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Opportunity Green: Deep Dive
This report was last updated in November 2023. Download the report here, or read the full text below.
Table of Contents
How Could Opportunity Green Address Climate Change?
Is There Room For More Funding?
Are There Major Co-Benefits or Adverse Effects?
Key Uncertainties and Open Questions
Summary
What is Opportunity Green? Opportunity Green is a UK-based nonprofit focused on addressing the gaps in global climate policy. Founded in 2021, it began with a focus on the global decarbonization of aviation and maritime shipping via policy, economic, and legal avenues. See our deep dive report for more information on decarbonizing aviation and maritime shipping. It also seeks to identify where there are gaps in law and regulation more broadly and how it can address these gaps to accelerate decarbonization in other sectors, including buildings and steel. We base our recommendation on Opportunity Green’s aviation and maritime shipping work and have not assessed its efforts in other sectors.
How could Opportunity Green address climate change? Opportunity Green invokes three main strategies in its work to decarbonize maritime shipping and aviation: (i) facilitating a private sector coalition to promote sustainable fuels, (ii) increasing representation from climate-vulnerable countries in the International Maritime Organization (IMO) to promote more progressive policies, and (iii) identifying and pursuing strategic legal action. Through these strategies, Opportunity Green aims to reduce emissions by decreasing demand for aviation and shipping, shifting industries to clean, alternative fuels, and ensuring that climate-vulnerable countries are supported in the transition.
Is there room for more funding? Opportunity Green could use additional funding to cover operational costs, hire more staff across projects, increase analytical capacity, and expand its communications team. Opportunity Green’s leadership values a healthy work culture and would also use funds to help ensure employee security and progression.
Are there major co-benefits or adverse effects? We think Opportunity Green’s potential co-benefits and adverse effects are linked to the technologies for which it advocates. For example, co-benefits of green hydrogen-derived alternative fuels include lower air pollution, and adverse effects include toxicity and other safety concerns. See our deep dive on Decarbonizing Aviation and Maritime Shipping for more information.
Key uncertainties and open questions: Our key uncertainties include our ability to evaluate the effectiveness of a young organization, potential difficulties attracting industry members to a coalition with ambitious climate targets, the effectiveness of legal action as a climate intervention, and the general feasibility of decarbonizing aviation.
Bottom line / next steps: We classify Opportunity Green as one of our top recommendations for nonprofits addressing climate change. We think it has a strong theory of change that tackles multiple pathways of influence, including coalition and capacity building, policy advocacy, and legal action. Opportunity Green is a small organization with robust plans for growth and the ability to utilize significant amounts of additional funding.
What is Opportunity Green?
Opportunity Green is a UK-based nonprofit focused on the gaps in global climate policy. Founded in 2021, it began with a focus on the global decarbonization of aviation and maritime shipping via policy, economic, and legal avenues. It also seeks to identify where there are gaps in law and regulation more broadly and how it can address these gaps to accelerate decarbonization in other sectors, including buildings and steel. We base our recommendation on Opportunity Green’s aviation and maritime shipping work and have not assessed its efforts in other sectors. See our deep dive report for more information on decarbonizing aviation and maritime shipping.
Opportunity Green was founded by Aoife O’Leary, a lawyer and economist who previously created and led the shipping program at the Environmental Defense Fund. As of November 2023, Opportunity Green has 12 staff based in the UK.
How Could Opportunity Green Address Climate Change?
Opportunity Green invokes three main strategies: (i) facilitating a private sector coalition to promote emissions standards and fuel mandates, (ii) increasing representation from climate-vulnerable countries in the IMO to promote more progressive policies, and (iii) identifying and pursuing strategic legal action. Opportunity Green determines its priorities among these strategies based on available funding and project feasibility.
Strategies
Facilitating a private-sector coalition to promote sustainable fuels
Opportunity Green established the Skies and Seas Hydrogen Accelerator (SASHA) Coalition to unite companies in maritime shipping, aviation, and alternative fuel production to advocate for policies that facilitate commercial-scale production of clean fuels such as e-ammonia, e-methanol, and e-SAFs.[1] Policy goals include increasing the ambition level of e-fuel targets in EU climate regulations (the Fit for 55 package) and ensuring safeguards against reliance on biofuels and LNG.[2] To achieve these goals, Opportunity Green facilitates meetings between SASHA members and policymakers and coordinates the drafting of public and private letters. SASHA is in its early stages, and our understanding is that it will initially focus on UK and EU-based companies and policy. The inaugural members of this coalition have not yet been released.
Increasing IMO representation to promote more progressive policies
The International Maritime Organization (IMO) is a UN agency that regulates shipping globally and, combined with national and subnational policies, is considered an effective and comprehensive avenue for establishing ambitious emissions standards.[3] While the IMO’s standards are the most ambitious to date, Opportunity Green believes that to align with climate goals, the IMO needs to incorporate stronger commitments and clarity to ensure advancement toward its stated targets.[4] Specifically, Opportunity Green advocates for at least 37% lifecycle emissions reductions by 2030 and 96% by 2040.[5]
To influence the IMO to raise the ambition level of its targets, Opportunity Green works to increase the representation and participation of climate-vulnerable countries in IMO functions. Opportunity Green has begun capacity building by engaging with countries that have (i) historically been absent from IMO convenings and (ii) are disproportionately affected by climate change, such as Small Island Developing States (SIDS).[6] Opportunity Green claims that because these countries feel climate change more acutely, despite accounting for very few emissions, they tend to support more progressive international policies, especially ones that substantially reduce Global North emissions and enable climate finance for adaptation.[7] It thinks that increasing the number of progressive voices could help move the moderate block, including the US and EU, that has dampened IMO ambition levels. Opportunity Green is now beginning work with EU Member States to identify an EU champion of the climate-vulnerable supported policies in the IMO and is commissioning research to support climate-vulnerable countries in highlighting the potential benefits of raising additional climate finance from a levy on shipping pollution.
As part of this work, Opportunity Green has filed a submission to the International Tribunal for the Law of the Sea (ITLOS) in support of the Commission of Small Island States (COSIS)’s request for the Tribunal to recognize countries’ obligations to regulate shipping emissions in line with 1.5°C climate goals.[8] A favorable advisory opinion from the ITLOS could increase pressure on IMO member states to align IMO ambition with the Paris Agreement goals. It may also open avenues for future State climate litigation (for example, actions against national governments or supporting a climate-vulnerable country to take action against another government).
Identifying and pursuing strategic legal action
Opportunity Green sees litigation and non-judicial legal action as complements to policy advocacy, especially for sectors where policy efforts have lagged. It claims that climate litigation and legal action have historically focused on governments and that increasing legal pressure on corporations is important. Opportunity Green has defined the scope of its legal strategy as “cases that seek broader systemic outcomes and social impacts, in contrast to traditional litigation that prioritises the immediate aims of an individual claim.”
Opportunity Green has identified aviation, shipping, and buildings as key sectors for strategic climate legal action. As an example, aviation is a potentially key sector for a variety of reasons, including
The International Civil Aviation Organization (ICAO), the entity tasked with governing aviation internationally, is not considered an effective lever for standards setting or implementation[9]
Without strong global policies, countries are less likely to take action independently given the inherently international nature of the sector
A legal victory against one major multinational corporation in the private sector could have a significant impact on the entire industry
Aviation’s direct client-facing nature makes reputational damage a powerful lever to influence industry behavior change.
The first phase of Opportunity Green’s strategy includes analyzing litigation cases in the aviation industry, identifying cases with precedent, and ranking each case with respect to feasibility, risk, and scale of impact. Opportunity Green’s lawyers are UK-qualified but have experience with EU law, so it does not restrict itself by jurisdiction. This phase is close to completion, although it will not be made public to maintain confidentiality over potential actions.
In the second phase, Opportunity Green will directly participate in climate judicial (e.g., court-based) and non-judicial actions (e.g., actions outside of a court setting, such as in front of advertising standards agencies or other non-court-based regulators or letter-writing campaigns such as to company directors) and assist NGOs without legal teams to develop and take their own actions. It has launched this second phase by challenging an airport expansion project in Crete.[10] Our understanding is that the choice of beginning with airport expansion was based on timing and opportunity as well as the potential to broaden the impact by challenging the international financing of airport expansions by the European Investment Bank. Airport expansion does not represent the full breadth of legal opportunities that Opportunity Green is considering. A particular future focus will likely be unilateral action by Opportunity Green and support to other NGOs focusing on corporate responsibility, including greenwashing allegations related to offsets and sustainable aviation fuels (SAFs).
Opportunity Green has also undertaken legal work in the maritime shipping sector and is conducting a similar scoping exercise to identify potentially impactful legal actions. Recently, it has compiled a report highlighting the cruise industry’s misleading claims about the climate benefits of liquified natural gas (LNG) and filed complaints with the UK’s Advertising Standards Authority (ASA).[11] The overall purpose is to delegitimize investment in LNG as a ‘transitional’ fuel in the shipping industry more widely by raising awareness of the issue with regulators and building a basis of legal and regulatory decisions against its use. Greenwashing by cruise companies is the first step in this approach, and Opportunity Green’s legal team is currently strategizing further LNG-related actions in the shipping sector.
As a result of targeted funding, Opportunity Green is also undertaking legal work related to the building and steel sectors, adopting a similar strategic legal review approach. The building sector work is focused primarily on decarbonizing homes and is considering issues such as the adverse health impacts of gas cookstoves and the inefficiency of hydrogen as a potential future fuel in domestic heating. The steel work began in Q4 2023. We have not assessed these work streams.
Theory of change
We use the above strategies to construct two theories of change to reflect our impression of how Opportunity Green can influence the decarbonization of (i) aviation and (ii) maritime shipping. Below each theory of change, we discuss and evaluate the main assumptions related to the theory of change. For each assumption, we rank whether we have low, medium, or high certainty about the assumption.[12] Our assessment is based on both primary and secondary evidence, as well as our general impression of the plausibility of the assumption. Importantly, a number of the stages of the theory of change may not be amenable to easy measurement or quantification, are not supported by a robust evidence base, or are expected to occur in the future but have not occurred as of yet.
Aviation
Examining key assumptions
1. SASHA can influence the adoption of ambitious policies for sustainable fuels (medium certainty)
We believe that coalitions can be a powerful form of political advocacy, especially with private-sector involvement. While still in its early stage, one of SASHA’s first initiatives was to produce an in-depth report evidencing that insubstantial policy support of green hydrogen has slowed demand and investment. We think this analysis helps build the case for policy intervention and is an important resource for potential new members.
Opportunity Green expressed that it plans to ensure that SASHA promotes ambitious targets and policies and that companies must align with these ambition levels to be considered for membership. We think that if the size and influence of SASHA grow, it will be in a strong position to pressure other industry actors to support more progressive policies. However, if ambition levels are too high, especially in the absence of a successful track record, it could be the case that SASHA may have difficulty attracting members. This may not be the case given (i) the growing number of relevant climate tech start-ups and (ii) our impression is that these start-ups tend to be more progressive than established companies. We may be wrong and address this in our Key uncertainties and open questions section.
2. Increased consumer awareness of the sector’s emission results in direct demand reduction and policies to reduce air travel (medium certainty)
Although we are not optimistic about voluntary behavior change in individuals, we see more potential for demand reduction resulting from (i) corporate consumers and (ii) policy. It is our impression that corporate consumers that ship products by air could noticeably reduce demand if they transition to other forms of transport. For example, Apple has stated that it will begin to rely more on maritime shipping and rail to ship its products.[13] France’s legislation to ban short-haul domestic flights (2.5 hours or less) resulted from public advocacy following the Yellow Vest protests.[14] We think this policy is replicable, although likely limited to countries with substantial rail infrastructure.[15]
3. Absent policy perception of risk influences the aviation industry to pursue fleet transformation and increase e-SAF purchase commitments (low certainty)
We think the aviation industry will unlikely be moved by the perception of risk – via increased consumer awareness or internal risk assessment – without stringent regulation. This is because (i) there are often no viable alternatives to air travel, and (ii) the loss of revenue due to behavior change or policy may not be large enough to incentivize investment in high-cost interventions such as e-SAFs.
4. Policies and industry offtake agreements enable e-SAFs to become cost-competitive and scale to meet the needs of the aviation sector (low certainty)
The production cost of e-SAFs will depend on the cost of sourcing green hydrogen and CO2. The most climate-beneficial sources of CO2 may either be through carbon removal technologies like direct air capture (DAC), which are currently quite expensive, or sustainable biomass, for which feedstocks are limited. E-SAFs are among the most costly fuels, given the price of feedstocks and the complex chemical reactions involved in the production process. We think that it will require broad and ambitious incentives for e-SAFs to become cost-competitive with conventional jet-fuel or biomass-based sustainable aviation fuels, and we think it is possible that they may be unable to scale to meet the needs of the sector. We address this as a key uncertainty.
Maritime Shipping
Examining key assumptions
1. SASHA can influence the adoption of ambitious policies for emissions standards and clean fuel technologies (medium certainty)
Same as assumption 1 for aviation.
2. Increased participation of underrepresented, climate-vulnerable countries leads to more ambitious IMO policy (medium certainty)
We think that increasing the participation of underrepresented, climate-vulnerable countries could lead to increased pressure to put the policy in place to achieve the IMO’s progressive standards and targets. This is evidenced by the request of countries, led by Tuvalu and Antigua and Barbuda, for the relevant judicial body to consider shipping emissions.[16]
However, we also think that given such recent modifications (July 2023) to the most progressive climate targets for the shipping sector, it may be unlikely to expect further action in the short term.[17] In particular, we think that member states may be reluctant to vote for stricter measures if they fear pressure to ensure that their domestic policies match the ambition level of the IMO. We think this might already be happening at the EU level, given that its maritime shipping regulations are weaker than those of the IMO.[18]
3. Absent policy, consumer awareness of greenwashing in the context of LNG accelerates industry’s switch to clean fuels such as e-ammonia or e-methanol (low certainty)
Given the high costs and low supply of clean alternative fuels and vessels powered by them, we are concerned that consumer awareness may not significantly influence the industry’s transition away from LNG in the absence of robust policy. We think it is especially unlikely in the context of cruise lines given the industry’s poor environmental track record, evidenced by their continual breach of environmental regulations even after facing lawsuits and fines.[19]
4. Policies and industry offtake agreements enable alternative fuels such as e-ammonia and e-methanol to become cost-competitive and scale to meet the needs of the shipping sector (medium certainty)
The cost trajectories of e-ammonia and e-methanol are highly correlated to the cost of green hydrogen. Given cross-sector demand and the uptick in supply-side hydrogen policy initiatives, we have medium certainty that green hydrogen can become cost-competitive and be scaled to meet the needs as a feedstock for these fuels. We think it may be more difficult for e-methanol to scale, as it also depends on sourcing atmospheric CO2. According to a 2019 study, while e-methanol and e-ammonia are more expensive than their fossil fuel counterparts at present, they could become cost-competitive by 2040 and even cheaper by 2050.[20] For more information on these fuels, see our deep dive report on decarbonizing aviation and maritime shipping.
Is There Room For More Funding?
Opportunity Green’s 2023 budget is £1,000,000 (about $1.24 million USD). Its projected 2024 budget is £1,750,000 (about $2.2 million USD). Funders include ClimateWorks Foundation, Oceankind, Oak Foundation, and the European Climate Foundation.
Our understanding is that as of November 2023, about 90% of Opportunity Green’s funds are restricted and directed to specific projects. Opportunity Green would like more unrestricted funds to allocate money based on its own priorities and invest more in its internal needs, such as operational expenses. Also, Opportunity Green said it would like more multi-year funding to ensure employee security and enable longer-term strategy building. Opportunity Green’s plans for growth include:
Increasing communications capacity across projects
Hiring more staff to engage in global hydrogen policy discussions and facilitate meetings between industry and policymakers
Hiring staff to educate NGOs and governments about the aviation and shipping sectors to build momentum for future climate finance efforts
Hiring staff with analytical skills to support on economic impacts of policies, especially with regard to climate finance
Hiring more lawyers, including a senior litigator, and contracting barristers for ad hoc opinions and consulting
Continuing to improve employee security and wellbeing to continue to foster a healthy work culture.
Based on these plans for growth, we think that Opportunity Green can absorb additional funding effectively.
Are There Major Co-Benefits or Adverse Effects?
We think Opportunity Green’s potential co-benefits and adverse effects are linked to the technologies for which it advocates. For example, co-benefits of green hydrogen-derived alternative fuels include lower air pollution, and adverse effects include toxicity and other safety concerns. See our deep dive on Decarbonizing Aviation and Maritime Shipping for more information.
Key Uncertainties and Open Questions
Organizational effectiveness: Opportunity Green is young and still establishing a track record of success. We have high confidence that Opportunity Green will be effective given the credentials and experience of its CEO and staff, its diversified theory of change, and its leadership’s focus on growing sustainably as an organization. As Opportunity Green matures and executes its strategy, we expect to learn more about its effectiveness.
Industry coalition strength: Opportunity Green has chosen to ensure that SASHA coalition members share ambitious policy goals. We think this could reduce the coalition’s size and influence, especially if it excludes more established industry players. As SASHA membership expands, we will have more information to assess its progress and standing.
Effectiveness of litigation: Giving Green has historically been skeptical regarding the effectiveness of legal action as a climate intervention.[21] We think that Opportunity Green’s strategy is novel in that it takes a comprehensive approach, beginning with an in-depth analysis and ranking of possible legal strategies. However, we are unsure about its initial project, which targets an airport expansion project in Crete. Specifically, we are uncertain about this project’s replicability and the potential for leakage if the airport expansion is simply delayed or results in additional infrastructure elsewhere. We will update our assessment as Opportunity Green progresses with its legal strategy.
Feasibility of decarbonizing aviation: Aviation is one of the most difficult sectors to decarbonize as there is no clear, viable technological pathway. We believe that Opportunity Green’s strategy to promote both the adoption of e-SAFs and demand reduction for air travel is pragmatic. However, it is possible neither of these approaches can scale to meet mid-century goals. We think that a possible scenario is that the aviation sector cannot fully decarbonize and could, for some time, rely on carbon removal to compensate for these unabated emissions.[22]
Opportunity Green’s cost-effectiveness: We chose not to quantify Opportunity Green’s cost-effectiveness given the high uncertainty across key parameters and the shortcomings of these models to address the complexity of the space. Instead, our general research into what is needed to decarbonize aviation and maritime shipping forms the basis of our evaluation, and we think that our analysis of the technical, policy, investment, and philanthropy landscapes enables us to identify organizational strategies that are highly effective. By not modeling Opportunity Green’s organizational cost-effectiveness, we may lose the ability to compare its cost-effectiveness with that of other giving opportunities. However, it’s important to note that our cost-effectiveness analyses are generally regarded as rough plausibility checks.
Bottom Line / Next Steps
We classify Opportunity Green as one of our top recommendations for nonprofits addressing climate change. We think it has a strong theory of change that tackles multiple pathways of influence, including coalition and capacity building, policy advocacy, and litigation. The organization could use additional funding to support operational costs, hire more staff across projects, increase its communications capacity, and create an advisory panel of senior lawyers.
We believe its strategies and geographies of focus complement those of Clean Air Task Force, another Giving Green recommendation identified, in part, for its work to decarbonize aviation and maritime shipping. We plan to continue assessing our key uncertainties and believe that we will be able to substantially improve our understanding of the severity and importance of some or all of these uncertainties in the near future.
Endnotes
Opportunity Green is a registered charity in the UK. This non-partisan analysis (study or research) is provided for educational purposes. Unless otherwise cited, information in this deep dive comes from direct correspondence with Opportunity Green.
[1] We use e-SAFs to refer to synthetic jet fuels, produced using green hydrogen and sustainable CO2.
[2] The Fit for 55 package is an EU-level policy which aims to reduce the EU’s emissions by 55% by 2030; it contains the FuelEU maritime shipping and aviation initiatives targeted toward increasing the use of sustainable fuels.
[3] “The global scope of the IMO presents a unique opportunity to develop consistent, comprehensive global policy solutions for decarbonization.” Global Maritime Forum (2022)
[4] The IMO’s strategy isn’t currently binding, and it lacks specific measures to achieve its stated targets. Nevertheless, it represents significant progress from previous positions. However, the absence of alignment with the 1.5° C target is a major shortfall.” ClimateWorks (2023)
[5] “Include a 2030 target of at least 37% annual GHG reduction emissions on a lifecycle basis…” Opportunity Green (2023)
[6] “Opportunity Green has particular expertise in shipping policy at the international level. It specifically works with climate vulnerable countries, who are traditionally under-resourced and underrepresented at the International Maritime Organization (“IMO”), providing them with briefing notes, facilitating information sharing and networking events and hosting bilateral meetings as required to help in the preparation of countries’ positions.” Opportunity Green (2023)
[7] “This raises intriguing questions about how these divergent approaches will unfold. Fuel standard measures and pollution levies are of high interest to many countries because they can generate climate finance for adaptation and mitigation in countries most impacted by climate change. However, those countries aren’t necessarily in the room to help make those decisions.” ClimateWorks (2023)
[8] The International Tribunal for the Law of the Sea (ITLOS) is an independent judicial body established by the 1982 United Nations Convention on the Law of the Sea. The Commission of Small Island States on Climate Change and International Law (COSIS) is a UN commission with a mandate to “to promote and contribute to the definition, implementation, and progressive development of rules and principles of international law concerning climate change, including, but not limited to, the obligations of States relating to the protection and preservation of the marine environment and their responsibility for injuries arising from internationally wrongful acts in respect of the breach of such obligations."
[9] “In the past few years ICAO has faced criticism and been seen rightly or wrongly as an outlier even in the UN system for its lack of transparency in decision-making, its lack of access to information by the media, undue influence of industry (“captured by producer interests”: The Economist), restricted involvement of civil society and independent scientists, and its political interference in the culture and workings of the Secretariat.” Centre for Aviation (2021)
[10] “Our findings show the project is based on flawed and lacking climate change analysis and brings into question the commitments of Greece and the EIB to climate action and the Paris Agreement temperature goal.” Opportunity Green (2023)
[11] “As a result of the findings in the report, Opportunity Green has also filed a series of complaints to the UK’s Advertising Standards Authority (ASA) against some of the biggest international cruise companies to try to put an end to this apparent LNG greenwashing, which is potentially misleading consumers.” Opportunity Green (2023)
[12] We describe our certainty as low/medium/high to increase readability and avoid false precision. Since these terms can be interpreted differently, we use rough heuristics to define them as percentage likelihoods the assumption is, on average, correct. Low = 0-60%, medium = 70-80%, high = 80-100%.
[13] “The company is shifting more product volume to shipping modes that are less carbon-intensive than air transport, such as ocean or rail. Apple’s carbon footprint methodology shows that shipping the same product by ocean emits 95 percent fewer emissions than by air.” Apple (2023)
[14] “The ban was originally put forward by a Citizen's Convention that suggested all flights should be banned if there is a 6-hour train journey available, which would have banned more flights. The Convention was convened by President Macron after the Yellow Vest 'Gilet Jaune' protests against social inequality.” Forbes (2023)
[15] “Rutherford says there’s a sweet spot: For trips of less than 500 miles, replacing a flight with high-speed rail could put a dent in air travel. Flights of less than 500 miles make up about a quarter of the United States’ domestic air traffic.” Washington Post
[16] The International Tribunal for the Law of the Sea (ITLOS) is an independent judicial body established by the 1982 United Nations Convention on the Law of the Sea. It has jurisdiction over any dispute concerning the interpretation or application of the Convention, and over all matters specifically provided for in any other agreement which confers jurisdiction on the Tribunal. Disputes relating to the Convention may concern the delimitation of maritime zones, navigation, conservation and management of the living resources of the sea, protection and preservation of the marine environment and marine scientific research.” ITLOS n.d.
[17] “The IMO’s global purview and the need to account for perspectives of a large and diverse set of Member States (and organizations with observer status that influence those Members) have resulted in slow action from this body on decarbonization.” Global Maritime Forum (2022)
[18] “A substantial surprise lies in the European Union’s positions. Despite enacting various shipping legislations, the IMO’s strategy outpaces the European Union’s ambitions in certain aspects.” Climateworks (2023)
[19] “Cruise companies have been fined for everything from illegal dumping of toxic chemicals, sewage, plastics, and oil into our oceans, as well as violating local port regulations, and even continuing to violate federal and state laws while under court-ordered probation.” Friends of the Earth n.d.
[20] Fuel production cost estimates and assumptions. Lloyd’s Register (2019)
[21] “Litigation was ranked third, reflecting the fact that litigation is a mixed-success endeavor, in that it may often not achieve its goals, and is subject to existing precedent and legal institutions.” Giving Green (2021)
[22] “This is difficult in practice, and CDR could start well before 2050 to accommodate a more feasible trajectory of emissions reduction. It is followed by an increasing removal effort due to the rising RF induced by the fleet.” Sacchi et al (2023)