IMSML Website Article 09/2025: Resolution MEPC.376(80) - Guidelines on Lifecycle GHG Intensity of Marine Fuels (LCA Guidelines), Part 2 of 5, PART II - METHODOLOGY

This is the second part of an article on the LCA Guidelines.

PART II - METHODOLOGY

SECTION 3 - GENERAL APPROACH

Does WtW GHG emissions quantification apply across all geographical regions? Yes, quantifications are made where emissions occur, and allow for the quantifying of GHG over the entire fuel / energy supply chain, see Paragraph 3.1.

What is the benchmark for assessment methodology for the quantification of environmental impacts of products, processes and services in the supply chain? The Guidelines adopt ISO 14044:2006 Environmental Management - Lifecycle Assessment - Principles and Framework, see Paragraph 3.2.

What do the following emissions represent?

[1] WtT emissions - GHG emissions resulting from growing or extracting raw materials, producing and transporting the fuel to the point of use, including bunkering, see Paragraph 3.3;

[2] TtW emissions - GHG emissions resulting from fuel utilisation onboard (eg combustion), including potential leaks (fugitive emissions and slip), when relevant for GHG assessment, see Paragraph 3.4.

[3] WtW emissions (ie a sum of WtT and TtW emissions) - Quantify the full life cycle GHG emissions for a given fuel and fuel pathway, used in a given energy converter on board, see Paragraph 3.5.

What are the characteristics of the ‘Attributional Approach’ adopted by the Guidelines? It considers all processes along the supply chain of fuel / energy carrier pathways, allowing the quantification of contribution per segment to the overall GHG intensity of the final fuel / energy product used on board a ship, see Paragraph 3.6.

How do the Guidelines deal with concerns with respect to the uncertainties and the risk of arbitrariness? Where there are consequential elements such as Indirect Land Usage Change (ILUC), it is suggested that feedstocks with associated ILUC should only be assessed through a ‘risk-based-approach’ (in the framework of sustainability themes / aspects), see Paragraph 3.7.

If more than one product results from a conversion process, how should emission related to fuel production be allocated? It should be allocated between both the ‘main product’ and the ‘co-product. Emissions are allocated using their energy content (ie energy allocation approach), see Paragraph 3.8.

What if co-products allocation cannot be performed based on their energy content? An example where this may arise is oxygen resulting from water electrolysis for H2 production. In this scenario, other methods could be considered on a case by case basis (see Paragraph 3.8), for example:

[1] Mass allocation;

[2] Market revenue allocation (ie also popularly known as own as ‘economic allocation’).

What are the characteristics of a ‘co-product’? Paragraph 3.9 defines it as:

[1] An outcome of a production process;

[2] Has economic value;

[3] Possessing an elastic supply (intended as the existence of a clear evidence of the casual link between feedstock market value and the quantity of feedstock that can be produced).

What about raw materials used to produce the fuels has no economic value (eg waste) and/or unavoidably produced and with negligible value, needing further processing to be used in the main conversion process (eg residue)? The definitions of ‘co-product’ is also applicable here. For feedstock that is a waste (residue or by-product), these emissions are considered as WtT start at the feedstock collection point onwards until the point of the final fuel / energy product, see Paragraph 3.10.

According to the IPCC Guidelines for National Greenhouse Gas Inventories (ie the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, what should be reported as an ‘information item’? Any carbon in the fuel that is derived from biomass, see Paragraph 3.11.

According to the IPCC Guidelines, what should not be included as an ‘information item’? The sectoral or national totals, as there could be double counting, since net emissions from biomass are already accounted for in the Agriculture Forestry and Other Land Use (AFOLU) sector at a national level, see Paragraph 3.11.

Does the scope of the IMO LCA guidelines affect or change the IPCC Guidelines? No. Under Paragraph 3.12, it is explained that the IPCC Guidelines stipulate:

[1] International waterborne navigation (international bunkers) is grouped under ‘Mobile Combustion’ under the Energy sector; BUT …

[2] Emissions from fuel used by ships in international transport should not be included in national totals in national GHG inventories.

Could a fuel batch be a mix of fuels made from various feedstocks and sources (eg blending 20 percent bio-diesel into fossil MGO) and/or through different production pathways? Yes, the calculation should be done using the weighted averages of the energy of the various fuel components. Relevant information should accompany each component fuel in the FLL, see Paragraph 3.13.

Should blended fuels be included in the certification schemes? Yes, the relevant GHG default or actual emission factors (gCO2/MJ) should be determined in proportion to the energy of each fuel part of the blend, see Paragraph 3.13.

SECTION 4 - WELL-TO-TANK (WtT)

What are the two fundamental concepts for documenting a ‘fuel pathway’? Paragraph 4.2 mentions this

[1] Feedstock structure:

[a] nature / carbon source;

[b] feedstock type pair.

[2] Production / conversion process - Note that the same feedstock and fuel type pair can have different production or conversion process.

What is the aim of the WtT methodology? To quantify and evaluate the GHG intensity of fuel production according to the following steps in a generic WtT supply chain (see Paragraph 4.3):

[1] First step - Feedstock extraction / cultivation / acquisition / recovery;

[2] Second step - Feedstock, early processing / transformation at source;

[3] Third step - Feedstock transport to conversion site;

[4] Fourth step - Feedstock conversion to product fuel;

[5] Fifth step - Product fuel transport / storage / delivery / retail storage / bunkering;

[6] Sixth step - Usage of the bunker fuel by the ship.

What emissions will be taken into account? Paragraph 4.5 identifies the following emissions:

[1] Raw materials extraction or cultivation;

[2] primary energy sources used for production of goods and utilities (eg energy carriers like fuels and electricity);

[3] Transport and distribution (including bunkering);

[4] Direct land use change;

[5] Changes in carbon stocks (soil carbon accumulation).

What does ‘processing’ include? Paragraph 4.6 explains that it includes:

[1] All steps and operations needed for the extraction , capture or cultivation of the primary energy source;

[2] Basic transformation at source and operations needed to make the resource transportable to the marketplace (eg drying, chemical / physical upgrade such as gas-to-liquid, etc).

What is covered by the phrase ‘transporting, processing and distribution’? Paragraph 4.7 provides that it includes transportation of products in the fuel pathway to the place of:

[1] Transformation;

[2] Conditioning (eg compression and cooling);

[3] Distribution to the market place (eg bunkering);

[4] Eventual leakages;

[5] Fugitive emissions at any of the stages [1]-[4] above.

What are the most appropriate and reliable methodology for the allocation of emission to co-products? Energy content should be used. This can be determined via an appropriate certification method using values that are predictable, reproducible and stable, see Paragraph 4.8.

How can ‘land use change’ (LUC) be classified? There are two types: Direct LUC (DLUC) and indirect LUC (ILUC), see Paragraph 4.9.

What is DLUC based on and what is its effect? DLUC is based on ISO 14067: 2018 and is a change in the use or management of the land within the product system being assessed., see Paragraph 4.10. It has the following impact:

[1] Emissions and sequestration resulting from carbon stock changes in:

[a] Biomass;

[b] Dead organic matter;

[c] Soil organic matter.

Note, that [a]-[c] are evaluated in accordance with IPCC Guidelines.

[2] It is sector or country-specific data on carbon stock (ie if available, it may be used);

[3] In the absence of [2] above, IPCC’s Tier 1 default emission factors may be considered.

What is the basis of ILUC? It is based on ISO 14067: 2018 which provides the following definition (see Paragraph 4.11):

[1] A change in the use or management of the land;

[2] The change is a consequence of direct land use change;

[3] This change may be outside the product system being assessed.

What causes ILUC? It is a result of economic impacts induced by (see Paragraph 4.11):

[1] Increased biofuel demand on commodity prices;

[2] Resulting shifts in demand and supply across economic sectors (eg primarily food and feed production);

Can ILUC be directly measured? NO. It is projected with economic models, see Paragraph 4.11.

Why is the quantitative assessment of GHG effects of ILUC subject to uncertainty, high quantitative variability and to the risk of arbitrary conclusions? It is due to the variability of assumptions underlying the evaluation of indirect effects, see Paragraph 4.12.

What are the factors  affecting the spatial dimensions of ILUC emissions? The following factors are documented in Paragraph 4.12:

[1] Local / regional conditions and practices for agriculture;

[2] Current and expected food import demand;

[3] National current accounts;

[4] Type of feedstock;

[5] Alternative economic uses of the same feedstock.

What should a qualitative risk-based approach to ILUC encompass? Paragraph 4.13 identifies two things:

[1] Low-ILUC - qualifies and characterizes biofuel production projects that supply additional feedstock without disrupting existing land uses (see Paragraph 4.13.1);

[2] High-ILUC - qualifies and characterizes biofuel production projects based on / or displacing food and feed crops resulting in a significant expansion of the feedstock production area shifting into land with high-carbon stock (see Paragraph 4.13.2).

SECTION 5 - TANK-TO-WAKE (TtW)

What is the aim of the TtW methodology? To quantify and evaluate the intensity of CO2, CH4 and N20 emitted on board a ship related to the following (see Paragraph 5.1):

[1] Fuel usage;

[2] Combustion / conversion;

[3] All relevant fugitive emission with a Global Warming Potential.

How are the two most important values of TtW calculated under the LCA Guidelines? Paragraph 5.3 makes the following provisions:

[1] TtW GHG Intensity Value 1, see Paragraph 5.3.1;

[2] TtW GHG Intensity Value 2, see Paragraph 5.3.2.

What does the actual GHG intensity depend on? Paragraph 5.4 explains that it depends on both:

[1] Properties of the fuel - eg for CO2, the emission factors are based on the molar ratio of carbon to oxygen multiplied with the carbon mass of fuel (assuming that all carbon fuel is oxidised, ie stoichiometric combustion);

[2] Efficiency of the energy conversion - eg CH4 and N20 emission factors are dependent on the combustion and/or conversion process in the energy converter.

What additional ‘future use’ can be taken into account by the TtW methodology? Eg fuel cells with a reforming unit, and electro-chemical reactions forming GHGs, see Paragraph 5.5.

SECTION 6 - WELL-TO-WAKE (WtW)

What is the aim of this methodology? To integrate WtT and TtW parts, ie to quantify the full life cycle emission related to the production and use of a fuel, see Paragraph 6.1.

SECTION 7 - SUSTAINABILITY

Paragraph 7.1 provides a list of how marine fuels should be assessed on a life cycle basis:

[1] Greenhouse gases (GHG), see Paragraph 7.1.1;

[2] Carbon source, see Paragraph 7.1.2;

[3] Source of electricity / energy, see Paragraph 7.1.3;

[4] Carbon stock - direct land use change (DLUC), see Paragraph 7.1.4;

[5] Carbon Stock - indirect land use change, see Paragraph 7.1.5;

[6] Water, see Paragraph 7.1.6;

[7] Air, see Paragraph 7.1.7;

[8] Soil, see Paragraph 7.1.8;

[9] Waste and chemicals, see Paragraph 7.1.9;

[10] Conservation, see Paragraph 7.1.10.

Could other social and sustainability themes /aspects (ie not listed in [1]-[10] above) be considered? Yes, this can be done at a later stage, see Paragraph 7.1.

Note, the metrics / indicators of each sustainability theme / aspect is found in Table 1, Paragraph 7.2

SECTION 8 - FUEL LIFECYCLE LABEL (FLL)

What is FLL? It is a technical tool to collect and convey information relevant for the life cycle assessment of marine fuels and energy carriers (eg electricity for shore power) used for a ship’s propulsion and power generation onboard in the context of the Guidelines, see Paragraph 8.1.

How parts are there to FLL? Paragraph 8.2 identifies 5 Parts:

[1] PART A:

[a] A-1 - Fuel type;

[b] A-2 - Fuel Pathway Code;

[c] A-3 - Lower Calorific Value;

[d] A-4 - Share in Fuel Blend;

[e] A-5 - WtW GHG emission factor.

[2] PART B:

[a] B-1 - Emissions credits related to biogenic carbon source;

[b] B-2 - Emissions credits related to source of captured carbon.

[3] PART C:

[a] C-1 - Value 1 (Carbon source NOT taken into account): TtW GHG emission factor;

[b] C-2 - Value 2 (carbon source taken into account): TtW GHG Emission factor;

[c] C-3 - Energy Converter

[4] PART D: WtW GHG Emission factor.

[5] PART E: Sustainability (Certification).

Could different parties (fuel suppliers, owners / operators, Administration / RO etc) use different parts of the FLL for different purposes along the fuel pathway? Yes, each interested party may use those parts relevant to their activities and purposes rather than the complete, integrated document, see Paragraph 8.3

Thank you for reading IMSML Website Article 09/2024

Stay tuned for the next IMSML Website Article 10/2025: Resolution MEPC.376(80) - Guidelines on Lifecycle GHG Intensity of Marine Fuels (LCA Guidelines), PART III - DEFAULT EMISSION FACTORS AND ACTUAL VALUES

Signing-off for today,

Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT

Professor of Maritime and Transport Law

Head of the Centre for Advocacy and Dispute Resolution

Faculty of Law

Universiti Teknologi MARA Shah Alam

Selangor, Malaysia

Tuesday,  4 March 2025

Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my