons-in-need. While the

removal of the on-board human element certainly

enhances human security from one angle, attempting

to construct and implement MAVs into maritime set-

ups could be a costly process that could end up

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putting other seafarers at risk. This safety and security

issue is further exacerbated by a simple thought: if

countries and corporations start integrating MAVs

into their operations, there is a possibility of human

security being complicated due to the lack of the

human element to make on-the-spot judgements to

rescue persons out at sea – MAVs could end up

endangering more seafarers out at sea and resultantly

leading to more complicated safety and security risks

than originally imagined, if the relevant stakeholders

do not conduct proper planning, war-gaming,

assessments and trials while hastening the process of

introducing automation into the maritime industry.

5.3 Jumping the Gun

Furthermore, while the security of the operator is

protected, gunning for the short-term benefits of

MAVs without truly understanding the depths of

autonomous technologies could lead to the opening of

a can of worms for all stakeholders inside the

maritime industry itself – cyber-security threats. There

are risks and vulnerabilities associated with the

operation of MAVs and this could expose the

maritime industry to cyber threats, including attacks

on the MAVs itself or other areas of the maritime

industry that are reliant on technology for operations,

such as automated gantries controlled by software,

MAV docking systems and autonomous tugs. Attacks

on these segments are major unknown factors as these

cyber-hackers could potentially alter data-gathering

computers and systems, which could cause significant

damage to the overall functioning of the maritime

industry [36]. Any flaw in the design of the software

governing the control of MAVs’ movements and

operations could be disastrous as well, as this could

give unauthorized access allowing criminal elements

to take control of the electronics of a MAV – which

could lead to disaster on an unimaginable scale. The

above-mentioned problems are particularly relevant,

especially when looking at the sea-based transport of

natural gas and oil. Past notable cyber-security attacks

include targeted strikes on shore-side corporation

such as Saudi Aramco, the world’s most valuable oil

producer, as well as on the IMO itself in 2020, when

its website and web-based services were breached by

a cyber-attack according to its official press release

[37]. Another hallmark example of cyber-attacks in the

maritime sector is the LockBit ransomware attack on

Petrologis Canarias, a supplier of maritime refuelling

services, in 2021 – a simplistic display of the fragility

of the maritime domain to cyber-security attacks [38].

With these natural resources notoriously known for

its profit margins and flammability, if the

implementation of MAVs is rushed without the

necessary cyber-security precautions set in place, this

could potentially lead to exacerbated safety and

security concerns, setting the stage for seaborne

disasters on an unimaginable and potentially

irrecoverable scale.

The dynamic and ever-changing cyber

environment necessitates a constant updating of the

maritime industry’s technological systems, security

features and threats to defend MAV users against

cyber-attacks, and the field of cyber-security has

become one of increasing concern for the IMO and

other international bodies [39]. While the IMO has

provided additional documents to cover risks related

to the cyber space such as the Guidelines of Maritime

Cyber Risk Management in 2017, some scholars have

contended that the legal acts, standards and draft in

place do not pay enough attention to the cyber-

security of MAVs, arguing that the IMO has not

developed an up-to-date standard for assessing cyber-

security risks, while postulating that the IMO lacks

any functional mechanism to exert influence on

owners and manufacturers of ships [40]. Klein

essentially offers the same argument by stating that

the number of states who have ratified the

Convention for the Suppression of Unlawful Acts

Against the Safety of Maritime Navigation (SUA) in

its entirety remains low [41] – the IMO website states

that while 94.88% of states had ratified the original

SUA 1988, only 39.74% of states, which amounts to 52,

have ratified the updated 2005 Protocol to SUA 1988.

While there are other underlying issues that have

contributed to the low signatory/ratification rates of

the 2005 Protocol, the non-ratification would mean

that a large majority of states are not covered under

the legal umbrella of the IMO, as the SUA Convention

is the primary safeguard in the case of a cyber-

security attack meant to cause death, serious injury or

damage to others. States’ non-signature and/or non-

ratification would undoubtedly complicate safety and

security issues plaguing the development and

implementation of MAVs in the maritime industry.

A proper unpacking of the myths surrounding the

drivers behind the autonomous revolution in the

maritime industry presents grounds justifying the

gross over-calculation of benefits that industry

stakeholders have imagined for MAVs to contribute

to their operations. Firstly, while the complete

removal of the human element from maritime

operations seems logical in theory, it is still

impractical and unrealistic in actual application. For

full autonomy to be achieved, MAVs need to be in-

built and retrofitted with a myriad of operating

systems that will fulfil the requirements of a ship set

forth by the IMO and allow it to travel in accordance

with maritime traffic rules, while autonomously

equipped to reproduce the functions that were

previously fulfilled by the on-board human element.

A survey conducted by the Institute of Marine

Engineering, Science and Technology revealed

significant levels of pessimism towards the

replacement of the human element, with 85% agreeing

that seafarers would continue to be an essential

component of the long-term future of the maritime

shipping industry [42]. There was also notable

ambiguity towards the prospect of human operators

being replaced by autonomous technology and

machines – with more than 80% expressing concern

towards the potential impacts of MAVs to the

maritime industry itself, citing examples such as

Tesla’s car crash while operating on its Autopilot

technology [43]. While recognizing the tantalizing

prospects surrounding the future of autonomous

vehicles, this paper contends that similar to how

autonomous land vehicles have yet to reach full

autonomy, the development of MAVs remains a far

cry from reliably replacing the on-board human

element in its entirety.

Secondly, while the increasing relevance of the

above-discussed drivers have added societal

627

pressures on governments and corporations to look

towards autonomous technology as a solution, this

paper contends that the relative immaturity of the

autonomous vehicle dimension means that a rushed

implementation of MAVs without understanding its

operational framework and limits would open a bag

of worms and lead to complications that could cripple

the entire maritime industry’s operations. The depths

of autonomous technology have not matured to a

stage where it is able to reliably perform all the

functions imagined by the wider international

community, and its rushed introduction could

possibly lead to the reverse effect from intended, in

the form of additional exorbitant costs and increased

danger sprouting from categories such as emerging

cyber-security threats and increased occurrences of

maritime collisions.

6 OTHER NEXUSES OF MAVS: COMPLICATING

THE EQUATION

After unpacking myths surrounding drivers of the

autonomous revolution inside the maritime industry

itself, this paper seeks to go one step further by

looking into other implications surrounding the

implementation and applicative practicality of MAVs

into maritime operations in both the commercial and

military sectors. A working label is attached to

discussions in this segment – Other Nexuses of

MAVs, which will be divided into two sub-

discussions. The first will discuss the legal status of

MAVs in international law and its ambiguous political

status with respect to maritime travel, while the

second will look at structural constraints and the

overall operational environment itself.

6.1 Legal Complications

First off, an appreciation of MAVs and its label, legal

position(s) and rights in international law is only

possible after understanding the international

organizations (IOs) and conventions set forth to

delineate rules and streamline behaviour inside the

maritime industry. The IMO is a specialized agency

under the UN’s Economic and Social Council, the

global standard-setting agency primarily responsible

for the security, safety and environmental

performance of the shipping industry [44]. Some of

the more prominent and known IMO conventions

include the International Convention for the

Prevention of Pollution from Ships (MARPOL), the

Convention on the International Regulations for

Preventing Collisions at Sea (COLREGS), and the

previously-discussed SOLAS – the IMO designed

these conventions as regulatory frameworks meant to

dictate the rules in the maritime industry, and to

guide ship and seafarer behaviour out at sea ever

since the IMO’s formation came into force in 1958.

However, the kicker lies herein – the regulations and

conventions designed by the IMO were clearly written

for manned vessels, or essentially, human-controlled

ones. This is understandable given the fact that

autonomous technology was an undeveloped and far-

away possibility at the time, but potential cracks in

the glass start to emerge when thinking about how the

rules are going to apply for MAVs that eventually do

not require the on-board human element, especially

those that are able to attain full autonomy.

Following the rise of autonomous technology to

prominence in the maritime industry, the IMO’s

Maritime Safety Committee conducted a Regulatory

Scoping Exercise (RSE) for the use of MASSs – it

provided a working definition for MASSs and set four

degrees of autonomy that will be used for the

classification of autonomous vehicles in the maritime

dimension. Degree One and Two still includes the

presence of the on-board human element, while

Degree Three is the classification for remotely-

controlled ships, with Degree Four referring to fully

autonomous ship [45]. MAVs that are classified under

Degree Three and Four autonomy would face issues

when attempting to apply the regulations of other

IMO conventions that were written earlier in time.

This in-built problem can be illustrated by first

looking at MARPOL – MARPOL Regulation 37

indicates that in the event of an oil pollution incident,

every ship has to carry a Shipboard Oil Pollution

Emergency Plan (SOPEP) on-board that describes the

immediate action taken by persons on-board to

reduce and control the discharge of oil into the ocean

[46]. It is evident that SOPEP was drafted under the

assumption of the presence of an on-board human

element, and without it, MAVs would be unable to

meet the requirements of a SOPEP set by the IMO.

Incidents of accidental discharge of pollution into the

sea are extremely harmful to marine biodiversity, and

adaptations/adjustments would have to be made to

many other IMO conventions beside MARPOL, to

ensure that MAVs can be properly and safely infused

into the daily operations of the maritime industry.

History is irrefutable evidence of the long-drawn

process when it comes to re-drafting of international

conventions, one that requires the continuous

investment of time, resources and energy, and

attempting to introduce autonomous technology into

the maritime industry without accurately drafted IMO

conventions in place could produce safety and cost

complications on a potentially unimaginable scale.

While not dismissing or undervaluing the

importance of environmental protection, the issue of

adaptation is even more pervasive when looking at

the Convention on the International Regulations for

Preventing Collisions at Sea (COLREGS). COLREGS

came into force in 1977 and as its name suggests, it is

the primary IMO document that serves to prevent

collisions out at sea – it delineates the rules of

maritime traffic and applies to all vessels that can be

used as a means of transportation on water. In this

case, the position of MAVs is clear – regardless of the

presence of the on-board human element, MAVs are

expected to comply with COLREGS. Questions have

been raised over whether MAVs are able to maintain

total compliance – Li and Fung points to the primacy

of the role of the master’s role when on-board a ship,

while raising their doubts over the ability of

unmanned ships to replace the on-board role and to

discharge the master’s responsibilities in ensuring the

safe operation of the vessel, in line with international

maritime law [47]. A few concerns come to the surface

when attempting to analyse MAVs and COLREGS,

and many scholars have raised concerns over the

ability of autonomous technology to replicate

628

functions of the on-board master – Rule 14 of

COLREGS states that when two power-driven vessels

are on a collision course, both vessels are expected to

alter their course to starboard in order to ensure that

they will pass on the port side of the other. Turning

starboard when on a collision course is delineated in

COLREGS, but also forms part of an unwritten

rulebook that mariners are expected to abide by when

out at sea – these unwritten rules are often generated

in hindsight after ship-ship interactions take place,

and this rulebook allow for increased convenience

and greater clarity. [48] Furthermore, Rule 5 of

COLREGS states that every vessel shall maintain a

proper look-out by sight and hearing and all other

available means to make a full appraisal of the

situation and of the risk of collision - Rule 5 is the

hallmark example of an IMO convention that is

written under the assumption of the presence of an

on-board human element. While audio-visual sensors

have been developed by the advancement of

technology and a future where autonomous

technology is able to fulfil Rule 5 can be visualized,

there is notable ambiguity in the writing itself, with

no further elaboration besides the one-liner

summarized above. Carey contends that ship owners

could find themselves subject to criminal liability for

failing to obey COLREGS, if the terms of Rule 5

represent an implicit statement that delineates the

compulsory requirement of an on-board human

element [49]. While the RSE conducted by the IMO in

2021 has attempted to address the applicability of

COLREGS to MASS and MAVs in general [50], clarity

is still an issue, and the IMO will require more time to

work with stakeholders inside the maritime industry

to adjust the wordings of its international conventions

to ensure that MAVs are able to operate safely out at

sea.

The above-discussed ambiguity of MAVs and their

legal and political position inside the maritime

industry is further amplified by the classification of

MAVs under the auspices of international law –

UNCLOS does not provide an official definition for

the terms, “ship” or “vessel”, and a study of IMO’s

conventions does not provide further clarity –

MARPOL Article 2(4) defines a ship as “a vessel of

any type whatsoever operating in the marine

environment …” – this appears to suggest that the

two terms can be used interchangeably, and scholars

have criticized the UN for failing to define either term

[51]. Norris appears to use both terms interchangeably

in his work [52] due to the same critical reasons, but

other scholars like Vallejo have challenged this claim

of interchangeability, contending that the term “ship”

is built upon the term “vessel” [53]. The very fact that

scholars are unable to identify a uniform position by

both the UN and its IMO arm is a clear indicator that

there is a serious problem of ambiguity in the writings

of official IOs and international law as an extension –

if ships and vessels are not allocated proper

definitions by the relevant authorities, it would be

even harder to identify the position to park MAVs

under, and thereafter harder to assign liability to

operators, seafarers and manufacturers of MAVs in

the case of maritime accidents, which could prove to

be both a logistical and political nightmare for

stakeholders in the maritime industry.

6.2 One is not the Other

Secondly, it is also important that stakeholders

consider the operational environment of the maritime

industry itself when attempting to assess the

applicative practicality of MAVs. This point is a

simplistic, yet poignant one – key activities of the

maritime industry are conducted out at sea, and the

operational context has to be considered before

attempting to introduce a new feature out into the

high seas. Most autonomous vehicles operate via pre-

computed geographical maps for self-navigation,

along with a host of sensors and artificial intelligence

to ensure vehicular safety and operational reliability.

The success of autonomous technology on land

should not come as a surprise – the management of

road conditions, maps and navigational routes fall

under the supervision of the state’s ruling polity (and

therefore have limited levels of variance), but this

situation unfolds itself in drastically different manners

out at sea. There are little demarcations of lanes and

travel routes out at sea, and while the IMO and states

have attempted to recommend and enforce specified

sea travel routes for safer maritime operations, these

enforcement mechanisms remain severely limited in

nature due to other political and legal concerns

surrounding issues such as conflicting territorial

claims. Furthermore, the environmental effects of

climate change also create a foreboding sense of

unpredictability, as changing sea levels could produce

new obstacles that could impede the navigation of

MAVs out at sea, while essentially deeming the

mapping of the maritime dimension as a near-

impossibility.

7 BEWARE OF THE ‘LOW-HANGING FRUIT’

The rapid advancement of technology in the past

century has unlocked possibilities like never before –

the prospects of mobile phones and unfettered

internet access were viewed as dreams by past

generations, yet these dreams have translated into

actual reality, and the current generation is resultantly

enjoying the ease of access and convenience that

technology has afforded to them. This development

has also encouraged many to dream about the

limitless possibilities of convenience, from online

shopping and cashless payment to ideas like self-

driving vehicles. However, this paper seeks to attach a

figurative expression to label the infiltration of

autonomous technologies into the maritime

dimension – the “Low-Hanging Fruit”, which seeks to

encompass all the concerns over MAVs and its

applicative practicality into the maritime industry

itself. As its name suggests, a low-hanging fruit is

often used to describe an easily-achievable task or

goal – and the purported success of Tesla’s self-

driving vehicles into countries’ land transportation

system is the paint on the surface here, a direct

display of the potential of autonomous technology in

vehicular operations. Along with the drivers of

autonomy, the push for MAVs is understandable.

However, it is important that industry

stakeholders have to consider the operational

environment of the maritime dimension when

attempting to introduce autonomous technology into

629

ships and vessels. The potential benefits of cost, safety

and security seem attainable at first glance, but a

closer study would reveal that there are other

concerns behind MAVs that could exacerbate these

problems – attempting to pluck the fruit from the tree

could end up collapsing the whole tree instead.

Furthermore, the relative immaturity of autonomous

technology, combined with the under-development of

state and industry infrastructure, as well as the

ambiguity surrounding the political and legal

writings for MAVs, are further displays of the issues

surrounding the applicative practicality of

autonomous vehicles in the maritime industry itself.

Without these technological, infrastructural and legal

developments catching up, the rushed introduction of

MAVs into maritime operations could prove

disastrous. Putting these developments into context,

the fruit might not be fully ripe yet – are we

attempting to reap the rewards by ‘plucking’ the fruit

too early?

7.1 Conclusion – Pumping the Brakes

As the wave of autonomous technology continue

dominating discussions worldwide, both state policy-

makers and engineering bigwigs should make it an

imminent priority to re-assess the overall practicality

and cost-benefit measurements surrounding the

increased investment into the development of MAVs

– these concerns present significant risk of

implementation, and the rushed plucking of the ‘Low-

Hanging Fruit’ could end up inflicting massive

economic and political consequences on stakeholders

inside the maritime industry. This paper contends

that it is crucial to start pumping the brakes on the

implementation of MAVs in the maritime dimension

itself, and this paper intends to serve as a gloomy and

cautionary tale for governments, automotive

manufacturers and seafarers who rely on the

continued operation of the maritime industry for

survival – after all, unlike cars on land, ships and

vessels simply do not stop instantly when the

operator hits the brakes. Water simply behaves

differently from land, ships and vessels have different

operating systems from cars, and industry

stakeholders have to start a level-headed reassessment

of the supposed potential and applicative practicality

of autonomous vehicles into the maritime dimension

itself.

ACKNOWLEDGEMENTS

The author would like to express his sincerest gratitude to

Dr Collin Koh Swee Lean (Senior Fellow, RSIS) for his

guidance and mentorship, and to Assistant Professor Chang

Jun Yan (Military Studies Programme, RSIS) for providing

comments on an earlier draft.

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