Last week’s meeting of IMO’s sixth Intersessional Working Group (IWG) on Reduction of GHG Emissions from Ships seems to have covered a lot of ground; ShipInsight published IMO’s summary of the meeting earlier this week.
But because it was a Working Group, it was not open to the media and its papers will not be made public via IMO’s online document library, IMODOCS. As a result, it is hard to know whether it specifically addressed my plea before the meeting for guidance on what IMO’s next GHG strategy – due in 2023 – will look like.
I have since spoken to one of its 394 attendees – Dr Tristan Smith, Reader in Energy and Shipping at University College London – to gain a better understanding of its discussions. I have quoted him in the past and his remarks have previously sparked a range of views from readers.
But first things first: My interpretation of IMO’s Initial Strategy is that it only addresses carbon emissions from ships and not the wider well-to-wake implications. That was the premise for my comments before the meeting in which I argued that if the 2023 strategy document is eventually drafted along more holistic lines to allow carbon-based fuels in some circumstances, then developing hydrogen- and ammonia-based technologies may prove to be wasted effort.
I have based that belief on the Initial Strategy’s lack of clarity over its list of 13 ‘candidate short-term measures’, one of which is to “develop robust lifecycle GHG/carbon intensity guidelines for all types of fuels” but does not define ‘lifecycle’. To me, the tone of the document is otherwise very much focused on emissions from ships themselves.
Tristan, however, drew my attention to other text in the document that refers to “low-carbon and zero-carbon fuels” but he nonetheless described the strategy’s approach as “currently ambiguous”. He agreed that upstream emissions must be accounted for somewhere, but said that “IMO sits in a difficult position because the land-side emission is regulated by national governments, not IMO.”
He mentioned two papers that had been submitted to the meeting: one, by Norway, which proposed that a ‘lifecycle’ analysis should apply only to operational CO2, and another, by South Korea that was more in line with my view that the fuel’s whole lifecycle should be considered. Because the papers are not available via IMODOCS, I have not yet been able to view either of them so cannot comment on their respective reasoning.
But I was encouraged by a paragraph in IMO’s summary that is headed ‘Alternative fuels’ which says, among other things, that the working group “agreed on the establishment of a dedicated workstream for the development of lifecycle GHG/carbon intensity guidelines for all relevant types of fuels” and that “many participants to the meeting highlighted the importance of undertaking this work as soon as possible.”
That sounds like a step forward, but it may not be all that it seems. The Norwegian and Korean papers demonstrate that there are two schools of thought within the IWG: those who want to prioritise tank-to-wake emissions accounting and others who want genuine lifecycle emissions accounting. “It's not clear to me how we're going to bridge those two things,” Tristan said.
He agreed with me, though, by saying that the well-to-wake group “have obviously got a more scientifically rational point” but, for the reasons I mentioned above, he believes IMO is going to find it difficult to regulate in this area.
This adds a new layer to my concern. I want to see the well-to-wake group prevail, but that will be difficult for an organisation that has no command over significant data that will be needed to make that assessment. And the IWG cannot make any decisions about this: it will submit a report to MEPC 75, which will meet next April, where this will all be discussed again.
It will be interesting to see the workstream’s recommendation to that meeting and what MEPC will decide. I fear that well-to-wake may end up in its ‘too difficult’ tray and that tank-to-wake will be confirmed in the 2023 strategy document, simply because it is the only step in the process that IMO can measure. It may be a cliché to say that if you can’t measure it, you can’t manage it, but it is nonetheless true.
In short, I do not feel the likely shape of the next GHG strategy is any clearer now than it was before the IWG meeting so I hope that IMO’s Fourth GHG study, which is outlined in IMO’s summary of the IWG’s discussions, will provide some clarity on which the new strategy can be built. That is due to be presented to MEPC 76 in October next year and I am looking forward already to seeing what it has to say.
• What changes would you like to see in the next GHG strategy? Will your future fuel strategies be affected if it confirms either well-to-wake or tank-to-wake as its defining measure? Email me now with your views.