IBIA believes full Well-to-Wake lifecycle emissions should be taken into account to ensure the IMO’s greenhouse gas policy is holistic, and continued efforts to decarbonise shipping doesn’t end up causing increased overall GHG emissions.

At its 78th session, the Marine Environment Protection Committee (MEPC 78, 6-10 June) held a truncated discussion on this complex subject due to time constraints.

Rather than having a full consideration of proposals, MEPC 78 agreed instead to establish a correspondence group on marine fuel lifecycle GHG analysis to further the work. The correspondence group will submit an interim report to MEPC 79, and final draft guidelines to be adopted by MEPC 80.

The majority view at the IMO is that the LCA guidelines will allow for a Well-to-Wake calculation, including Well-to-Tank and Tank-to-Wake emission factors, of total GHG emissions related to the production and use of alternative marine fuels.

Discussions also include which type of GHGs to be calculated (e.g. not just CO2 but possibly also methane, nitrous oxide, black carbon) and whether to include 20-year global warming potential (GWP) as well as 100-year GWP for each type of fuel and its GHG emissions for comparison purposes.

At present, IMO regulations only deal with Tank-to-Wake emissions from ships.

Apart from the complexity surrounding the LCA guidelines, in particular how to certify the Well-to-Tank part of emissions, the big question is how such LCA guidelines are eventually incorporated into IMO regulations.

The correspondence group has been asked to further develop the draft guidelines on lifecycle GHG intensity of marine fuels (draft LCA guidelines), and in doing so:

– Identify main initial fuel production pathways and feedstocks for inclusion
– Further consider sustainability criteria issues and further develop the Fuel Lifecycle Label (FLL)
– Develop methodologies that allow for the calculation of Well-to-Tank, Tank-to-Wake and entire Well-to-Wake GHG emissions default values
– Develop procedures that allow for continuous review of GHG emissions default values
– Develop guidance for third-party verification and certification schemes