Uncrewed Autonomous Marine Vessels Test The Limits of Maritime Safety Frameworks

WMU Journal of Maritime Affairs
https://doi.org/10.1007/s13437-022-00295-x
ARTICLE
Uncrewed autonomous marine vessels test the limits

of maritime safety frameworks
Fran Humphries1 · Rachel Horne1,2 · Melanie Olsen3 ·

Matthew Dunbabin4 · Kieran Tranter1,2
Received: 4 July 2022 / Accepted: 24 November 2022

© The Author(s) 2022
Abstract
Uncrewed and autonomous marine vessels (UMVs) challenge the underlying para-
digm of maritime laws and regulations. Yet UMVs are considered essential for safer,
more efficient, and more effective maritime futures. There is a fundamental chal-
lenge facing industry and regulators about how to develop and support the nascent
UMV industry while maintaining the safety and risk management principles and
processes in legacy laws and regulations predicated on the conventional crewed ves-
sel. This paper, drawing upon case studies of developer and operator experiences
with Australia’s maritime safety framework, argues for an “intent-based”, flexible,
and collaborative approach based on developers’ and operators’ experiences. The
case studies show that ad hoc and bespoke regulatory pathways, utilising exemptions
and discretions under Australian national laws, although problematic in terms of
regulatory consistency and capacity to deal with scale, did allow for the trialling and
deployment of two small UMVs. More importantly, the ad hoc approach facilitated
information exchange between industry and regulators that is generating reforms and
changes at the national level. Although focused on Australia, the findings are signifi-
cant for maritime futures. It reveals a dialectical approach whereby maritime nations
pragmatically work through the risks, standards, and processes that balance safety
with facilitating local UMV industries, and in turn, this creates a body of knowledge
to inform international reform processes. It also shows the importance of document-
ing and reflecting on the regulatory journeys of UMV pioneers as essential for safer,
more efficient, and effective maritime industries that leverage the potential benefits
of automation.
Keywords Maritime safety · Uncrewed autonomous · Marine vessels · Australia ·

Regulation
* Fran Humphries
fran.humphries@qut.edu.au
Extended author information available on the last page of the article
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F. Humphries et al.
1 Introduction
From Nikola Tesla’s 1898 patent that anticipated advanced autonomy in the maritime sec-
tor to today’s explosion of research and development on autonomous vehicles (Pribyl and
Weigel 2018), it seems certain that maritime futures will involve uncrewed and autonomous
marine vessels (UMVs). International and national maritime (shipping) safety frameworks
have evolved to regulate vessels in situations that assume onboard humans are in control of
the vessel, including the master and crew. With the rapid evolution of artificial intelligence
(AI), UMVs ranging from remotely controlled or fully autonomous surface and underwater
vessels pose new challenges for developers and owners who wish to trial and operate their
vessels in regulated waters. While there is a rapidly growing body of literature about UMVs
(Ziajka-Poznańska and Montewka 2021), there is little publicly available information about
the experiences of UMV developers and owners as they progress through national assurance,
accreditation, and approval pathways to conduct trials and ongoing operations. Using the
research and development pathway followed by two UMV developers under Australia’s mari-
time safety framework as case studies, this article analyses the challenges for UMV develop-
ers in trialling and operating their vessels under existing civil1 maritime frameworks. These
challenges are grouped into two themes. First, the challenges that arise from the requirements
that vessels are crewed by onboard humans and second, the challenges relating to the techni-
cal specifications for vessels, including risk management.
Automated vessels have attracted interest as a means of reducing accidents (of
which up to 96% are related to human factors) (Liu 2019), addressing the global
shortage of seafarers, and improving cost efficiency (Komianos 2018). They might
also reduce environmental damage related to human factors, such as the generation
and discharge of waste and effluent from onboard humans (Ahn et al. 2019), which
is a key contributor to marine pollution and the reduction of biodiversity (Brondizio
et al. 2019). On the other hand, AI and other advanced sensing and responding sys-
tems are not yet at a level where there is widespread trust to safely address human,
property, and environmental risks (Lazarowska 2019). Risks include system failures
causing collisions with manned vessels, loss of cargo, and ocean damage as well as an
increased susceptibility to piracy and terrorist attacks (physical and cyber) (Liu 2019).
There are multiple ways that UMVs can be categorised, according to the operational
domain (on, or below the surface) and the degree of autonomy (see Table 1). While there
is no agreed international terminology for the range of UMVs (IMO 2018), terminology
in the civilian sector relevant to this article includes the following:
• remotely operated vehicle (ROV) relates to underwater vessels with a tether that
supplies power and communication and is controlled directly by a remote opera-
tor (Blidberg 2001);
• uncrewed (unmanned) underwater vehicle (UUV) or uncrewed (unmanned) sur-
face vessel (USV), which contains its own onboard power and is controlled by a
remote operator through a communications link (Blidberg 2001);
1
Analysis of the use of UMVs for defence purposes is outside the scope of this article.
13
Uncrewed autonomous marine vessels test the limits of maritime…
• autonomous underwater vehicle (AUV), which is a submersible system with its

own onboard power and controls itself without the need for a communications
link (Blidberg 2001); and
• maritime autonomous surface ship (MASS), which “is a ship which, to a varying
degree, can operate independent of human interaction” (IMO 2021).
The International Maritime Organization (IMO) has acknowledged that “the

number of regulatory barriers increases as the autonomy level is increased” (IMO
2018). Most research and development projects design UMVs with the capacity to
change between levels of autonomy (IMO 2018), requiring flexibility in regulatory
requirements to accommodate UMVs. Indeed, the literature on the regulation of
UMV, especially in national waters, generally emphasises the emerging nature of the
technology and highlights the challenges for the existing maritime regulatory regime
when considering UMV (Qveim-Leikanger 2018; Yoo et al. 2020; Dean and Clack
2019; Judson and Horne 2019). Generally, the approach is to focus on the formal
rules and processes in the regime and identify the gaps and difficulties that possible
UMVs might have in being accommodated within the existing regime. The analysis
is generally desk-based speculation, familiar in the law and technology discipline
(Tranter 2011, 2021).
What is particularly rare is consideration of the practical experiences of pioneer
developers of UMVs in gaining approvals for trialling their vessels under legacy
maritime frameworks, which is what this paper aims to do. While Lutzhoft, Hyn-
nekleiv, Earthy, and Petersen have begun to consider human interactions with
maritime autonomy, they remain focused on the speculative potential within an
automated future, rather than the present human experiences of innovating with
automation and navigating existing regulatory frameworks (Lutzhoft et al. 2019).
This paper, drawing upon two of the co-authors’ experiences with Australia’s mari-
time safety framework as developers and operators of UMVs, argues for an “intent-
based”, flexible, and collaborative approach to reform of maritime frameworks
based on developers’/operators’ experiences that balance safety objectives with
UMV industry development.
This argument is in the following sections. Section 2 provides a brief overview
of the international maritime framework, including relevant treaties, agreements,
and guidance documents for addressing UMVs. It explains how international law
impacts Australia’s policy development for managing UMVs and provides a brief
overview of Australia’s maritime safety framework. Section 3 explores UMV devel-
oper and operator experience with Australia’s maritime framework using case stud-
ies of the Australian Institute of Marine Science (AIMS) and Queensland University
of Technology (QUT), which followed diverging approval pathways for the same
class of small underwater autonomous vessels (CoralAUV and RangerBot). Two of
this paper’s authors led the development and approval processes for these organisa-
tions. Section 3 highlights the case study experiences and outlines the key govern-
ance and process challenges and opportunities for complying with Australia’s legal
and policy approval pathways. Section 4 focuses on the analysis of the case study
experiences of regulatory challenges grouped into two themes: obligations relating
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F. Humphries et al.
Table 1 Levels of autonomy (adapted from IMO 2021 para 3.4)
Ship with automated processes and decision support Seafarers are on board to operate and control ship-
board systems and functions. Some operations
may be automated and at times be unsupervised
but with seafarers on board ready to take control
Remotely controlled ship with seafarers on board The ship is controlled and operated from another
location. Seafarers are available on board to take
control and to operate the shipboard systems and
functions
Remotely controlled ship without seafarers on board The ship is controlled and operated from another
location. There are no seafarers on board
Fully autonomous ship The operating system of the ship is able to make
decisions and determine actions by itself
to humans onboard and technical requirements. The challenges in each of these

themes are framed in the international, national, and case study contexts. The case
studies illustrate how the UMV developers addressed these challenges using risk-
based approaches during their approval pathways. Section 5 draws upon the case
study experiences of governance, process, and regulatory challenges and outlines
recent developments in international and Australian forums to facilitate governance
certainty for UMV actors. It highlights current developments for accommodating
UMVs in maritime frameworks, including the recent Australian Code of Practice,
with the COLREGs Operator Guidance Framework as an annex. The paper proposes
an “intent-based”, flexible, and collaborative approach to reforming maritime frame-
works, based on developer/operator experience that balances safety objectives with
facilitating the UMV industry.
2 Maritime law and UMVs
In Australian waters, there are a range of international conventions, Commonwealth

laws, and state or territory laws that give rise to requirements for UMVs, depending
on where the vessel operates and for what purpose. Australian waters comprise its
coastal waters (to 3 nautical miles) and territorial waters (to 12 nautical miles) that
are subject to Australia’s sovereignty, and the exclusive economic zone (to 200 nau-
tical miles) where Australia exercises sovereign rights for the purposes of exploit-
ing, conserving, and managing natural resources in the waters and seabed below,
among other rights.2 This section outlines Australia’s maritime framework after pro-
viding some context of the international framework that the domestic arrangements
implement.
There are a range of International Maritime Organisation (IMO), International
Labour Organisation (ILO), and United Nations Conference agreements that shape
the international maritime framework and its obligations for state parties. While the
2
See e.g. Seas and Submerged Lands Act 1973 (Cth).
13
framework covers a range of legal areas including safety, environment, liability, con-
tracts, salvage, and insurance, for the purposes of the analysis below, the interna-
tional agreements relevant to safety and conditions at sea include:
• United Nations Convention on the Law of the Sea (UNCLOS);

• Convention on the International Regulations for Preventing Collisions at Sea
(COLREGs);
• international convention for the safety of life at sea (SOLAS);
• International Convention for Standards of Training, Certification, and Watch-
keeping for Seafarers (STCW); and
• Maritime Labour Convention (MLC).3
UNCLOS is a legal framework for ocean governance in all marine spaces. While
the framework is much broader than maritime law (see e.g. Freestone et al. 2006;
Tanaka 2015), its provisions relevant to shipping include jurisdictional issues con-
cerning the nationality of ships (flag state), sovereignty and sovereign rights con-
cerning the subject matter and activities within maritime zones, shipping standards
(including environmental), and piracy and rights of innocent passage for vessels (see
e.g. Ringbom 2015; Marten 2011). COLREGs are a framework of navigational rules
that vessels must follow to prevent collisions, including rules relating to responsibil-
ity, lookout, safe speed, and precautions to avoid collisions (Achnioti 2021). SOLAS
sets out standards to achieve safety objectives on a range of issues, including con-
struction, cargo handling, communications, life-saving equipment and procedures,
maritime security, operations, and navigation (Chircop 2017). The STCW together
with its associated code sets standards of training, certification, and watchkeeping
for seafarers globally (IMO 2011). It uses a skills-based framework, where the sea-
farer needs to demonstrate knowledge, understanding, and proficiency of certain
tasks to be deemed competent for each rank and is periodically updated to address
competency requirements for new technologies (Sharma and Kim 2021). The MLC
aims to ensure worldwide protection of the rights of seafarers and to establish a level
playing field for decent working and living conditions for seafarers (ILO 2021). The
MLC includes a two-part code containing mandatory standards and non-mandatory
guidelines. The standards include minimum requirements for seafarers to work on
a ship, conditions of employment, accommodation, food and catering, and medical
care (Exarchopoulos et al. 2018). There are a range of codes that support the inter-
national maritime framework. For example, Sect. 4 below refers to the International
Safety Management (ISM) Code, which is integrated into SOLAS as the interna-
tional standard for the safe operation of ships and pollution provision and sets objec-
tives and requirements for safety management systems.
3
Other relevant international agreements include: International Convention for the Prevention of Pol-
lution from Ships, Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other
Matter, International Convention on the Control of Harmful Anti-fouling Systems on Ships, and Interna-
tional Convention on Load Lines.
13
F. Humphries et al.
Australia is a federation of states with three levels of government—Common-

wealth (national), state/territory, and local governments, each with their own laws
and policies. While maritime law is primarily the responsibility of the Common-
wealth government so that it can comply with its international maritime obligations,
state/territory, and to a lesser extent, local governments have overlapping laws and
responsibilities that impact on marine safety and pollution issues, ports, and water-
ways management. The national marine safety regulator, the Australian Maritime
Safety Authority (AMSA), is an entity of the Commonwealth Department of Infra-
structure, Transport, Regional Development, and Communications and is respon-
sible for registration, marine pollution, survey and certification of vessels, safety
standards for foreign vessels, crew competence standards, navigation aids, and
other responsibilities under a range of legislation. There are several other Common-
wealth agencies with responsibilities in the marine space including environmental
protection and marine parks, such as the Great Barrier Reef Marine Park Authority
(GBRMPA) highlighted in the case studies in Sect. 3. The legislation administered
by GBRMPA provides an additional layer of regulation for specific vessels operating
in the Great Barrier Reef.
Vessels in Australian waters will generally be subject to one of four key maritime
safety frameworks, none of which currently distinguish between conventional ves-
sels and UMVs. These are outlined in Fig. 1. AMSA regulates two distinct frame-
works for civil vessels; the third is the framework for defence vessels regulated by
the Department of Defence, and the fourth is the framework for recreational vessels
regulated by the relevant state or territory where the vessel is used. The first step for
determining which maritime framework applies is whether the vessel falls under the
definition of “vessel” for the purposes of the Marine Safety (Domestic Commercial
Vessel) National Law 2012 (Cth) (National Law).4 If so, the next step is to determine
whether it is a “domestic commercial vessel” (DCV) (Fig. 2). Generally, a DCV
is a “vessel for use in connection with a commercial, governmental, or research
activity” (National Law schedule 1, Sect. 7), which is not a “regulated Australian
vessel” (RAV) or “foreign vessel” that are both regulated under the Navigation Act
2012 (Cth) (Navigation Act); not a “defence vessel” (regulated under the Australian
Defence Maritime Seaworthiness Framework5) or a recreational vessel or other ves-
sel owned by a school, prescribed community group, or sports institute under cer-
tain circumstances (regulated under relevant state/territory laws).6 Australian ves-
sels used in connection with a commercial, governmental, or research purpose and
which travel outside of the exclusive economic zone (EEZ) will generally be RAVs
4
A vessel is a “a craft for use or that is capable of being used, in navigation by water, however propelled
or moved, and includes an air‑cushion vehicle, a barge, a lighter, a submersible, a ferry in chains and
a wing‑in‑ground effect craft.” National law schedule 1, part 1 Sect. 8(1). This is expanded upon and
subject to various exclusions under marine safety (domestic commercial vessel) national law regulation
2013 (Cth) Sect. 12.
5
https://www.defence.gov.au/business-industry/seaworthiness#:~:text=Australia’s%20Defence%20mar
itime%20capability%20consists,enough%20to%20be%20technically%20sound.
6
An analysis of state and territory legislation relevant to maritime safety requirements is beyond the
scope of this paper.
13
under the Navigation Act. An owner of a vessel that would otherwise fall within the
National Law as a DCV may apply for an “opt-in declaration” that the vessel is a
RAV to be regulated under the Navigation Act under certain circumstances (Naviga-
tion Act Sect. 25). Foreign vessels (a vessel that does not have Australian nationality
and is not a recreational vessel) are regulated under the Navigation Act. Some small
UMVs operated directly off a mothership, which is a RAV or foreign vessel, may
be considered “ships equipment” and therefore not be subject to legislative require-
ments independent to the primary ship (which will include them in their safety man-
agement systems and survey) (Navigation Act Sect. 1; see McLaughlin 2011).
There is a standard set of requirements for DCVs under the National Law, which
must be complied with unless a specific exemption or general exemption applies.
Generally, a DCV must be crewed by persons holding the required certificate of
competency and have a unique vessel identifier, certificate of survey, and be listed
on a certificate of operation (National Law Schedule 1, Part 4, Divisions 1–4).
AMSA will assign a DCV a vessel service category (the use and operational area
categories), which determines the requirements that will apply under the marine
orders and the National Standard for Commercial Vessels (NSCV), which includes
the technical standards for compliance with international agreements, including
vessel design, construction, equipment, survey, operation, and crew competencies
(NSCV Part B, Sect. 2.4). As the National Law and associated standards are based
on the assumption that vessels will be crewed, UMVs will not comply with all of
the requirements for conventional vessels. However, the framework has built-in flex-
ibilities for managing the risks of specific vessels under certain circumstances that
might be relied upon in the short term to accommodate UMV trials and operations.
Flexibility mechanisms include:
• general exemptions, which are instruments that set out relevant criteria and con-
ditions for certain vessels, operations, and crew, including three that are particu-
larly relevant to UMVs:
○ Marine Safety (Certificates of Survey) Exemption 2020 (Cth), which exempts

specified categories of vessels from the requirement to hold a certificate of
survey subject to conditions (i.e. non-survey vessel permit);
○ Marine Safety (Certificates of Operation) Exemption 2020 (Cth), which
exempts specified categories of vessels from the requirement to hold a cer-
tificate of operation (e.g. vessels operating in sheltered waters under 7.5 m
that do not carry passengers or dangerous cargo);
○ Marine Safety (Temporary Operations) Exemption 2020 (Cth), which allows
specific temporary operations including trials and operation without a cer-
tificate of survey or operation (i.e. temporary operations permit);
• specific exemptions, which AMSA may grant on a case-by-case basis if AMSA

is “satisfied that the exemption concerned, taken together with the conditions to
which it is subject, will not jeopardise the safety of a vessel or a human onboard
a vessel” (National Law schedule 1, Sect. 143(5)). UMVs frequently require a
13
F. Humphries et al.
Fig. 1 Four key maritime safety frameworks in Australia
specific exemption from the survey and crewing requirements, but applying for
these can be complex and time-consuming for each case and does not offer cer-
tainty for the UMV industry;
• equivalent means of compliance to meet a required outcome of the NSCV if
AMSA is satisfied that it “is at least as effective as any part of the standards
that it replaces” (Marine Order 503 (Certificates of Survey—National Law) 2018
(Cth) Division 4, Sect. 17(2)).
Like the National Law, the Navigation Act framework, which regulates RAVs
and “foreign vessels”, assumes that humans will be onboard the vessel. The Nav-
igation Act gives effect to Australia’s obligations under international agreements.
This means that a UMV would need to comply with relevant Navigation Act and
marine order requirements, including the provisions that implement international
convention requirements, depending in the vessel’s size and class. For example, a
RAV must have a safety certificate for the kind of vessel specified under the SOLAS
or a non-SOLAS certificate,7 which may be subject to conditions and if the survey
requirements are satisfied, the vessel may be certified (Navigation Act Sect. 100).
Foreign vessels are expected to be certified in compliance with relevant interna-
tional conventions.8 Foreign vessels entering Australian ports are subject to the port
state control regime under the guidance of the IMO and two regional memoranda of
7
Marine Order 31 (SOLAS and non-SOLAS) Certification 2019 (Cth) s 7. Schedule 1. Passenger vessels
or cargo vessels greater than 10 m in length must have a non-SOLAS certificate specified in schedule 2.
See regulation 12 of chapter 1 or regulation 10 of chapter VIII of the International Convention for the
Safety of Life at Sea.
8
Memorandum of Understanding on Port State Control for the Indian Ocean Region 1998 article 2.4;
Memorandum of Understanding on Port State Control in the Asia–Pacific Region 1994 article 2.5; see
also relevant conventions e.g. Maritime Labour Convention art V.
13
Fig. 2 Determining whether a vessel is a DCV, RAV, or foreign vessel. Examples are in order of decreas-
ing size. UW, underwater
understanding, which provide guidance on how to meet the provisions of relevant

international conventions.9
There is significant uncertainty regarding the exact requirements that UMVs
need to comply with under the Navigation Act, due to the reference to international
9
Australia is a member of two regional port state control regimes that cover the Asia–Pacific and Indian
Oceans surrounding it, in cooperation with other countries: the Tokyo (Asia–Pacific) Memorandum of
Understanding; Memorandum of Understanding on Port State Control in the Asia–Pacific Region 1994
Memorandum rev18.pdf (tokyo-mou.org); Memorandum of Understanding on Port State Control for the
Indian Ocean Region 1998 https://iea.uoregon.edu/MarineMammals/engine/Documents/2-1036-1064.
html
13
F. Humphries et al.
convention requirements, and there are also fewer flexibilities available than under
the National Law. The flexibility mechanisms available include exemptions and
alternative means of compliance in accordance with some international conventions,
but they are limited by strict parameters and conditions in the international agree-
ments themselves. These difficulties are likely part of the reason why there are cur-
rently no authorised RAVs which are autonomous and remotely operated vessels in
Australian waters (only DCVs operating under the National Law). The following
section outlines the experiences of UMV operators under the National Law regula-
tory pathway.
3 Australian experiences with regulatory pathways: challenges

and opportunities
There is at least a dozen market-ready UMVs operating in a civilian capacity in

Australian waters, but there may be many more that are not the subject of publicly
available information. The Australian Defence Force also operates some of these
vessels (or modified versions of these vessels) and several other vessels. While most
UMVs operating in Australia are small, Table 2 demonstrates that sizes can range
between 160 cm and 24 m. The variety of vessels (by way of size, purpose, depth
and geographical areas) that are operating in Australian jurisdictions illustrates that
regulatory frameworks already have the flexibility to handle diverse subject matter.
This flexibility requires human resources to make informed discretionary decisions
under the National Law. It could be anticipated that this resource-intensive regula-
tory approach risks being swamped with the expected influx of UMVs in Australian
waters. This section highlights the vastly different experiences that AIMS and QUT
had for the same class of vessels in the same geographical area to trial their vessels
in Australian waters from 2020 to 2022. They are useful case studies for illustrating
the complexity of Australia’s regulatory pathway under the National Law.
The vessel structure and software for the submersible “RangerBot” were devel-
oped by QUT Centre for Robotics in Australia as a novel completely vision-based
robotic tool to help monitor and manage various threats on the Great Barrier Reef.
The RangerBot platform is a battery-powered small body (0.75 m × 0.44 m with a
weight of 16 kg), with a range of 6 h at 1-knot speed and self-righting capabilities.
It has rules-based fully autonomous software with machine learning capabilities.
It has “real-time” onboard vision for navigation, obstacle detection, and manage-
ment tasks.10 Australia’s tropical marine research agency, AIMS, purchased some
RangerBots from QUT, which were used as a pre-testing platform for the develop-
ment of the submersible CoralAUV. The CoralAUV was developed in a joint project
that began in 2019 between AIMS and QUT. It has a small body (1.2 m × 0.51 m),
weighs 35 kg, has a range of 4 h at 1knot using electric thrusters, and is self-right-
ing. It has a rules-based fully autonomous software system with vision-based navi-
gation systems, radio communications, and full transparency in decision-making.
10
https://research.qut.edu.au/qcr/Projects/rangerbot/
13
Table 2 Examples of UMVs operating in Australia
UMV Depth Size Operational area Level of autonomy Developer (D) and owner/operator (O)
SEA-KIT Omega class Surface 24 m Offshore Remote and semi-autonomous SEA-KIT International (D)
SEA-KIT X class Surface 12 m Offshore Remote and semi-autonomous SEA-KIT International (D) Fugro (O)
DriX Surface and UW 8 m All areas Remote, semi- and fully autonomous iXBlue (D and O)
Bluebottle Class Surface Up to 6.8 m Ocean Remote and semi-autonomous Ocius (D)
C-Worker 5 ASV Surface 5 m Ocean Remote and fully autonomous L3Harris (D)
WAM-V Surface 5 m Inshore Semi-autonomous QUT (D & O)
Wave glider Surface 3.5 m Ocean Remote and semi-autonomous Liquid Robotics (a subsidiary of Boeing) (D)
Sirius UW 2 m Ocean Remote and semi-autonomous University of Sydney (D&O)
Slocum Gliders UW 1.5 m Ocean Remote controlled Teledyne Webb Research (D) range of partners with
Australia’s Integrated Marine Observing System
(O)
CoralAUV UW 1.2 m Inshore Fully autonomous QUT and AIMS (D) AIMS (O)
RangerBot UW 750 cm Inshore Fully autonomous QUT and AIMS (D) AIMS (O), QUT (O)
Remus 100 UW 160 cm Coastal Remote and semi-autonomous Hydroid (D)
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F. Humphries et al.
AIMS has a research project with multiple partners to develop the next generation
of artificial intelligence for the platform, so that it can make decisions based on its
interpretation of the environment, rather than program input. There is limited lit-
erature available about how to safely handle this “true AI” autonomous decision-
making function. The CoralAUV’s computer has been built to handle the existing
level of autonomy and the “true AI” system but is currently only authorised to use
the lower level of autonomy.
AIMS’ and QUT’s RangerBots and CoralAUV operate within the Great Barrier
Reef Marine Park (GBR) and are subject to a range of authorisation requirements.
These include regulation as a DCV under the National Law and as a research vessel
under the Great Barrier Reef Marine Park framework administered by the Great Bar-
rier Reef Marine Park Authority (GBRMPA).11 If there was no element of autonomy
involved in the operation of the CoralAUV and Rangerbots, they would be treated in
the same way under the National Law because they have a similar size and operate
in the same operational area. However, because of the vessels’ autonomous charac-
teristics, regulators used a combination of temporary operations permits and specific
exemption tools to make decisions about vessel safety and risk. In September 2020,
QUT applied to AMSA and GBRMPA for approval to use the RangerBots in open
water to carry out survey and imaging work in the GBR. GBRMPA issued QUT
with a permit to use the RangerBots for multiple uses (including the crown of thorns
elimination and reef imaging work on the GBR) until 2024. AMSA authorised the
activities to be conducted between 16 September 2020 and 16 December 2020 under
a temporary operations permit and issued a second temporary operations permit for
the period 17 December 2020 to 17 March 2021. In 2021, AMSA advised QUT to
apply for a 5-year specific exemption to continue to operate their vessels. In contrast,
AIMS applied to GBRMPA for a special use permit, initially valid only for the dura-
tion of the trial itself, and to AMSA for a temporary operations permit (90 days) to
trial the RangerBot and the CoralAUV in the GBR. AMSA granted the permit for
trials between 3 July 2020 and 30 September 2020 for the RangerBot and between
24 February 2021 and 24 May 2021 for the CoralAUV. While it did not continue
trials with the RangerBot, AMSA advised AIMS in April 2021 to apply for a 2-year
specific exemption to continue to trial the CoralAUV. Similarly, AIMS sought and
obtained a routine operations permit for the Coral AUV in November 2021 under
AIMS’ overarching GBRMPA general permit (2021–2027).
The first key observation about AIMS’ and QUT’s experiences of the National
Law pathway is that the order of the steps in the application process is somewhat
bespoke and ad hoc. AMSA advised both entities to apply for 90-day temporary
operations permits as a first step for putting their vessels in the water for trials. After
AIMS’ first temporary operations permit for the CoralAUV expired, AMSA advised
it to apply for a 2-year specific exemption to continue trialling the CoralAUV to
build a safety case for another approval for ongoing operations. In contrast, after
QUT’s first temporary operations permit expired, it was advised to make a fresh
11
There is a range of other legislation that applies to their operation in this geographical area, which is
beyond the scope of this article.
13
application for another temporary operation permit to continue operational survey

work by the RangerBot. When the second permit expired, AMSA advised QUT to
apply for a 5-year specific exemption to continue operations apparently in lieu of
a certificate of survey and certificate of operation. Since this advice was received,
AIMS has maintained a holding pattern in lodging a specific exemption as it was
clear that external support was going to be needed to work through the process, and
there were other avenues to conduct approved test and evaluation (tethers or work-
ing with QUT). AIMS expects to submit a specific exemption for the CoralAUV in
2022, seeking a 5-year exemption with guidance from QUT.
There are practical reasons for this bespoke approach for the approval pathway.
First, RangerBots and CoralAUV would not meet the threshold requirements under
the existing maritime framework. Basic risk criteria for traditional vessels such as
fuel type and engine power are not applicable, leading to confusion in how to cat-
egorise a novel platform class. Second, although the vessel size and operational
area may be similar for the RangerBots and CoralAUV, they vary in their software,
behaviour, and level of automation, requiring a case-by-case assessment of their
safety case. For example, the CoralAUV is capable of self-navigating a reef contour,
whereas the RangerBot is designed for simpler missions. Understanding the control
logic assisted AIMS greatly in confidently assessing its safe operation in a complex
reef environment. This level of trust is not available for black-box devices that have
not gone through a rigorous test and evaluation regime (typically, these are associ-
ated with expensive military-grade systems). These commercial/low-rate-production
level autonomous systems are challenging to assure in an operational sense due to
the lack of insight into their control algorithms. A classic example of this was a bug
in the software where the device would return to its home waypoint in China if a
particular mission configuration was run at a particular time. The black box nature
of this device meant AIMS could not predict this behaviour occurring. Unpredict-
ability compromises the trust associated with an autonomous system.
A second key observation about AIMS’ and QUT’s experiences of the National
Law process is the inadequate trial procedures and uncertainty about the end point
of the approval pathway for ongoing operations. Both entities found that 90 days
were too short to test and trial UMV platforms under a temporary operations per-
mit. A more realistic development cycle is 2 years to implement an iterative build-
develop-test approach with field trials. Sea trials typically have several months of
lead time to secure ship, staff, and approvals, and understanding and implementing
the learnings from the trials also take several months. A single test event can take
3 months from mobilisation to implemented lessons learnt. However, the developer
requires certainty that their vessel will be approved throughout their test and evalu-
ation phase, and so they would be targeting approval to conduct test and evalua-
tion across multiple design iterations. Consistency and certainty for the trial phase
are undermined by the current approach because each permit application is assessed
individually by AMSA staff with varying degrees of understanding of AI and
autonomy. Many of the permit conditions for the CoralAUV were not appropriate
for longer-term trials, such as the requirement to beam over the radio “autonomous
systems in progress” every few minutes to alert manned vessels in the area. There
was also a lack of guidance on how to communicate awareness to the general public
13
F. Humphries et al.
which predominantly uses mobile phones in inshore regions. Both AIMS and QUT
required multiple temporary operations permits or a special exemption authorisation
to build data for a safety case for ongoing operations. However, at the time of writ-
ing, there is no publicly available policy position from AMSA about the process for
approving ongoing operations for UMVs. The cumulative cost of time and money
for each application, together with the uncertainty about whether the trials can pro-
ceed beyond the expiry of the permit and what the process might be for approvals
for ongoing operations, has the potential to significantly deter investment in UMV
technologies in Australian waters.
A third key observation about AIMS’ and QUT’s experiences was the ad hoc
nature of information requirements for building a safety case and requirements for
a specific exemption, including safety management systems, for UMV applications.
AIMS and QUT had different levels of operational use and operation experiences.
For every hour of in-water operation, both AIMS and QUT invested many hours on
background systems which are considered proxies for safety cases and approvals.
There are no publicly available guidelines for the testing evidence needed to dem-
onstrate a safety case for the temporary operations and the specific exemption path-
ways. This includes a lack of information about how AMSA would handle safety
requirements that are not applicable in the case of UMVs, for example, minimum
crewing requirements. The current framework also lacks protocols to manage cir-
cumstances that can go wrong with UMVs. For example, if the UMV drifts outside
a certain area or is beyond its tolerances or running low on the battery charge, then
it can be programmed to surface as a safety protocol. The current exemption permit
application requires a fault analysis and effect evaluation; however, the mitigation
is specified by the applicant. There are unique challenges for developing a safety
management plan for UMVs including how to manage the “black box” features of
artificial intelligence systems and conducting enough boundary testing to be assured
that the platform’s behaviour will be predictable in similar conditions. Control logic
typically has some form of heuristics/rules-based overlay. It is impossible to be cer-
tain that the platform does not have any unanticipated actions without the visibility
of the ruleset. For example, if an internal sensor fails and goes outside its tolerance,
this could trigger a unique behaviour mode. Without the awareness that this linkage
existed, it is unlikely that a real-world test case would trigger this behaviour mode.
These “black boxes” range in their levels of visibility of machine decision-making.
Opaque systems may result in unexpected behaviour when a vessel may attempt to
automatically return to the country of manufacture as a default safety cut-off. Often,
the regulator (and sometimes operators) would not have access to visibility for com-
mercial and intellectual property reasons, which poses problems for developing a
transparent safety case that may meet a regulator’s standards for a safety manage-
ment system. The lack of strategic guidance for a UMV test and evaluation frame-
work and safety management plans may undermine the safety objectives of the leg-
islation framework and increase approval timeframes and costs for the industry to
build a safety case.
A fourth key observation about AIMS’ and QUT’s experiences was the blur-
ring of government responsibilities for UMV safety approvals. Both obtained a
permit from GBRMPA to operate their platforms in the GBR, which required
13
information about risk management and safety management systems. The

GBRMPA approval process—focused more on environmental risks to the GBR—
is distinct from AMSA’s process. In AIMS’ and QUT’s experience, there was no
evidence that the two regulators worked together. GBRMPA took the lead in pre-
scribing terms and conditions for trials and operations in the GBR, which AIMS
and QUT shared with AMSA and were largely adopted for their approvals under
the National Law. As the autonomous systems knowledge base grew, the terms
and conditions became more consistent. There are broader regulatory factors at
the federal, state, local, and community levels that impact on whether a UMV
platform will gain approval to operate in Australian waters. These factors include
the proposed use of platforms in First Nations people’s sea country for which
there seem to be ad hoc processes or guidance for consultation with traditional
owners in the permitting process. While analysis of these other regulatory fac-
tors is beyond the current scope, they emphasise the importance of coordination
between regulators in their approaches to new UMV technologies.
The experiences of AIMS and QUT offer valuable insights for Australia’s
approach to maritime governance and approval pathways. Overall, while Australia’s
National Law has built-in flexibilities for managing new technologies under bespoke
approval pathways, this approach is not sustainable for regulators and the industry
long-term. The human resources necessary for regulators and industry to understand
the information requirements for building a safety case places significant cost in
time and funding on regulators and developers to work through risk and compliance
issues on a case-by-case basis. The ad hoc approach creates uncertainty for indus-
try development and reduces the transparency necessary for trust between govern-
ment, industry, and other stakeholders affected by UMVs in shared waters. As with
the approach taken for conventional vessels, the end goal is to have sufficient trust
that UMV systems will uphold the safety standards commensurate with the risk and
move towards an assurance model where third parties certify compliance with these
standards. Even if there is a consistent assurance process for UMVs, the flexibilities
(case-by-case approvals) will continue to accommodate unique cases or high auton-
omy levels, until sufficient trust is established. An important lesson is that if there
had been coordination and cooperation between different regulators as suggested
in Sect. 5 below that drew more systematically from the past experiences of UMV
developers, then the process might have been less ad hoc, focused, and streamlined
in the case of the RangerBots and CoralAUV.
4 Compliance with maritime safety requirements

at the international, national and industry levels
The literature on regulatory barriers for UMV trials and operations has grown expo-
nentially over the past 10 years (Ziajka-Poznańska and Montewka 2021). Numerous
industry and government-funded projects, bringing together many maritime stake-
holders, are exploring the regulatory, technological, social, and economic factors
13
F. Humphries et al.
relevant to accommodating UMVs.12 There are a range of threshold questions to

determine whether international agreements apply to UMVs. Generally, the relevant
international maritime agreements disconnect the definition of a “ship” or “vessel”
from the question of whether it is crewed (Ringbom and Veal 2017). There remain
significant challenges, however, in the definitional, technical, and operational provi-
sions of international and national frameworks for accommodating UMVs. There
are a range of issues that regulators and stakeholders are grappling with. These
range from worldwide jurisdictional, insurance, and cybersecurity issues that affect
the maritime industry at a macro level (Ringbom et al. 2021), to issues at a micro-
practical level such as the need for flag states to issue digital certificates and docu-
ments instead of requiring physical documents to be kept onboard (IMO 2018).
The analysis below focuses on some of the challenges that UMV developers face
for trialling and developing a safety case for the use of their vessels in Australian
waters under current maritime frameworks. These challenges are grouped into two
themes, namely how the international and national frameworks manage: (1) obliga-
tions for humans onboard a vessel and (2) technical requirements. Drawing from the
experiences of trialling the CoralAUV and RangerBot vessels in Australian waters,
this section provides insights into the challenges that UMV developers and operators
face for compliance of these requirements.
4.1 Obligations concerning humans onboard a vessel
Modern international maritime agreements were concluded during the twentieth

century with the assumption that humans (master, crew, pilots, etc.) will be onboard
and assume various rights and responsibilities for operating the vessel. The rise
of UMVs raises questions about which international conventions apply to UMVs,
which is the subject of ongoing debate13 and not in the scope of this paper. It also
raises the question of who assumes responsibility and liability in the case of UMVs
(remote operator, computer programmer, vessel owner, etc.). Under UNCLOS,
assuming it applies in a given case, all ships must be “in the charge of a master
and officers who possess appropriate qualifications” (article 94(4)(b)). The obliga-
tion does not specify that the person in charge is present on board the vessel, so
autonomy levels 1–3 might comply (see Table 1), but level 4 full autonomy possibly
would not. However, various international agreements such as SOLAS, MARPOL,
and STCW (and the Navigation Act that implements them in Australia) presuppose
that there is a master onboard (IMO 2018). There are many other specific obliga-
tions relating to various seafarers being physically onboard such as the requirement
12
E.g., Advanced Autonomous Waterborne Applications Initiative (AAWA) (2016), remote and autono-
mous ships; the next steps, AAWA position paper, https://www.rolls-royce.com/~/media/Files/R/Rolls-
Royce/documents/customers/marine/ship-intel/aawa-whitepaper-210616.pdf; advanced, efficient, and
green intermodal systems (AEGIS) to design Europe’s next generation waterborne logistics systems and
autonomous vessels https://aegis.autonomous-ship.org/
13
For example, note that whether UNCLOS applies to a UMV will depend on whether its legal status is
“ship” or alternatively “devices” or “equipment”, or something else, which is dependent on the policy of
the flag state (Veal et al. 2019).
13
that the officer of the watch is “physically present on the navigating bridge or in
a directly associated location such as the chartroom or bridge control room at all
times”.14 While these obligations might be barriers to compliance by UMVs,15 other
obligations have scope for broader interpretations. For example, the obligation to
render assistance to persons in distress at sea could arguably partially be carried
out by a UMV if it is capable to render assistance through electronic lookout or
towing.16
Under Australia’s maritime framework, many regulatory requirements presup-
pose master and crew will be on board a vessel. The definitions of crew refer to the
crew being on board the vessel,17 whereas definitions of a “master” (the “person who
has command or charge of a vessel”18) and “pilot” (“a person who does not belong
to, but has the conduct of, a vessel”19) are not as narrowly defined. However, more
detailed obligations may assume people are on board. For example, to have legal and
internationally recognised nationality of a vessel and protection on the high seas and
in foreign ports, a ship must be registered on the Australian International Shipping
Register or the General Shipping Register or be exempt from registration. This poses
challenges for UMVs because several conditions for registration on the International
Register under the Shipping Registration Act 1981 (Cth) require masters and seafar-
ers to be on board the vessel. For example, requiring that:
• an Australian national or resident is a master and chief engineer onboard

(Sect. 33A);
• a compulsory work agreement between the owner/operator and seafarers onboard
a ship (Sect. 11A and 15F(3)(b)); and
• compulsory compensation insurance to protect human life onboard
(Sect. 61AM(1)).
There do not appear to be similar limitations for the General Register, which may
cause confusion and inconsistency in the case of UMVs.
International obligations concerning the standards of training, certification, and
employment for seafarers often centre around the definition and location of “seafar-
ers”, which may be problematic for some automation levels of UMV. For example,
14
STCW, chapter VIII, regulation 2(2)(1); see also SOLAS chapter V regulation 15.
15
Under SOLAS, national maritime authorities have the ability to prescribe exemptions and equivalence
standards concerning chapter 5 if their introduction is not unreasonable or unnecessary: SOLAS chapter
V regulation 3(2).
16
UNCLOS, article 98(1), SOLAS article 10(a); International Convention on Salvage, 28 April 1989,
ATS 1998 No 2, article 10(1); see Chircop 2015).
17
“crew of a vessel means individuals employed or engaged in any capacity on board the vessel on the
business of the vessel, other than the master of the vessel or a pilot”; Navigation Act 2012 (Cth) s 3(1);
Marine Safety (Domestic Commercial Vessel) National Law Act 2012 (Cth) schedule 1, part 1, division 1,
s 6. The Shipping Registration Act 1981 (Cth) has a similar definition for “seafarer” s 3(1).
18
Navigation Act 2012 (Cth) s 3(1); Marine Safety (Domestic Commercial Vessel) National Law Act
2012 (Cth) schedule 1, part 1, division 1, s 6; Shipping Registration Act 1981 (Cth) s 3(1).
19
Navigation Act 2012 (Cth) s 3(1); Marine Safety (Domestic Commercial Vessel) National Law Act
2012 (Cth) schedule 1, part 1, division 1, s 6; Shipping Registration Act 1981 (Cth) s 3(1).
13
F. Humphries et al.
the STCW only applies to “seafarers serving onboard seagoing ships entitled to
fly the flag of a Party” (article 3) and does not extend to remote operators (Naw-
rot and Pepłowska-Dąbrowska 2019). An extensive literature review has revealed
an absence of a training framework for operators of autonomous vessels and uncer-
tainty about the equipment that will be needed for training (Emad et al. 2021). The
MLC, as a framework for seafarers’ employment rights and conditions, applies to
seafarers defined as “any person who is employed or engaged or works in any capac-
ity on board a ship to which this Convention applies” (article 2(2)). However, the
treaty provides that the competent authority of a member state has the authority to
determine whether any categories of persons are to be regarded as seafarers for the
purpose of the MLC if there is any doubt (article 2(2)), arguably providing flex-
ibility to include remote operators of UMVs. These obligations may be interpreted
and applied under National Law in a way that imposes conditions on UMVs that are
difficult or impossible to comply with and which could create a discrepancy between
different nations (Karlis 2018). For example, under Australia’s Navigation Act, it
is an offence to take a RAV to sea without a maritime labour certificate concern-
ing the living and working conditions of seafarers with requirements for the mini-
mum number of seafarers on vessels, food, water, and accommodation among others
(part 5). A UMV operator could seek exemption from some accommodation and
food requirements, but AMSA does not have the power to exempt the requirement
for a maritime labour certificate.20 Australia’s National Law is more flexible when it
comes to labour certificate requirements21 so that the operator of domestic commer-
cial UMV may apply for a specific exemption from relevant requirements.
4.2 Obligations related to technical requirements
Different levels of autonomy have implications for many of the existing rules and
standards applying structural and technical requirements, including regarding soft-
ware, to vessels. This section outlines two examples of the technical requirements
that apply under international agreements and Australia’s maritime laws with rel-
evance for the case studies—technical requirements for navigation and firefighting
purposes under COLREGs and SOLAS.
A fundamental principle of COLREGs is “that ships are controlled by human
beings and that navigational decisions are based on a seamanlike assessment of
the specific situation”, (regulations 5, 6, and 8; IMO 2018)such as in situations of
responsibility, lookout, safe speed, and precautions to avoid collisions. Many obli-
gations imply human cognitive judgment that is not defined but rather is based on
seafarer practice acquired through years of navigational experience, such as the prin-
ciple of prudent seamanship in assessing a “proper” lookout, a “safe” speed accord-
ing to the circumstances or other discretionary benchmarks in COLREGs (Achnioti
2021; Stevens 2020). As the obligations relate to vessels rather than the seafarers
20
Marine Order 11 (living and working conditions on vessels) 2015 (Cth) ss 7, 39, 41, 51, 54, 58, 60.
21
See Marine Order 11 (living and working conditions on vessels) 2015.
13
per se, one interpretation is that they are capable of application to a remotely oper-
ated UMV (Nawrot and Pepłowska-Dąbrowska 2019) who controls the vessel but is
perhaps difficult to apply to fully automated vessels (level 4) due to the obligations
requiring human cognitive judgement.
Various obligations under SOLAS and associated codes for a fire emergency and
evacuation preparedness are unsuitable for UMVs. For example, requiring the out-
put signal for fire detection to the navigation bridge, continuously monitored cen-
tral control station or onboard safety centre, and requirements that the main control
station for the fixed deck foam system must be located adjacent to the accommo-
dation spaces.22 Other challenges under SOLAS include the many obligations for
firefighting that require manual operations such as the capability to apply manual
extinguishers and systems; the immediate replacement of discharged extinguishers;
manual requirements for ventilation, detection of gas and other fumes, and cooling
systems; requirements for supervision or patrols by personnel for early detection of
hazards; drill procedures and means of escape; and the list goes on (Shiokari and
Ota 2019). There is an exemption clause under SOLAS for ships “which embodies
features of a novel kind” for various requirements if compliance with which might
“seriously impede research into the development of such features and their incorpo-
ration in ships engaged on international voyages” (chapter 1 part A, regulation 4(b)).
It is likely that this exemption clause will need to be used to more fully support the
operation of regulated Australian vessels in compliance with SOLAS.
In the Australian domestic context, DCVs must comply with the National Stand-
ard for Commercial Vessels, being a technical standard covering vessel survey, con-
struction, equipment, design, operation, and crew competencies. It was written with
conventional vessels in mind and does not provide requirements tailored to UMVs.
At the time of the case studies, UMV operators did not have access to tailored Aus-
tralian technical requirements, which increased the difficulty and complexity of
achieving compliance with technical requirements. However, in May 2022, Trusted
Autonomous Systems released the Australian Code of Practice for the Design, Con-
struction, Survey, and Operation of Autonomous and Remotely Operated Vessels
(“Australian Code of Practice”) which is intended to fill that gap.23 As elaborated
in Sect. 5, this Australian Code of Practice provides an Australian-centric voluntary
technical standard for operators to use as a benchmark of good practice and to sup-
port applications to AMSA for approvals (Horne 2022a).
4.3 Case study observations and learnings
The National Law covers a suite of mandatory risk controls for crewed vessels but
the risks informing these controls are not necessarily relevant to UMVs. For exam-
ple, there is no need to have requirements such as minimum crewing, manual fire
22
International code for fire safety systems chapter 9, paragraph 2.1.2.2, and chapter 14 paragraph 2.3.1;
Shiokari and Ota 2019.
23
The Australian Code of Practice is available to download here: https://tasdcrc.com.au/code-of-pract
ice-autonomous-vessels/#download.
13
F. Humphries et al.
extinguishing, and other requirements like minimum drinking water onboard. Man-
datory safety features for humans onboard such as life rafts and life jackets are non-
sensical for uncrewed vessels. As was seen in the experiences of AIMS and QUT,
the lack of a regulatory framework for UMVs means the developer/operator must
demonstrate to AMSA that the UMV is safe (the equivalent of a survey), that the
mission is sound (the equivalent of a certificate of operation), that the operator is
competent and authorised to perform the mission (the equivalent of a licensing
structure), and that the AI is trusted enough to perform the mission predictively
(through a demonstrated body of evidence, or through controls to manage uncer-
tainty). The industry is in a state of evolution and so each developer/operator has
their own way of building arguments to address these criteria. For new autonomous
system concepts and prototype vessel classes, this body of evidence does not exist.
Therefore, the risk is managed through a combination of test-environment/test-range
controls, mission constraints/controls, onboard safety features such as kill switches,
and a layered safety management system for each component. This leads to a first
principles assessment of autonomous systems conducting an operation in a target
environment, which arguably is a safer approach than trying to certify an autono-
mous vessel against a legacy safety management framework not designed for it (such
as the National Law).
After reviewing the National Law and having preliminary conversations with
AMSA, AIMS and QUT identified that the temporary operations approach24 was
appropriate. AIMS took a high-level approach to justify that its small UMV tri-
als were safe, and therefore, a temporary operations permit was appropriate. The
National Law requirements were antithetical to the objectives, construction, and risk
profile of small UMVs. AIMS conducted an assessment against the risks to the envi-
ronment, to the vessel, to the deploying ship/personnel, and to other marine users.
Controls were put in place to mitigate identified risks, and these controls formed
the basis of the temporary operations permit application. By taking this approach,
AIMS was able to focus on key risks associated with UMVs (such as lithium battery
incidents). These do not necessarily track to the key risks associated with conven-
tional crewed vessels, upon which the national law was formulated (such as the risk
to humans from capsizing). The articulation of the specific risks and controls for
the planned operation of the UMV coupled with demonstrated evidence of AIMS’
experience in marine operations was sufficient for AMSA to authorise the temporary
operations permit for the small UMVs in a controlled at-sea environment. This out-
come was sufficient to meet AIMS’ immediate needs but did not provide a pathway
for the ongoing use of the vessels.
QUT took a similar high-level approach focused on addressing risks to the envi-
ronment, the vessel, and other immediate marine users. Having similar controls to
AIMS and specific fault behaviours mapped to mitigate environmental and opera-
tional risk for the temporary operations permit QUT also emphasised the operational
24
“Temporary operations approach” refers to seeking a temporary operating permit under Marine safety
(Temporary operations) Exemption 2019, which enables a domestic commercial vessel to operate for a
specified period without certification (see Sect. 3 above).
13
context in terms of the small size low kinetic energy thresholds and the construction
material of RangerBot as posing low environmental and operational risks.
One of the more concerning realisations that emerged from AIM’S and QUT’s
approval process under the national law was that risks unique to autonomous sys-
tems were not covered. These risks are some of the most dangerous (highest likeli-
hood, highest probability) and if a gap analysis against the National Law approach is
conducted, they are not considered in the approval process. As an example, autono-
mous systems typically have high-density power systems onboard. This has a suite
of controls needed in order to safely manage to prevent injury to the deploying and
maintenance crew. Recharging these battery systems must be done in a controlled,
safe environment to minimise the risk of combustion, and cybersecurity considera-
tions are essential for command and control and maintaining the integrity of the ves-
sel’s artificial intelligence-driven decision-making. Mechanisms for identifying and
recovering from faults typically corrected by the crew in crewed vessels must also
be established to maintain vessel reliability throughout its planned mission. Main-
taining the integrity of telemetry recordings for post-mission analysis in the event
of an incident in riskier missions is another area that may be critical in regulating
autonomous platforms in higher-risk environments (such as near oil and gas plat-
forms). The context and intent of autonomous systems differ significantly to that of
crewed vessels and so an approach to regulation based on the risk profile of autono-
mous systems is essential if they are to be effectively and safely regulated.
4.4 An “intent‑based” flexible and collaborative approach to maritime

governance and regulation
In response to the rapid technological developments of UMVs, international organi-

sations, regulators, and other relevant entities have begun to develop guidance docu-
ments for compliance with existing regulations and proposals for reform to maritime
compliance regimes to ensure the use of UMVs are as safe as conventional vessels.
In 2021, the IMO finalised a regulatory scoping exercise on MASS to assess how
existing IMO instruments (including COLREG, SOLAS, and STCW) might apply to
ships with various levels of automation. It identified a range of high-priority issues
to address, including developing common MASS terminology and definitions (e.g.
master, crew, responsible person) and gaps in functional and operational require-
ments concerning remote control stations and remote operators as seafarers (IMO
2021 paras 5.4–5.8). The IMO also recommended the development of a goal-based
MASS instrument e.g. a code for completion in 2025 including functional require-
ments and corresponding regulations for different autonomy levels (IMO 2021 paras
6.2–6.3). In the meantime, the Maritime Safety Committee of the IMO approved
Interim Guidelines for MASS trials in 2019 which provide guidance on how UMVs
can comply with international obligation rather than creating flexibility for imple-
menting them. Under the guidelines, “trials should be conducted in a manner that
provides at least the same degree of safety, security and protection of the environ-
ment as provided by the relevant instruments” (IMO 2019 Sect. 2).
13
F. Humphries et al.
There are several Australian proposals which will support the use of domestic
UMVs in the interim until convention-level and legislative-level amendments are
made. The primary development is the publication of the Australian Code of Prac-
tice, with the COLREGs Operator Guidance Framework as an annex. The code
provides an Australian-centric voluntary technical standard for operators to use as
a benchmark of good practice and to support applications to AMSA for approvals
(Horne 2022a), and the Framework helps unlock COLREG compliance. There is
also an Independent Review of Domestic Commercial Vessel Safety Legislation and
Costs and charging arrangements underway, which may lead to recommendations
for legislative change to better accommodate emerging technology.25 The GBRMPA
is also in the process of developing an internal policy related to the management of
autonomous systems. These are positive indicators of Australian support for the use
of UMVs and should enable more efficient regulatory process to the extent possible
until there are more substantive reforms.
4.5 Technological challenges and an “intent‑based” approach
The case study experience demonstrated that (at least in 2021), AMSA appeared
to lack applied expertise in AI or automation-specific technical know-how. Specific
safety controls imposed without this technical knowledge may not be practically
viable. The approach of issuing 90-day temporary operations permits fell short of
the minimum 2-year development cycle for an iterative-develop-test-trials approach.
The ad hoc specific exemptions did not provide a pathway for the ongoing use of
the vessels. From a substantive compliance perspective, there were several examples
where national and international frameworks were unable to accommodate UMVs,
including the absence of humans onboard the vessel. The design and operational
parameters of UMVs can differ significantly to conventional vessels requiring an
approach to regulation based on the risk profile of autonomous systems.
Taking an “intent”-based approach to understanding and complying with legal
requirements will likely be required to facilitate the use of UMVs until convention-
level and then legislation-level change occurs. An example of this approach is the
COLREGs Operator Guidance Framework developed in Australia in collaboration
between Trusted Autonomous Systems and Frazer-Nash Consultancy.26 This frame-
work translates the COLREG rules into their “essence” in a way that makes sense
for UMVs, sets out the capabilities required to comply with the rule, and helps oper-
ators identify in which circumstances specific rules arise (Horne 2022b). This ena-
bling approach is likely to be attractive to operators and regulators alike and would
arguably enable compliance for a broader range of operations.
25
Further information is available here: https://www.infrastructure.gov.au/infrastructure-transport-vehic
les/maritime/independent-review-domestic-commercial-vessel-safety-legislation-and-costs-and-charging-
arrangements
26
The COLREGs Operator Guidance Framework is available to download here: https://tasdcrc.com.au/
code-of-practice-autonomous-vessels/#download
13
4.6 Informational challenges and a flexible approach
The case study experience demonstrated that the UMV operators/developers are also
developing the safety management systems and risk and evaluation frameworks that
the regulators use to regulate them. In effect, the “regulated’” is setting the rules for
their regulation because decision-makers are unclear about what the endgame is and
how to get there. At the same time, there was no evidence that information about the
unique experiences of UMV progress through the regulation pathways was retained
for current and future decisions.
While the experiences of AIMS and QUT highlighted some of the negatives associ-
ated with a bespoke and ad hoc approach to UMV regulation, the flexibility afforded by
Australia’s maritime frameworks can be an effective regulatory tool until more infor-
mation about the needs of industry and regulators is known. The industry needs clear
information about the opportunities and challenges for choosing different regulatory
paths. For example, Australia’s National Law is more flexible when it comes to gen-
eral and specific exemptions and equivalent means of compliance. However, the “opt-
in” provisions under the Navigation Act may be significant for developers/operators of
UMVs which may not be suitable under the National Law. UMVs that fall under the
scope of the Navigation Act need not spend any time outside Australia’s EEZ as the
requirements apply to vessels operating both within and outside Australia’s jurisdiction.
However, it offers developers/operators of UMV the flexibility of trialling or operating
the vessels beyond Australia’s national jurisdiction if desired. Furthermore, some small
UMVs that operate directly off a mothership (which is a RAV or foreign vessel under
the Navigation Act) may be considered “ships equipment” and therefore not be subject
to legislative requirements independent to the primary ship (which will include them in
their safety management systems and survey) (McLaughlin 2011).
4.7 Organisational challenges and a collaborative approach
The case study experience demonstrated that the regulatory challenges are much larger
than determining a pathway through the National Law and instead require a whole-of-
government approach to empower staff from AMSA, GBRMPA, and other relevant
state agencies to understand how UMV works and what is required for building a con-
sistent approval/accreditation system. There are other authorisations that need to be
taken into account, including the proposed use of UMVs in Australia’s First Nations
peoples’ Sea Country, for which there are no protocols or guidance for consultation as
part of the permitting process. The expected influx of UMV applications will test the
cohesiveness of Australia’s national maritime safety regime. Although not within the
scope of this paper, the interrelationship between air, sea, and land domains within their
safety management frameworks and operational activities is a key driver for a whole-
of-government approach built on cooperation and transparency of decision-making and
information, which is currently lacking in Australia. Cooperation requires the genuine
inclusion of all relevant stakeholders in the maritime framework including government,
industry, First Nations peoples, surveyors, and so on in the development of the broader
UMV maritime frameworks.
13
F. Humphries et al.
This cooperative approach extends to the international context. For some aspects of
the navigational framework, for example, it might be possible to achieve international
agreement on broader interpretations of existing requirements, such as an agreement that
competence levels could be met if a human in real time is making decisions and remotely
controlling the ship (IMO 2019). However, in many cases, international agreements will
require an amendment to better accommodate various levels of autonomy. For example,
the technical requirements for electronic lookout and communication, including redun-
dancy requirements (e.g. COLREGs, SOLAS)27or procedures for changing navigational
obligations when changing between levels of autonomy. Given that accommodation of
the special characteristics of UMVs in the international framework will take time, there
is likely to be a lag between the development of trusted automated technologies and
appropriate international regulation (Liu 2019). National governments need to consider
whether forging ahead with their own UMV frameworks will cause inconsistency with
international obligations as the IMO suggests (IMO 2018), or whether national govern-
ments need to adopt their own positions on UMVs to inform and shape international law.
In the meantime, UMV developers and operations need the scope to trial their vessels
and build a safety case that can cooperatively feed into legislative and policy develop-
ments as the case studies demonstrated.
5 Conclusion
The regulatory experiences of AIMS and QUT in ensuring that CoralAUV and
RangerBot were approved for trials and operation revealed the strengths and
weaknesses of Australia’s maritime framework. The strength of the National Law
is that it did, eventually, allow for bespoke approvals. However, it highlighted
how disruptive, at a fundamental level, UMVs are to maritime regulation and
processes. The Australian maritime framework that is enacted and informed by
international maritime treaties and agreements is predicated on the paradigm
of a crewed conventional vessel, that is a vessel that has humans onboard, and
that those humans are responsible for key roles in the operation, navigation, and
safety. The bulk of the obligations under maritime frameworks concern humans
onboard and the technical specifications for vessels to safely provide for onboard
humans. UMVs, especially the small UMVs developed and deployed by AIMS
and QUT, are antithetical to the foundational paradigm. While UMVs can have
humans onboard and resemble conventional vessels that meet existing obliga-
tions, that is not the trajectory of development. UMV strategic advantage lies in
size, build cost, and costs and energy consumption to operate compared with con-
ventional vessels.
27
For example, traditional requirements for a physical navigation bridge instead of an electronic bridge
poses a significant barrier for UMVs, such as the SOLAS requirement for two independent means of
communication between the navigation bridge and the engine room (SOLAS chapter II-1, regulation 37);
IMO 2018 p. 20).
13
International and domestic maritime frameworks need to reckon with UMVs.

The Australian case studies highlight, not only the limitations of legacy mari-
time frameworks, but also the need for an intent-based flexible and collabora-
tive approach of regulators and developers/operators working together. The ad
hoc reliance on bespoke exemptions, while not a long-term solution, is effective
in building information flows between regulators and the UMV actors. This, as
seen in the case studies, can be two ways. Firstly, regulators can increase their
knowledge of the actualities of automation in the sector, and secondly, developers/
operators, who are often located outside of the conventional shipbuilding industry,
can engage with the safety concerns and priorities of regulators. This process can
lead to a more adapted and informed approach to UMVs, as can be seen in some
of the recent Australian developments such as the Australian Code of Practice.
These ground-up reforms can be seen as parallel to formal UMV-related reform
processes at the IMO. What could be seen is a dialectical approach whereby mari-
time nations pragmatically work through the risks, standards, and processes that
balance safety with facilitating local UMV industries; in turn, this creates a body
of knowledge to inform international reform processes. This means that the experi-
ences of navigating regulatory pathways by actors such as AIMS and QUT for the
trialling and deployment of small UMVs such as CoralAUV and RangerBot are
not marginal. Rather, further studies and reflection on the regulatory journeys of
UMV pioneers are essential for the facilitation of a safer, more efficient, and more
effective maritime industries that leverage the potential benefits of automation.
Funding Part of this work was funded by the Queensland Government Australia and the Trusted Autono-
mous Systems Defence CRC (TASDCRC) under the Advance Queensland Initiative for the project “Ena-
bling Agile Assurance of Drones in Queensland”.
Data Availability There is no raw data to share as the findings relate to the experiences of two of the
authors.
Declarations
Conflict of interest The authors declare no competing interests.
Open Access This article is licensed under a Creative Commons Attribution 4.0 International License,
which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as
you give appropriate credit to the original author(s) and the source, provide a link to the Creative Com-
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are included in the article’s Creative Commons licence, unless indicated otherwise in a credit line to the
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not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission
directly from the copyright holder. To view a copy of this licence, visit http://creativecommons.org/licen
ses/by/4.0/.
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Authors and Affiliations
Fran Humphries1 · Rachel Horne1,2 · Melanie Olsen3 ·

Matthew Dunbabin4 · Kieran Tranter1,2
1
School of Law, Queensland University of Technology, Brisbane, Australia
2
Trusted Autonomous Systems (TAS), Brisbane, Australia
3
ReefWorks, Australian Institute of Marine Science, Townsville, Australia
4
School of Electrical Engineering and Robotics, Queensland University of Technology, Brisbane,
Australia
13

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WMU Journal of Maritime Affairs

Uncrewed autonomous marine vessels test the limits

Fran Humphries1 · Rachel Horne1,2 · Melanie Olsen3 ·

Received: 4 July 2022 / Accepted: 24 November 2022

Keywords Maritime safety · Uncrewed autonomous · Marine vessels · Australia ·

• autonomous underwater vehicle (AUV), which is a submersible system with its

The International Maritime Organization (IMO) has acknowledged that “the

Table 1 Levels of autonomy (adapted from IMO 2021 para 3.4)

to humans onboard and technical requirements. The challenges in each of these

2 Maritime law and UMVs

In Australian waters, there are a range of international conventions, Commonwealth

• United Nations Convention on the Law of the Sea (UNCLOS);

Australia is a federation of states with three levels of government—Common-

○ Marine Safety (Certificates of Survey) Exemption 2020 (Cth), which exempts

• specific exemptions, which AMSA may grant on a case-by-case basis if AMSA

Fig. 1 Four key maritime safety frameworks in Australia

understanding, which provide guidance on how to meet the provisions of relevant

3 Australian experiences with regulatory pathways: challenges

There is at least a dozen market-ready UMVs operating in a civilian capacity in

application for another temporary operation permit to continue operational survey

information about risk management and safety management systems. The

4 Compliance with maritime safety requirements

relevant to accommodating UMVs.12 There are a range of threshold questions to

4.1 Obligations concerning humans onboard a vessel

Modern international maritime agreements were concluded during the twentieth

• an Australian national or resident is a master and chief engineer onboard

4.2 Obligations related to technical requirements

4.3 Case study observations and learnings

4.4 An “intent‑based” flexible and collaborative approach to maritime

In response to the rapid technological developments of UMVs, international organi-

4.5 Technological challenges and an “intent‑based” approach

4.6 Informational challenges and a flexible approach

4.7 Organisational challenges and a collaborative approach

International and domestic maritime frameworks need to reckon with UMVs.

Authors and Affiliations

Fran Humphries1 · Rachel Horne1,2 · Melanie Olsen3 ·

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Table 1 Levels of autonomy (adapted from IMO 2021 para 3.4)

2 Maritime law and UMVs

Fig. 1 Four key maritime safety frameworks in Australia

3 Australian experiences with regulatory pathways: challenges

4 Compliance with maritime safety requirements

4.1 Obligations concerning humans onboard a vessel

4.2 Obligations related to technical requirements

4.3 Case study observations and learnings

4.4 An “intent‑based” flexible and collaborative approach to maritime

4.5 Technological challenges and an “intent‑based” approach

4.6 Informational challenges and a flexible approach

4.7 Organisational challenges and a collaborative approach