Briefing: IMO MEPC ISWG-GHG 11

Background:
The 11th meeting of the Inter-sessional Working Group on the Reduction of GHG Emission from Ships (ISWG-GHG 11) was held from the 14th to the 18th of March 2022. There have typically been one or two ISWG-GHG meetings held in between the full Marine Environmental Protection Committee meetings, the next one, MEPC 78, is scheduled for 6-10 June this year.

Because of the limited time to debate technical issues at the full MEPC meeting, these Working Group meetings have been instrumental in resent years to debate and find majority consensus on a number of controversial issues over the past few years, keeping the MEPC roughly on schedule. In recent meetings the MEPC has generally endorsed and formalized the recommendations from this Working Group, so we consider it a forecast of where the MEPC may be headed in future meetings

Summary:
The main effort of the Working Group at this virtual meeting was to consider the Life Cycle Assessment Guidelines, which is the process by which the CO2 equivalent content of any fuel is to be established on a WtW (well-to-wake basis), which is a combination of the WtT (well-to-tank) and the TtW (tank-to-wake) GHG emissions. Currently all IMO GHG regulations (EEDI, EEXI, and CII) only include fossil fuels and the TtW fuel factors.

Although LCA Guidelines are to be crafted to be neutral without a specific use of regulation in mind, it is generally recognized that they would likely become the basis for the assessment for any current and future fuels, including bio-, e- and fossil-based fuels for all IMO GHG regulations, potentially including updates to the current EEDI, EEXI and CII, as well as future long-term GHG measures.

The positions of the national delegations are still somewhat divergent and perhaps the most important achievement of this ISWG-GHG session was to establish terms of reference for a correspondence group that will be tasked to define in some detail the LCA methodology. Although urgency on this development was stressed throughout the meetings, there is significant resistance on the part of some countries, while the US, EU and the Pacific islands are trying to press the issue forward.

Note that, even without agreement, ISWG-GHG 11/2/3 Annex 1 already includes, for the first time, suggested default Well-to-Tank factors [gCO2eq/MJ] for most fossil fuels, biofuels, carbon capture, as well as alternate production pathways for Methane, Methanol, Hydrogen, and Ammonia (corresponding to Green, Blue, Black production). Also included are extension of the current Tank-to-Wake factors [g CO2/g Fuel] for fossil fuels, to include these alternative fuels.

Recommendations:
While these fuel factors will be subject to adjustments as the process of definition and approval of the guidelines is taken forward and can be taken as currently representing default conservative values for Well-to-Wake fuel evaluations. These factors will, for the first time, enable the consideration of biofuels, renewably produced e-fuels, and CCS contributions to meeting CII and other future IMO regulations for mitigating GHG from ships.

These future fuels will be critical for the marine industry to transition to the planed low carbon future, and will have a significant impact of ship purchases, ship conversion, and scrapings. These draft guidelines can and should be used now to evaluate mid- and long-term transition plans through 2030 and beyond.

HEC is here to help you understand how these regulations will affect your fleet and the future of your shipping business. HEC has experience and expertise with all levels of energy efficiency design and can help with fleet CII analysis and projections, pathway to compliance recommendations, fuel conversions and repowering, carbon capture design and wind-assisted propulsion.