Policy Brief: Methane-Based Fuels in the IMO Life Cycle Assessment Guidelines
Credit: IMO
An Assessment of the Four Submissions to the IMO Intersessional Working Group on Reduction of GHG Emissions from Ships – ISWG-GHG 22, Agenda Item 4
Prepared by: Equal Routes, Secretariat of Maritime Beyond Methane (MARBEM)
Scope of Policy Brief
Maritime Beyond Methane (MARBEM) is a global initiative accelerating the shipping industry’s transition beyond methane-based fuels — fossil, bio- and e-LNG. This brief assesses the four submissions under the International Maritime Organization (IMO) Intersessional Working Group on Reduction of GHG Emissions from Ships, ISWG-GHG 22, agenda item 4.
This brief is intended to provide IMO delegates and NGOs with consultative status with information on the implications of the four submissions for methane-based fuels. Its purpose is to complement analyses published on the broader IMO Net Zero Framework discussions at ISWG-GHG 22. Where a submission raises issues outside the scope of this brief, this is noted and those elements are assessed on their own merits.
The four submissions are separate proposals to be considered on their own terms, not competing alternatives to a single decision.Three of them would primarily advantage methane-based fuels – fossil Liquefied Natural Gas (LNG) and bio-LNG (or biomethane) – and considered viable solutions at the International Maritime Organization (IMO) moving forward.
Read the Policy Brief here.
Summary of Recommendations
-
22/4 - Include avoided livestock methane in the WtT emissions factor
Recommendation: Maintain the Well-to-Tank boundary at the feedstock collection point, and treat avoided-emissions crediting as a consequential question.
Avoided livestock methane depends on a counterfactual that is neither uniform nor static; section 3.10 places the WtT boundary at the feedstock collection point for waste feedstocks. Invoking a counterfactual makes this consequential, not attributional.
-
22/4/1 - Remove sustainability theme/aspect 2 (carbon source).
Recommendation: Retain sustainability theme/aspect 2 (carbon source) as a distinct sustainability indicator.Carbon origin is a relevant sustainability aspect to identify which fuels are eligible for actual emissions values. Removal advantages fossil LNG and makes CCS harder to differentiate from true decarbonization.
-
22/4/2 - Actual WtT values for purely fossil pathways.
Recommendation: Retain paragraph 10.4 of the LCA Guidelines and adopt a single, globally representative, conservative default WtT value for fossil pathways.
Actual values create incentives to certify the lowest Emission Factors and systematically underestimate life cycle emissions. Existing verification requirements already understate upstream methane.
-
22/4/3 - Quantified ILUC factors; Work plan on DLUC and soil carbon; Actual WtT values for fossil fuels.
Recommendation: Advance the ILUC and DLUC elements, and consider the actual WtT values element on its own merits.
The first two elements would strengthen the LCA framework. Strengthening them improves the accuracy of biofuel life-cycle assessment, but should remain separate from proposals to allow actual WtT factors for fossil fuels.
