Former IMO Official Highlights Potential Opposition to Well-to-Tank Emissions Analysis

Hughes served as the IMO's head of air pollution and energy efficiency until February 2020. Image Credit: IMO

A former key official at the IMO has raised questions over the practicability of giving a full well-to-take view on marine fuel emissions at the global level.

The IMO should not include upstream well-to-tank emissions in its regulations on marine fuel GHGs. Edmund Hughes, the organisation's former head of air pollution and energy efficiency, said in a LinkedIn post on Tuesday.

"One of the critical policy questions not fully explored, and one that several of the large, major trading developing countries have a strong position on, is that 'well-to-tank' emissions, ie those emissions generated upstream of the ship, should not be regulated by IMO," Hughes said.

"This is because those States consider those emissions come under their jurisdictional control and as such their national 'carbon' budget/NDC.

"Indeed the IPCC Guidelines on reporting national GHG emissions inventory identify that upstream emissions should be reported, and therefore controlled, at a national level."

Several shipping industry bodies have argued that any new regulations on the industry's GHG emissions must take on a full well-to-wake analysis to give an accurate accounting of each alternative fuel's environmental credentials.

Taking a tank-to-wake analysis on its own, the GHG emissions from biofuels would appear similar to those from conventional bunkers. and green methanol and methanol produced from fossil natural gas would have identical emissions.

But Hughes suggested there may be other means of the IMO taking a well-to-wake analysis into account.

"Alternatively, consideration could be given to rewarding the use by ships of 'zero' emission fuels using well-to-wake emission factors but not penalising existing ships that are unable to use such fuels," he said.

"It comes back to the key question: how can you attain the right regulatory balance that enables the energy transition in maritime transport without leading to significant impacts on the sector or those states that depend on it for trade and economic development?"