Italy’s Government to Ban Cruise Ships From Venice

In a landmark move, Italy’s cabinet on Tuesday declared the lagoon a national monument and banned large cruise ships from entering starting Aug. 1.

Italy announced on Tuesday that it was banning large cruise ships from entering Venice’s waters and was also declaring the city’s lagoon a national monument, in a move to protect a fragile ecosystem from the downsides of mass tourism.

The ban, demanded for decades by both Venice residents and environmentalists, will take effect on Aug. 1.
“The intervention could no longer be delayed,” Italy’s culture minister, Dario Franceschini, said in a statement.
In recent weeks, as cruise ships returned to Venice after the pause imposed by the pandemic, protesters in the city rallied on small boats and on the waterfront with “No big boats” flags. Last Sunday, they demonstrated during the Group of 20 summit for economic ministers that took place in the city, attracting international media attention.
“My heartbeat is so fast I could be having a heart attack,” said Tommaso Cacciari, an activist and spokesman for the No Big Ship Committee, responding to Tuesday’s announcement. “We have been fighting for 10 years, and now this victory feels almost unbelievable.”
In April, the government of Prime Minister Mario Draghi announced that it was planning to ban large cruise ships from the San Marco basin, the San Marco canal and the Giudecca canal, but no date for the ban was set. Also, the prohibition was conditioned on the building of a new port where tourists could disembark to visit the city, a project that could take years.
Tuesday’s decision removed that condition, so the ban could be enforced in weeks, not years.
Mr. Franceschini explained that the government had drafted the urgent decree to avoid “the real risk of the city being put on the blacklist of “World Heritage in Danger” sites established by UNESCO, the United Nations culture body.
In 2019, UNESCO warned Venice about the “damage caused by a steady stream of cruise ships.” Before a UNESCO World Heritage Committee beginning later this week that could have seen Venice added to the blacklist, the Italian government approved the decree making Venice’s waterways a national monument, a status usually given to artworks and historical buildings that puts the lagoon under enhanced state protection.
Over the last 10 years, Venice has been caught up in a clash between those representing the economic interests of cruise traffic — which employs thousands of people in the area — and others who want to protect a delicate environment from gigantic boats that disgorge tourists en masse.
The ban applies to ships that are either heavier than 25,000 tons, longer than 180 meters (about 590 feet), taller than 35 meters (about 115 feet), or that employ more than a set amount of fuel in maneuvering. The ban is such that even large yachts could be affected.
The government also decided to give power to the regional port authority to determine how five temporary docks can be built in Marghera, a nearby industrial port, while respecting maritime safety and environmental laws.
The intention to divert the cruise ships to the port of Marghera has raised eyebrows. The port is built for cargo ships and is not nearly as picturesque as the city’s lagoon. Moreover, the port’s channel is not large and deep enough for most cruise ships and would require major construction work.
Among the many projects considered by governments over the years, one envisioned a permanent passenger terminal at the Lido entrance to the lagoon. Activists considered that the best solution for the city and for the cruise industry.
Mr. Draghi’s cabinet also moved on Tuesday to establish compensation for sailing companies that will be affected by the ban and for other businesses connected to the cruise traffic inside the lagoon.
“It is a positive decision and could be the beginning of a new era,” said Francesco Galietti, national director for the Cruise Lines International Association. He added that the association has been asking for the temporary docking sites in Marghera since 2012.
The cruise industry is hoping, Mr. Galietti said, that the new docking sites would be ready in 2022, when tourists are expected to return en masse to cruises. This year, only 20 liners were expected to arrive in Venice.

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First post-COVID cruise ship leaves Venice amid protest

By Giulia Segreti and Alex Fraser

VENICE (Reuters) – The first cruise ship to leave Venice since coronavirus restrictions were eased set sail on Saturday, but some local residents protested over the return to normal, unhappy about the passage of giant liners through the historic lagoon city.

Hundreds of people rallied on land and small boats fluttering flags saying “No big ships” surrounded and followed the 92,000-tonne MSC Orchestra as it departed Venice port en route for Croatia and Greece.

“We are here because we are against this passage but also against a model of tourism that is destroying the city, pushing out residents, destroying the planet, the cities, and polluting,” said Marta Sottoriva, a 29-year old teacher and Venice resident.

But port authorities, workers and the city government welcomed the departure of the Orchestra, operated by MSC Cruises, seeing it as a symbol of business kicking off after the health crisis that hit hard at the cruise industry and the wider travel sector.

“We are happy to be back… to restart the engines. We care a lot about Venice and we’ve been asking for a stable and manageable solution for ships for many years,” said Francesco Galietti, national director for the trade group Cruise Lines International Association (CLIA).

Some residents have been urging governments for years to ban large cruise ships and other big vessels from passing through the lagoon and docking not far from the famed St. Mark’s Square.

Campaigners worry about safety and the environment, including pollution and underwater erosion in a city already in peril from rising sea waters.

“The struggle is very long, I think we are against very big financial interests,” Marco Baravalle, a 42-year old researcher, and member of the No Grandi Navi (No big ships) group.

He and other protesters were worried that “everything will go back to what we had before the pandemic”, he added.

Italy’s government ruled in April that cruise ships and container vessels must not enter Venice’s historic centre but rather dock elsewhere.

But the ban will not take effect until terminals outside the lagoon have been completed, and a tender for their construction has not been launched yet. Part of the traffic might be diverted to the nearby port of Marghera starting from next year.

WHERE JOURNEYS BEGIN OR END

The Orchestra was escorted outside the port not just by small vessels protesting but by tugboats that saluted it with water sprays, a sea tradition reserved for special occasions.

The 16-deck ship can carry over 3,000 passengers and 1,000 crew but for this voyage will be sailing at only half capacity due to COVID-19 social distancing rules.

“It’s an important day for us, for 4,000 workers and many others who work in this sector. We are starting again after over 17 months, finally there is light at the end of the tunnel,” said Alessandro Santi, chairman of the Federlogistica business group.

He said the port community favoured the bans but alternatives had to be found given the importance of tourism for the city.

The CLIA estimates that the cruise business represents more than 3% of Venice’s GDP.

“Venice is where many itineraries begin or end, the economic impact on Venice is huge,” said Galietti. “If Venice is taken off the itineraries all the Adriatic (Sea) will suffer the consequences … it would be a huge impact.”

Reporting by Giulia Segreti; Editing by Frances Kerry
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Venice’s first cruise ship since the pandemic departs in a sea of protest

The first cruise ship to dock in Venice since the start of the pandemic more than a year and a half ago has left the Italian port city amid vocal protests.

Protesters drove up to the cruise ship in small boats, brandishing flags and posters, and shouting slogans like “Large ships out of the lagoon.”

The movement No Grandi Navi (No large ships) had called for a demonstration at the beginning of the week to protest against the route the cruise took through the lagoon.

The protesters don’t want large ships passing through anymore, after months of being free of cruise ships entering Venice, a World Heritage site, due to the coronavirus pandemic.

The topic has even mobilised support from stars like Rolling Stones singer Mick Jagger and actor Tilda Swinton, who in an open letter to the Italian government called for a halt to cruises in the lagoon.

Before the pandemic, Venice was hounded by millions of tourists every year, with cruises being especially controversial among locals.

“It was like an April Fool’s joke,” No Grandi Navi wrote in the call to protest, alluding to a regulation that came into force on April 1 that recognises the issue but allows for ships’ passing until a solution has been found.

The Italian government has called for ideas on where large ships could dock outside of the lagoon. No concrete plans have been presented yet.

Meanwhile, the cruise industry body Clia was also surprised the ships could dock in Venice again, but said it was a positive signal for the billion-euro industry.

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Economy or environment? Cruise ship’s return divides Venice

VENICE, Italy — For some it was a welcome sight, for others a return to the bad old days.

As the first cruise ship since the coronavirus pandemic began made its way through the heart of Venice on Saturday, it was escorted by triumphant water-spouting tugboats and elated port workers.

But the 92,409-ton, 16-deck MSC Orchestra was also met by a small armada of wooden boats carrying flags bearing the message “No Big Boats” as it traveled down the Giudecca Canal, past the iconic St. Mark’s Square and the Doge’s Palace.

Hundreds of people also gathered along the canal to protest as the ship left the city en route to Croatia and Greece.

“We can’t accept anymore that just for the business of a few, they insult the city in this way,” said one of the protest’s organizers, Tommaso Cacciari.

“Some say we are the most beautiful city in the world,” he said. “We are a very fragile city, a very unique city, and so we can’t adapt the city to the cruise ships. If they want to come to Venice, they have to be less polluting, smaller and much safer.”

The MSC Orchestra’s voyage, the first through Venice by a cruise ship in more than 18 months, reignited a movement that for more than a decade has opposed the passage of the enormous ships through the lagoon because of environmental and safety concerns.

Protesters like Cacciari say the liners are ruining the fragile marine ecosystem and architecture of the city, which is already in peril from rising sea waters. Protesters say that when the cruise ships sail through the Giudecca Canal in the middle of town, they move a lot of water that slowly erodes the canal floor and crushes against the underwater foundations the city was built upon.

“It is a great provocation that a ship has passed,” environmental expert Andreina Zitelli, a member of the Venice Environmental Association, told The Associated Press. “You cannot compare the defense of the city with the defense of jobs in the interest of big cruise companies.”

But Francesco Galietti, director of the Cruise Lines International Association Italy, said the community wanted ships to return after the pandemic wreaked havoc on the Italian economy.

“We have been asked to come back,” Galietti said. “We are happy to contribute to the prosperity of Venice.”

The Venice Port Authority said that the cruise ship business accounts for 3 percent of the city’s gross domestic product and that around 4,000 jobs depend on it.

Before the pandemic, the city welcomed an estimated 25 million visitors a year. In 2019, 667 cruise ships embarked nearly 700,000 passengers in Venice, according to the cruise lines association.

Galietti said the association has been asking the government for years to come up with a more manageable and sustainable solution for cruise ships’ access to Venice and the lagoon but to no avail.

Prime Minister Mario Draghi’s government pledged this spring to get cruise ships out of the Venice lagoon, but reaching that goal will take time.

The government said that it was organizing bids for a workable alternative outside the lagoon and that the request for proposals should be posted any day now.

But even an interim alternative route to the Giudecca Canal — moving larger ships to an industrial port west of Venice — wouldn’t be ready until next year, the Ministry for Infrastructure and Sustainable Mobility told the AP. Building a new port outside the lagoon would take even longer.

Many of the protesters said it is the cruise ship industry that should change and reduce its environmental impact.

“We hope that the Venetian cause will make them rethink their whole approach to the holiday and travel business,” said environmental activist Jane Da Mosto, executive director of the nonprofit group We Are Here Venice. “This is one of the places where we have to start now.”

Claudio Lavanga reported from Venice and Yuliya Talmazan from London.

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Shipping rule cleans the air but dirties the water

In an unwelcome twist, a global effort to curb pollution from the heavy fuel oil burned by most big ships appears to be encouraging water pollution instead. A 2020 regulation aimed at cutting sulfur emissions from ship exhaust is prompting many owners to install scrubbing systems that capture pollutants in water and then dump some or all of the waste into the sea.

Some 4300 scrubber-equipped ships are already releasing at least 10 gigatons of such wastewater each year, often in ports and sometimes near sensitive coral reefs, researchers reported last month in the first effort to quantify and map the releases worldwide. The shipping industry says pollutants in the waste don’t exceed national and international limits, and that there’s no evidence of harm. But some researchers fear scrubber water, which includes toxic metals such as copper and carcinogenic compounds called polycyclic aromatic hydrocarbons, poses a rapidly growing threat, and they want to see such systems outlawed.

“There’s definitely reason for concern,” says Ida-Maja Hassellöv, a maritime environmental scientist at the Chalmers University of Technology who studies the issue. “A ban of the scrubbers is most urgent.”

The emerging debate is the result of a 2020 regulation put into place by the International Maritime Organization (IMO), an arm of the United Nations that works with 174 member states to develop common rules for international shipping. By banning the use of sulfur-heavy fuel oil, the rule intended to reduce pollutants that contribute to acid rain and smog. IMO estimated the rule would slash sulfur emissions by 77% and prevent tens of thousands of premature deaths from air pollution in ports and coastal communities.

But cleaner fuel can cost up to 50% more than the sulfur-rich kind, and the rule allows ship owners to continue to burn the cheaper fuel if they install scrubbers. In 2015, fewer than 250 ships had scrubbers (often to comply with local regulations); last year, that number grew to more than 4300, according to industry figures.

A scrubber system sends exhaust through a meters-tall metal cylinder, where it is sprayed with seawater or freshwater, depending on the type, at rates comparable to gushing fire hydrants, to capture pollutants. In the most popular systems, called open loop scrubbers, seawater is discharged to the ocean after little or no treatment. Other systems retain sludge for disposal on land and release much smaller (but more concentrated) amounts while at sea.

To come up with its estimate of annual discharges, a group led by environmental policy researcher Bryan Comer of the International Council on Clean Transportation (ICCT), a nonprofit think tank, analyzed roughly 3600 scrubber-equipped ships. The 10 gigatons a year they calculated is likely an underestimate, Comer says, because more ships are adding scrubbers and many have discharge rates higher than the IMO estimates used in the study.

The ICCT study, released on 29 April, also examined the routes taken by the ships in 2019 and found that scrubber discharge is concentrated where shipping traffic is dense, such as the North Sea and the Straits of Malacca. But it also spans the exclusive economic zones of many nations, which extend 370 kilometers out to sea. “Our mapping shocked even me,” Comer says, because it wasn’t obvious that so many kinds of ships, operating all over the world, would opt to install exhaust scrubbers.

Researchers are particularly worried about discharges in areas that IMO has designated as ecologically sensitive. The Great Barrier Reef, for example, receives about 32 million tons of scrubber effluent per year because it’s near a major shipping route for coal. Ships also release scrubber water around the Galápagos Islands.

Ports see substantial discharges, too. Cruise ships dominate those releases, contributing some 96% of discharges in seven of the 10 most discharge-rich ports. Cruise ships typically need to burn fuel in port to continue to operate their casinos, heated pools, air conditioning, and other amenities. Most ports have shallow water, so pollutants are less diluted and can accumulate more rapidly.

Industry organizations, including one called the Clean Shipping Alliance 2020, say the discharge figures are misleading. They argue, for example, that it is the waste’s possible toxicity that matters, not its volume.

So far, few researchers have tested scrubber water on marine life. One laboratory study, published last month in Environmental Science & Technology, found that samples from three North Sea ships harmed the development of a common copepod (Calanus helgolandicus), a tiny crustacean that is a key part of Atlantic Ocean food webs. At very low doses, young copepods stopped molting, and the animals died at rates three times that found in the wild. Such impacts could be “a big deal” for food webs in the real world, says co-author Peter Thor, a marine ecologist now with the Swedish University of Agricultural Sciences.

“We were surprised that we saw effects at such low concentrations,” says Kerstin Magnusson, a co-author and a marine ecotoxicologist with the Swedish Environmental Research Institute. None of the measured pollutants alone occurred at what seemed to be a harmful concentration; instead, the mixture could be to blame, and it’s possible that scrubbers generate new compounds.

Next, the researchers, who are participating in a €7.5 million European effort to study shipping pollution called EMERGE, would like to study how scrubber water affects fish larvae, which are likely more sensitive than copepods to scrubber pollutants.

But shippers have become hesitant to share samples and data with scientists. “We’re reluctant to give it to organizations which we know have already an established agenda,” says Mike Kaczmarek, chairman of the Clean Shipping Alliance 2020. The group will work with “science-based organizations where we think that [the data will] get an objective treatment.” He points to studies that predict no harm from scrubber discharges, and says that, so far, there’s no evidence of actual damage. “Show me the harm,” Kaczmarek says. “There isn’t any.” Comer, however, says those studies have methodological lapses that make it impossible to know whether they used samples that meet existing guidelines.

The ultimate solution, he and others say, is to require ships to use the cleanest fuel, called marine gas oil. In the meantime, 16 countries as well as some localities have banned the most common scrubbers. Those bans have reduced discharges by 4%, Comer says. “There needs to be a global fix on top of that,” he says. “That’s going to take a long time,” he concedes, given that it can take years for nations to agree on new shipping rules, especially when they increase costs.

 

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Global scrubber washwater discharges under IMO’s 2020 fuel sulfur limit

A rapidly growing number of ships are being fitted with exhaust gas cleaning systems, or “scrubbers,” as a way to comply with the International Maritime Organization’s (IMO) 2020 global fuel sulfur limit. Scrubbers remove sulfur from ship exhaust by spraying a buffer solution, usually seawater, over it and then discharging the washwater overboard, often without treatment. The washwater is more acidic than the surrounding seawater and contains polycyclic aromatic hydrocarbons, particulate matter, nitrates, nitrites, and heavy metals including nickel, lead, copper, and mercury. Scrubber washwater is toxic to some marine organisms, harms others, and can worsen water quality.

This report is the first global assessment of the mass of washwater discharges expected from ships using scrubbers. The authors used 2019 ship traffic, as a pre-COVID-19 baseline, and considered approximately 3,600 ships that had scrubbers installed by the end of 2020. Results show that absent additional regulations, ships with scrubbers will emit at least 10 gigatonnes (Gt) of scrubber washwater each year. For context, the entire shipping sector carries about 11 Gt of cargo each year. Real-world discharges might be higher, as the authors used conservative estimates for washwater flow rates and the scrubber-equipped fleet now stands at more than 4,300 ships.

Approximately 80% of scrubber discharges occur within 200 nautical miles of shore, and there are hot spots in heavily trafficked regions, including the Baltic Sea, North Sea, Mediterranean Sea, the Strait of Malacca, and the Caribbean Sea. Scrubber discharges also occur in IMO-designated Particularly Sensitive Sea Areas (PSSAs), including the Great Barrier Reef, where about 32 million tonnes (Mt) of scrubber washwater is expected. But that represents only 5% of the 665 Mt expected to be discharged in PSSAs around the world. The Baltic Sea PSSA, for example, is projected to receive 295 Mt of discharges.

Although several governments have taken preventative measures and banned the use of scrubbers in their ports, internal waters, and territorial seas, many have not. Policymakers concerned about the impacts of washwater discharges can consider several actions: The IMO could immediately call on ships to voluntarily stop dumping scrubber washwater in PSSAs. The IMO could then prohibit the use of scrubbers as a means of compliance with fuel sulfur standards and require that ships use cleaner fuels at all times. Countries and ports could ban scrubber discharges in their waters, and flag states could agree to phase out the use of scrubbers on ships flying their flag.

Shipping traffic is not distributed evenly and understanding how much washwater is expected to be discharged and where could improve policymaking. The interactive map below is filled with details of the distribution of scrubber washwater discharges. It has six different layers, and after activating the layer(s) you want to explore, move your cursor to the location of interest and left click to get more information. Additionally, a spreadsheet summarizing the amount of scrubber washwater discharges within each country’s Exclusive Economic Zone, territorial seas, internal waters, major ports, and from ships that fly each country’s flag, is attached below.

See the full map here.

 

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Charleston cruise ship critics join ‘rethink’ campaign heading into 2021

Charleston cruise ship critics join ‘rethink’ campaign heading into 2021
by, Skyler Baldwin

Charleston cruise ship critics announced they were joining forces with the Global Cruise Activist Network’s “Rethink Cruise Tourism” campaign last week. Most cruise lines remain halted, but a vaccine on the horizon could signal an end to the industry’s months-long shutdown. Things must be different after the pandemic, the residents who make up Charleston’s Communities for Cruise Control insist.

The campaign hopes to bring about change to the social, economic and environmental aspects of a responsible cruise industry before restarting the cruise ships sector after its pandemic pause.

“Cruise ships are proven to spread COVID-19,” said Carrie Agnew, executive director for Charleston Communities for Cruise Control. “They are responsible for spreading this disease and remain a threat to public health and safety. It is not safe to resume cruising during a global pandemic and any future infectious disease outbreaks.”

The announcement comes as the idle cruise industry works through initial phases of a U.S. Centers for Disease Control plan aimed at safely resuming cruises from the U.S. At this point, CDC says the risk of spreading the disease on cruise ships would still be “very high.”

Carnival Cruise Lines is the main cruise operator from downtown dock near the eastern end of Market Street. Currently, Carnival’s Charleston operations have been suspended through at least Feb. 28, 2021. Ports of call are also halted indefinitely, according to South Carolina Ports Authority.

The Global Cruise Activist Network released two videos, “RethinkBeforeRebook” and “RethinkBeforeReinfect,” as part of the campaign, along with a series of graphics and fact sheets to prove a vision of what the new normal of the cruise industry could be.

The graphics promote a rethinking of the way the system works, each one targeting a different part of the network.

The network also published “Principles for Responsible Cruise Tourism” in September, providing a roadmap for a transition to the socially and environmentally responsible future GCAN members are looking toward. It addresses a range of concerns, including labor, climate change, pollution, public health and more.

SC Supreme Court won’t rehear case giving Charleston cruise terminal opponents their say

By David Wren dwren@postandcourier.com

Aug 10, 2020 Updated Aug 12, 2020

A last-minute appeal from one of South Carolina’s top politicians failed to sway state Supreme Court’s justices, who unanimously rejected a request to reconsider their previous ruling in a lawsuit over whether Charleston residents can oppose a new cruise ship terminal.

The high court on Friday turned down a request to rehear the case weeks after Jay Lucas, speaker of the S.C. House of Representatives, argued that state residents don’t automatically have a right to challenge environmental permits even if they’ll be affected by their outcome.

Lucas filed a “friend of the court” brief month requesting a rehearing in the years-old case, drawing criticism from project opponents who called his filing “inexcusably late.”

The denial means the S.C. Administrative Law Court must now consider evidence and testimony from opponents of the terminal to determine whether the State Ports Authority can get a permit to build the terminal at Union Pier in downtown Charleston. The Supreme Court in February overturned the lower court’s 2014 ruling that said people living nearby — as well as historic preservation and environmental groups — didn’t have a right to fight the permit issued by the S.C. Department of Health and Environmental Control.

Blan Holman, one of the attorneys representing opponents of the terminal, said the high court’s decision will have far-reaching environmental consequences. 

“We are relieved that the Supreme Court upheld the rights of families and property owners to protect themselves from unlawful pollution,” he said. “The State Ports Authority’s attempt to gut challenges to illegal DHEC permits would have crippled our ability to protect our beaches from offshore oil drilling and defend our neighborhoods from toxic waste dumps. All South Carolinians should breathe a sigh of relief.”

A spokeswoman for the SPA did not immediately respond to a request for comment Monday. The authority and DHEC had also asked the Supreme Court to reconsider its earlier ruling.

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Carnival’s cruise ships pollute more than all of Europe’s cars study

By Melissa Locker

Carnival Corporation and its Princess subsidiary just can’t seem to quit polluting the planet. As the Financial Times reports, Carnival’s pollution problem is so bad that across its fleet, the large boats pollute 10 timesmore than all 260 million of Europe’s cars. That tidbit comes courtesy of a study by the European think tank Transport & Environment, which looked at 203 cruise ships sailing European waters in 2017. The organization found that Carnival–and its brands–were the proud owners of seven of the 20 most polluting cruise-ship lines.

The report also found that besides over-tourism and crashing into ports, there’s a good reason for European cities to dislike cruise ships: they are emitting sulfur dioxide all over the place. If you can’t keep your pollutants straight, sulfur dioxide causes both acid rain and lung cancer. Cruise lines, it turns out, have been dropping the gas all over Europe; the report says Barcelona, Palma Mallorca, and Venice were the cities worst affected by sulfur dioxide emissions. Per the FT, “sulfur dioxide emissions from cars was 3.2m kt versus 62m kt from cruise ships, with Carnival accounting for half that, the study found.”

The report comes just days after Carnival agreed to pay a $20-million fine and undertake increased monitoring of its delightful practice of dumping sewage and plastic waste directly into the ocean (as well as its leaking gas, dirty water, and oily discharge). The company apparently tried to cover up its environmental misdeeds by falsifying records, fixing problems right before inspections, and even trying to get the U.S. Coast Guard to redefine the terms of its environmental compliance plan.

This isn’t the first time that the company has admitted culpability. It has a long list of environmental violations dating back to 1993. Carnival was hauled into court in 2016, and the company pleaded guilty to dumping oily waste from its Princess Line ships; it was fined $40 million and given a five-year probation period. On Monday, it admitted to violating that probation, which resulted in this latest $20-million fine as well as a dressing down by U.S. District Judge Patricia Seitz. “You not only work for employees and shareholders. You are a steward of the environment,” she told Carnival CEO Arnold Donald, according to NPR. “The environment needs to be a core value, and I hope and pray it becomes your daily anthem.” Couldn’t have said it better ourselves.

We reached out to Carnival for comment or, you know, a plan to stop polluting. Here’s what they sent:

CLIA and its cruise line members are committed to a zero-emission future, as is the entire maritime sector. The cruise industry represents less than 1% of shipping and is making progress towards this goal, but it will take time. The industry welcomes the involvement of civil society in this discussion and is disappointed Transport & Environment has published the internal analysis, conducted exclusively by internal staff, without discussion, input or updated insights from the cruise industry or cruise destinations. There is further concern that the results have been published without any academic scrutiny, peer review or scientifically-robust methodology.