1. SCOPE
This Newsletter aims to inform all interested parties about the publication of Marine Advisory: 18/2023-Rev.1 by the Liberia Maritime Authority. The purpose of this Marine Advisory is to provide information regarding the interim guidance on the use of biofuels for fuel oil consumption data and operational carbon intensity calculations which was approved by the Committee at MEPC 80.
The 2022 Guidelines on operational carbon intensity indicators and the calculation methods (resolution MEPC.352(78) CII guidelines, G1) provide the possibility for the CO2 Emission Conversion Factor (Cf) to be obtained from the fuel oil supplier, supported by documentary, in case the fuel oil is not covered by the relevant guidelines.
2. REQUIREMENTS
Pending the development of the comprehensive method to account for well-to-wake GHG emissions and removals based on the IMO Guidelines on Life Cycle GHG Intensity of Marine Fuels (LCA), biofuels that have been certified by an International certification scheme, such as ICAO’s CORSIA approved sustainability certification schemes or other International certification schemes acceptable to the Administration, meeting the sustainability criteria and the conditions below are eligible for a reduced Cf:
- Biofuels that provide well-to-wake GHG emission reduction of at least 65% as compared to well-to-wake emissions of fossil MGO;
- Achieving emission intensity not exceeding 33gCO2eq/MJ;
- Proof of sustainability or equivalent documentation from a recognized scheme should be provided along with the Bunker Delivery Note (BDN) to facilitate verification of the reported biofuel consumption.
3. CALCULATION AND ASSIGNMENT OF CARBON CONVERSION FACTOR (CF) FOR BIOFUELS
The assigned Cf is equal to the value of the well-to-wake GHG emissions of the fuel according to the certificate (expressed in gCO2eq/MJ) multiplied by its lower calorific value (LCV, expressed in MJ/g) for the corresponding amount of fuels consumed by the ship. In any case, the Cf value of a biofuel cannot be less than 0. For biofuel blends, the Cf should be based on the weighted average of the Cf for the respective amount of fuels by energy. The revised interim Guidance in MEPC.1/Circ.905/Rev.1 introduces a change in the calculation of the carbon conversion factor (Cf) for biofuel blends from energy-weighted to mass-weighted averaging. This corrects a methodological inconsistency and may affect CII calculations for ships using blended fuels.
The revised guidance applies from 1 January 2027, and will require verification of supporting documentation accordingly.
However, Biofuels that are not certified as ‘sustainable’ or not fulfilling the well-to-wake emission factor criterion above should be assigned a Cf equivalent to Cf of fossil fuel type.
PhRS Note: Any existing SEEMP Part II that includes a calculation method for the conversion factor of biofuel blends in accordance with MEPC.1/Circ.905 should be revised to reflect MEPC.1/Circ.905/Rev.1. The revised SEEMP Part II should be submitted to PhRS for review as soon as possible to ensure issuance of the new Confirmation of Compliance by 31 December 2026.
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For any questions or further assistance, please do not hesitate to contact us at technical@phrs.gr or Liberia’s Regulations and Standards Department at RegsAndStandards@liscr.com.