Alternative Fuels

INTERVIEW: EU definition only covers half of shipping emissions – Opportunity Green

January 29, 2024

“Well-to-wake emissions are what we need to look at for climate change,” Opportunity Green’s legal director Carly Hicks told ENGINE.

PHOTO: MSC's LNG-powered cruise ship MSC World Europa. MSC Cruises 


“Tank-to-wake is just not an adequate approach,” she argued, “We are talking about combating climate change, and climate change doesn’t start at tank-to-wake. When talking about climate change, you have to deal with full extent of the problem, not just half of the problem.” 

The EU has been looking to the IMO’s Energy Efficiency Design Index (EEDI) for inspiration when it decided to use a tank-to-wake (TtW) approach. This means that ships with low TtW emissions can qualify for green investments – even if the fuels they run on have high well-to-wake (WtW) emissions, which is what counts, according to Hicks.

LNG off the hook

By relying on EEDI when it revised its taxonomy, the EU will allow several LNG-capable ships to be eligible for green investments by only promising reductions in onboard carbon dioxide (CO2) emissions, and not their lifecycle CO2 emissions. Methane, the other major greenhouse gas (GHG), and of particular concern for LNG, is not included in the EEDI at all. Methane is a potent GHG that traps 86 times more heat than CO2 does.

LNG lobbyists and engine-makers insist that methane slips from LNG-powered engines can be controlled. "But that's only half of the problem," Hicks argued, "Arguing about tank-to-wake emissions only addresses the issue at hand, and not the bigger picture. Regulations need to consider well-to-wake emissions to actually make a difference.” 

She called LNG detrimental to shipping's green transition since it generally emits more lifecycle GHG emissions than fossil fuels. Her claim is supported by several studies conducted by the International Council on Clean Transportation (ICCT).  

LNG (2.755 mtCO2/mt of fuel) has a lower carbon factor than VLSFO (3.151) and LSMGO (3.206). However, it can have significantly greater WtW emissions than conventional marine fuels, partly because of its higher upstream methane emissions from leakages during extraction, processing and transport, according to an ICCT working paper.

Hicks pointed out that even onboard technologies - such as scrubbers and onboard carbon capture - only address exhaust emissions and not upstream CO2 and methane emissions.

“EEDI-based criteria that is imported in the taxonomy are not ambitious enough to change shipping’s business-as-usual practices”, Hicks stressed.  

The taxonomy also does not specify a “minimum level" for methane slip reduction to qualify for green investments, she said. “I mean, theoretically we could be looking at a 0.001% of reduction in methane slip to technically satisfy that requirement. And I think, realistically, this is not what we should be seeing.” 

E-methane to the rescue?

If fossil methane is the problem, can e-methane be the solution? At least not in the immediate future, according to Hicks. 

E-methane can be used as a drop-in fuel for LNG-capable vessels without any modifications since e-methane and LNG are essentially methane molecules produced in different ways. However, ships must run on 100% e-methane rather than LNG-blends to significantly reduce WtW emissions. 

According to Hicks, e-methane's scalability and wide availability is still in question, and its production costs could be significantly higher than for green ammonia or e-methanol in the longer run. 

“Also, the problem of methane [slip] does not go away,” she added. 

Hicks argued that the EU should instead focus more on driving investments into scaling up fuels like green hydrogen, green ammonia and e-methanol – which have a zero-emission potential. 

“We are not at the point where we need to make marginal gains at the moment in the shipping sector. We need to be looking at investments that are transformative and not sanctioning business-as-usual," she said.

Opportunity Green has asked the European Commission (EC) to review its revision and remove the EEDI-based technical criteria, Hicks said. She expects the EC to reply to its request by May this year. If the EC rejects the request for internal review, Opportunity Green will present its arguments before the EU’s Court of Justice.  

By Konica Bhatt 

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