final report study on decarbonisation of the ... - belgium
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Final report
Study on decarbonisation of the Belgian
maritime sector for small vessels (<5000
GT)
Report for: Federal Public Service of Mobility and Transport
Vooruitgangstraat 56
1210 BRUSSEL
Year: 2021
Author: Sebastiaan Boschmans, Kris Vanherle, Tim Breemersch
Transport & Mobility Leuven
Diestsesteenweg 57
3010 Leuven
Belgium
http://www.tmleuven.be
2
Contents
Contents .............................................................................................................................................................. 2
List of figures...................................................................................................................................................... 3
List of tables ....................................................................................................................................................... 6
Abstract ............................................................................................................................................................... 7
1 Emission estimations of vessels in scope of the study ....................................................................... 8
1.1 Vessels in scope ........................................................................................................................ 8
1.2 Emission reporting – International & Belgian context ...................................................... 8
2 Initiatives and already implemented Belgian measures .................................................................... 12
2.1 Public initiatives and measures ............................................................................................. 12
2.2 Private sector initiatives and measures ................................................................................ 16
3 Greenhouse gas reducing measures for vessels smaller than 5000 GT ......................................... 19
3.1 Technical measures ................................................................................................................. 19
3.2 Operational measures ............................................................................................................. 48
3.3 Overview of carbon reducing measures and feasibility .................................................... 52
4 Programmes to support implementation of decarbonizing measures ........................................... 55
4.1 Carbon pricing......................................................................................................................... 55
4.2 Tax exemptions ....................................................................................................................... 58
4.3 Subsidies and funding ............................................................................................................ 63
4.4 Environmental differentiated incentives ............................................................................. 72
4.5 Energy efficiency indices and monitoring systems............................................................ 73
5 Conclusions ............................................................................................................................................. 75
6 Further possible research on Belgian level ......................................................................................... 80
Abbreviations, symbols and units ................................................................................................................. 81
Appendix ........................................................................................................................................................... 83
3
List of figures
Figure 1: CO2 emissions non-transport versus transport including domestic navigation. .................... 9
Figure 2: Decomposition of domestic maritime navigation emissions. .................................................... 9
Figure 3: Vessel length and GT correlation for international maritime navigation vessels. ............... 10
Figure 4: Decomposition analysis of international maritime navigation emissions. ............................ 10
Figure 5: Behydro hybrid diesel/hydrogen engine. ................................................................................... 17
Figure 6: CO2 emission reduction potential from individual measures (Source: Bouman et al., 2017).
........................................................................................................................................................................... 20
Figure 7: Power requirements for conventional and more slender hulls (study of average power
demand for a conventional vessel design with a block coefficient of 0.82, versus a slender design
with a block of 0.75, both with a deadweight of 110,000 tons) (Source: Lindstad and Bø, 2018). ... 21
Figure 8: Gram CO2 per ton km as a function of speed, for alternative shortsea vessels hull designs,
at 50% load factor on a roundtrip basis. Study applied to the European General Cargo Fleet
(Source: Lindstad et al. 2016). ....................................................................................................................... 22
Figure 9: Indication of reduction potential per vessel type. (Green = feasible, red = not realistic,
black = not applicable). ................................................................................................................................. 23
Figure 10: WTW CO2 eq. emissions per kWh (GWP100) as a function of fuel and a 4-stroke engine
(Source: Lindstad et al., 2020). ...................................................................................................................... 25
Figure 11: Reduction potential per vessel type LNG. (Green = feasible, Orange = technically
feasible but big obstacles). ............................................................................................................................. 26
Figure 12: Energy chains for powering ships with renewable energy sources. (Source: International
Transport Forum 2020). ................................................................................................................................ 27
Figure 13: WTW CO2 equivalents (incl. CO2, CH4, N2O) from various hydrogen and ammonia fuel
pathways, compared to conventional fuels (MGO used as reference fuel for % variation) (Source:
SFI Smart Maritime 2020, Lindstad 2020). ................................................................................................. 28
Figure 14: Reduction potential of H2 and NH3 per vessel type. (Green = feasible, Orange = feasible
with big obstacles, Red = Not realistic, Black = not applicable). ........................................................... 29
Figure 15: Marine fuels path ways (fuel labelling: Grey = Fossil; Blue with carbon capture; Green =
Renewable; Orange = Any blending of Grey, Blue and Green) (Source: Lindstad 2020). ................. 30
Figure 16: Reduction potential of synthetic e-fuels TTW per vessel type. (orange = feasible with big
obstacles). ......................................................................................................................................................... 31
Figure 17: WTW CO2-eq emissions per kWh (GWP100) for distinct biofuels - Source [1] is the State-of-the-Art
technologies, measures, and potential for reducing GHG emissions from shipping study (Bouman et al., 2017);
Source [2] is The Role of Sustainable Biofuels in Decarbonising Shipping (SSI, 2019) presented at Cop 25 in
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December 2019. Sources for [3] are: Thinkstep (2019), for the basic Biogas WTT; and Lindstad (2019), for the
impact of un-combusted methane, which is the same level as for fossil fuels.. .......................................................... 33
Figure 18: Reduction potential of biofuels WTW for vessels in scope. (orange = technically feasible
but big obstacles). ........................................................................................................................................... 34
Figure 19: Alternative power and propulsion setups for offshore support vessels (Source: Lindstad
et al., 2017). ...................................................................................................................................................... 36
Figure 20: Reduction potential of hybrid power and propulsion systems for the vessels in scope.
(green = technically feasible, orange = technically feasible but big obstacles). .................................... 38
Figure 21: Belgium's energy mix (source: Elia 2020). ............................................................................... 39
Figure 22: Reduction potential full electric for vessels in scope (orange = technically feasible but big
obstacles, red = not realistic, black = not feasible). .................................................................................. 40
Figure 23: Wind-assisted propulsion device (Source: ITF 2020). ........................................................... 42
Figure 24: Reduction potential of wind-assisted propulsion for the vessels in scope (green =
technically feasible, red = not realistic). ...................................................................................................... 43
Figure 25: Energy saving devices installed on vessels smaller than 5000 GT (Source: Clarkson WFR
database). .......................................................................................................................................................... 45
Figure 26: Energy Saving Measures - Energy saving potential in function of payback time, based on
Clarkson WFR database sample. .................................................................................................................. 46
Figure 27: Sankey diagram of maritime fuels and T-s diagram of an ORC (Source: Zhu et al. (2020).
........................................................................................................................................................................... 47
Figure 28: Fuel and cost per ton transported as a function of speed and fuel cost for a standard
Aframax (Source: Lindstad et al. 2015). ...................................................................................................... 49
Figure 29: Reduction potential of speed optimization for vessels in scope. (green = technically
feasible, orange = technically feasible but big obstacles, black = not applicable)................................ 50
Figure 30: Schematic representation of capacity utilization (source: ETP-ALICE physical internet
2020). ................................................................................................................................................................ 51
Figure 31: Reduction potential of capacity utilization for the different vessels in scope (orange =
technically feasible but big obstacles, black = not applicable). ............................................................... 52
Figure 32: Overview of carbon pricing mechanisms for domestic aviation and domestic navigation.
Source: Taxing Energy Use: Using Taxes for Climate Action (OECD)................................................ 55
Figure 33: Effectiveness of the carbon pricing schemes, relation between carbon pricing gap and
carbon intensity of GDP. .............................................................................................................................. 56
Figure 34: Tax exemptions on ship fuels per country. Source: Transport and Environment69. ........ 59
Figure 35: Overview of fossil fuel tax exemptions for some European countries.72 ........................... 60
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Figure 36: Estimation of job creation related to Belgium off-shore wind sector................................. 68
6
List of tables
Table 1: Fuel Price Projections (2020-2050) - Lower bound (USD/GJ) from Lloyd's Register and
UMAS. .............................................................................................................................................................. 31
Table 2: Overview of the feasibility and reduction potential of the different vessels in scope for all
presented measures. Green is technically feasible, orange is technically feasible with big obstacles,
red is not realistic and black not applicable for the given time horizon. TTW means tank-to-wake,
WTW means well-to-wake. ........................................................................................................................... 53
Table 3: Overview table technical measures............................................................................................... 84
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Abstract
Under current IMO and European legislation on decarbonizing the maritime sector, authorities
focus on large vessels. Many of the relevant measures are only applicable on vessels larger than
5000GT, however some are on smaller as well. This study shifts the focus towards vessels that do
not fall under current legislation and tries to shed light on technical and operational practices that
are applicable on small ships navigating in Belgian waters.
The study concludes that it often is hard for vessels with specific operating conditions to
implement several measures. This is particularly the case for hull optimization, wind assisted
propulsion, capacity utilization and speed optimization. In addition those measures are existing
technology and most have low energy savings. This also holds true for the presented energy saving
devices.
Furthermore alternative propulsion types have been studied. The main obstacles of alternative fuels
and battery electric propulsion are the costs and volumetric efficiency. Energy savings are
substantial for battery electric, hydrogen, ammonia, biofuels and synthetic e-fuels. However this
depends on the respective energy source, production process and carbon content. The reduction
potential of LNG is limited.
The Belgian federal government has several possibilities to ease the uptake of the presented
measures. As a first measure Belgium could opt to implement a one sided carbon taxation scheme.
A second option is to reduce the favourable tax regime for conventional marine fuels. The opposite
could be done for electricity and sustainable alternative fuels. A last option identified is a R&D or
modal shift subsidy.
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1 Emission estimations of vessels in scope
of the study
1.1 Vessels in scope
This section aims to clarify the scope of the emissions and ships subject to the analysis of reducing
CO2 emissions in the study. The report will go deeper into the following ships and activities :
1. domestic maritime navigation
2. international maritime navigation on Belgian territory i.e. territorial sea, the economic
exclusive zone and maritime inland waterways i.e. inland waterways navigable by seagoing
vessels
3. estuary shipping (“estuaire vaart”) i.e. seaworthy ships active in maritime waters
4. recreative shipping activity (“pleziervaart”), both maritime and on inland waterways
For the above, in all cases, a threshold of 5000 gross tonnage (GT) is applied. This threshold value is
mostly relevant for the 2nd category as the other ships are typically (well) below this size.
In terms of ship registration, both ships with a registered flag in Belgium as well as international ships
active on Belgian territory are in scope.
1.2 Emission reporting – International & Belgian context
The starting point is the international emission reporting requirements. For international CO2
inventories, the relevant reporting category of the Intergovernmental Panel on Climate Change
(IPCC) is classified under the category code and name 1.A.3.d “domestic navigation”.1 This includes
domestic maritime shipping (i.e. maritime shipping with origin and destination in the reporting
country) as well as inland navigation. Total emissions in this category reported for Belgium are 401
kilotons (kt) CO2 in the latest available reporting year, 2018.2
The emissions in scope of this study do not match this reporting category as they include international
maritime navigation <5000 GT (excluded from 1.A.3.d) yet exclude inland navigation (included in
1.A.3.d)3. The latter excludes recreative shipping (federal competence) which is in scope of this study.
This complicates matters as a specific approach is needed for the sub-sets of ships and emissions.
For Belgium, the 'Emission Model for Shipping and Rail' or EMMOSS-model, developed by TML,
is used for both emission inventory of maritime shipping and inland navigation. To get a grasp of the
importance of the sector, Belgium reports 401 kt CO2 emission, constituting 0.48% of Belgium’s total
CO2 emissions:
1 https://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/1_Volume1/V1_8_Ch8_Reporting_Guidance.pdf 2 CRF tables from https://klimaat.be/in-belgie/klimaat-en-uitstoot/uitstoot-van-broeikasgassen/nationale-inventaris 3 Inland navigation, however, is a competence situated on federal level, but due to the completely different way of
registration, this category will be excluded from the study.
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Figure 1: CO2 emissions non-transport versus transport including domestic navigation.
However, due to the misaligned scope, this is both a potential underestimation (excluding
international shipping <5000 GT) as well as a potential overestimation (including inland navigation).
We thus zoom into the sub-categories:
1.2.1 Domestic maritime navigation (<5000 GT)
Fully relying on the latest EMMOSS estimates (2018), we find 123 kt CO2, with the following
distribution by ship type:
Figure 2: Decomposition of domestic maritime navigation emissions.
The majority of these emissions fall into the category of dredging (“bagger”) as well as tug (“sleep”).
Only 2% consists of classic (small) cargo vessels.
1.2.2 International maritime navigation (<5000 GT)
Secondly, international navigation of small cargo ships on the Belgian Continental Shelf (BCS) are in
scope. EMMOSS does not use a GT cut-off value. Based on the relation between GT and length,
vessels with a GT smaller than 5000, have a maximum length situated in the range between 100 m
and 150 m. When we include all vessels with a length smaller than 150 m, the total emissions of this
category will be 180 kt CO2. Looking at the graph, this will be an overestimation because this would,
in some cases, even include vessels of 10000 GT.
10
Figure 3: Vessel length and GT correlation for international maritime navigation vessels.
The opposite is true if we take all vessels with a length smaller than 100 m. The total emissions would
be around 71 ktT CO2. This would however be an underestimation because it would not include all
vessels satisfying the 5000 GT threshold (see GT to length ratio in Figure 3 – own calculation based
on EMMOSS fleet data).
The breakdown of the emissions per ship type in the 150 m threshold category is as follow:
Figure 4: Decomposition analysis of international maritime navigation emissions.
1.2.3 Estuary shipping
Estuary shipping is roughly speaking the shipping category whereby reinforced vessels navigate
parallel with the coast line. However, within the Belgian emission inventory, it is impossible to isolate
this category, because some emissions are included in the maritime navigation sub-category and some
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emissions are categorized in the inland waterway (IWW) sub-category. Because the activity in IWW
is negligible and because the maritime navigation part is already mainly included in the previous
discussed categories discussed in paragraphs 1.2.1 and 1.2.2, the abandonment of the effort to
estimate the emissions of this sub-type is justified. However some of the measures identified for the
other categories to reduce the emissions, can still be applicable for estuary shipping. There can be
thought of alternative fuels, electrical propulsion via energy stored in batteries, etc. The relevance of
those measures for estuary shipping will therefore be investigated.
1.2.4 Recreative shipping
Emissions of recreative shipping are included in the IWW inventory. The IWW inventory also
includes recreative vessels that mainly are navigating in open sea, because it captures all vessels that
depart and arrive in a Flemish port. Detailed information about the emissions of recreational crafts
is very limited. The EMMOSS model is likely to underestimate emissions as not all crafts are
registered in the monitoring system. The EMMOSS methodology4 in this respect:
“
We add the following: the emissions related to recreative shipping are only partly included, because not all pleasure boats
are registered by the waterway authorities. The emissions are mainly part of the shipping category M0 (small motor
boat)
We merken hier op dat de emissies van pleziervaart slechts voor een deel werden meegerekend, gezien niet alle
pleziervaartuigen geregistreerd worden door de waterwegbeheerders. De emissies van pleziervaart zitten voornamelijk in
de scheepscategorie M0 (klein motorschip).
”
Total CO2 emissions reported for IWW in Flanders is 212 kt CO2. About 2 kt, less than 1%, is
included in the M0-class which partly includes recreative shipping.
This is most certainly an underestimation. The Dutch emission inventory now includes an estimate
based on fuel sales and as such estimates CO2 emissions from recreative shipping explicitly5.
According to the Dutch emission inventory; about 8.7% of total emission from inland navigation can
be attributed to recreative shipping. Assuming the same ratio for Flanders, this would mean about 18
kt CO2.
4 Source: https://www.tmleuven.be/en/project/emmoss 5
http://www.emissieregistratie.nl/erpubliek/misc/documenten.aspx?ROOT=\Algemeen%20%28General%29\Exports\
Emissie%20en%20Belasting%20oppervlaktewater%20per%20doelgroep
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2 Initiatives and already implemented
Belgian measures
In this chapter existing initiatives and measures that were implemented to decarbonize the Belgian
maritime sector will be discussed. Those can be for large vessels as well as for small vessels. If there
are initiatives or measures identified that are only applicable for small vessels, the focus will lie on
those, but the chapter will try to capture a complete picture of the existing decarbonizing efforts.
2.1 Public initiatives and measures
Public initiatives can be taken on several levels. Taking into account the global nature of the
international shipping sector, Belgium believes that decarbonization will be most effective when
tackled at the highest level. Therefore, the Belgian government decided to prioritize the discussions
in the International Maritime Organization (IMO). Nevertheless, national initiatives will remain
necessary for those ships and crafts that are not subject to the IMO regulations. On EU level, an EU
emission trade system (ETS) regulates the emissions for certain sectors. The system assures that the
total emissions of those sectors remain below a certain maximum or cap. This system does not include
transport modes running on fossil fuels. The European aviation sector is the only fossil fuel transport
sector that is currently included in the system, however only intra-European flights are subject to this
system.6
2.1.1 International level
IMO is a specialized agency of the United Nations that sets the standards for safety, security and
environmental performance of the international maritime sector.
In 2018, the International Maritime Organization adopted the Initial IMO greenhouse gas (GHG)
strategy, that included its ambitions related to decarbonization. It wants to reduce CO2 emissions
across international shipping by at least 40% by 2030 and by at least 70% by 2050 compared to 2008.7
IMO already developed several measures to reduce carbon emissions, of which the Energy Efficiency
Design Index (EEDI) and the Energy Efficiency Existing Ship Index (EEXI) are the most important
technical ones. Those are respectively applicable to newbuild and existing vessels. The Ship Energy
Efficiency Management Plan (SEEMP) and Carbon Intensity Indicator (CII) are the most important
operational measures. Whereas EEDI, EEXI and SEEMP are applicable to ships of 400 GT and
upwards and therefore also to some of the ships in scope of our study, the CII requirements will only
be applicable for ships above 5000 GT because they are linked to the IMO Data Collection System
(DCS). Hereafter those four measures will be shortly discussed.
Energy Efficiency Design Index (EEDI)
The first mandatory measure introduced by the IMO is the Energy Efficiency Design Index. This is
the most important measure to induce companies to use more energy efficient and less polluting new
built vessels. The index came into force in 2013 and is expressed in grammes of CO2 emitted per unit
of transport work (gCO2 per tonne mile for example). Therefore a high value of the index
characterizes a vessel with a low energy efficiency. In future years, the energy efficiency will be
6 https://www.nationaalenergieklimaatplan.be/nl 7 https://www.imo.org/en/MediaCentre/HotTopics/Pages/Reducing-greenhouse-gas-emissions-from-ships.aspx
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measured by comparing the value of the EEDI against the baseline value that was initially set. The
EEDI differs for vessel types and segments as well as the relative reduction of the index that should
be met. Every five years the EEDI for the new built vessels is tightened and more stringent goals are
set. How those objectives should be achieved is not specified. Companies are free to choose the most
preferred technology. This freedom should stimulate innovation and cost-effectiveness.8
The following types of vessels were included in the initial scope: tankers, bulk carriers, gas carriers,
general cargo ships, container ships, refrigerated cargo carriers and combination carriers. However in
2014 the selection of vessels in scope was widened. Liquefied natural gas (LNG) carriers, Roll-on,
Roll-off (RoRo) cargo ships, RoRo passengers ships and cruise passengers ships with non-
conventional propulsion were added. The regulations are applicable on the forementioned new built
vessels with a GT bigger than 400 GT.9 This means, however, that not all vessels of our scope are
under the EEDI regulation, like for example fishery boats and tug boats. In addition IMO regulation
is not applicable on domestic navigation, which means that the emissions of domestic navigation,
which is an important part of this study, are not addressed by the IMO regulation as specified in
MARPOL Annex VI, regulation 19.10
Energy Efficiency Existing Ship Index (EEXI)
The Energy Efficiency Existing Ship Index is a requirement solely applicable on existing,
internationally navigating, vessels larger than 400 GT and was approved in November 2020. The
EEXI can be seen as an addition to the EEDI requirements for existing vessels and is about to enter
into force in 2023, pending its adoption in 2021.11
Ship Energy Efficiency Management Plan (SEEMP)
The Ship Energy Efficiency Management Plan (SEEMP) is a mandatory operational measure to
reduce the emissions and improve the efficiency of existing vessels with a gross tonnage above 400
GT. IMO provides guidelines on best practices of energy efficient ship operation, as well as guidelines
for voluntary use of the Energy Efficiency Operational Indicator (EEOI). The latter is a monitoring
tool to manage the ships and fleet efficiency performance over time. By implementing the plan,
shipowners have to explore and consider new technologies and practices that improve the efficiency
of their vessels.
Carbon Intensity Indicator (CII)
Pending its adoption in 2021, the carbon intensity indicator and rating scheme will be applicable to
all vessels larger than 5000 GT . Ships will be rated with a rating of A to E on an annual basis. The
rating mechanism will become more and more strict, so that the energy efficiency of the vessels will
increase. When a ship receives a D or E rating for three consecutive years, an action plan should be
developed that pursues a better rating. This plan should be included in the SEEMP.12
8 https://www.imo.org/en/OurWork/Environment/Pages/Technical-and-Operational-Measures.aspx 9 https://www.ilent.nl/onderwerpen/aanvragen-certificaten/ieec-en-seemp 10 https://www.imo.org/en/OurWork/Environment/Pages/Index-of-MEPC-Resolutions-and-Guidelines-related-to-
MARPOL-Annex-VI.aspx 11 https://www.dnvgl.com/maritime/insights/topics/eexi/index.html 12 https://www.dnvgl.com/maritime/insights/topics/decarbonization-in-shipping/regulatory-overview.html
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IMO Data Collection System (DCS)
In March 2018 the Data Collection System entered into force, requiring vessels above 5000 GT to
collect details on the consumption of fuel oils used. The data captured is reported to the flag state on
an annual basis, and thereafter transmitted to the IMO Ship Fuel Oil Consumption Database. The
methodology applied to collect the data and report it to the member state is to be included in the
SEEMP.
2.1.2 European level
On a European level, the importance of decarbonizing maritime shipping is emphasized by the
European Green Deal as communicated by the European Commission in December 2019. EU’s
ambition is to become the first climate neutral continent by 2050. With regard to shipping, the
commission indicated several measures that could be considered to achieve this goal: including
shipping into EU ETS, re-considering tax exemptions for conventional maritime fuels, scaling up
production and deployment of alternative fuels and regulating access for the most polluting vessels
in ports and waterways. The EU parliament endorsed the importance of these initiatives, however
they stressed to not undermine the competitiveness of the EU flagged ships. The focus here should
also be on not implementing double regulations, i.e. the measures should be complementary to other
international maritime regulation. Bringing the European Monitoring, Reporting and Verification
(MRV) system in line with the IMO DCS is one important aspect.15
Monitoring, Reporting and Verification (MRV)
The EU monitoring, reporting and verification (MRV) system was introduced under Regulation (EU)
2015/757.13 This system reports and monitors the fuel consumption, CO2 emissions, transport work
per voyage and this on an annual basis, for vessels calling at EU ports.14 The commission estimated
that by implementing this system, awareness and transparency would increase and the emissions and
fuel consumption could drop by 2% on an annual basis. However, the MRV is only implemented for
vessels above 5000 GT. Fishery boats, dredging vessels and offshore supporting vessels are not
included. Therefore this system will not be discussed in detail here.15
2.1.3 Belgian level
In line with the European ambition, Belgium’s National energy and climate plan reflects the ambition
to reduce the non-ETS emissions, including emissions from transport with 55% by 2030 compared
to 2008. The goal is to be a climate neutral country by 2050. The federal public services, representing
Belgium in IMO, continue to strive for ambitious international regulations, and advocate for
measures that lead to effective GHG emission reductions. Belgium furthermore supports initiatives
for the uptake of alternative fuels and also focusses on the implementation of shore power
infrastructure. The Belgian federal government endorsed these ambitions in a policy statement of 5
November 2020 from the Minister for North sea.16,17
13 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R0757 14 https://ec.europa.eu/clima/policies/transport/shipping_en 15 https://www.europarl.europa.eu/RegData/etudes/BRIE/2019/642224/EPRS_BRI(2019)642224_EN.pdf 16
https://diplomatie.belgium.be/nl/Beleid/Coordinatie_europese_zaken/Beleid_belgie_binnen_EU/Energie_en_klimaat 17 https://www.blauwecluster.be/nieuws/nieuwe-beleidsverklaring-voor-de-noordzee-kleurt-blauw
15
2.1.4 Local level
On local level, several initiatives are taken with regard to the supply of alternative fuels, especially in
the ports of Antwerp, Ghent and Zeebrugge, with primary focus on hydrogen and ammonia. Some
of them will be discussed hereafter.
Promotion of energy efficient vessels and alternative fuels
As mentioned before, Belgium emphasized the importance of alternative fuels in their new national
climate plan submitted in 2019, like amongst others: LNG, ammonia, hydrogen and biofuels. A study
on safety of bunkering facilities for LNG has already been carried out in 2012 commissioned by a
consortium of the Flemish department of mobility and public works, the port of Antwerp and
Fluxys.18 This demonstrates that the believe in alternative fuel applications is already present for a
longer period.
Shore power infrastructure
The interest in shore power infrastructure has gained more and more attention in recent years. At
this moment many vessels need to rely on their own electricity supply when they are not navigating
and are stationary in the port. Their electricity supply is originating from fossil fuels, which logically
has an impact on GHG emissions as well as particular matter, NOx and other harmful pollutants.
When instead shore power would be used no pollutants would be emitted locally. The only emissions
would originate from the electricity production.
In 2012, a consortium of the Port of Antwerp, Flemish department of mobility and public works,
Waterwegen en Zeekanaal NV, nv De Scheepvaart and the port of Ghent, investigated the
possibilities of a shore power network in Flanders. As part of the shore power network a uniform
management and payment system would be adopted as well. The study resulted in the adoption of
an online operational Central Management system, as well as a pilot project that installed and adapted
shore power boxes in three locations that were connected to the central system. The last objective
was to develop a strategy to simulate the expansion of shore power in Flanders. Although this study
was related to shore power for inland navigation and not for maritime navigation, the study is an
important indication that the technology gains interest and that it can be expanded to the maritime
sector as well.19,20 The port of Zeebrugge for example expressed its interest in the technology and
emphasized the benefits of it. Zeebrugge also has wind turbines that could supply renewable energy
to the charging points.21
2.1.5 Public initiatives and relevance for the study
From the previous sections, it is clear that several public initiatives exist to decarbonize maritime
shipping. On a national and regional level, stakeholders emphasize the importance to implement
regulation on a sufficiently high level, i.e. worldwide and European, because the one-sided
implementation of national or regional decarbonizing measures would deteriorate the competitive
position of the local maritime sector. In addition, the focus lies on adopting alternative fuels and
shore power infrastructure.
18 https://www.mobielvlaanderen.be/persberichten/artikel.php?id=489#gsc.tab=0 19 https://www.binnenvaartservices.be/walstroom/docs/2016-08-tent-walstroom-samenvatting-en.pdf 20 https://ec.europa.eu/inea/ten-t/ten-t-projects/projects-by-country/belgium/2012-be-92063-s 21 https://portofzeebrugge.be/nl/de-haven/duurzaamheid/walstroom
16
This high level approach is understandable, but most of the international and European regulation
focusses on vessels larger than a specified gross tonnage. The EEDI, EEXI and SEEMP for example
are only applicable on international, and thus not domestic, navigating vessels bigger than 400 GT.
For the IMO monitoring system DCS and CII the same holds true, but for vessels larger than 5000
GT. The European monitoring system captures all vessels calling at EU ports and larger than 5000
GT.
It is therefore clear that not all vessels in scope of this study are captured by the international and
European legislation. This once more indicates the relevance of this study, to also discuss the
decarbonizing possibilities of smaller vessels.
2.2 Private sector initiatives and measures
Besides the measures taken in the public sector to comply with the ambitious climate goals, there are
private initiatives as well. Those pilot projects and initiatives are implemented because the involved
companies on the one hand want to contribute their bit in reducing greenhouse gas emissions. On
the other hand they believe that investing in those technologies will be profitable in the future and
will yield them a high return on investment. Those private initiatives are often the result of a
collaboration between two or three companies. Most of them are private projects and therefore ad
hoc and without an overarching vision. The following elaborates on some of these initiatives.
MIDC platform of the Royal Belgian Shipowner Association
The Royal Belgian Shipowners Association (RBSA) was founded in 1909. Since then almost all
shipowners navigating under the Belgian flag are affiliated with the organization. The RBSA has the
goal to represent their partners in dealing with the authorities and social partners, as well as to defend
their common interests.22 In 2016 the association created the Maritime Industry Decarbonisation
Council (MIDC), because they recognized the importance of acting to decarbonize the maritime
sector. MIDC is a platform enabling different stakeholders, like for example shipowners, charterers,
engine makers, to collaborate on decarbonization activities. Those activities are mainly focused
around sharing information related to technological innovation, access to finance and clear
regulations. Thanks to this platform and the collaboration, the different stakeholders can bundle their
efforts and therefore succeed in decarbonizing the sector in the most cost-effective way.
The RBSA focusses via MIDC on different types of measures on the short, as well as on the long
term. Operational and technical measures can be applied and installed in a rather short term. Those
actions could for many vessels already reduce emissions with about 30% against the initial baseline
set in 2008. Besides those short term measures, the long term measures are important as well. Those
give the opportunity to tackle the decarbonization efforts on a more structured and efficient way, and
they give the possibility to implement more innovative technologies and actions. Alternative fuels,
for example, require many in depth studies on several topics like safety, education of workforce and
financials. MIDC helps to structure the debate on all these issues in the setting of a think tank by
industry.23
22 https://kbrv.be/royal-belgian-shipownersassociation/ 23 https://midc.be/about/
17
BeHydro
One of the most promising private initiatives in Belgium is the foundation of BeHydro. BeHydro is
a joint venture between CMB, an Antwerp based Belgian shipping company founded in 1895, and
Anglo Belgian Cooperation (ABC), a motor building company based in Ghent, Belgium and founded
in 1912. This joint venture has the ambition to develop different maritime and rail related hydrogen
applications, because they recognize the work that needs to be done to make the transportation sector
more green and sustainable. The emissions of harmful pollutants need to be reduced in the maritime
sector as well as for transport on land. The other ambition of Behydro is to invest in R&D and
therefore develop a financially profitable business case.
One of the technologies the joint venture developed, is a dual-fuel motor, that operates on 75%
hydrogen and 25% diesel. This motor is based on the initial DZC motor of ABC. Diesel is only
needed in this motor for the initial fuel injection. However, when no hydrogen is available the engine
is capable to immediately change to a monofuel diesel operation. Figure 5 explains how the
combustion works. The fact that a substantial lesser amount of diesel is needed to run this motor, if
enough hydrogen is available, makes it possible to efficiently reduce emissions. The motor emits 65%
to 85% less CO2. The emissions of other pollutants is depending on the quality of the after-treatment
systems, that reduces amongst other things the amount of NOx emitted. Besides this dual-fuel engine,
there also is a full hydrogen motor available, that emits no CO2.
Figure 5: Behydro hybrid diesel/hydrogen engine.24
Currently BeHydro has 4 different engines in its product range with 6, 8, 12 and 16 cylinders. Their
theoretical power ranges are respectively: 1000, 1335, 2000 and 2670 kW. For the first two engines
the cylinders are placed in line. Those from the 12 and 16 cylinder engines are set up in V-shape. All
those engines are spark ignited. Comparing these technical specifications to those of engines on for
example tugboats25 26, dredging vessels27 and fishery boats28, leads to the conclusion that those
engines are capable of replacing the engines of the existing vessels.24
The biggest advantage of this system is that no expensive investments should be made in the
equipment needed for propulsion with fuel cells. The motor developed by BeHydro is a retrofit on
existing engine which makes it financially more feasible. Besides this advantage the possibility for a
dual-fuel engine allows to more gradually invest in hydrogen infrastructure. A disadvantage that
24 https://www.behydro.be/en/home.html 25 https://www.multraship.com/images/fleet/downloads/fleet_89_attachment.pdf 26 https://www.multraship.com/images/fleet/downloads/fleet_78_attachment.pdf 27 https://www.jandenul.com/sites/default/files/2020-10/De%20Lap%C3%A9rouse%20%28EN%29.pdf 28 https://www.statistiekvlaanderen.be/nl/vissersvloot
18
should be mentioned is the lower volumetric energy density of hydrogen, which has an impact on the
autonomy of the vessels equipped with this engine. The more hydrogen the engine is using the less
autonomy the vessel will have. Therefore the technology is only applicable on vessels with a short
travelled path. This makes it a good technology for some of the vessels in the scope of this study.
Cooperation agreement to bring hydrogen expertise together
In November 2019 seven big industrial companies and public stakeholders - Deme, Engie, Exmar,
Fluxys, Port of Antwerp, Port of Zeebrugge and WaterstofNet - agreed to cooperate in establishing
a hydrogen economy in Belgium. Two crucial elements were identified. First, the availability of
renewable energy is crucial to produce green hydrogen. Second, efficient and economically feasible
technologies should be adopted to import, transport and store hydrogen. It is with regard to the latter
aspect that the aforementioned stakeholders will work out a study that will combine and bring
together their relevant expertise and knowledge in a structured way.
First alternative energy hub with LNG
In 2016 the port of Antwerp and Engie group agreed upon a concession to build an alternative energy
hub for LNG bunkering in the port. This LNG bunkering installation was the first shore to ship
bunkering station in Europe and is active since 2017. Both partners contributed to the realisation of
this project starting from their own interests.
The port of Antwerp has a leading role in Europe in promoting green and sustainable ports. In the
past years, several projects, some of which in collaboration with other ports, have been realised
focussing on LNG as one of the early identified alternative sustainable fuels. The realisation of the
first LNG bunkering facility in Europe puts this ambition into practice, and makes LNG permanently
available for several vessels. Vessels that are able to bunker LNG are inland navigation vessels, smaller
maritime vessels, dredging vessels and tugboats. This makes the initiative of relevance in this study.
Engie, the other partner in the project, wants to become a leading company, amongst other things,
in the energy transition in the transport sector. They acknowledge the importance of the usage of
more sustainable and more green solutions in the transport sector, because currently too much
harmful pollutants are emitted, which is bad for human health. Engie was responsible for the
realisation of this alternative bunkering station, and is responsible for the maintenance and operation.
Although the primary focus was on inland and coastal navigation, dredgers and tug boats, this
initiative could serve as well for other maritime vessels.29,30
Besides the above discussed example, several other projects have been carried out by different
consortia to implement LNG bunkering stations in the Belgian ports. Fluxys for example realized a
facility in the port of Antwerp as well as in the port of Zeebrugge. Both are already fully operational
and supply small vessels navigating on LNG. Bigger vessels, LNG carriers, could also be served by
these bunkering facilities.31,32
29 https://www.portofantwerp.com/nl/news/eerste-alternatieve-energiehub-met-lng-voor-binnenscheepvaart-en-
wegtransport-belgi%C3%AB 30 https://www.portofantwerp.com/nl/news/energietransitie-de-antwerpse-haven-nieuwe-impuls-voor-lng-als-
alternatieve-brandstof-voor 31 https://www.fluxys.com/nl/products-services/lng-ship-loading 32 https://www.fluxys.com/nl/products-services/lng-bunkering
19
3 Greenhouse gas reducing measures for
vessels smaller than 5000 GT
Where the previous chapter discussed the public and private initiatives already existing to reduce the
carbon emission of the maritime sector, this chapter will go deeper into further possible
decarbonizing measures. Section 3.1 will describe the possible technical measures, and section 3.2
will handle possible operational measures. The measures that will be described, will be applicable on
vessels smaller than 5000 GT, with a focus on the vessel types that are the main contributors to the
carbon emissions of studies scope as mentioned in sections 1.2.1 to 1.2.4. Besides these vessel types,
there will be a focus on the category of ships strongly represented in the Belgian market, such as
supply vessels for off-shore activities.
3.1 Technical measures
The measures discussed here to decarbonize the maritime sectors in scope, i.e. Belgium maritime
navigation, international maritime navigation in Belgian waters, estuary shipping and recreative
shipping for vessels smaller than 5000 GT, are based upon the review of secondary sources, published
reviews and technical studies and publications from SINTEF ocean. Besides the theoretical
background provided by scientific papers, the results of stakeholder consultation will be included as
well. Stakeholder consultation was performed by means of bilateral communication as well as by a
survey handling several aspects related to the hereafter proposed measures.
Figure 6 gives an overview of the potential of several CO2 equivalent reducing measures by Bouman
et al. (2017). This overview was based on a review of nearly 150 publications. Although the review
does not differentiate the vessels types and sizes, it reports several measures that could be applicable
on smaller vessels as well. After screening the proposed measures on applicability on smaller vessels,
the following technical measures will be further discussed in this report:
• Hull design optimization
• Alternative maritime fuels (H2, NH3, LNG, Synthetic e-fuels, biofuels)
• Electric propulsion solutions (Hybrid propulsion and Electric propulsion)
• Wind assisted propulsion
• Energy Efficiency and Propulsion Efficiency Devices
Besides those technical measures, also two operational measures will be discussed. This is significantly
less than the technical measures, because most of the operational measures are applicable on
transport and trips with a certain length, which hardly is the case for those small vessels in scope.
The discussion of the technical and operational measures will focus on applicability, technological
feasibility, reduction potential and possible shortcomings or points of attention. The discussion of
the Energy efficiency and Propulsion Efficiency Devices will be discussed with the emphasis on the
relation between energy saving potential and cost-effectiveness.
20
Figure 6: CO2 emission reduction potential from individual measures (Source: Bouman et al., 2017).
3.1.1 More slender hull
The main goal of hull optimization and using a newly designed hull is reducing the friction of the
vessel and therefore the drag on the vessel. When the drag forces and thus the friction is lowered,
the power requirement will be lower for the same capacity carried. Therefore the amount of fuel
combusted is also significantly lowered. This has a direct impact on the emissions of the vessels.
Several options exist to lower the friction of the vessel with the water. One option is to reduce the
speed as will be explained in section 3.2.1. When it comes to hull design the optimal form can be
obtained by experimenting with the different parameters that specify the form of the hull; the length,
beam and block coefficient. Empirical evidence will then lead to the most optimal solution. Several
options also exist in how to optimize the hull shape, and have been tested in practice as well.
However, in many cases this experimentation leads to a more slender hull than the normal hull design
of conventional vessels. The drag reduction is achieved because these more slender hulls are more
streamlined and less full-bodied than conventional hulls.
The emission reduction potential of this technology is based on two main parameters related to the
friction the vessel experiences with the water, the navigation speed and the height of the waves
through which it navigates. Figure 7 shows the required power for navigating at a certain speed for
different heights of waves. In calm water at low speeds the influence of the slender form on the
required power and therefore also emissions, is negligible. When navigating at higher speeds and
navigating in less calm waters the benefits of the slender hull form become visible. Because of this
the estimation of Lindstad et al. (2015, 2016, 2017 and 2018) for the reduction potential also
21
differentiates between ocean going vessels and shortsea vessels. They estimated that the relative CO2
emission reduction potential lies between 2% and 30% for ocean going vessels, and between 13%
and 28% for Shortsea vessels.
Figure 7: Power requirements for conventional and more slender hulls (study of average power demand
for a conventional vessel design with a block coefficient of 0.82, versus a slender design with a block of
0.75, both with a deadweight of 110,000 tons) (Source: Lindstad and Bø, 2018).
Figure 8 is comparable to Figure 7 but only differentiates upon two parameters, the navigation speed
and the slenderness of the vessel. The legend shows the dimensions of the hull, where the last
parameter is the block coefficient. It can be seen in the figure that the lower this coefficient gets the
less CO2 per ton km is emitted. This information shows that speed is a very important parameter to
establish successful decarbonization with this technology. This means that although the technology
is applicable on all types of vessels, it will only be effective on vessels that reach a certain speed and
vessels that navigate in relative uncalm waters.
22
Figure 8: Gram CO2 per ton km as a function of speed, for alternative shortsea vessels hull designs, at
50% load factor on a roundtrip basis. Study applied to the European General Cargo Fleet (Source:
Lindstad et al. 2016).
Applicability on vessels in scope
Because this study focusses on the Belgian maritime emissions, there should be looked at the potential
reduction in the North Sea. The region in scope of this study is the North Sea, therefore the reduction
potential lies between 13% and 28%, as is estimated in the study. The concrete reduction potential is
strongly depending on weather conditions. The Belgian part of the North Sea is characterised by
many short and relatively low height waves. The Flemish institute for the sea (Vlaams Instituut voor
de Zee (VLIZ)) reported an average wave height of 1m and an average period of 6s.33 Figure 7
indicates how speed and wave type relate to the power reduction potential. Interpreting this graph
declares that vessels navigating in the North Sea will be situated in the lower range of the possible
reduction potential, stated earlier. This reduction potential holds true for the following vessels in
scope of this study: cargo vessels (general and container), tanker vessels and estuary shipping vessels.34
This technology can also be applicable on fishing vessels, however no real examples exist of vessels
that implemented a more slender hull. This is because of the life cycle and stability concerns of those
vessels. Nevertheless a concept fishing vessel of DNV-GLS, “Catchy”, reports a reduction potential
of 3%. Yet it needs to be mentioned that this is still a concept vessel and no reduction potential is
known for North Sea fishing navigation.35
Based on this, it can be concluded that cargo ships, tankers, estuary vessels and fishing boats will be
the most suitable vessels to achieve a CO2 reduction in an efficient way with this technology. For
33 http://www.vliz.be/imisdocs/publications/140590.pdf 34 Eskeland, G.S., Lindstad, H.E., Sandaas, I. and Steen, S., 2016, January. Revitalization of Short Sea Shipping Through
Slender, Simplified and Standardized Designs. In SNAME Maritime Convention. The Society of Naval Architects and
Marine Engineers. 35 https://sintef.brage.unit.no/sintef-xmlui/bitstream/handle/11250/2684524/CoolFish%2b-%2bReport%2b-
%2bPropulsion_and_fuels%2b-%2bsigned.pdf?sequence=1&isAllowed=y
23
small vessels, the fuel savings achieved by hull optimization with a smaller hull are comparable to fuel
savings obtained by scale benefits when doubling the vessel size of a ship with a conventional hull.
Figure 9 gives an overview of the reduction potential of this technology for the vessels in scope. The
reduction potential for container, estuary shipping, general cargo, tanker and vehicle cargo is based
on research from Lindstad et al. (January 2016) on short sea shipping vessels. For fishing vessels this
is based on a concept study of DNV-GLS. For dredgers, pleasure boats and tugs the technology is
not applicable, for gas tankers it is not realistic. This is explained hereafter.
Figure 9: Indication of reduction potential per vessel type. (Green = feasible, red = not realistic, black =
not applicable).
Technical concerns
Tugboat owners indicated that this technology will not be an option because a different hull design
will have a dangerous impact on the stability of the vessel under certain load conditions. Tugboats
are small powerful vessels that need their current hull shape to perform properly.
For dredging vessels, the same holds true. Those vessels perform very specific tasks and changing
the hull would have implications on the operability. Besides this, a more slender hull would reduce
the capacity of the vessel. Because those vessels most often navigate well completely loaded, a smaller
hull would result in a smaller capacity, which is not acceptable.
The implementation of this technology on pleasure boats is strongly depending on which vessel type
is used. Yacht owners for example indicated that retrofitting the hull of an existing vessel would be
complex and therefore not preferable. Other smaller boat clubs indicated that the cost of hull
optimization is too high for the reduction potential. In addition, stakeholders also indicated that this
category of vessels is continuously improving the design and therefore the additional gains are limited.
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For Gas Tankers, this technology is not realistic. Gaseous liquids do have a very low density and
therefore occupy a very large volume. Those vessels thus have a very specific design to transport this
bulky liquids.
This means that when the adoption of this technology is considered, some concerns should be taken
into account. In the first place the slender hull design of the hull is only applicable on newbuild
vessels. A retrofit is not possible with this technology. Most vessels on which this technology can be
applied (fishery boats, cargo ships, tankers), have a very long lifetime and will be used as long as
technically possible. This has an impact on the reduction potential of this technology on the short
term, and must be taken into account when considering to implement it. However some technologies
exist that pursue the same goal of reducing the friction and therefore the drag force, fuel
consumption, and emissions emitted. Some of those technologies can be retrofitted on existing
vessels and will be discussed later on.
No matter which way you twist or turn it, the slender hull design will have an impact on the technical
specifications of the vessel and will impact the usage of the vessels. The operation profile of the
vessel should therefore be taken into account when investigating the possibility to perform hull
optimization.
3.1.2 Alternative maritime fuels
Currently most of the vessels in scope and in general are navigating on conventional maritime fuels.
Relatively few vessels are navigating on other fuels in Europe and the world. This is mainly due to
the tax exemptions that are applied for conventional maritime fuels. However, research is done into
several other maritime fuels by research institutions, universities, sectorial players and other
stakeholders. This has led to several new fuels. Some of those fuels are broader investigated than
others. The following ones will be discussed: liquified natural gas (LNG), hydrogen (H2), ammonia
(NH3) and synthetic e-fuels.
LNG
LNG or liquified natural gas is a fossil fuel that can be used as an energy source for maritime
navigation. The development of the technology that enables the usage of it as a maritime fuel and an
alternative for maritime gasoil (MGO) and heavy fuel oil (HFO) has been triggered in 1980 by the
beneficial environmental aspects of it over the conventional fuels. The usage of LNG namely has
three big advantages. The emissions of SOx have been reduced to nearly zero, since LNG does not
contain any sulphur. During the combustion stage of LNG, no particular matter (PM) is emitted as
well. A last advantage is that thanks to the usage of low pressure Otto-process engines the emissions
of NOx did drastically drop.
Besides these environmental benefits, there are also climatic benefits during the combustion stage.
The emissions of CO2 are about 25% lower compared to conventional fuels, as was estimated in a
study of Lindstad et al. (2020). Bouman et al. (2017) even reports a reduction potential of about 30%.
This is due to the high hydrogen-to-carbon ratio. However to estimate the CO2 emissions, the well-
to-tank (WTT) emissions should also be taken into account. These mainly relate to the CO2 emitted
during the process of extracting LNG from its gas source, treating it to a usable fuel and transporting
it to the tank of the respective vessel. When in addition the leakage of un-combusted methane is
taken into account, the climatic advantages of LNG compared to HFO and MGO are significantly
weakened. During WTT as well as during tank-to-wake (TTW) the leakage of methane directly in the
atmosphere can occur. Since methane’s greenhouse gas potential is much worse than CO2 itself, this
25
is a very severe situation and methane leakage should be reduced to make LNG a climatic interesting
fuel.
Figure 10: WTW CO2 eq. emissions per kWh (GWP100) as a function of fuel and a 4-stroke engine
(Source: Lindstad et al., 2020).
Figure 10 translates this information into a graphic representation. It indicates the percentual
difference in emissions between Marine Gasoil and LNG. This leads to a potential CO2 equivalent
reduction of 15% to a CO2 equivalent increase with 8%. This information clearly shows that the
decarbonizing potential of this fuel is limited. Other technologies presented here will have a higher
climatic impact. However there is still a climatic reduction potential, and big environmental benefits
occur when using this fuel. From this point of view using LNG as a maritime fuel can certainly be
beneficial. A broader discussion on the environmental benefits of this technology however falls out
of the scope of this study.
Applicability on vessels in scope
Figure 11 shows the reduction potential of the vessels in scope of this study. The overview is mainly
based on the information given in the previous section and shown in Figure 10. The extrapolation to
the vessels in the scope of this study is legitimate, because this reduction potential holds true for all
vessels using 2-stroke engines. For 4-stroke engines used in the vessels in scope this technology will
not be applicable, because those still need to be developed. For pleasure boats the technology is
technically feasible, however the are some obstacles that will be explained hereafter that holds back
the adoption of this technology for this category of vessels.
26
Figure 11: Reduction potential per vessel type LNG. (Green = feasible, Orange = technically feasible but
big obstacles).
Technical concerns
In Figure 11, pleasure boats are indicated as technically feasible but having big obstacles that hinder
the adoption of the technology. This statement is confirmed by several pleasure boat organizations.
Mostly representatives of small pleasure boat associations indicated that the implementation of this
technology on smaller vessels is feasible but the storage volume still is a technical concern. In
addition, the extra tanks needed are hard to implement on the small space available. Besides these
concerns, the investment in this technology is very costly.
For fishing vessels, literature suggests that reduction potential is in line with the estimations for other
vessels using dual stroke engines. However for the same space and costs concerns as for pleasure
boats, the technology will be hard to implement and therefore, not the best option for the fishery
boats in scope of the study.
For the other vessels in scope, a study of the European commission reports the price gap between
LNG and HFO will become smaller in coming years36, and thanks to its good environmental
perception compared to conventional fuels, it therefore can be expected that a growing number of
ships are to be delivered or retrofitted with dual-fuel Otto engines fulfilling all EEDI requirements.
However the GHG savings on a well-to-wake (WTW) basis even in the best case scenario will be
next to nothing, due to methane leakage. Almost all stakeholders mention the impact of methane
leakage and therefore do not think that it is a good way to reduce carbon emissions. Nevertheless
studies show that the local environmental benefits are substantial. This can beneficial for vessels that
are navigating close to inhabited areas.
36 https://ec.europa.eu/transport/sites/transport/files/2015-12-lng-lot3.pdf
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Unconventional fuels: hydrogen (H2) and ammonia (NH3)
Unconventional fuels like hydrogen and ammonia have been recognized to have a high potential in
reducing greenhouse gas emissions of several economies. This is not different for the maritime sector.
Several technologies exist to convert the energy stored in those fuels into useful power at the screw
of the vessel. Figure 12 indicates the different options for hydrogen as well as for ammonia. Both
have two comparable solutions. For hydrogen propulsion, the fuel should be produced in the first
place. This can be done by different industrial processes. A distinction is therefore made between
green, blue and grey hydrogen, however, it is not the goal of this report to go deeper into the different
sources of hydrogen, therefore there will be a focus on green hydrogen here. Green hydrogen is
produced from the electrolysis of water using renewable electricity to power this process. Once the
hydrogen is produced it must be liquified. Thereafter two possibilities exist. The hydrogen can either
be used in a combustion engine (cfr. BeHydro motor) and will be powering the vessels screw via the
thermotechnical process, or a fuel cell will convert the hydrogen in electricity that is on its own turn
converted into mechanical work at the screw via an electric motor.
The process to use NH3 as maritime fuel is comparable to that of hydrogen. A first step is to produce
hydrogen., for which exist several options as well. Secondly, nitrogen must be produced. This is done
by air separation. Thereafter the hydrogen and nitrogen will form ammonia in a synthesis process.
Once the ammonia is formed, the same steps follow as for hydrogen. Either it can be used in a
combustion engine, by simply burning the fuel to release the energy and transform it to mechanical
power at the screw by a thermotechnical process, or the energy stored in ammonia can be converted
into mechanical work at the screw, via a solid fuel cell and an electric motor.
Figure 12: Energy chains for powering ships with renewable energy sources. (Source: International
Transport Forum 2020).
Because the chemical formula of hydrogen and ammonia both do not contain any carbon element,
the conversion of this fuel to mechanical power at the screw will not produce any CO2 emissions nor
the combustion of it nor the conversion in a fuel cell. This means that the potential to decarbonize
maritime navigation with those fuels is high. However this only describes the tank-to-wake emissions
of using those fuels. Besides these emissions, the well-to-tank emissions should also be taken into
28
account. These will be emitted in the production process as described earlier. When all the steps in
the process are powered by using renewable electricity, the well-to-wake emissions of CO2 will be
zero as well. However if grey hydrogen is used, this is hydrogen produced from a gas steam reforming
process, or when it is produced by using the European electricity mix, the CO2 emissions will not
equal zero. Figure 13 gives a schematic overview of this. Depending on how the fuel is produced and
whether the CO2 produced in the production process is captured or not, the total CO2 emissions of
the usage of H2 and NH3 can strongly vary.
Figure 13: WTW CO2 equivalents (incl. CO2, CH4, N2O) from various hydrogen and ammonia fuel
pathways, compared to conventional fuels (MGO used as reference fuel for % variation) (Source: SFI
Smart Maritime 2020, Lindstad 2020).
In addition to the information on the energy chain of hydrogen and ammonia, Figure 12 also gives
an insight on the energy chain and the efficiency of electric propulsion, where the (renewable)
electricity is stored in a battery and directly used by an electric motor to propel the vessel. This
indicates that of the 100 kWh renewable electricity, electric propulsion will efficiently use 76% to
80% of it. For hydrogen this respectively is 15-25% and 18-26% by using a fuel cell and an electric
motor, and a combustion engine. For ammonia the efficiency is slightly higher, 22-31% by using the
combustion engine and 24-38% by using the solid fuels cells and the electric motor. Directly using
the electricity via a battery and an electric motor is by far the most efficient way to propel a vessel.
This information therefore raises serious questions, whether the renewable electricity available should
be used to produce hydrogen and ammonia, because the propulsion efficiency of these fuels is much
lower than electric propulsion via batteries. Batteries and electric propulsion, however, do also have
shortcomings which will be discussed later.
29
Applicability on vessels in scope
Figure 14 displays the reduction potential for the different technologies from tank-to-wake. For
container vessels, gas tankers, general cargo, tankers and vehicle cargo the reduction potential during
navigation will be close to 100%, since those fuels do not contain carbon elements.37 However big
obstacles exist as will be shown later on. For the vessels indicated with a red marker the technology
is not realistic to implement. For vessels in black it is not an option, as will be discussed in the next
section.
Figure 14: Reduction potential of H2 and NH3 per vessel type. (Green = feasible, Orange = feasible with
big obstacles, Red = Not realistic, Black = not applicable).
Technical concerns
For fishing vessels and pleasure boats in the scope of this study, hydrogen and ammonia are not
applicable as maritime fuels. This is mainly because for these two categories the shipowners often
work on their engines themselves, instead of working with specialized firms. Because hydrogen and
ammonia are completely other fuels than the conventional maritime fuels this could lead to dangerous
situations with risk for explosion. In addition, the extra storage tanks needed are heavy and require a
lot of space, which means retrofitting this technology would be hard. Even for newbuilds this concern
forms a big obstacle.
The same holds true for the dredging vessels, estuary shipping and tugboats. Those vessels often
have a very specific design and the vessels in scope of the study are rather small, which means the
extra space and weight of the storage tank is too difficult to build on these types of vessels.
The retrofitting obstacle is mentioned by several smaller recreative shipping associations. However
the biggest concern mentioned by recreative shipping associations and tugboat owners from the
37 Lindstad, 2020. Alternative Marine Fuels, Dr Elizabeth Lindstad, CIMAC Norway meeting 28-10-2020.
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survey is the fragile situation of the hydrogen economy. Serious infrastructure investments should be
made to transport hydrogen as well as develop bunkering facilities. But since the number of vessels
navigating on hydrogen is low, the industry is not willing to make this investment. This is the chicken
and the egg problem. Someone needs to invest first. However the BeHydro initiative, as mentioned
earlier, can ease the situation, because hydrogen can be used in the redesigned conventional diesel
engine. Thus this is a way to reduce investment requirements and it simplifies the adoption of
hydrogen as a maritime fuel.
Synthetic e-fuels
Synthetic e-fuels are relatively new fuels, that are finding their way to the maritime industry. Those
fuels are produced as shown in Figure 15. A synthesis process of captured CO2 from a certain
industrial process together with hydrogen produced from renewable electricity, leads to the
production of synthetic e-fuels. Different types of e-fuels can be produced from this process by
slightly changing the parameters. Amongst others e-diesel, e-methanol, e-LNG can be produced in
this way. The biggest benefit of these e-fuels is that they are interchangeable or can be blended with
conventional maritime fuels, as it also was the case for hydrogen in certain combustion engines.
Therefore no investments in new engines are needed. The fuel can be used in existing engines and
thus is directly usable in the current vessels.
Figure 15: Marine fuels path ways (fuel labelling: Grey = Fossil; Blue with carbon capture; Green =
Renewable; Orange = Any blending of Grey, Blue and Green) (Source: Lindstad 2020).
These fuels can be used to decarbonize the maritime industry, because they make it possible to use
CO2 as a raw material in the first place. In addition, the high energy efficiency is promising. However,
since those fuels are relatively new, a lot of research needs to be done on their impact on the
environment and the climate.
31
Applicability on vessels in scope
Figure 16 displays the reduction potential of synthetic e-fuels for the vessels in the scope of this study
for tank-to-wake emissions. As can be seen, the uncertainty for the usage of synthetic e-fuels is still
very large. The reduction potential ranges from 1% for synthetic e-diesels to 100% for amongst others
e-hydrogen.38 For all the vessels in scope of the study the adoption of synthetic e-fuels will be
technically feasible, because they can be used as drop-in fuels. However some e-fuels will not be
applicable or not realistic. For example e-hydrogen or e-ammonia will have the same obstacles as the
ones mentioned earlier in its respective section. In any case more research needs to be done regarding
those fuels, to substantiate the applicability on the vessels in scope.
Figure 16: Reduction potential of synthetic e-fuels TTW per vessel type. (orange = feasible with big
obstacles).
Technical concerns
For the case of synthetic e-fuels the same concerns hold true as for hydrogen and ammonia. Because
no existing vessels are navigating on synthetic e-fuels, the question is whether investments in crucial
infrastructure, like bunkering facilities for example, will be done to really use these fuels in maritime
shipping. If this is the case then the question rises whether the production capacity will be available
to produce these fuels in the needed quantities. If not, the prices of e-fuels, which are currently very
high compared to other fuels, will not be able to drop.
Table 1 shows current and future price projections for different types of fuels, also for different types
of synthetic e-fuels. Based on this information, synthetic e-fuels are said to be 10 to 20 times as
expensive as conventional maritime fuels. Although prices will most likely drop, industrial
stakeholders will not be willing to make big investments in these e-fuels while the future usage of
38 Lindstad, 2020. Alternative Marine Fuels, Dr Elizabeth Lindstad, CIMAC Norway meeting 28-10-2020.
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them is to be determined and very uncertain. In addition, it has to be seen whether the price drop
will be large enough to become competitive with the usual maritime fuels.
Table 1: Fuel Price Projections (2020-2050) - Lower bound (USD/GJ) from Lloyd's Register and UMAS.
Primary energy
source
Fuel 2020 2030 2040 2050
Oil LSHFO 8 11 11 11
Biomass Bio-Diesel 22 24 27 29
Biomass Bio-methanol wood 23 25 27 30
Biomass Bio-methanol waste stream 19 21 23 25
Substitution price from biofuels 9 19 26 33
Renewable electricity E-diesel 130 114 99 83
Renewable electricity E-methanol 84 73 63 52
Renewable electricity E-LNG 69 60 51 42
Renewable electricity E-ammonia 55 47 39 30
Renewable electricity E-hydrogen 52 44 36 28
Natural gas NG-ammonia 28 26 24 23
Natural gas NG-hydrogen 25 23 21 19
Biofuels
Biofuels are fuels produced from biomass as feedstock and currently heavily investigated. Several
types of biofuels do exist , such as biodiesel, biogas and bio ethanol and methanol. These biofuels
are produced from different types of feedstock.
There are multiple reasons for the increased interest in those types of fuels. A first reason is that it is
relatively easy to use this fuel as a drop-in fuel for several engines. This makes that no big investments
in technology on board of the vessels must be made, which lowers the threshold for a successful
adoption of the fuel. A second reason are the low tank-to-wake emissions of other pollutants. The
advantages are comparable to those of LNG, which means that when vessels are propelled using this
fuel type, the SOx, NOx and PM emissions are significantly reduced. However the environmental
impact is greatly depending on the type of feedstock used as well as the type of fuel. The same holds
true for the climatic impact of this fuel type. For some biofiuels, depending on the feedstock used,
significant emission reductions could be achieved and therefore it is an interesting decarbonizing
measure. Yet, for other biofuels the emissions are far greater than the emissions of conventional
maritime fuels.
33
Figure 17: WTW CO2-eq emissions per kWh (GWP100) for distinct biofuels - Source [1] is the State-of-the-Art
technologies, measures, and potential for reducing GHG emissions from shipping study (Bouman et al., 2017); Source
[2] is The Role of Sustainable Biofuels in Decarbonising Shipping (SSI, 2019) presented at Cop 25 in December
2019. Sources for [3] are: Thinkstep (2019), for the basic Biogas WTT; and Lindstad (2019), for the impact of un-
combusted methane, which is the same level as for fossil fuels..
Figure 17 illustrates this. It shows the well-to-wake CO2-equivalent emissions for several fuels.
Biodiesel made from palm oil is for example of a fuel where the decarbonization potential is
completely absent. The carbon emissions could even increase by 306%. The same holds true for
biodiesel originating from soybean oil. The complete opposite holds true for biofuel produced from
waste and residues. In this case, the carbon emissions could even be reduced to zero, because the
emissions related to this feedstock would be emitted in any case.
All those biofuels, as can be seen in Figure 17, are characterized by great uncertainty, and this is mainly
depending on the feedstock used. The production method of the respective component, the transport
mode used, as well as the land use do have a great impact on the carbon emissions. The uncertainty
of biofuels is therefore mainly captured in the well-to-tank emissions, and not really in the tank-to-
wake emissions, because the fuels are comparable to other fossil fuels. Which means that the
composition of the fuel is similar and therefore the emissions emitted during the combustion phase
are also similar. When a decarbonizing investment should be made, the emphasis should therefore
lie on the reduction potential over the whole well-to-wake emissions chain. Fuels originating from all
kinds of waste products would thus be the ideal solution. Here the emissions would be emitted
anyway, and by using it as an energy resource the climatic gains are significant. In addition, the engine
used is also of importance. A dual-fuel diesel engine is characterized by a far better thermal efficiency
than the dual-fuel Otto engine. Furthermore the diesel type engines have less methane slip compared
34
to Otto engines. Another advantage of those dual-diesel engines is the ability to combust nearly all
biofuels. A pure diesel engine is not capable of doing this and can only burn biodiesels.
Applicability on the vessels in scope
Figure 18 shows the reduction potential of the well-to-wake emissions using biofuels for the different
vessels in scope of the study. As mentioned earlier the reduction potential of this technology is mainly
situated in the well-to-tank emissions. Therefore the reduction potentials shown are equal for all
vessels in scope. They are indicated to be technically feasible but at the moment coming with big
obstacles that are explained next.
Figure 18: Reduction potential of biofuels WTW for vessels in scope. (orange = technically feasible but
big obstacles).
Technical concerns
The adoption of the technology will greatly depend on the price of the biofuel. Table 1 indicates the
price of biofuels in the previous chapter. Those forecasts show that the price of those fuels is
currently comparable to the price of grey hydrogen, hydrogen made from a natural gas reforming
process. However when the most promising - decarbonizing wise - biofuel, is used, the reduction
potential of biofuels is far greater than those of grey hydrogen for the same price, because the well-
to-tank emissions are much smaller. When focussing on green or blue hydrogen the price of those
fuels is almost double the price of most biofuels. This is even more pronounced for the synthetic e-
fuels. The estimates of the forecast however show that the prices of biofuels are increasing in the
coming years. Nevertheless, they remain one of the promising alternative maritime fuels, at least when
considered on the short term and on the condition that correct biofuels, i.e. biofuels with low overall
well-to-wake emissions, like for example biofuels originating from waste products, are chosen. The
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uptake of this technology can be intensified by introducing incentives that reduce the current price.
Although the focus should be on the correct biofuels, those with low overall well-to-wake emissions.
Since biofuels could be used in some cases as drop-in fuels, the investments in new equipment could
be weakened. This could cancel out, at least partly, the cost of biofuels at the moment.
3.1.3 Electric propulsion systems
Hereafter two electric propulsion systems will be described. One focusses on the implications of
hybrid power systems. The second one will go deeper into the option of using a full electric
propulsion system.
Hybrid power system
A hybrid power propulsion system uses a combination of two power supplies to provide power to
the propeller: a conventional diesel engine combined with a battery-electric motor. Thanks to the
electric engine, the propulsion system is better able to respond to different load conditions. Load
fluctuations will be better absorbed, which makes it possible for the diesel engine to operate in a
more steady manner. Diesel engines running at very low load conditions are also avoided when using
electric motors. This ensures that the diesel engines operate in more optimized conditions. The usage
of electric motors is also beneficial for the dynamic positioning (DP) systems. They are better suited
to provide peak power and they enable the vessel to abort its DP operation safely supposing all
engines should stop and not start again.
Figure 19 gives an overview of the different propulsion set-ups that exist for hybrid propulsion
systems. The first shown system is just a standard setup where only fossil fuel engines are used. The
second one is an option where the battery electric motors form an additional power supply to the
existing conventional engines. The last setup is one where the usage of a battery electric motor, makes
it possible to reduce the number of conventional engines.
36
Figure 19: Alternative power and propulsion setups for offshore support vessels (Source: Lindstad et al.,
2017).
Besides the operational advantages there also are the climatic advantages. With IMO and the EU
putting more and more focus on sustainability, the research into this hybrid propulsion technology
to reduce carbon emissions has been expanding. The decarbonization benefits are straightforward
during the tank-to-wheel emissions. Because no combustion process is taking place during this phase
the carbon emissions equal zero. However the same consideration as for hydrogen and ammonia
applies here. To actually decarbonize maritime navigation, the emission reduction should be
established over the whole life-cycle of the energy consumption. Therefore also well-to-tank (battery)
emissions should be taken into account. When using electricity produced from renewable energy
sources, the carbon emissions over the entire life-cycle equal zero. This is not the case when using
the standard EU electricity mix. However, as Figure 12 indicated, the energy chains of a battery
electric process have a much higher efficiency than any other propulsion technology, and therefore
this will be an efficient decarbonizing measure in any case. A recent review by Nguyen et al (2020) of
major studies on the potential of energy systems and propeller configurations in reducing CO2
emissions indicates significant potential for emission reductions by switching to electric or hybrid
propulsion systems. The reported potential of CO2 emissions reduction for hybrid propulsion spans
from 22% to 75%. A more detailed allocation of the reduction potential per vessel type is shown
hereafter.
Applicability on vessels in scope
Figure 20 shows the reduction potential of the different vessels in scope. Hybrid propulsion is one
of the technologies in scope that has already been investigated quiet extensively. This research shows
that the technology is applicable on almost all vessels in scope.
The different vessels will use hybrid propulsion in different ways. For container vessels, general cargo,
tanker and gas tanker the main support of the electric power systems will be used to power auxiliary
operations in ports like, for example, operations of cranes and pumps. In addition the power can also
37
be used for reefer plugs. The reduction potential obtained by using hybrid power systems in this way
will be around 5% as was reported by Lindstad et al.39 Kim et al. reported other numbers for a
container specific study. From their estimations the reduction potential lies between 9% and 21% for
battery/generator hybrid container vessels.40
Dredgers use hybrid propulsion systems to even out large fluctuations in power output and to replace
the auxiliary motor in parts of the operation. As reported on the dredging expo of 2017 by Vinton
Bossert the reduction potential lies around 10%.41
In estuary shipping, this technology is partly used to propel the vessels. It is possible for example to
have a combination of LNG and batteries or diesel and batteries. As estimated by Łebkowski et al.
the reduction potential of hybrid estuary shipping vessels is situated between 9% and 30%.42
For tugboats, hybrid propulsion enables a wide range of operating modes and a better combination
of distinct power systems, and therefore in most cases it is better suited for the operational profile of
tugs. Based on a study of Lindstad et al., the reduction potential of this technology is about 6% to
9% based on estimations for offshore support vessels.43
For pleasure boats, the reduction potential strongly depends on the type of vessels. In particular
newbuild small boats, yachts and touring boats could benefit from hybrid-electric propulsion systems.
The reduction potential of those vessels will be in line with those of the other vessels and will
therefore be around 10%. Sailing boats as well could use an electric motor to power the support
operations in ports.
And last for fishing vessels, hybrid propulsion contributes to the support and optimization of the
operation of the main machinery, that is less prone to load fluctuations. This means that amongst
other things support operations in ports, like using cranes, pumps, winches and power intensive
heating and cooling would be powered by electric power. A study of Gabrielii et al. from 2020 reports
a possible fuel saving of around 15%.44
39 Lindstad, E. and Bø, T.I., 2018. Potential power setups, fuels and hull designs capable of satisfying future EEDI
requirements. Transportation Research Part D: Transport and Environment, 63, pp.276-290. 40 Kim, K., Park, K., Lee, J., Chun, K. and Lee, S.H., 2018. Analysis of battery/generator hybrid container ship for co 2
reduction. IEEE Access, 6, pp.14537-14543. 41 Dredging Expo 2017. MORE EFFICIENT DIESEL. ELECTRIC POWER PLANT FOR. DREDGES. Authors:
Vinton Bossert, P.E. President, Bossert Dredge. 42 Łebkowski, A., 2018. Reduction of Fuel Consumption and Pollution Emissions in Inland Water Transport by
Application of Hybrid Powertrain. Energies, 11(8), p.1981. 43 Lindstad, H.E., Eskeland, G.S. and Rialland, A., 2017. Batteries in offshore support vessels–Pollution, climate impact
and economics. Transportation Research Part D: Transport and Environment, 50, pp.409-417; Peralta P, C.O., Vieira,
G.T., Meunier, S., Vale, R.J., Salles, M.B. and Carmo, B.S., 2019. Evaluation of the co2 emissions reduction potential of li-
ion batteries in ship power systems. Energies, 12(3), p.375. 44 Gabrielii, C.H. and Jafarzadeh, S., 2020. Alternative fuels and propulsion systems for fishing vessels. SINTEF Rapport.
38
Figure 20: Reduction potential of hybrid power and propulsion systems for the vessels in scope. (green =
technically feasible, orange = technically feasible but big obstacles).
Technical concerns
However, most stakeholders pointed at several shortcomings of the technology that should be
mentioned. One of the most stringent problems is the dependency on batteries with an energy density
that is too low, especially when compared to conventional maritime fuels. This low energy density
has implications, the batteries take up a lot of space on board of the vessel and more important the
weight of them should not be underestimated. This place and weight aspect therefore also has an
effect on the operation of the vessel and the capacity of it. More research should therefore be done
into good battery technologies for the technology to have its breakthrough.
In addition of the concerns related to the battery technology, the power supply is a problem as well.
Currently the time for loading the batteries is too long. But more importantly, although there exist
several initiatives to provide shore power and infrastructure for charging the batteries, the
infrastructure is not developed extensively enough, which hinders the adoption of the technology.
Besides these previous concerns, pleasure boat associations (yachts, small boats, tour boats) indicate
that the technology is expensive to retrofit, and should therefore be ideally used in newbuilds.
Full electric propulsion system
Full electric propulsion is the logical extension of hybrid propulsion systems. In this study, it will be
defined as a propulsion technology where all the engines providing the power to the screw are
electrical motors. The electrical energy for those engines is only stored in batteries. This means that
options where the electric energy for the engines produced by diesel generators are excluded. The
reasons to use a full electric propulsion system are comparable to those for the hybrid option. In the
first place, it concerns the energy efficiency of the electric motors, and the whole energy supply chain
to provide the electricity. In addition, as was mentioned before, electric engines are better in dealing
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with varying load conditions. High peak power and load fluctuations are therefore better handled by
electric engines than by the conventional fossil fuel engines. The energy efficiency and the good
adaptation of power supply to the load conditions lead to significantly less carbon emitted. However
when saying this, it concerns well-to-tank emissions, because the tank-to-wake emissions of electric
vessel equal zero anyway, since no carbon containing fuels are combusted on board of the vessel.
The carbon emissions during the well-to-tank phase are mainly related to the way of producing the
electricity, as could also be seen in the energy supply chain in Figure 12. This means that when using
the standard electricity mix of Belgium, wherein gas power plants are included, the carbon emissions
emitted during well-to-tank will be greater than when renewable energy sources will be used directly.
Figure 21 unveils the Belgium’s energy mix. 34,4% of this energy mix is coming from fossil fuels.
Very few studies, if any, exist on the reduction potential of full electric maritime navigation with
electricity produced from Belgium’s energy mix. Nguyen et al., however, studied the reduction
potential of full electric maritime navigation globally and estimated emission reductions to be in the
range of 16% to 77%. Although it is hard to estimate, it can be assumed that the carbon reduction
potential of Belgian electric vessels will be in the higher part of the previously mentioned range, as
Belgium’s CO2 emissions per kWh are well below the European average, as can be found from
OECD data.45 When all electricity is coming directly from renewable energy sources the well-to-wake
emissions are reduced to zero. In any case, using full electric propulsion would be very beneficial as
a carbon emissions reduction measure, because this means that the carbon emissions are captured
under the European Emission Trade System (EU ETS). The total emissions of the system are capped,
so that the additional emissions from the maritime sector should be captured by reductions elsewhere.
Where at this moment carbon emissions of the maritime industry benefit from tax exemptions, it
should lose this favourable regime by adopting electric propulsion systems.
Figure 21: Belgium's energy mix (source: Elia 2020).
45 http://www.compareyourcountry.org/climate-policies?cr=oecd&lg=en&page=2
40
Applicability on vessels in scope
As can be seen in Figure 22, the reduction potential has a very wide range. This is because the
reduction potential of full electric vessels is mainly situated in the well-to-tank emissions. In other
words the type of energy resource used is important to estimate the reduction potential. But which
energy source is used for which vessel is uncertain. This explains the wide range. When strongly
polluting energy resources are used, the reduction is close to nothing. From the other side, when
renewable energy resources are used, the reduction potential is close to 100%. The emissions emitted
during navigation are, in any case, reduced to zero when using full electric power.
Figure 22 makes a distinction between red vessels, for which the technology would be feasible but is
not realistic at the moment, black vessels, for which the technology is most likely not applicable in
the future, and orange vessels, for which the technology could be technically feasible, but for which
big obstacles still exist. The technical concerns for those vessels will be discussed next.
Figure 22: Reduction potential full electric for vessels in scope (orange = technically feasible but big
obstacles, red = not realistic, black = not feasible).
Technical concerns
Container vessels, gas tankers, tankers, general cargo and vehicle cargo have red markers, because for
those vessels the technology could be an option. They have sufficient space to store the batteries and
could deal with their weight. However at this moment they are not realistic due to a too small
operability range, due to the current battery technology. This also means that installing batteries
currently would occupy too much space, and that weight would be too high. When technology
evolves and batteries will obtain a higher energy density the technology could be realistic for those
vessels.
From bilateral talks with dredgers and tugboat owners, the same concerns came up. The weight and
space that go together with the usage of batteries to propel the vessel solely with electric power, form
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a big obstacle at the moment. For those types of vessels, this will most certainly also not really be
applicable in the future, because the vessels are too small to store all the batteries needed, even if the
technology will improve.
Little literature is available for full electric propulsion for estuary ships and fishing vessels. Therefore
more research should be done into this topic. However it can be logically argued that the technology
would not really be applicable for these vessels as well, due to the limited space available.
Currently small pleasure boats will be the only vessel type of the study that could adopt this
technology without many problems. Those vessels are small, have low weight, do not make long
uninterrupted trips and do not require a lot of power. Therefore, not many batteries will be needed,
which weakens the weight and space concern. For larger pleasure boats, the same problems hold true
as for all other vessel discussed earlier.
In addition of the concerns about the energy density of batteries, the lack of shore power and loading
infrastructure is also hindering the uptake of the technology.
For the time being the technology will therefore only be applicable on vessels, and more precisely
pleasure boats for the scope of this study, that have flexible capacity, are not permanently in operation
or where the extra weight is not really a concern. When the research into new and better battery
technology starts paying off, and when investments in infrastructure are expanded so that an
economy of scale can develop, the technology will become a better option for many stakeholders.
3.1.4 Wind-assisted propulsion
The concept of wind-assisted propulsion is quiet straightforward. Wind will be used to propel the
vessel and this can be done by all kinds of sails and kites depending on the vessel used. The biggest
benefit of this technology is that it uses a free energy source and therefore less fuel must be
combusted. This on its turn can lead to a significant emission reduction as well as savings on
operational costs. However the adoption of wind-assisted propulsion systems is more complex than
it seems at first sight. Not every wind-assisted system can be used on every vessel, because it greatly
depends on several parameters, such as vessel design, design speed, operation pattern and the
travelled distance. It is not the goal of this study to discuss the several options in great detail.
42
Figure 23: Wind-assisted propulsion device (Source: ITF 2020).
The potential fuel savings strongly depend on the sail types used. Where one single kite could provide
a reduction of combusted fuel with 20%, a propulsion system only using sails would not emit any
CO2. This leads to the logical point that when only sails are used the dependency on the weather will
be too high and this is not really a reliable solution for vessels used in the maritime industry. However
the North sea is characterized by a windy environment and therefore it will be beneficial to use the
available wind resource in an efficient way.
Applicability on vessels in scope
Figure 24 gives an indication of the applicability and the respective energy savings for the different
vessels in scope. When a green marker is displayed the technology is feasible for that particular vessel
type. When a red marker is displayed the technology will not be realistic. The related technical
concerns will be discussed further.
43
Figure 24: Reduction potential of wind-assisted propulsion for the vessels in scope (green = technically
feasible, red = not realistic).
For container vessels, estuary shipping, general and vehicle cargo and tankers the technology is
feasible, but the energy savings depend on the technology used. The MV Ankie, for example, a
shortsea vessel, had one retrofitted ventifoil in 2018 which led to 8% fuel savings. Nowadays the ship
has two retrofitted ventifoils of 10 m height that were to be extended to 16 m by the end of 2020.
This will result in fuel savings of about 20% when navigating in 5 bft conditions, and an annual
average of 8% for navigation in the North Sea and Baltic Seas.46
Besides ventifoils, the Flettner rotor technology, as shown in Figure 23, could also be applicable. The
Paris Process on Mobility and Climate (PPMC) transport reports on two smaller vessels using Flettner
rotor technology to reduce emissions. The energy savings of those vessels were both around 2.6%.
Those vessels, the M/V Estraden and the E-ship 1 respectively, have a gross tonnage of 18 205 GT47
and 12 968 GT48. This means that they do not fall into the scope of this study. However this indicates
that the technology is available for smaller vessels and that it is legitimate to extrapolate the reported
number to the vessels in scope of this study.49
Another technology, besides ventifoils and Flettner rotors, that uses wind power are kites. Kites are
not really suitable for the vessels already mentioned, but they are for fishery vessels. A French fishery
boat has been using kites of an effective size of 200 square meters for about 40% of the time and
46 https://www.swzmaritime.nl/news/2020/09/30/reducing-shipping-emissions-starts-with-wind-power-and-carbon-
capture/?gdpr=accept&gdpr=accept 47 https://bore.eu/bore-fleet/vessel/m-v-estraden/ 48 https://www.auerbach-schifffahrt.de/PDF/DB_ESHIP1_141106.pdf 49 http://www.ppmc-transport.org/flettner-rotors-using-wind-energy-on-merchant-vessels/
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saves between 15% and 25% of fuel.50 Another example of a fishery boat using sail technology is the
10 m case ship of Amble A. (1985). They reported a reduction of 15% to 25%. 51
Using wind-assisted propulsion for pleasure boats is not relevant, because shipowners specifically
chose a sailing boat when they want to navigate wind-assisted vessels.
Technical concerns
In contrast to normal tankers, the technology is not applicable on gas tankers, because, as was
mentioned earlier, gas tankers have a very specific form, and the deck is not suited to install any wind-
assisted technology.
For dredging vessels and tugboats, the technology does not seem to be realistic because of the varying
load profiles of those types of vessels.
In addition, for all vessels in scope, deck space must be sacrificed to install the sails, kites or other
wind-assisted systems. The high customization of this technology for every ship is another drawback
and makes it difficult to benefit from the economy of scale in the long run.
Finally, the weather condition should be mentioned. Since the weather is unpredictable, vessels
sometimes are obliged to use their fossil fuel engines when no wind is available. The reduction
potential of the vessel then significantly drops. The technology, however, remains promising, but will
never lead to zero carbon emissions.
3.1.5 Energy Efficiency and Propulsion Efficiency Devices
The previous technical measures pointed out are relatively new technologies and therefore have a few
shortcomings. The most important one is the fact that the adoption of the technology at the moment
is limited and very uncertain. This makes it difficult for shipowners to invest in those technologies
for several reasons. The low adoption rate in the first place makes that governments and amongst
others port and waterway authorities do not want to invest in uncertainty. The same holds true for
the shipowners, but this attitude makes that no one will invest in a certain technology which keeps
the adoption percentage similar as it was in the first place. As mentioned previously this is the
problem of the chicken and the egg. Who will invest first? This uncertainty has a few consequences.
Important scale benefits to reduce the cost of certain innovations are not achieved due to this
situation. This on its turn keeps prices high of, for example, alternative maritime fuels and their related
bunkering facilities and infrastructure. This in fact is a vicious circle. How this pattern can be broken
by implementing good support mechanisms will be discussed later on in section 4. However in the
absence of these support schemes, only big organisations and shipowners with a strong cash position
are willing to investigate and to invest in these uncertain technologies, as several stakeholders
indicated in bilateral talks and the survey. However, some new technologies and study results will
become available for small companies, and thanks to spill overs and information sharing. Smaller
companies can then implement this technology themselves. Yet there are other, cheaper measures
that could be implanted by those players with less financial strength. This gives them the opportunity
to immediately act instead of waiting for other technologies to have a breakthrough. Those smaller,
less uncertain measures which have a good reduction potential as well will be discussed in this section.
50 https://www.maritimejournal.com/news101/industry-news/kite-propulsion-powers-french-fishermen 51 Amble, A. 1985. Sail-assisted performance of a 33 foot fishing vessel. Results of full scale trials. Journal of Wind
Engineering and Industrial Aero Dynamics, 19: 149–156. The Netherlands.
45
Those technologies will, thus, mainly be evaluated on the decarbonisation potential in relation to the
cost-effectiveness. This information could support smaller companies, such as small fishery
companies and pleasure boat owners, to make the right investment decisions. Nevertheless all those
technologies will be interesting for other shipowners as well.
Figure 25: Energy saving devices installed on vessels smaller than 5000 GT (Source: Clarkson WFR
database).
Figure 25 is based on a sample of the Clarkson World Fleet Register (WFR) database and indicates
which types of energy saving technologies are installed on in-service vessels and will be installed on
on-order vessels. This shows that there are two main technologies that are most often adopted: bow
enhancement technologies, exhaust gas economizers and waste heat recovery systems. The latter two
are displayed as one category because they both tend to optimize the energy chain of the vessels.
Beside those two main technologies, several others do exist, but will not be discussed in detail.
However Figure 26 gives an overview of the energy savings and payback time of those additional
energy saving measures.
46
Figure 26: Energy Saving Measures - Energy saving potential in function of payback time, based on
Clarkson WFR database sample.
Bow enhancement
The technology of bow enhancement is largely comparable to what was discussed in section 3.1.1. In
that section the ambition mainly lay on designing a more slender hull for newbuilds. In this section
the goal is comparable. Bow enhancement does, as well, want to reduce the friction with the water.
However in this section the emphasis lies on the bow enhancement technologies that can be
retrofitted on existing vessels. Nevertheless many of those technologies can also be adopted on
newbuilds. Most of the reported installed energy saving devices are implemented on off-shore vessels.
It mainly concerns supply vessels for platforms and wind installations. Damen Shipyards and Ulstein
are providing solutions for optimizing the bow. When the payback time is involved, mainly the
retrofitted vessels are in scope. A study of DNV.GL reported that the cost for implementing an
optimization of the bow has an average cost of 600 000 USD.52 This optimization leads to a reduction
of 6% of bunker consumptions. Therefore the payback time is assumed to be twelve months when
the cost of maritime fuel is around 600 US dollar per tonne. Because this technology is easily
applicable on off-shore vessels, but also on cargo vessels, tugboats, ferries and tankers, it ideally serves
the vessels operating in the Belgian context, as can be seen from section 1.2.1 and 1.2.2.
Heat recovery systems
Another technology that, from the sample of the Clarksons database, seems to be often adopted is
heat recovery. Two types are mentioned: exhaust gas economisers and waste heat recovery systems.
However those can be placed all together under the same denominator of heat recovery systems.
52 https://www.swzmaritime.nl/news/2020/09/30/reducing-shipping-emissions-starts-with-wind-power-and-carbon-
capture/?gdpr=accept&gdpr=accept
47
Figure 27: Sankey diagram of maritime fuels and T-s diagram of an ORC (Source: Zhu et al. (2020).
Figure 27 first shows a Sankey diagram as was presented by Zhu et al. (2020).53 This is a graphical
overview of the efficiency of the combustion process. From the initial 100% energy at the start of
the process only 49.3% is efficiently used as shaft power. The rest of the available energy is lost in
the form of heat transported to the environment. However with the technology of heat recovery this
heat can be captured and transformed into useful electrical power. This is done by a Rankine cycle.
However for vessels with a power output smaller than 15 MW, an organic Rankine cycle (ORC)
should be used. This is a thermal cycle where heat at a low temperature can be used. This is not
possible with a normal Rankine cycle, since water is used that must be transformed to steam. That
cannot be achieved with the low temperature heat sources. Because an ORC uses an organic working
fluid of which the evaporating temperature is lower, this problem is eliminated. The thermal efficiency
of an ORC is estimated to lie around 20% as reported by Javanshir et al. and is dependent on the fuel
type that is used.54 This efficiency multiplied with the amount of usable heat recovered leads to a 2-
8% range of useful recovered electric power, as was reported by Zhu et al. (2020). The reported fuel
saving percentages are in line with the range of the recovered electric power. However, some other
studies point out that there are no fuel savings but that 1.2% additional fuel is used (Olaniyi and
Prause (2020)).55
Since fuel savings are situated in a wide range the same can be expected for the payback time of the
technology, as also can be seen in Figure 26. Olaniyi and Prause (2020) report a negative net present
value due to the high investment cost in the range of 2-9 MUSD and a yearly operational cost of 9-
27 k USD. Ng et al.56 reported fuel savings ranging from 5-9% and a payback time of approximately
10 years, caused by a specific installation cost of USD 5000-8000 per kilowatt. The system pack of
Orcan Energy AG reports energy savings of about 6-9% and a payback time of about 2-4 years. The
53 https://www.sciencedirect.com/science/article/abs/pii/S1364032119308196 54 https://www.mdpi.com/2071-1050/9/11/1974/pdf 55
https://www.researchgate.net/publication/344747647_Investment_Analysis_of_Waste_Heat_Recovery_System_Installat
ions_on_Ships'_Engines 56 Study of application of kng waste heat system onboard offshore vessel (Ng et al., 2020):
48
latter example is a system especially developed for smaller vessels as short sea shipping vessels,
offshore, inland waterway navigation, navy, fast ferries, dredging, fishing and yachting. Most of those
vessels are relevant for this study and therefore also worth mentioning.
It can be concluded that heat recovery systems can be potentially interesting but there is however an
uncertainty on the payback time of the respective systems. A good simulation of the technology
should be used before implementing it. Several stakeholders indicated that they were applying this
technology with positive results. In any case, most of the studies report savings around 5-10% and
therefore the net present value of the investment is positive. These significant percentages make the
technology worth investigating.
3.2 Operational measures
The previous section described the technical measures that could possibly be developed for the
decarbonisation of the Belgian maritime sector. Those were measures that had a technical impact on
existing vessels or newbuilds. This, however, is not the only option to reduce carbon emissions and
therefore decarbonize the sector. Smart operational measures that make that the same transport or a
comparable one can be delivered with less fuel usage, are also promising and should be investigated.
Since this study only investigates the maritime transport in Belgian waters and the transport therefore
often has a modest length, not all operational measures are applicable to the scope of this study. Two
operational measures are identified to be promising to reduce carbon emissions of the vessels in
scope. These will be discussed hereafter.
3.2.1 Speed optimization
The goal of optimizing the vessels navigation speed is comparable to the goal of hull optimization.
By optimizing the speed of the vessel, the friction with the water is reduced. At this moment, current
vessels mostly are designed to operate inside the boundary speed zone. This is a zone where the speed
resistance coefficient starts to increase dramatically with increasing speed. The relation between
power (P) and speed (v) is given here by P~v3. A higher navigation speed, therefore also means a
higher power requirement. When more power is needed, the fuel consumption will increase, as well
as the carbon emissions related to this increase.
Figure 32 shows the relation between the cost per ton and the fuel consumption per ton, and the
relation between the cost per transported ton and vessel speed, for different fuel costs. The figure
shows that the vessel speed matching the lowest fuel consumption is lower than the best economical
solution. However the optimum speed is not equal to the lowest speed possible, therefore an
optimizing process should take place for every vessel to identify the speed matching the lowest fuel
consumption. The graph makes clear that a discrepancy exists between the climatic and economic
optimal navigation speed. Yet, when the fuel cost is increased, the two optima tend to come closer
together.
49
Figure 28: Fuel and cost per ton transported as a function of speed and fuel cost for a standard Aframax
(Source: Lindstad et al. 2015).
Speed optimization as an operational measure is not profoundly studied for small vessels, and
therefore not for vessels in the scope of this study. Extra research on the topic is needed because
there are reasons to believe that this measure is less suitable for these types of vessels. In a bunker
cost perspective, Esa and Inkinen (2018)57 showed that, based on a study of bulk segment in Northern
Europe, cost savings by using slow steaming could be up to 25% depending on bunker cost
development. However, small vessels have an average design speed at least 25% lower than large
vessels, which reduces the potential saving (source: Delpth, 2015).
Applicability on vessels in scope
Figure 29 displays the reduction potential of the different vessels in scope of the study. For all those
vessels, the reduction potential is based on a case study of RoRo ships in intra-European traffic (Zis
and Psaraftis (2019)).58 They reported a potential saving of 10% fuel reduction for a 1 knot reduction
in speed. This reduction could be extrapolated to the vessels in scope. However, for some vessels the
operational measure will have big obstacles, or will be not applicable at all. These shortcomings will
be explained hereafter.
57
https://www.researchgate.net/publication/329378693_Impacts_of_vessel_speed_on_bunker_cost_in_short_sea_shippin
g_A_cross-examination 58 https://www.tandfonline.com/doi/pdf/10.1080/03088839.2018.1468938?needAccess=true
50
Figure 29: Reduction potential of speed optimization for vessels in scope. (green = technically feasible,
orange = technically feasible but big obstacles, black = not applicable)
Technical concerns
Many sectorial stakeholders will not investigate the technology, because the cost related to transit and
therefore the cost of fuel consumption is in many cases negligeable compared to the cost of
operations of e.g. dredging vessels, tugboats and fishing boats. Those shipowners therefore tend to
sail at a higher than economical speed in order to reduce time used in transit mode, to quickly reach
their destination or operation or mission.
For small cargo carrying vessels operating as coastal carriers or feeder services and thereby operating
on short distances are dependent on a high frequency of services in order to compete with other
transport modes, as well as to cope with trade unbalance. This results also in a tendency to sail at a
higher than economical speed. So, unlike large deep sea carriers, small vessels have not yet exploited
the potential for fuel savings by speed reduction.
For pleasure boats, the applicability of the technology is the most realistic. Larger recreative shipping
vessels like for example yachts and tour boats could reduce their emissions by reducing speed. The
technology is however not relevant for small motor boats, or sailing boats.
3.2.2 Capacity utilization
Amongst other things, trade imbalances, demand variations, market fluctuations and customer
demands for high frequency can lead to a high level of unutilised vessel capacity. By optimizing the
utilized capacity, vessels can be operated more efficiently which reduces the amount of fuel used and
therefore the amount of carbon emitted. Several possibilities exist to optimize this utilization, such
as optimal communication through the supply chain, efficient navigation schemes and price
differentiation. However capacity utilization could also be interpreted more widely. It also includes
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the optimal usage of vessels, so that the same amount of work can be performed in a more efficient
way and the emissions are also reduced. Figure 30 gives a schematic representation of this concept.
Figure 30: Schematic representation of capacity utilization (source: ETP-ALICE physical internet 2020).
The potential emission reduction of this operational measure is strongly dependent on the way of
implementation and the vessel type used, but in general it is applicable on all vessel types.
Applicability on vessels in scope
Cargo ships and tankers are the ones upon which most research has been done. Johnson & Styhre
indicated in a study from 2015 that the potential for increased energy efficiency was at least 2–8%,
by reducing unproductive time due to the port’s open hours and early arrival. This was based on a
case study of a short sea bulk shipping company transporting dry bulk goods mainly in the North
and Baltic seas.59 Another study of Styhre et al. from August 2010 reported a wide range of the CO2
reduction potential, i.e between 5% and 50%.60 Bauman et al. confirms the high uncertainty of the
emission reduction potential.61
Figure 31 gives an overview of the reduction potential of the different vessels in scope. As was
mentioned before, the applicability on cargo ships is most investigated, but in addition of the vessels
in scope, it also is the only type that could benefit from capacity utilization. Dredger, fishing boats,
pleasure boats and tugs will not be able to benefit from this technology as is explained hereafter.
59 https://www.sciencedirect.com/science/article/pii/S0965856414002857 60 https://publications.lib.chalmers.se/records/fulltext/124588.pdf 61 https://www.sciencedirect.com/science/article/pii/S1361920916307015
52
Figure 31: Reduction potential of capacity utilization for the different vessels in scope (orange =
technically feasible but big obstacles, black = not applicable).
Question marks can be placed on the feasibility of capacity utilization for short distance cargo
transport. One reason is the same as for for speed optimization, i.e high frequency services need to
be able to compete with other market players, as well as to cope with trade imbalances. Therefore
the same holds true for this operational measure, more research should be done into the efficient
organization and utilization of vessels and their capacity.
For dredging vessels, fishing boats and tugs the technology is not applicable, because those vessels
tend to perform their specific operations as fast as possible and at maximum capacity with the vessels
available. Therefore, no improvements can be made in capacity utilization.
The same holds true for tour boats in the recreative shipping sector. This sector is already navigating
with optimized capacity as some stakeholders indicated. For other types of recreative shipping vessels
the technology is not realistic, because it mostly concerns private shipowners.
3.3 Overview of carbon reducing measures and feasibility
This section aims to give an overview of the measures mentioned before and their emission reduction
potential. For the less far-reaching measures, the relation with the payback time will be given as well,
because those are more suitable to achieve carbon reduction in the short term.
The financial aspect can form a barrier for implementing decarbonizing measures. The graphical
representation in section 3.1.5 tried to clarify the possibilities of the different smaller technical
measures and energy saving technologies. It is important to emphasize that those smaller
technological measures presented are almost applicable on all vessel types in scope of this study
because they can be retrofitted on existing vessels. The reduction potential, however, can differ
depending on the implementation. The two reduction technologies discussed in detail in section 3.1.5
were heat recovery and bow enhancement. The benefits of all the smaller technological measures are
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the relatively easy implementation procedure, that all those measure can be retrofitted, and the low
cost compared to the other technical measures. This makes it possible for smaller shipowners to
reduce emissions in a relatively cheap way, which is indicated by the payback time in the figure.
Besides the smaller technical measures, more intervening technical measures have been discussed in
this section 3.1 as well as operational measures in section 3.2. Table 2 gives an indication of the
reduction potential, as mentioned in the sections 3.1 and 3.2, for all different technologies and vessels
in scope. The four colours indicated in the table are the same as used in the entire chapter 3. Green
stands for technically feasible, orange is technically feasible but with big obstacles,red means that the
technology is not realistic at the moment, and black indicates that the particular technology is not
applicable on the particular vessel type. The Appendix contains the more detailed overview table that
forms the basis for Table 2.
From Table 2, one can see that alternative fuels are the measures with the biggest reduction potential
for all vessels in scope, together with electric propulsion. However, these alternative fuels have some
important shortcomings at the moment. Most of them require infrastructure that is not available at
the moment. In addition, the storage of most of these fuels is a problem at the moment and the price
of those fuels is currently too high to make the technology economically feasible. This to a lesser
extent holds true for LNG. The CO2 reduction potential is limited due to methane slip and due to
WTT emissions, and therefore it is not the preferred option to reduce emissions of CO2. On the
contrary, it is a good fuel to reduce other emissions like for example NOx and SOx, but those were
not in scope of this study. Retrofitting this technology on existing vessels would also be too
expensive.
Full electric vessels are also identified as vessels with a high reduction potential, but before this
technology can be adopted, the battery technology should improve, so that they weigh less and
occupy less space. Also the recharging infrastructure should become widely available, before a
breakthrough of this technology can be expected. Therefore hybrid technology can be a good
intermediate solution. Since a combination of propulsion systems is used, the required battery power
is less, and thus the space and weight concern is weakened for those vessels.
A last alternative propulsion system discussed was wind-assisted propulsion. This is a technology that
can be applicable on cargo vessels. Ventifoils and Flettner rotors are the most promising technologies
for the vessels in scope. With the deck-space that they occupy, those technologies will not be
applicable on gas tankers and other non-cargo vessels. The other vessels in scope all have their own
optimal wind-assisted technology. The reduction potential however remains limited, but wind energy
is freely available and therefore the adoption of the technology can be taken in account.
Regarding the design of the vessels in scope, hull optimization and more specifically a more slender
hull can be an option for many vessels in scope. Mostly the cargo carrying vessels, because they
navigate in open sea where the advantages of this technology will be the largest. Vessels with a specific
design and operability, such as dredgers, tug boats, fishery boats and gas tankers, can hardly or not
implement this technology. The most important concern is the reduction of carrying capacity, due to
the more slender hull.
A last category of investigated measures were the organizational measures consisting in speed
optimization and capacity utilization. Those measures are mainly applicable on cargo carrying vessels,
because other technologies have very specific modes of operation to which those operational
measures will not apply. For the cargo carrying vessels, energy savings are possible, but this is strongly
dependent on market conditions. The high frequency of operations makes it hard to optimize supply
54
chains and therefore optimize the capacity used and the sailing speed. More research into smart
technological and digital tools needs to be done to make the implementation of the technology
possible.
Table 2: Overview of the feasibility and reduction potential of the different vessels in scope for all
presented measures. Green is technically feasible, orange is technically feasible with big obstacles, red is
not realistic and black not applicable for the given time horizon. TTW means tank-to-wake, WTW means
well-to-wake.
55
4 Programmes to support implementation
of decarbonizing measures
4.1 Carbon pricing
One of the mechanisms that is used to decarbonise different sectors is carbon pricing. The general
principle is simple. Carbon emissions are priced and therefore emitters are incentivised to reduce
their emissions until the abatement cost becomes higher than the carbon pricing. Therefore carbon
pricing will only be an efficient measure to reduce emissions when the carbon price is set high enough.
Figure 32: Overview of carbon pricing mechanisms for domestic aviation and domestic navigation.
Source: Taxing Energy Use: Using Taxes for Climate Action (OECD).
At the moment, several regions have implemented carbon pricing mechanisms. The main carbon
pricing scheme is the European Union Emission Trade System (EU ETS). This system was
implemented in 2015 and serves as a regulatory framework to reduce carbon emissions for all the
European Union member states. The system works based on permits or rights that are allowed to
CO2 or other carbon holding pollutant emitters . The absolute amount of CO2 emitted by the
countries under the system are capped at a certain maximum, and will reduce every year. In this way,
the total emissions are fixed. Because an emitter needs permits to emit CO2 and because the total
emissions are decreasing every year by the cap, the price of the permits will rise. In this way,
companies are forced to reduce their emissions as long as the abatement cost does not equal the cost
of the permits. However not all sectors are included under the EU ETS. The transport sector is the
most important sector that is not completely included in the system.
56
Besides the ETS system, several other countries have implemented carbon pricing systems. In Europe
the Nordic countries - Iceland, Denmark, Norway, Finland and Sweden - have or had already
implemented carbon pricing systems on top of the European ETS, if present. The same holds true
for Estonia, Latvia, the UK, France, Portugal, Switzerland and Slovenia. All those countries
implemented extra measures to align their policy with the ambitious climate goals they set. With those
extra measures these countries go further than others, nevertheless some of the subsectors of
transport remain largely untaxed on their carbon emissions, i.e. aviation and maritime navigation.
International aviation and maritime navigation are not subject to any carbon pricing scheme.
However this is not true for domestic aviation and maritime navigation. For these subsectors of
transport, there are indeed some countries that impose carbon taxation. Figure 32 indicates the
countries that implemented taxation schemes for domestic aviation and navigation. Focussing on
maritime navigation on the righthand side of the figure, shows that Estonia is the only EU member
state that implemented a significant taxation scheme on maritime navigation. Switzerland is the most
ambitious country in taxing the domestic aviation and navigation.62,63
Figure 33: Effectiveness of the carbon pricing schemes, relation between carbon pricing gap and carbon
intensity of GDP.
The goal of carbon pricing is to reduce the tonnes of CO2 emitted. Not all schemes of the different
countries are equally effective in achieving this goal. The effectiveness is often expressed as the size
62
https://openknowledge.worldbank.org/bitstream/handle/10986/28510/wb_report_171027.pdf?sequence=7&isAllowed
=y 63 https://www.oecd-ilibrary.org/sites/058ca239-en/1/3/3/index.html?itemId=/content/publication/058ca239-
en&_csp_=733ba7b0813af580090c8c6aac25027b&itemIGO=oecd&itemContentType=book#section-d1e5373
57
of the gap between the effective carbon rate (ECR) and a pre-set benchmark. The OECD often uses
the €30/tCO2 as a low-end carbon benchmark. This is also indicated in Figure 32. €60/tCO2 is
currently seen as a midpoint estimate of the carbon costs in 2020 and as the low-end price in 2030.
When the ECR is actually set at least as high as the holding benchmark, the carbon pricing gap equals
zero. If the ECR equals zero, the pricing gap will be 100%. The smaller this gap, the more effective
the scheme is likely to be in reducing CO2 emissions. Figure 33 tries to clarify this relation. The
carbon intensity is set out on the y-axis and the energy intensity of GDP on the x-axis. This means
that the isolines on the graph are lines with the same carbon intensities of GDP. The graph shows
that France, Norway, Switzerland and Ireland are performing best in reducing the carbon intensity
of their economies. The graph also shows that those countries have a relative small carbon pricing
gap. The opposite holds true for the countries located at the other side of the spectrum. Thus, the
smaller the carbon pricing gap, the further countries are in effectively reducing the carbon intensity
of their economies.64
The isocarbon lines shown in Figure 33 respectively equal the carbon intensity of GDP needed in
2020 (0.28 kg/USD), 2030, 2040 and 2050 (0.02 kg/USD) to keep the global temperature increase
under 2°C, as was agreed upon in the Paris Agreement. As can be seen, most European countries are
situated between the 2020 and 2030 isocarbon lines. This is mainly thanks to the EU ETS system.
Countries with an extra carbon pricing system are already located, between 2030 and 2040. The
world’s biggest economies however are far away from reaching the 2020 goal.
Belgium, as the other European Union countries, is located between the two highest isocarbon lines,
and therefore actually achieved the 2020 target. To further reduce the carbon emissions to reach the
2030 goal, extra carbon pricing measures can be a useful tool. Inclusion of shipping in the EU ETS
system is an option which is currently being discussed. In case the vessels in scope of this study are
left out of the ETS, Belgium can still chose to implement its own system of carbon pricing for this
segment.
Under domestic law, a carbon taxation scheme applied to maritime transport could lie within the
power of the federal authorities as well as the regions. The exercise of the power to tax is, in principle,
not tied to the possession of a substantial competence with regard to the matter subject to the tax.
The federal legislator enjoys a general tax power. The legislators of the regions do as well, but the
federal legislator can limit the tax power of the regions if he considers it necessary65.
Hereafter, we will assume that the intention would be to introduce a federal tax mechanism. The
federal legislator should respect the proportionality principle and not render the exercise by other
legislators of their powers impossible or overly difficult. When a tax measure is primarily aimed at a
non-fiscal goal, such as inciting citizens to act in a certain way, outside of the competencies of the
federal authorities, there is a good chance that the aforementioned test will not be met66. Since the
primary goal of carbon pricing would indeed be to influence the behaviour of those subject to it, we
will hereafter determine which authority has material powers in this regard.
64 https://www.oecd-ilibrary.org/sites/9789264305304-
en/1/2/2/index.html?itemId=/content/publication/9789264305304-
en&_csp_=154c2b4f72eadc55f10eae263e6bf524&itemIGO=oecd&itemContentType=book 65 Reybrouck, K. and Sottiaux, S., De federale bevoegdheden, Antwerp - Cambridge, Intersentia, 2019, 718, n° 1163, 722-723,
n° 1169 and 737, n° 1193. 66 Reybrouck, K. and Sottiaux, S., De federale bevoegdheden, Antwerp - Cambridge, Intersentia, 2019, 724-725, n° 1172.
58
It would be possible for the federal authorities to unilaterally introduce a carbon taxation scheme.
However, it would need to be verified that the scheme does not unduly interfere with the regional
competence with regard to air protection. The most secure course of action seems to be to introduce
the tax by means of a cooperation agreement between the federal state and the regions. However, an
alternative solution could also be developed, relying exclusively on federal legislation, preferably in
consultation with the regions.
Tax rules must, pursuant to Article 170, § 1, of the Belgian Constitution, be enacted at the level of
Acts of Parliament. The establishment of such rules cannot be entrusted to the government alone.
This so-called legality principle covers at least all “essential elements” of a tax, which includes the
identification of the persons subject to the tax, the matter subject to the tax, the tax base and any tax
exemptions and reductions67.
Furthermore, tax rules must respect the principle of equality, enshrined in Articles 10 and 11 of the
Belgian Constitution. Article 172 of the Belgian Constitution confirms the applicability of this
principle to taxation. This principle entails that every person or entity in the same situation should be
taxed equally and that taxpayers who are in substantially different situations should not be treated
identically. However, the principle of equality and non-discrimination does not preclude any
difference in taxation between categories of taxpayers, provided that such a difference is based on an
objective criterion and is reasonably justified. According to the case law of the Constitutional Court,
the existence of such a justification must be assessed in light of the purpose and effects of the measure
in question and the proportionality of the measure. In fact, the Court takes a reserved attitude when
reviewing tax laws and recognises that the legislator has a wide margin of appreciation to make policy
decisions. The Court will generally only intervene when there is no (reasonable) justification for any
difference between taxpayers68.
From the above it can be concluded that the implementation of a carbon taxation scheme can only
be done with good cooperation between the different legislative levels. However, the situation
remains complex due to the discussion going on concerning the integration of maritime navigation
in the EU ETS. Nevertheless, the monitoring system needed to capture the emissions of shipping,
only registers emissions from vessels above 5000 GT. In this context it can be argued that the
inclusion of maritime shipping into the ETS is most likely to be limited to this category of vessels,
what would mean that vessels in scope of this study would not be subject to such a taxation scheme.
Therefore, it could still be an option to implement a small vessel taxation scheme. But in addition, it
has to be seen, assuming the cooperation between the different legislative levels is fruitful, whether a
taxation scheme would jeopardise the competitive position of the industries subject to the tax.
4.2 Tax exemptions
Fuel tax exemptions
Fuel taxation is in line with carbon pricing and could incentivise shipowners to use cleaner maritime
fuels by penalizing the use of polluting conventional maritime fuels with a tax levied on the fuel sold.
However, maritime industry players are currently subject to favourable regimes when it comes to
taxation of the fossil shipping fuels used. Under the current European Energy Tax Directive (ETD)
67 Constitutional Court 21 December 2017, n° 145/2017, cons. B.52.2. 68 Constitutional Court 22 March 2018, n° 36/2018, cons. B.4.2; Couturier, J., Peeters, B. and Van de Velde, E., Belgisch
belastingrecht (in hoofdlijnen), Antwerp – Apeldoorn, Maklu, 2017, 33, n° 20; Velaers, J., De Grondwet, een artikelsgewijze
commentaar, Bruges, die Keure, 2019, 491.
59
(2003/96/EC) Article 14(1)(c), the taxation of maritime fuel sold to ships on EU territory is
prohibited. Therefore international maritime navigation pays no taxes on the fossil fuels they use.
This tax exemption amounts for €24 billion/year and is allocated over the different European
countries as shown in Figure 34 and estimated in a study by Transport & Environment.69 It can be
seen that the Netherlands and Belgium grant the biggest amount of tax exemptions. This is mainly
due to the presence of the two biggest European ports in Rotterdam and Antwerp.
Figure 34: Tax exemptions on ship fuels per country. Source: Transport and Environment69.
Article 14(2) of the same directive allows member states to limit the scope of the tax exemptions to
international transport and intra-Community transport (i.e. transport from one member state to
another). Which means that member states are allowed to levy a tax on ship fuels for domestic
maritime navigation.70 However no member state has implemented such a taxation scheme. Only
Iceland and a few non-European countries do not have tax exemption schemes on maritime fuels
for domestic maritime navigation. This indicates that the EU is not alone in favouring maritime
transport with tax exemptions. (ITF 2020)
Tax exemptions for the vessels in scope
The previous section gave an indication for the fuel tax exemptions (Figure 34 mentions subsidies,
but in most cases it concerns exemptions) in different countries. These estimations were given to the
maritime sector as a whole. This section aims to go deeper into detail on the tax exemptions granted
to the vessels in the scope of this study. The estimation of tax exemptions for the vessels in scope is
an exercise that has not been carried out in other studies. This is mainly because there is no
monitoring of the fuel sales from the vessels in the scope of this study. As was mentioned in section
2.1.1 and 2.1.2, the monitoring systems of the IMO and the European Union are only applicable on
vessels larger than 5000 GT. A study from WWF and Climact from 2019 also indicated that
69
https://www.transportenvironment.org/sites/te/files/publications/2019_09_EU_Shipping_24bn_fossil_tax_holiday.pdf 70 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32003L0096:en:HTML#d1e844-51-1
60
estimations are not available regarding the amount of tax exemptions for inland navigation (inland
navigation means navigation from one national port to another, which also includes maritime
transport in Belgium).71
Tax exemptions granted to the maritime sector in general in Belgium, and therefore also for the
vessels in our scope, are nevertheless relatively large. A document from the European Commission
from October 2020 shows that the favourable regime for fossil fuels in relation to the GDP is large.
In addition, it is clearly visible that most of the tax exemptions and subsidies are granted to oil, which
includes fossil fuels for road transport and maritime fuels.72 A study of Climate Action Network
Europe (CAN), the European Think Tanks Group (ETTG) and Milieudefensie indicated several
estimations for the Belgian fuel tax exemptions. The European Commission reported €2.49 billion
in 2019, the OECD reported €2.24 billion in 2018 and Climact reported €4 billion in 2019. However
for these studies as well it is difficult to include correct numbers for the vessels in the scope of this
study.
Figure 35: Overview of fossil fuel tax exemptions for some European countries.72
To estimate the tax exemptions granted to the vessels in the scope of this study, Transport &
Environment (T&E) developed a methodology in their study on tax benefit estimations of September
2019. In this methodology, they used CO2 emission data to estimate the fossil fuel usage, because of
the limited quality of the fuel usage reporting compared to emissions reporting. Thereafter the
nominal excise tax rates of the respective country applicable to diesel for road vehicles have been
used to estimate the tax exemptions. For Belgium, this resulted in an amount of €4.5 billion tax
exemption for the maritime sector. T&E used data from the EU emissions reports to the UNFCCC
from 2017, and specifically used category 1.D.1.b, international navigation.73 The total CO2 emissions
of this category equalled 24 435 kt.74 The emissions of the vessels that could be subject to a fuel
taxation (i.e. domestic maritime navigation, estuary shipping and recreative shipping) equal about 141
kt per year, as calculated in section 1.2. This results in a relative share of 0.57%. Using this share to
71 https://wwf.be/assets/IMAGES-2/CAMPAGNES/ELECTIONS2019/FF-report/WWF-fossil-fuels-final-report.pdf 72 https://ec.europa.eu/energy/sites/ener/files/progress_on_energy_subsidies_in_particular_for_fossil_fuels.pdf 73
https://www.transportenvironment.org/sites/te/files/publications/2019_09_EU_Shipping_24bn_fossil_tax_holiday.pdf 74 https://www.eea.europa.eu/data-and-maps/data/national-emissions-reported-to-the-unfccc-and-to-the-eu-
greenhouse-gas-monitoring-mechanism-16
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estimate the amount of tax exemptions for the vessels in scope results in respectively €26 million
each year. Many assumptions have been made here, and it must be emphasized that the number can
vary depending on those assumptions, but the result gives a grasp of what a fuel tax on maritime
fuels, even when only applied on the vessels in scope of this study, could yield. When even a small
fraction of the forementioned amount could be collected, this revenue could be used to subsidise
R&D into sustainable innovation for the maritime sector.
Because the current favourable regime is in stark contrast with the climate and sustainability
ambitions of the European Union, it is agreed upon by the European Council to revise the existing
Energy Tax Directive (ETD), and to align it with the holding ambitions and climate goals. A first
step was to evaluate the existing scheme. This delivered the following insights:
• The consumption of fossil fuels is favoured by the holding tax exemptions
• The reduction of greenhouse gas emission by adopting new technologies is not adequately
promoted
• The initial primary objective of a proper functioning internal market is no longer achieved
by this Energy Tax Directive.
The European Commission therefore consulted many stakeholders from citizens over national
administrations to all sectors of activity, with the goal to revise the ETD under the EU Green Deal.75
Belgium indicated in October 2020 that it was willing to investigate the phasing out of the fossil fuel
subsidies.76 Previous calculation showed that a fuel tax on maritime fuels could yield a serious
revenue. Belgium could therefore opt to cautiously implement a fuel tax independently from the
European Commission. An independent approach is preferable, since the current legislation and the
additional legislation of the European Commission that will be developed in future years, only
focusses and will most likely only focus on the larger vessels.
If Belgium indeed would choose to limit the scope of the tax exemption to international transport
and intra-Community transport, it lies within the powers of the federal authorities. As mentioned
above, the federal legislator enjoys a general tax power. Currently, the excise duties on energy
products and electricity, as well as the exemption regarding fuel for the purposes of navigation, are
indeed regulated by federal legislation77.
As the exemption is presently enacted in an Act of Parliament, the change could only be enacted
through a new Act of Parliament. The principle of hierarchy of norms precludes that the exemption
could be abolished by a mere Royal Decree. In addition to that, as we have seen above, the so-called
legality principle embodied in Article 170, § 1, of the Belgian Constitution requires that all “essential
elements” of a tax be enacted at the level of Acts of Parliament.
Article 14(2) of the ETD provides that in case the member states limit the scope of the tax
exemptions to international transport and intra-Community transport, they may apply a level of
taxation below the minimum level set out in the directive. At first sight, this implies that Belgium
would be free to determine the level of taxation imposed on domestic maritime navigation fuels.
75 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12227/public-consultation 76 https://ec.europa.eu/energy/sites/ener/files/progress_on_energy_subsidies_in_particular_for_fossil_fuels.pdf 77 Art. 429, § 1, g), of the Loi-programme of 27 December 2004 (Moniteur Belge 31 December 2004).
62
Electricity and alternative fuel tax exemptions
A decarbonizing measure that is in line with the sustainability and emission reduction goals is the
adoption of a favourable taxation scheme for electricity, alternative fuels and other new sustainable
technologies. Few European Union member states have already implemented these schemes. Sweden
and Denmark do levy reduced tax rates for shore power and electric charging of vessels. However
there is a minimum level of taxation determined by the ETD. (ITF 2020)
The European Community Shipowners’ Associations (ECSA) emphasizes the need to create a level
playing field for the taxation of energy usage in maritime shipping. They indicate that the favourable
regime for the use of fossil maritime fuels is not stimulating stakeholders to invest in greener
alternative fuels, electricity usage and other sustainable new technologies. To enable the transition
towards the decarbonisation of maritime transport, a profound taxation scheme should be
established.78 The revision of the ETD will be the key point to make this transition, because it remains
hard for member states to implement unilateral legislation. Nevertheless some countries already
implemented a taxation scheme that favours sustainable technologies. Belgium, therefore, could also
focus on the investigation into comparable taxation schemes.
Member states are free to apply national tax exemptions or reduced rates to biofuels, as Article 16(1)
of the ETD allows this for biomass-based products. For various alternative transport fuels, such as
hydrogen, e-fuels, synthetic fuels, bio-methane and renewable fuels of non-biological origin, there is
uncertainty regarding the applicability of the ETD. Finally, the ETD does not provide for EU-wide
preferential tax treatment of shore-side electricity79.
If Belgium were to grant exemptions or reductions by way of derogation from the ETD for specific
policy considerations, such as the reduction of greenhouse gas emissions, it would have to file a
request with the European Commission. The request would then be examined, taking into account,
inter alia, the proper functioning of the internal market, the need to ensure fair competition and
Community health, environment, energy and transport policies. After all this, the Council may grant
an authorisation for a maximum period of 6 years80.
Like a change of the exemption regarding fuel for the purposes of navigation, as discussed above,
other derogations from the ETD would also lie within the powers of the federal authorities, because
of the general tax power of the federal legislator and the fact that the excise duties on energy products
and electricity are currently regulated by federal legislation.
As confirmed in Article 26(2) of the ETD, tax exemptions or reductions within the meaning of the
ETD could amount to state aid. If that is the case, the normal EU rules on state aid will apply and
the aid measures have to be notified to the European Commission.
78 https://www.ecsa.eu/news/revised-energy-taxation-directive-should-enable-transition-decarbonisation-maritime-
transport 79 European Commission, Commission Staff Working Document. Evaluation of the Council Directive 2003/96/EC of 27 October
2003 restructuring the Community framework for the taxation of energy products and electricity, 11 September 2019, SWD(2019) 332
final, 33-34 and 37. 80 Art. 19 Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation
of energy products and electricity (OJ L 283 of 31 October 2003, 51).
63
Reductions in environmental taxes81 under the ETD can be deemed compatible with the internal
market and be exempted from the obligation to be notified to the European Commission in
accordance with Article 44 of the General Block Exemption Regulation. According to that article the
following conditions must be met:
(1) The general conditions in Chapter 1 of that Regulation must be fulfilled;
(2) The beneficiaries of the tax reduction shall be selected on the basis of transparent and objective
criteria and shall pay at least the respective minimum level of taxation set by the ETD;
(3) Aid schemes in the form of tax reductions shall be based on a reduction of the applicable tax rate
or on the payment of a fixed compensation amount or on a combination of these mechanisms;
(4) Aid shall not be granted for biofuels which are subject to a supply or blending obligation.
If the abovementioned conditions cannot be met and the aid must be notified, paragraphs 167 et seq.
of the Commission Guidelines on state aid for environmental protection and energy 2014-202082
contain guidelines on how the compatibility of aid in the form of reductions in or exemptions from
environmental taxes shall be assessed by the Commission.
As can be concluded from the above, the federal government would be able to implement an
advantageous scheme for green technology for domestic maritime navigation. For some sustainable
maritime fuels the applicability of the ETD is even uncertain, which would mean that it potentially
could be applicable on international maritime navigation in Belgian waters as well. The revision of
the tax exemptions could in any case be a favourable regime to incentivize the adoption of sustainable
shipping technology.
4.3 Subsidies and funding
Besides the incentive of carbon pricing to reduce greenhouse gas emissions of the maritime sector,
other financial support mechanisms, such as subsidies could be implemented.
In case of subsidies, EU law concerning state aid is relevant. As a principle, state aid to undertakings
is prohibited. Pursuant to Article 107(1) of the Treaty on the Functioning of the European Union83
(hereafter: “TFEU”), save as otherwise provided in the Treaties, any aid granted by a member state
or through State resources in any form whatsoever which distorts or threatens to distort competition
by favouring certain undertakings or the production of certain goods, shall, in so far as it affects trade
81 An “Environmental tax” is defined in Article 2(113) of the General Block Exemption Regulation as “a tax with a
specific tax base that has a clear negative effect on the environment or which seeks to tax certain activities, goods or
services so that the environmental costs may be included in their price and/or so that producers and consumers are
oriented towards activities which better respect the environment”. In our view, it follows from the wording of Article 44
of the General Block Exemption Regulation that in fact all taxes under the ETD can be deemed to be such
environmental taxes. In recitals 6 and 7 of the preamble to the ETD the link between the taxation of energy products and
electricity on the one hand and environmental protection and the Kyoto Protocol on the other is expressly made. 82 OJ C 200, 28 June 2014, 1. 83 OJ C 326, 26 October 2012, 1.
64
between member states, be incompatible with the internal market84. It is undeniable that subsidies
are covered by this provision85.
Article 107(2) of the TFEU declares some types of aid compatible86. However, it seems that none of
these exceptions can be relevant in the present case.
Pursuant to Article 107(3) of the TFEU, the following aids may be considered to be compatible with
the internal market:
(a) Aid to promote the economic development of areas where the standard of living is abnormally
low or where there is serious underemployment, and of the regions referred to in Article 349 of the
TFEU, in view of their structural, economic and social situation;
(b) Aid to promote the execution of an important project of common European interest or to remedy
a serious disturbance in the economy of a member state;
(c) Aid to facilitate the development of certain economic activities or of certain economic areas,
where such aid does not adversely affect trading conditions to an extent contrary to the common
interest;
(d) Aid to promote culture and heritage conservation where such aid does not affect trading
conditions and competition in the Union to an extent that is contrary to the common interest;
(e) Such other categories of aid as may be specified by decision of the Council on a proposal from
the Commission.
The Treaty allows further possibilities for approval of state aid under specific rules. For instance,
according to Article 93, state aids shall be compatible with the Treaties if they meet the needs of
coordination of transport.
As a general rule, state aid must be notified to and cleared by the Commission before it is granted87.
Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid
compatible with the internal market in application of Articles 107 and 108 of the Treaty88 (hereafter:
“General Block Exemption Regulation”) exempts member states from this notification obligation
for several types of aids if the conditions laid down in chapter I of the regulation, as well as the
specific conditions for the relevant category of aid laid down in the regulation are fulfilled89. For
example, section 7 of the General Block Exemption Regulation contains specific provisions on aid
for environmental protection. Within that section, Article 36 provides that investment aid, including
the acquisition of new ships or retrofitting of existing ships, enabling undertakings to go beyond
Union standards for environmental protection or to increase the level of environmental protection
in the absence of Union standards may be compatible with the internal market. Similarly, the
84 For further clarification on the key concepts relating to the notion of state aid, reference should be made to the
Commission notice on the notion of State aid as referred to in Article 107(1) of the Treaty on the Functioning of the
European Union, OJ C 262, 19 July 2016, 1. 85 ECJ 22 June 2006, C-182/03 and C-217/03, Belgium and Forum 187 ASBL, ECLI:EU:C:2005:266, cons. 86. 86 It concerns social aid granted to individual consumers, aid to make good the damage caused by natural disasters or
exceptional occurrences and aid to certain areas of Germany affected by the division of Germany. 87 Article 108(3) TFEU. 88 As amended, OJ L 187, 26 June 2014, 1. 89 Article 3 General Block Exemption Regulation.
65
Community guidelines on State aid to maritime transport90 state that investment aid may be
permitted, in line with the EU safe seas policy, in certain restricted circumstances to improve
equipment on board vessels entered in a member state’s registers or to promote the use of safe and
clean ships. Thus, aid may be permitted which provides incentives to upgrade EU-registered ships to
standards which exceed the mandatory safety and environmental standards laid down in international
conventions and anticipating agreed higher standards, thereby enhancing safety and environmental
controls. Within the context of this report this will not be discussed further.
Furthermore, in accordance with Commission Regulation (EU) No 1407/2013 of 18 December 2013
on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union
to de minimis aid91, small state aid amounts are exempted from state aid control as they are deemed to
have no impact on competition and trade in the EU’s internal market. The total amount of de minimis
aid granted per member state to a single undertaking may not exceed €200,000.00 over any period of
three fiscal years.
Whether a subsidy scheme can be deemed compatible with the internal market depends on the
features and characteristics of the scheme in question.
Under domestic law, it should be examined whether the establishment of a subsidy scheme would
require an Act of Parliament or if such a scheme can be implemented by a Royal Decree. The Belgian
constitutional system includes a principle of separation of powers in which the executive branch only
has the powers which have been assigned to it by an Act of Parliament or the Constitution itself.
Article 108 of the Constitution expressly confers to the executive branch the power to take all
necessary measures to implement Acts of Parliament. While the remit of that power might be
considered as a very broad one by the courts, the measures still require a legal basis in an Act of
Parliament92. Therefore, a new subsidy scheme by the federal authorities can only be established by
an Act of Parliament, unless a legal basis can be found in an existing Act.
The relevant rules would need to ensure that the subsidies are awarded in a manner compatible with
the principle of equality and non-discrimination. This principle has its basis in Articles 10 and 11 of
the Belgian Constitution. The Constitutional Court has previously ruled that in the case of subsidy
schemes, it is mainly for the legislator to decide if and under which conditions he wishes to grant
subsidies and in doing so he has a wide margin of appreciation. Whilst the legislator must respect the
principle of equality and non-discrimination, the Court considered itself competent to conduct only
a marginal review. In the view of the Court, only in case of arbitrariness or blatant unreasonableness,
it can criticize the choices made by the legislator93.
When taking a decision on the award of a subsidy, the granting authority shall not only be obliged to
respect the relevant procedures and provisions contained in the applicable Act and/or Royal Decree,
but also the general principles of good administration. The most important of these general principles
is the principle of due care. Other general principles of good government, which are sometimes
deemed to emanate from the principle of due care, the right to be heard, the principle of impartiality,
the duty to give reasons, the principle of reasonableness, the principle of equality and non-
90 OJ C 13, 17 January 2004, 3. 91 OJ L 352, 24 December 2013, 1. 92 Vande Lanotte, J. et al., Belgisch publiekrecht, Deel II, Bruges, die Keure, 2015, 821, n° 1165-1166 and 889-891, n° 1290-
1295. 93 Constitutional Court 5 March 1996, n° 13/96, cons. B.3.5; Constitutional Court 24 October 2019, n° 153/2019, cons.
B.7.2.
66
discrimination, the principle of legal certainty and the principle that a decision should be made in a
reasonable length of time94.
The principle of transparency, which was first developed in EU law, implies an obligation of the
government to ensure publicity and disclosure of its actions. That principle is not yet considered a
principle of good government in Belgian law. However, there are several legal authors who support
the application of the principle in the context of the distribution of scarce public goods, like subsidies.
This would imply that anybody who shows an interest in a scarce public good can apply for it, that
his request would be compared with other applicants on an objective basis and that the reasons of a
rejections are clearly communicated to him95. While the principle of transparency is not a binding
principle in Belgian law, from a policy viewpoint it seems preferable for any subsidy scheme to respect
it.
Any decision of the competent authority concerning the award of a subsidy can be considered to be
an administrative act, which can normally be challenged before the Belgian Council of State96.
However, it may be useful to establish a specific appeals procedure for decisions concerning
subsidies.
Hereafter two subsidy schemes will be discussed that could influence the adoption of decarbonizing
measures. The schemes will be discussed against the context of the above.
Funding mechanisms and R&D subsidies for new technology
Carbon pricing as discussed in the previous section is one of the best solutions to push the industry
towards R&D. Research and development is essential in reducing emissions and moving towards a
more sustainable way of maritime transport. R&D stimulates the adoption of new, cleaner, more
efficient technologies. When no new technologies would be adopted in future years, the most
important way to reduce emissions would be the reduction of maritime transport in general. As this
is not an option in the growing economy, there should be a focus on R&D and increasing the
investments and subsidies for it. The benefits will emerge in different phases. First the investments
will lead to faster development of new technologies. Once the new technology is adopted, the R&D
subsidies can be used to optimize the production process. Thereafter this can lead to economy of
scale as the technology deems to be effective.
Because carbon pricing should not be the only way to stimulate R&D, direct subsidies could be used
as an incentive as well. Although several initiatives are taken at a European level, not many individual
countries are implementing their own subsidy mechanisms to support research into new innovating
technologies. The European Commission investigated the adoption of a new fund supporting the
fishery and the maritime sector, the European fund for maritime affairs and fisheries. This fund for
the period from 2021 to 2027 intends to be less complex and more flexible as the previous one and
has an estimated budget of €5.9 billion. For the fisheries this fund will help to support small-scale
coastal fishermen. This is in line with the decisions taken in 2014 in the context of the reform of the
Common Fisheries Policy. For the maritime sector the fund means investments in new maritime
markets, technologies and services such as ocean energy and marine biotechnology. The budget will
94 Opdebeeck, I. and De Somer, S., Algemeen bestuursrecht. Grondslagen en beginselen, Antwerp – Cambridge, Intersentia, 2017,
358-403, for an analysis of these principles. 95 Ibid., 359-360, n°776. 96 Article 14 Coordinated Acts of 12 January 1973 on the Council of State, Moniteur Belge 21 March 1973.
67
be allocated to the different member states, who will decide which projects they finance or co-
finance.97;98
Funding of sustainable technology and innovation in Belgium
In Belgium the department of agriculture and fisheries from the Flemish Government deals with the
economic matters concerning fisheries. However, the related technical and operational matters are a
competence of the federal authorities. In this aspect Belgium mainly focusses on the compliance with
the European Common Fishery Policy (CFP). The goal of the CFP is amongst other things to
guarantee the evolution towards a more sustainable fishery sector and to support young small-scale
coastal fishermen.99 An important part of policy regarding fisheries is dealt with on regional level.
Therefore, a relatively large part of the budget of the CFP for the Belgium member state is more
specifically allocated to Flanders. To be more precise in the period from 2014 until 2020 Flanders
received €47.1 million from the European fund. This budget was supplemented by the Belgian
Federal government with €27 million.98 100
To support the Belgian fishery sector, Belgium could opt to extend the amount of funding rewarded
to the Flemish department of agriculture and fisheries. This could serve to focus on implementing
greener technologies in the fishery boats as well as for education of fishery men to handle alternative
fuels in a safe way. Nevertheless the share of fishery carbon emissions in the total emissions from the
vessels in scope, is rather limited.
Besides the European fund for maritime affairs and fisheries, the importance of the Belgian Federal
government approach towards decarbonizing the maritime sector is of importance as well. Belgium’s
federal minister for the North Sea, Vincent Van Quickenborne, clarified the ambitions of the new
federal government. The emphasis lies, amongst other things, on the strengthening of the blue off-
shore energy, which entails focussing on wind energy infrastructure, battery technology and
alternative fuels. In addition, he also wants to focus on sustainable and safe maritime navigation.101
Belgium and the European Union have been investing heavily in renewable energy sources. An
important energy resource in the scope of this study is off-shore wind energy. The Belgian off-shore
wind energy sector will provide about 18 000 jobs in the future (Figure 26). Those are not only related
to the energy sector. An important share of the jobs will be created in building, servicing and
operating the off-shore wind farms. Belgium’s strong expertise related to dredging and sand
extraction is of importance here, and is a real export product. A green off-shore windfarm should
also be built and serviced by sustainable vessels. This would create opportunities for strong Belgian
companies.102 Therefore Belgium should also keep focussing on investing in high-technology vessels
as a Belgian trademark.103
97 https://ec.europa.eu/commission/presscorner/detail/en/IP_18_4104 98 https://www.ewi-vlaanderen.be/sites/default/files/bestanden/bijlage_1.pdf 99
https://diplomatie.belgium.be/nl/Beleid/Coordinatie_europese_zaken/Beleid_belgie_binnen_EU/Landbouw_en_visser
ij 100 https://lv.vlaanderen.be/nl/nieuws/lancering-visserij-verduurzaamt-erkenning-van-belgische-rederijen-rond-
verduurzaming 101 https://www.blauwecluster.be/nieuws/nieuwe-beleidsverklaring-voor-de-noordzee-kleurt-blauw 102 http://www.vliz.be/imisdocs/publications/266141.pdf 103 https://www.belgianoffshoreplatform.be/nl/news/bop-uitgenodigd-op-de-commissie-voor-energie-en-klimaat/
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Figure 36: Estimation of job creation related to Belgium off-shore wind sector.104
Several possibilities are available to invest in sustainable shipping initiatives. The European
Investment Bank (EIB) for example focusses on granting loans to projects that are in line with the
European Renewable energy strategy. One windfarm has been granted a loan of €250 million. The
building of the 8 windfarms will need an investment of €8 billion. Besides this, the development of
the off-shore wind energy sector will also result in an increase of the annual GDP with €1 billion as
estimated by the Belgian Offshore Platform (BOP).103 At least a fraction of this extra created GDP
should flow back to the development of new sustainable technologies for maritime shipping
presented in chapter 3 . It concerns, for example, investment in promising alternative fuels and battery
technology.
R&D funding in Nordic regions
As an example, the Nordic region is a frontrunner in reducing the maritime emissions by stimulating
R&D. They adopted several pathways to outperform the binding Paris Agreement. The budget
allocated to research and development is mainly rewarded to research projects on new technologies,
implementing partnerships and cluster support between the government and private stakeholders,
and marketing and financial support to stimulate the scale-up of new promising technologies.
Although several mechanisms exist to support R&D, it however remains hard to make a clear impact-
assessment of the respective subsidies, because relatively few studies deliver a clear assessment. Very
few governments commission yearly studies on the evaluation of subsidy mechanisms, and when they
do the studies are often not very profound.105
R&D Subsidies in Belgium
As mentioned above, a fraction of the extra GDP created by the offshore wind-sector, could flow
back to investments in R&D on top of the subsidies from European funding. Two concerns arise
here. In the first place the subsidy could be seen as state aid, and this is only allowed if it is compatible
with the internal EU market. A second concern is the legislative level on which this should be
implemented.
104 https://www.belgianoffshoreplatform.be/app/uploads/Studie-Socio-economische-impact-van-de-belgische-offshore-
windindustrie.pdf 105 Navigating towards cleaner maritime shipping, lessons from the Nordic region, International maritime forum, 2020
69
State aid for R&D will primarily be justified on the basis of Articles 107(3)(b) and 107(3)(c) of the
TFEU. Pursuant to these provisions, the Commission may consider this compatible with the internal
market state aid to promote the execution of an important project of common European interest, or
to facilitate the development of certain economic activities within the Union, where such aid is
necessary, appropriate and provides an incentive effect whilst being proportionate, and does not
adversely affect trading conditions to an extent which goes contrary to the common interest106.
Section 4 of the aforementioned General Block Exemption Regulation contains provisions on several
types of aid for research and development and innovation, including aid for research and
development projects, research infrastructures, innovation clusters, process and organisational
innovation and research and development in the fishery and aquaculture sector. As explained above,
if an aid measure fulfils the criteria set out in the provisions of the General Block Exemption
Regulation, it is deemed compatible with the internal market and must not be notified to the
European Commission.
If the R&D subsidies cannot be deemed compatible under the General Block Exemption Regulation,
they have to be notified to the European Commission. The Commission has adopted a Framework
for state aid for research and development and innovation with principles and guidelines on how it
will conduct the compatibility assessment of notified R&D aid107.
Additional mechanisms to subsidise R&D projects with regard to new technologies for maritime
transport could lie within the powers of the federal authorities. Pursuant to Article 6bis of the SIRA,
the communities and regions enjoy competence for scientific research related to their powers,
whereas the federal authorities enjoy competence for scientific research which is necessary for the
execution of their own powers and in certain other areas. Because maritime transport in general is a
federal area of competence108, supporting R&D projects on new technologies for maritime transport
could in our view be considered a federal matter.
Similarly, supporting R&D projects pertaining to product standards could be considered a federal
competence, because product standards fall within the federal powers. The Constitutional Court has
defined product standards as rules that determine in a mandatory way the requirements that a product
must meet when put on the market, with a view, among other things, to protection of the
environment. In particular, they set limits for the levels of pollutants or nuisance that cannot not be
exceeded in the composition or emissions of a product, and may include specifications on the
properties, testing methods, packaging, marking and labelling of products109.
However, more general R&D projects pertaining to technologies for the reduction of greenhouse gas
emissions, renewable energy sources and efficient use of energy should probably be considered a
regional matter, in view of the regional powers regarding the protection of the environment110,
106 Communication from the Commission, Framework for State aid for research and development and innovation, OJ C 198, 27 June
2014, 1, cons. 5. 107 Communication from the Commission, Framework for State aid for research and development and innovation, OJ C 198, 27 June
2014, 1. 108 Reybrouck, K. and Sottiaux, S., De federale bevoegdheden, Antwerp - Cambridge, Intersentia, 2019, 691, n° 1109. 109 Constitutional Court 22 December 2010, n° 149/2010, cons. B.4.1. 110 Art. 6, § 1, II, al. 1, 1°, SIRA.
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regarding “new energy sources” with the exception of nuclear power111, regarding “energy recovery
by industry and other users”112, and regarding “rational energy usage”113. In recent years, the Belgian
Council of State has expressly confirmed that scientific research concerning the climate and climate
change lies primarily within regional powers114. Nevertheless, the federal authorities can support
scientific research with regard to the powers of the communities and regions, i.a. in case it pertains
to actions or programmes which exceed the interests of a community or a region (which is presumable
the case for combating climate change) and subject to the condition that the federal authorities submit
a proposal for cooperation to the communities and/or regions prior to their decision115.
The picture sketched and the competence allocation in this matter is rather ambiguous. Nevertheless
the possibility exists for federal authorities to fund R&D projects. It could therefore be investigated
further how a R&D funding scheme should be implemented.
Modal shift subsidies
Another subsidy mechanism is the support for modal shift from road transport towards maritime
transport. Several schemes are implemented in different countries. The Nordic region however again
has some concrete examples of how to implement this type of subsidies. Norway and Sweden both
implemented support mechanisms that more or less have the same characteristics. Companies that
want to obtain support need to adopt a business plan that clearly indicates how they are planning to
make the transition towards more sustainable seaborn transport. Therefore the plan, also, needs to
be very specific on the number of tonne-kilometres transported with sea transport and the emissions
that are reduced by this transition. The subsidy amount is based upon those two parameters, and is
calculated by multiplying the number of tonne-kilometres with the difference in the external cost of
road transport and sea transport. The total budget of the Norwegian and Swedish schemes are topped
at respectively NOK 382 million and SEK 150 million. Payments of the subsidy are done on a regular
basis, upon evidence of the change in tonne-kilometres transported with sea born transport.116
In the federal climate and energy plan, Belgium sets out its roadmap of how it will proceed in reducing
its emissions in the period form 2021-2030. In this document it emphasizes the importance of the
modal shift towards more sustainable modes for passenger transport as well as freight transport.
Belgium wants to support the general energy transition with €35 billion. A part of this should go to
reducing road transport and stimulating maritime transport.
However this can again be conceived as state aid. The compatibility of state aid for a modal shift is
usually assessed under article 93 of the TFEU, which provides that “aids shall be compatible with the
Treaties if they meet the needs of coordination of transport”. According to a constant decisional
practice of the Commission, aid for the coordination of transport will be deemed compatible with
the internal market under Article 93 of the TFEU if the following conditions are met:
111 Art. 6, § 1, VII, al. 1, f), SIRA; see also Reybrouck, K. and Sottiaux, S., De federale bevoegdheden, Antwerp - Cambridge,
Intersentia, 2019, 638, n° 1013 and Vermeir, T., “Het energiebeleid”, in Seutin, B. and van Haegendoren, G. (eds.), De
bevoegdheden van de gewesten, Bruges, die Keure, 2016, (245), 268, n° 508, who specify that “new energy sources” are
considered to include all non-fossil fuel energy sources. 112 Art. 6, § 1, VII, al. 1, g), SIRA. 113 Art. 6, § 1, VII, al. 1, h), SIRA. 114 Council of State, Legislation Section, recommendation 61.858/1/V of 29 September 2017, Parl.Documents Chamber of
Representatives 2017-2018, n° 3047/001, 20, n° 4.1. 115 Art. 6bis, § 3, SIRA. 116 Navigating towards cleaner maritime shipping, lessons from the Nordic region, International maritime forum, 2020
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(a) The aid must contribute to a well-defined objective of common interest. The aim of the European
Union multimodal transport policy is to achieve a modal shift from road freight to other modes of
transport;
(b) Aid must be necessary to achieve the objective of common interest, and it must have an incentive
effect, i.e. the aid must change the behaviour of the beneficiary in such a way that it engages in
additional activity, which it would not carry out without the aid or that it would carry out in a restricted
or different manner, so that the objective of common interest would not be achieved;
(c) The aid must be proportionate. Aid is considered to be proportionate only if the same result could
not be reached with less aid and less distortion. The amount and intensity of the aid must be limited
to the minimum needed for the aided activity to take place;
(d) The access to aid must be open to all potential users on non-discriminatory terms. This requires
that the aid must be granted on the base of objective, transparent and non-discriminatory criteria;
(e)The aid must not lead to distortions of competition contrary to the common interest117.
Subsidy mechanisms to incite a modal shift in order to reduce greenhouse gas emissions would most
likely fall within the regional area of competence regarding the protection of the environment118,
which, as seen above, includes the power to take measures to reduce greenhouse gas emissions into
the air. In the Belgian distribution of powers, the financing of measures normally coincides with the
substantive competencies. Financing is an instrument to realise policy priorities pertaining to a
particular area of competence. Consequently, an authority cannot, in principle, finance policies that
fall outside its powers119. Presumably, the power to subsidise mechanisms to incite a modal shift in
general therefore lies with the regions.
Nevertheless, a federal competence for measures to support a modal shift from road transport
towards maritime transport could be defended on a number of grounds. First of all, measures taken
by the regions must not exceed their territorial competence. The Belgian system of devolutionary
state reform requires that the subject of each rule issued by a region can be located within the territory
of that region. This way, each specific situation is regulated by a single authority only120. A modal
shift from road transport towards maritime transport necessarily concerns emissions into the air over
the Belgian maritime areas (and other maritime areas, for that matter), which traditionally are not
considered part of any of the regions. Therefore, one might argue that measures taken to incite such
a modal shift cannot lie within the powers of any one region.
117 See for instance: European Commission, Decision of 11 August 2015, SA.41100 (2015/N), Austria - Special
Guidelines for the Programme of Aid for Innovative Combined Transport for 2015-2020; European Commission,
Decision of 30 September 2016, SA.23216 -C 54/2007 (ex NN 55/2007), Germany – State aid to Emsländische
Eisenbahn GmbH; European Commission, Decision of 15 May 2018, SA.49153 (2017/N), Czech Republic – Aid for
intermodal transport units; European Commission, Decision of 24 October 2018, SA.50584 (2018/N), Belgium –
Structural aid measure reducing the cost disadvantage of bundling volumes transported by rail/inland waterways to and
from Flemish seaports in order to promote a modal shift. 118 Art. 6, § 1, II, al. 1, 1°, SIRA. 119 Van Eeckhoutte, D., “De bevoegdheidsoverdrachten inzake openbare werken, vervoer en verkeersveiligheidsbeleid”,
in Alen, A. et al., Het federale België na de Zesde Staatshervorming, Bruges, die Keure, 2014, (457), 471, n° 25; Constitutional
Court , n° 54/96 of 3 October 1996, B.5; Council of State, Legislation Section, recommendation 31.341/VR of 28
February 2001, Parl.Documents Chamber of Representatives 2000-2001, n° 0774/010, 5-6, n° 2.2. 120 Constitutional Court, n° 33/2011 of 2 March 2011, B.4.4 and B.5.
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Inasmuch as a modal shift subsidy would conceivably relate to product standards, it could be
considered to lie within the powers of the federal authorities, because product standards, as seen
above, are a federal matter.
Another argument in favour of a federal competence in this matter could be made by linking the
power to take measures regarding a modal shift to the power to regulate the transport modes
concerned. In this case, these modes are road transport and maritime transport. As mentioned above,
maritime transport in general is a federal area of competence. Therefore, initiatives favouring a modal
shift towards maritime transport could be considered to lie within the federal powers. However, one
might as well argue that these initiatives also concern road transport, and that the regions are
competent for the “roads and their appurtenances” and for the “legal system of the roads”121. From
that fact, it could be inferred that the regions are competent to pursue a modal shift policy that
discourages the excessive use of roads, and the congestion that results from it. A recommendation
by the Legislation Section of the Council of State of 2013 seems to confirm the latter analysis122.
Because the modal shift measures discussed here would, by assumption, be primarily aimed at
reducing the emission of greenhouse gases, this reasoning does not seem to apply here.
Therefore, as with a R&D subsidy, the federal authority seems to have some competence to
implement a modal shift subsidy scheme. However from the above it can be concluded that there are
some uncertainties and ambiguous positions. If the federal authorities, thus, want to implement a
modal shift subsidy it should be in close cooperation with the regions, in order to clearly align the
competences and applicability.
4.4 Environmental differentiated incentives
Besides these incentives on a higher level, there are also more local options to stimulate shipowners
to introduce cleaner technologies on their vessels. One way of achieving this is by reducing the tariffs
for maritime services for ships that comply with sustainability standards. Examples and best practices
in some of the Nordic countries in Europe are lower port fees and lower fairway dues for clean ships.
Within Belgium, the determination of port and waterway fees are an area of competence of the
regions. That is the case because their more general competence regarding ports and waterways
includes the power to regulate any duties and taxes and the right to collect them123.
Importantly, the Flemish region has in the Ports Decree entrusted the task to determine the port fees
to the autonomous port authorities of its maritime ports. The fees must be in reasonable proportion
to the value of the benefits received in return124. The EU Seaports Regulation provides that port
infrastructure charges may vary, in accordance with the port’s own economic strategy and its spatial
planning policy, in relation to, inter alia, certain categories of users, or in order to promote a more
efficient use of the port infrastructure, short sea shipping or a high environmental performance,
energy efficiency or carbon efficiency of transport operations. The criteria for such a variation shall
be transparent, objective and non-discriminatory, and shall be consistent with competition law,
including rules on state aid. Port infrastructure charges may take into account external costs and may
121 Art. 6, § 1, X, al. 1, 1° and 2°bis, SIRA. 122 Council of State, Legislation Section, recommendation 54.196/3 of 25 October 2013, www.raadvst-
consetat.be/dbx/adviezen/54196.pdf#search=54.196, 4-5, n° 3.4. 123 Parl.Documents Chamber of Representatives 1988, n° 516/1, 17; Van Hooydonk, E., “Goederenvervoer algemeen”, in
X., Transportgids, Mechelen, Wolters Kluwer, s.d., 2.1.3.5/25-28. 124 Art. 15, § 3, Decree of 2 March 1999 on the policy and the management of seaports (Moniteur Belge 8 April 1999).
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vary depending on commercial practices125. Clearly, therefore, port fees may be differentiated in
relation to greenhouse gas emissions, but the power to do so does not rest with the federal authorities.
The reduced tariffs are calculated in line with the existing environmental indices. Which index is used
is depending on the situation. Several indices exist, some examples follow hereafter: Clean Shipping
Index (CSI), Environmental Ship Index (ESI) and the Environmental Port Index (EPI). These indices
are calculated based upon the major environmental influencing factors, namely: CO2, SO2, NOx and
PM. CO2 is only one factor whereon the calculation is based (ITF 2020). This means that this
environmentally differentiated incentives are of a lesser importance for this study, whereas the focus
here lies on decarbonising the maritime sector. Therefore this type of incentives will not be further
discussed.
4.5 Energy efficiency indices and monitoring systems
As indicated in section 2.1.1 the decarbonizing initiatives of IMO in the form of energy efficiency
indices are only applicable on a certain category of vessels. The following indices: EEDI, EEXI and
SEEMP are applicable on vessels larger than 400 GT navigating in international waters. However
shipowners who only navigate in national waters, are also allowed to implement these decarbonising
measures. The CII, different from the previous three indices, is applicable to vessels larger than 5000
GT navigating in international waters, but can also be applied to domestic navigation vessels larger
than 5000 GT. This measure is only applicable on larger vessels due to the connection with the fuel
consumption monitoring system (DCS) of IMO. Which therefore also only applies to vessels larger
than 5000 GT navigating in international waters. As mentioned in section 2.1.2 there also exists a
monitoring system on European level. This applies to all the vessels navigating under European flag
larger than 5000 GT.
This information shows that many vessels in scope of this study are not included in the legislation of
IMO and Europe. To effectively decarbonise the complete maritime sector, Europe and IMO should
try to extend the applicability of the legislation in a complementary way.
As mentioned above, maritime transport in general is a federal area of competence126. Therefore, the
extension should be handled on the federal level. However, Article 6, § 4, 3°, of the SIRA provides
expressly that regional governments are to be involved in the drafting of general police regulations
and regulations on traffic and transport. From this it is inferred that the competent authority to adopt
these regulations is the federal state127. As the regulations concerning the monitoring of emissions
from marine transport could arguably be regarded as such, the federal authorities could be deemed
to have the competence to establish a purely domestic monitoring system similar to the current EU
MRV and IMO DCS.
In fact, Regulation (EU) 2015/757 of the European Parliament and of the Council of 29 April 2015
on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport,
125 Art. 13(4) Regulation (EU) 2017/352 of the European Parliament and of the Council of 15 February 2017 establishing
a framework for the provision of port services and common rules on the financial transparency of ports (OJ L 57 of 3
March 2017, 1); see also Van Hooydonk, E., The EU Seaports Regulation. A commentary on Regulation (EU) 2017/352 of the
European Parliament and of the Council of 15 February 2017 establishing a framework for the provision of port services and common rules on
the financial transparency of ports, Antwerp, Portius Publishing, 2019, 998-1001, nos. 324-326 and 1011-1029, nos. 330-339. 126 Reybrouck, K. and Sottiaux, S., De federale bevoegdheden, Antwerp - Cambridge, Intersentia, 2019, 691, n° 1109. 127 Van Hooydonk, E., “Goederenvervoer algemeen”, in X., Transportgids, Mechelen, Wolters Kluwer, s.d., 2.1.3.5/117.
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and amending Directive 2009/16/EC128 has been implemented in Belgium by the federal authorities
through a federal Act of Parliament and various Royal Decrees129. If the implementation of the
existing EU monitoring, reporting and verification system is regarded as a federal responsibility, it
seems only logical that the creation of a domestic one for smaller ships is as well.
One might argue that the creation of a domestic monitoring system could also be deemed to be a
measure related to the competence of the regions concerning the protection of the environment130.
However, at the time of the implementation of the abovementioned Regulation in a federal Act, the
Flemish Government itself expressly recognised that the implementation only concerned federal
competences131.
From the above, it can be concluded that the federal authorities can be deemed competent for the
adoption of new emissions monitoring schemes for the vessels in scope of the study.
128 OJ L 123, 19 May 2015, 55. 129 Article 3 of the Act of 17 December 2017 amending the Act of 25 December 2016 establishing administrative fines
applicable in the event of violations of Acts on maritime navigation (Moniteur Belge 19 January 2017); Article 3 of the Royal
Decree of 28 September 2016 amending the Royal Decree of 4 December 2012 appointing the officials responsible for
implementing and monitoring the legal and regulatory provisions on shipping and amending the Royal Decree of 4 June
2003 establishing the template of the identity card proving the capacity of officials in charge of control of maritime
navigation (Moniteur Belge 24 November 2016); Articles 4.1 and 4.19 of the Royal Decree of 14 July 2020 on the
enforcement of regulations on maritime navigation (Moniteur Belge 21 August 2020). 130 Art. 6, § 1, II, al. 1, 1°, SIRA. 131 Note for the Flemish Government on the position concerning the draft of an Act amending the Act of 25 December
2016 establishing administrative fines applicable in the event of violations of Acts on maritime navigation, available on
beslissingenvlaamseregering.vlaanderen.be/document-view/51ae68c0-dec1-11e9-aa72-0242c0a80002.
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5 Conclusions
This report focused on measures that could be taken to decarbonise the Belgian maritime sector for
vessels smaller than 5000 GT. Those vessels nowadays are not always subject to IMO and EU
legislation, because the policy measures mainly focus on larger vessels, which is logical in a certain
aspect because those are the largest carbon emitters. In addition, IMO regulations are only applicable
on vessels navigating internationally, and therefore this does not apply on domestic navigation and
most of the recreative shipping vessels. This study therefore aims to capture the vessels that are
currently largely exempt from decarbonizing legislation. Many of the vessels in scope are active in
sectors that are really trademarks for the Belgian economy. It thus is needed to also focus on the
greening of those vessels.
The study started by identifying the vessels subject to this study. This have been the following main
vessels and activities: domestic maritime navigation, international maritime navigation on Belgian
territory, estuary shipping and recreative shipping. For all the above mentioned vessels the gross
tonnage is limited to a maximum of 5000 GT. The total carbon emissions of these categories have
been estimated. For both domestic maritime navigation and international maritime navigation this
has been done by consulting the latest EMMOSS estimates. For the former this resulted in 123 kT
of CO2 emissions. The vessels contributing to those emissions are mainly: dredging and sand
extraction vessels, tugs and fishing vessels. For the latter the estimation was more complex to make,
because EMMOSS uses the vessel length instead of gross tonnage to categorize vessels. Therefore a
correlation between those two parameters has been sought. Based on this correlation the estimation
of the carbon emissions yielded 71 kt CO2 for the lower estimate and 180 kt CO2 as a higher estimate.
In this category of vessels, the biggest emissions come from tankers, cargo vessels, sand extraction
vessels and fishery vessels. The category of estuary shipping is mainly included in domestic navigation
and international maritime navigation and therefore it is hard to separate it. Recreative shipping was
the last category of vessels for which emission estimations have been carried out. The estimations for
this category are most likely an underestimation of the real emissions because not all vessels are
registered by waterway authorities. It is estimated that those vessels emit about 18 kt CO2.
Thereafter the report aimed to discuss the current initiatives to reduce carbon emissions, public
initiatives as well as private initiatives. For the public initiatives several legislation levels have been
taken into account. In the first place the international level has been studied, and more specifically
the IMO regulation. From this it was clear that most of the energy indices (EEDI, EEXI and
SEEMP) apply on international navigating vessels larger than 400 GT. This means that it is partly
applicable on the vessels in scope. The IMO data collection system is only applicable to vessels larger
than 5000 GT, and because the CII is based on the data collection system this means this threshold
also applies to this index. The vessels in scope are therefore not subject to this specific IMO
legislation. For the monitoring system of the European Union the same holds true. It is only
applicable on vessels larger than 5000 GT. On a national level, Belgium has indicated in its national
energy and climate plan that it wants to support IMO and the EU in decarbonising the maritime
sector, and they allocate the main initiative to those parties. On a local level the same holds true,
although there are some initiatives to promote cleaner technologies. In general it can be concluded
that there are structured public initiatives to reduce carbon emissions, however, those are mainly
applicable to larger vessels and not to the vessels in scope.
For private initiatives it can be concluded that they are mainly implemented on an ad hoc basis. They
are not really structured or streamlined. Several parties are trying to implement decarbonising
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measures like the hydrogen engines of BeHydro for example. But more support and a more
structured approach is needed here to really green the vessels in scope of the study in an efficient
way.
From the initiatives it was clear that some parties are taking steps to reduce the carbon emissions of
the maritime sector and therefore also the vessels in scope. It was the goal of this report to give a
clear overview of which technologies are applicable to the respective vessels in scope. A
differentiation was made between technical measures and operational measures. It can be concluded
that more technical measures exist for this category of vessels, because operational measures mainly
have their biggest impact on relatively long trips. Whereas in this study only vessels navigating in
Belgian waters were in scope, long trips were not relevant in this study. In the category of technical
measures, a differentiation was made between more drastic measures and smaller measures with a
shorter payback time.
From the more drastic measures discussed, it can be concluded that the feasibility depends on the
time horizon. Measures that are applicable on the short term, i.e. measures that are technically feasible
without big obstacles, are typically characterised by smaller reduction potentials than measures that
are feasible on the longer term. In the category of short term measures the following measures were
discussed: hull optimization to a smaller hull, hybrid propulsion, wind-assisted propulsion and vessels
navigating on LNG as an alternative fuel. However most of those technologies are only applicable
on a selection of the vessels in scope.
It can be concluded that a more slender hull can be mainly adopted on cargo vessels. The other
vessels in scope have a very specific design that is needed to optimally conduct their operations. For
example, tug boats are small boats with a very large installed power. The form of their hull is designed
to grant the optimal stability during operation. A more slender hull would make it impossible to
perform their specific tasks. Pleasure vessels also have their specific designs, however yachts could
still be an option here. For dredging vessels those stability concerns hold also true and in addition
the reduced capacity is an extra concern. For cargo vessels the reduced capacity is a smaller obstacle
because those vessels are not always navigating at full capacity. One category of cargo vessels that is
not an option is gas tankers. These vessels also have their specific design due to the low density of
gas.
Hybrid propulsion is a technology that can be applied and is already tested on almost all vessels in
scope. The fuel savings and carbon reduction potential is varying depending on the vessel type from
3% to a maximum of 30%. The applicability on fishing vessels is currently, as can be concluded from
literature, only applied on a conceptual designs. This is mainly because those vessels mostly have a
very long lifetime and new technologies are not easily adopted.
Wind-assisted propulsion is predominantly feasible and applicable on cargo vessels. It was not the
goal of this study to go very deeply into the possible systems, however it can be concluded from
literature that Ventifoils and Flettner rotors are the best options to effectively reduce carbon
emissions. Nevertheless the gains are limited. The reduction potential for cargo vessels is lying
between 2.6% and 8%. The same concern related to gas tankers holds true for this technology. Since
these vessels have a very specific design and therefore the deck space to place this type of wind-
assisted propulsions systems is rather limited, the technology is not realistic for those vessels.
Although examples exist of wind-assisted propulsion for dredging vessels, tugboats and fishing
vessels, it can be argued that given their very specific operation and limited deck space it would be
not realistic to apply this technology to those vessels.
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A last technology that could be feasible on the short term is using LNG as an alternative propulsion
fuel. Currently some vessels are already using LNG, however there are some doubts to raise about
the technology. In the first place the reduction potential of the technology is estimated to be around
15%, but due to methane leakage and depending on the type of engine used this reduction potential
has to be verified. Other alternative fuels will have a higher reduction potential. This leads to the
point of the economic feasibility of LNG. Currently the investments needed on board are significant
and often too large for shipowners. From a climatologic view these investments will not be justified.
As a last concern the safety issue can be raised. LNG can be explosive and therefore it should be
handled in the correct way.
Besides those short term carbon emission reducing technologies, there are also technologies that will
be introduced on the longer run. In this category the alternative fuels can be presented: hydrogen,
ammonia, synthetic e-fuels and biofuels. Another alternative propulsion technology discussed, is full
electric propulsion.
It can be concluded that the reduction potentials of the alternative fuels discussed in this report, on
a tank-to-wake basis, are very large. For hydrogen this is close to 100%, however emissions should
be evaluated on a well-to-wake basis. The reduction potential only will remain at 100% if these
alternative fuels are produced with renewable energy sources. If this is not the case the reduction
potential must be lowered depending on the electricity production method used. The reduction
potential of synthetic e-fuels could be at 100% as well when non-carbon holding fuels are used, when
this is not the case the reduction potential must be lowered. The reduction potential of biofuels on a
well-to-wake basis ranges between 25% and 75%. However, the specific reduction potential for all
the alternative fuels on a well-to-wake basis is still to be investigated further.
There exist several reasons why those alternative fuels are currently not yet adopted widely. In the
first place the availability and the refuelling options are limited or not present at the moment. When
those are not available shipowners are not tempted to invest in those green technologies. In addition
the fuel prices of those alternative fuels are too high to be economically feasible for shipowners. For
hydrogen and ammonia the storage ability (this is also true for their synthetic equivalents) is a
problem. The energy density is lower than conventional fuels and therefore extra tanks should be
installed. Furthermore safety issues do not allow the adoption of this technology on all vessel types.
An element in favour of the alternative fuels is the fact that some of them could be used as a drop-
in fuel and therefore no investment should be made in new engines.
A last long term measure is the usage of full electric propulsion systems. The reduction potential of
this technology will be the same as for non-carbon holding alternative fuels and therefore will equal
100% on a tank-to-wake basis. The same holds true for well-to-wake if the electricity used to propel
the vessels is originating from renewable energy resources. If this is not the case than the reduction
potential must be lowered with certain percentage points depending on which type of electricity
production technology is used.
Currently the feasibility of full battery electric propelled vessels is limited. The main reason is the low
energy density of the current battery systems. This has as an implication that a lot of capacity in the
vessels must be used to store batteries. In addition, the extra weight is an obstacle. This will have an
impact on the required power needed to propel the vessel. Due to this it was concluded that the
technology is currently not realistic for any vessel in the scope of this study. The only exception here
are smaller electric pleasure crafts, those can use electric propulsion, since their required power is
limited.
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In addition to those larger technical measures, smaller, less drastic measures with a shorter payback
time were also discussed. This was based on a sample of the Clarkson WFR database for vessels
smaller than 5000 GT. From this sample it could be concluded that bow enhancement technology
and waste heat recovery are the main energy saving and carbon emission reducing technologies
applied nowadays. Bow enhancement devices differ from hull optimization. The former are small
additional elements installed on the hull of the vessels to reduce friction with the water. Heat recovery
devices recover residual heat and use it efficiently. Other energy saving devices exist, however bow
enhancement and heat recovery were respectively representing 61% and 32% of the reported sample.
All those smaller energy saving measures have a rather short payback time between 1 and 4 years.
The reduction potential is situated between 2% and 8%.
A last category of possible carbon reducing measures are the operational measures. Here speed
optimization and capacity utilization were discussed. Both can best be applied on cargo vessels and
are less or not applicable on dredgers, tug boats and fishing vessels. Capacity utilization is also not
applicable on pleasure boats. The applicability on cargo vessels is mainly depending on market
situations. Since the supply chains are usually short and market demand is varying heavily,
optimization processes are hard to implement on the short trajectories in scope, and therefore
obstacles are hard to overcome. The reduction potential when possible and correctly applied is
respectively around 10% and between 2% and 50% for speed optimization and capacity utilization.
As was concluded from the initiatives, the vessels in scope are in many cases not bound to regulations
on different levels, because those are only applicable to larger vessels. In addition the existing
initiatives to reduce the emissions of the vessels are mainly ad hoc and not really structured. To
optimize this process and to incentivise shipowners to adopt decarbonising technologies on their
vessels, several implementation measures have been proposed. A carbon taxation scheme could be
an option to stimulate more sustainable technology, however Belgium is only allowed to implement
a carbon taxation scheme on domestic navigation and not on international navigation. The latter is
regulated by IMO and the EU. As discussed in the report the EU is investigating how to implement
maritime navigation in its EU ETS. In any case it can be doubted when maritime navigation is
included, that it will be applicable on the vessels in scope of this study. Nevertheless, Belgium is
allowed to adopt a decarbonisation scheme for domestic navigation, as this is a competence of the
federal authorities.
In line with carbon taxation are the currently holding tax exemptions for maritime fuels. Those are
hindering the adoption of green technologies, because alternative fuels or other propulsion
technologies can never be competitive. Yet, Belgium cannot impose a fuel tax for international
maritime navigation. It can again only act on the national level, and therefore only on domestic
maritime navigation, a part of estuary shipping and recreative shipping. A fuel tax on maritime fuels
on the vessels in scope could result in tax profits around €20 million, which could be returned to
shipowners via subsidies. To establish a level playing field between conventional maritime fuels and
alternative fuels and propulsion types, the federal authorities are allowed to reduce tax rates on these
alternative technologies as well. In some cases, this should be requested to the European
Commission.
From the report it can be concluded that subsidies, i.e. R&D subsidies and modal shift subsidies, are
often viewed as state aid by the European Commission. This is only allowed if it is compatible with
the internal market. In many cases it can be argued that this will hold true because the subsidies
granted are supporting an important project of common European interest, i.e. global warming and
climate change.
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The competence allocation for the granting of those subsidies between the regions and the federal
authorities, can often be ambiguous. However, for both subsidy mechanisms, good arguments can
be given to allocate at least a substantive part of the competence to the federal authorities.
Nevertheless, because of the ambiguous situation, close cooperation between the federal and regional
authorities is needed to create enough clarity around this matter.
Environmental differentiated incentives have been discussed to reduce emissions. It can be
concluded that this is a competence of the regions and that it is of less importance for the reduction
of carbon emissions.
The holding monitoring systems from IMO and the EU, as was concluded above, are not applicable
on the vessels in scope of this study. Belgium nevertheless is authorized to one-sidedly implement a
scheme that is in line with those schemes, to also monitor the emissions of vessels smaller than 5000
GT.
In general, it can be concluded that several steps can be taken to decarbonise the Belgium maritime
sector for small vessels. Further steps are therefore discussed in the next section.
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6 Further possible research on Belgian level
As can be seen from the findings of this study, the vessels in scope are not sufficiently dealt with in
IMO and EU legislation. The consequence of this is that a relatively limited number of studies has
focused on the technical feasibility of decarbonizing measures for vessels smaller than 5000 GT. The
same holds true for the economic feasibility. Further work on different topics that will be named
hereafter, could help to implement a meaningful policy with regard to the vessels in scope.
A first category of further work concerns the proposed technical measures. From this study it is clear
that alternative fuels like hydrogen, ammonia, synthetic e-fuels and biofuels could be a serious option
to reduce the carbon intensity of the maritime sector. However for many of those alternative fuels
the same obstacles emerge. The availability of these fuels via bunkering facilities is currently limited.
Most of those fuels also have a smaller energy density than the conventional maritime fuels, which
means that more storage is needed to carry the required amount of fuel. In addition, the safety issue
related to these fuels is an issue as well. And as a last concern the large investments and the currently
high prices for those fuels should be mentioned. The adoption is therefore depending on whether
these obstacles can be removed. Further research could thus investigate into the possibilities to
ameliorate the infrastructure, storage and safety of the aforementioned alternative fuels.
Another element that could be subject to further study is the economic feasibility of the proposed
measures. A non-negligible part of the vessels in scope is owned by small companies or private
shipowners with relatively small cash buffers compared to other shipowners. For those specific
companies it is less obvious to invest in decarbonising measures. Therefore, there should be a
profound study into the payback times of several technologies mentioned. This could shed light for
shipowners in which technology to invest.
Chapter 4 dealt with the mechanisms that could help implement the decarbonising measures,
described earlier. The most important concern in that aspect is that the competences are mostly on a
higher level than the Belgian federal authorities. IMO and the EU have legislation implemented partly
related to the vessels in scope, however, this mostly focusses on larger vessels. This is also true for
the emission monitoring system. As was mentioned in the section 4.5, Belgium could opt to
implement a monitoring scheme for the vessels not subject to the monitoring system of IMO or the
EU. The concrete structure of this could be studied in more detail in a following study. The same
holds true for a carbon taxation scheme. The maritime sector will most likely be brought under EU
ETS, however this as well will most likely only be true for vessels larger than 5000 GT. Therefore the
possibilities regarding a taxation scheme for smaller vessels could be investigated as well.
A last element related to the implementation trajectories is the adoption of subsidy schemes. As was
explained above the interpretation with whom the competence lies is rather ambiguous. However, it
could be argued that the federal authority is competent to implement subsidy schemes in cooperation
with the regions. The concrete implementation of the scheme can be subject to further study.
Lastly, although decarbonising measures for the maritime sector will most likely also result in a
reduction of other pollutants like SO2, NOx, BC and PM, it could be argued that the focus of the
greening of maritime transport should be widened to those pollutants as well. This would mainly
affect the view that has been sketched regarding LNG as a maritime fuel.
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Abbreviations, symbols and units
CO2 Carbon dioxide
GT Gross tonnage
IPCC Intergovernmental Panel on Climate Change
kt Kilotonne
BCS Belgian Continental Shelf
m Meter
IWW Inland Waterway
ETS Emissions Trading System
EU European Union
IMO International Maritime Organisation
EEDI Energy Efficiency Design Index
EEXI Energy Efficiency Existing Ship Index
SEEMP Ship Energy Efficiency Management Plan
CII Carbon Intensity Indicator
DCS Data Collection System
g Gram
LNG Liquified Natural Gas
EEOI Energy Efficiency Operational Indicator
MRV Monitoring Reporting Verification
NOx Nitrogen oxide
RBSA Royal Belgian Shipowners’ Association
MIIDC Maritime Industry Decarbonisation Council
CMB Compagnie Maritime Belge
ABC Anglo Belgian Corporation NV
R&D Research and Development
kW Kilowatt
H2 Hydrogen
NH3 Ammonia
VLIZ Vlaams Insituut voor de Zee
FPS Federal Public Service
MGO Maritime Gasoil
HFO Heavy Fuel Oil
82
PM Particular Matter
SOx Sulphur oxide
WTT Well-to-tank
TTW Tank-to-wake
kWh Kilowatt hour
DP Dynamic Positioning
OECD Organisation for Economic Cooperation and Development
WFR World Fleet Register
USD United States Dollar
MW Megawatt
ORC Organic Rankine Cycle
MUSD Million United States Dollars
kUSD Thousand United States Dollars
P Power
v Speed
RoRo Roll-on Roll-off
ECR Effective Carbon Rate
t Tonne
GDP Gross Domestic Product
ETD Energy Tax Directive
WWF World Wide Fund for Nature
CAN Climate Action Network
ETTG European Think Tanks Group
T&E Transport & Environment
UNFCCC United Nations Framework Convention on Climate Change
ECSA European Community Shipowners’ Associations
TFEU Treaty on the Functioning of the European Union
CFP Common Fishery Policy
NOK Norway Krone
SEK Sweden Krone
CSI Clean Shipping Index
ESI Environmental Ship Index
EPI Environmental Port Index
Appendix
Table 3 gives an overview of the important parameters related to the technical measures studied in
section 3.1.
Table 3: Overview table technical measures.
Hull optimization LNG Hydrogen/ Ammonia Synthetic e-fuels Biofuels Hybrid power and propulsion system
Full electric Wind-assisted
Description
Improved hull design by increasing length, beam and adjusting block coefficient to keep or improve carrying capacity while reducing power requirement. Reduces drag and power requirements.
LNG-powered ship either with pure gas engine or dual-fuel engines.
Hydrogen in fuel-cell, ammonia I FC or in diesel electric engine.
Synthetic electro-fuels or E-fuels are gaseous or liquid fuels from hydrogen and captured carbon using renewable electricity.
Produced from biomass.
Combining 2 power sources and typically using batteries for peak power.
Full electric: electric powertrain and battery system, with charging from grid.
Kit sails, wing sails, fletner rotors
Hydrogen and ammonia are unconventional zero-carbon fuels; 3 distinct production pattern & energy source: 1.electrolysis with renewable energy; 2.steam reforming of natural gas; 3. electrolysis with EU-el-mix.
On a WTW basis, only (1) is to be considered.
WTT: For biofuels, there are large variations in WTT emissions, due to different sources of origin and all indirect effects.
Field of influence Hull design Fuel Low carbon fuels Low carbon fuels Low carbon fuels Energy system, Alternative energy sources
Energy system, Alternative energy sources
Propulsion
Applicability New builds only New builds New builds only Existing; New builds Existing; New builds Retrofit; New builds New builds Retrofit; New builds
Tech. Feasibility Most vessel, size and operation area.
Applicable to all types of vessel with diesel engine.
Potentially suitable for most ships, new builds, provided new energy system design, new infrastructure and safety regulation and class approval. But limited applicability due to low energy density; requires much space onboard; risk of explosion, find out where to place the tank.
fully compatible to be blended with grey diesel and LNG
Low sulphur content. Possible as drop in fuel (no need for new infrastructure). Compatible with combustion engines.
most appropriate for DP operations and operating under varying conditions (Offshore vessels, Drilling, Tugboats..)
most suitable for short sailing routes/time.
Kite, flettner rotor and single sail most appropriate for small and coastal vessels.
86
Maturity studies have been performed
currently best LNG technology only available on 2-stroke engines. 4-stroke still to be developed
Ammonia: engine technology for ammonia will be commercial the next challenge will be fuel supply, fuel price and access to Green ammonia Hydrogen within +5 years..
Technology has to be improved and production cost has to come
applicable to dual-fuel engines (biodiesel need for pure diesel engine)
technology available technology available Available in the market today; expect rapid development over the next 2-5 years
Challenges / bottleneck port fees (ref length) / rules and general regulations
no real challenges
Challenge: supply chain; infrastructure; new ship design; investment cost; technical service; safety issues; learning; class approval;
Production cost, availability, LCA assessment, infrastructure
Large variations in WTT emissions, due to their different source of origins / feedstock
System complexity
limited range (up to 40 nm for ferries); uncertain availability of green electricity; space needed for batteries; battery cost. Battery technology not competitive against diesel due to energy density.
Deck space, depends on operational performance and weather; need extra operation (cost)
Cost / Economic feasibility +10% building costs retrofit too expensive; M€ + 0
M€+ 0 high, appr. 3-10 times relative to VLSFO costs of 400 USD/ton.
3 times more expensive than MGO/LSHFO
00.000€ + z f battery + capex +10% newbuild
needs diesel engine and storage tanks for diesel as back-up.
M€ =
Overall saving CO2 eq. WTW 13-28%
15% CO2 eq. emissions when including CH4 and considering WTW. (25% CO2 TTW)
100%: only if produced with renewable energy source
1-100% depending on % of blend in
25-75% CO2e WTW Large variation in WTW GHG savings depending on the feedstocks used.
3-5% 100% if green electricity.
Kite up to 20%; Flettner rotor: up to 25%; Small ships: fletter rotor (econowind) savings 2.6 %, 6 years payback; Sail: saving 8%, 5 years payback.