Zero Emission Technologies At Berth and Their Impact on FuelEU Compliance

This newsletter series has previously outlined the Onshore Power Supply (OPS) requirement and benefits under FuelEU as also stipulated in Annex III of FuelEU, which incentivizes the adoption of zero-emission technologies while ships are in port. Today's newsletter dives deeper into Zero Emission Technologies (ZETs) at berth going beyond the obvious choice of OPS discussing battery charging, or fuel cells powered by hydrogen or ammonia. The newsletter answers questions such as how exactly are these solutions assessed in the FuelEU compliance framework and what makes some zero-emission technologies more favorable than others?

Recap of Zero Emission Requirements And Technologies At Berth

Article 6 of the FuelEU Maritime Regulation requires the use of OPS for container and passenger ships morred at berth for 2 hours or more starting from 1 January 2030 (find out more in our previous newsletter). As an alternative, the regulation outlines the use of ZETs that are equivalent to the use of OPS.

OPS, Batteries, Fuel Cells — What Counts?

The FuelEU Maritime Regulation allows to account for 0 emissions when using OPS as per Annex I. Equally, ZETs must fulfill the requirement of no tank-to-wake (TtW) emissions as well as air pollutants. As per Annex III, options include among others:

• Fuel cells consuming fuels with no TtW emissions

• Electrical energy storage: Charged onboard or at berth.

• Renewables: Wind or solar panels

Note that while the above may fulfill the requirements for ZETs at berth, they will have different impacts on the overall WtW GHG intensity of a vessel under FuelEU.

Zero Emission Technologies And FuelEU GHG Intensity Reductions

Let's dive into how each of these different options influence the overall WtW GHG intensity of a vessel under FuelEU Maritime.

Onshore Power Supply (OPS):

The use of OPS comes with a number of advantages. The WtW GHG emissions of this option are considered 0 and its energy can be fully accounted for in the intensity calculations.

Fuel Cells:

The use of fuel cells is considered a ZET at berth if the used fuel has 0 TtW GHG emissios. This may be tricky for ammonia as it produces small amounts of N2O. While fossil, bio, as well as e-hydrogen fulfill the requirement of 0 TtW GHG emissions at berth, their WtT emissions significantly differ and therefore have a different impact on the vessels overall compliance status.

Onboard Electrical Energy Storage:

Similar to fuel cells, the use of electricity from onboard electrical energy storage may impact the vessel's overall compliance status differently dependent on the energy source. Generally, the electrical energy storage can be either charged by onboard systems such as generators resulting in the consideration of the corresponding fuel's GHG intensity, by OPS at berth with correspondingly 0 emissions, or by battery swaps at berth.

Renewables:

This refers to electrical energy directly generated onboard by systems such as solar or wind. Similar to OPS, the WtW GHG emissions of such solutions are considered 0. Note, however, that the energy cannot be accounted for in the overal intensity calculation of the vessel as it was produced directly onboard.

Compliance Strategy At Berth: Cost Impacts Of Different Zero Emission Technologies At Berth

The below table outlines the impact of different zero emission technologies on the overall FuelEU compliance costs of a ship consuming 11,578 tonnes of HFO, 1,400 tonnes of MGO, and 4.75 GWh of OPS. Please find the detailed breakdown of calculations and assumptions in Chapter 3.6.1 of ESSF SAPS' Report on Calculation Methodologies under FuelEU, which has been used as a source for the below table.

	GHG Intensity [in g CO2e / MJ]	Compliance Balance [t CO2e]	Delta CB to Base Case [t CO2e]	Penalty [in €]
Base Case (OPS)	88.63	-1,602	-	1,057,942
FC with fossil H2	93.95	-4,651	-3,049	2,897,664
FC with e-H2	81.58	+2,312	+3,913	-
Batteries (OPS)	88.16	-1,358	+244	901,319
Batteries (onboard fuel)	91.41	-3,334	-1,733	2,135,163
Solar/wind	91.49	-3,067	-1,465	1,962,301

As the example case shows, most of the ZET options at berth are less beneficial than OPS. Only a fuel cell system with e-H2 considered as RFNBO, or a combination of onboard electrical energy storage charged by OPS outcompetes the somewhat most straight forward option of OPS. Ready to equip your vessels with OPS? Contact our partners by pressing below!

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Conclusion

As seen in many previous newsletters, compliance under FuelEU again proofs to be a strategic decision that requires a deep understanding of the regulation, underlying technology, and the economic impacts. The standard option of OPS appears to be not only straight forward but also reasonable when comparing its impact with other ZETs. A subsequent retrofit with onboard electrical energy storage slightly enhances its compliance impact. Only when going above and beyond, a fuel cell system with RFNBO categorized e-H2 showcases even better results even resulting in tradeable surplus of about 578,000€ (assuming a value of 250 €/tCO2e). Note that ammonia-based FCs may not be considered a ZET.

For a deep dive into the methodologies and calculation examples, refer to Chapter 3.6 of the ESSF SAPS' Report on Calculation Methodologies under FuelEU.

BetterSea’s FuelEU Maritime Compliance Platform with integrated marketplace provides you with a fast, streamlined, end-to-end process covering all potential compliance options, including external pooling and surplus trading. It allows you to comprehensively strategize your FuelEU and EU ETS compliance on a ship-specific level amidst volatile markets. Book a demo below!

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Stay tuned for more insights on navigating maritime decarbonisation compliance in our upcoming newsletters. If you have any questions or need further guidance, feel free to reach out!

Best regards,

The BetterSea Team

Contact Us: info@bettersea.tech

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