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Feb 25, 2016
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Lockton Edge

Britannia and UK Club to merge

The European Union’s Emissions Trading System (EU ETS) was extended to cover emissions from shipping as of 1st January 2024.

The EU ETS is limited by a 'cap' on the number of emission allowances. Within the cap, companies receive or buy emission allowances, which they can trade as needed. The cap decreases every year, ensuring that total emissions fall.

Each allowance gives the holder the right to emit:

  • One tonne of carbon dioxide (CO2), or;
  • The equivalent amount of other powerful greenhouse gases, nitrous oxide (N2O) and perfluorocarbons (PFCs).
  • The price of one ton of CO2 allowance under the EU ETS has fluctuated between EUR 60 and almost EUR 100 in the past two years. The total cost of emissions will vary based on the cost of the allowance at the time of purchase, the vessel’s emissions profile and the total volume of voyages performed within the EU ETS area. The below is for illustration purposes:
  • ~A 30.000 GT passenger ship has total emissions of 20.000 tonnes in a reporting year, of which 9.000 are within the EU, 7.000 at berth within the EU and 4.000 are between the EU and an outside port. The average price of the allowance is EUR 75 per tonne. The total cost would be as follows:
  • ~~9.000 * EUR 75 = EUR 675.000
  • ~~7.000 * EUR 75 = EUR 525.000
  • ~~4.000 * EUR 75 * 50% = EUR 150.000
  • ~~Total = EUR 1.350.000 (of which 40% is payable in 2024)
  • For 2024, a 60% rebate is admitted to the vessels involved. However, this is reduced to 30% in 2025, before payment is due for 100% with effect from 2026.
  • Emissions reporting is done for each individual ship, where the ship submits their data to a verifier (such as a class society) which in turns allows the shipowner to issue a verified company emissions report. This report is then submitted to the administering authority, and it is this data that informs what emission allowances need to be surrendered to the authority.
  • The sanctions for non- compliance are severe, and in the case of a ship that has failed to comply with the monitoring and reporting obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance, the competent authority of an EEA port of entry may issue an expulsion order. Where such a ship flies the flag of an EEA country and enters or is found in one of its ports, the country concerned will, after giving the opportunity to the company concerned to submit its observations, detain the ship until the company fulfils its monitoring and reporting obligations.
  • Per the EU’s Implementing Regulation, it is the Shipowner who remains ultimately responsible for complying with the EU ETS system.

There are a number of great resources on the regulatory and practical aspects of the system – none better than the EU’s own:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02003L0087-20230605

https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-sector_en

https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/what-eu-ets_en

Britannia and UK Club advises that a merger process has been commenced between the two clubs, which would in GRT terms would be of the same size as Gard. The merged club would also in USD income terms be of equals size to Gard. Gard additionally writes about USD 300 million in marine hull and energy income. Given that most observers generally were expecting that consolidation would be focused on the smaller and weaker clubs, the move is surprising since it involves the IGA’s second and fifth largest clubs measured in GRT.Britannia has made the following announcement: “The boards of the Britannia Steam Ship Insurance Association Limited, the United Kingdom Mutual Steam Ship Assurance Association (Europe) Limited and the United Kingdom Mutual Steam Ship Assurance Association (Bermuda) Limited are in merger discussions. The Clubs are leaders in their field and strong supporters of mutuality. The boards of the Clubs will now begin a process to determine whether the merger is possible and delivers appropriate benefit to their respective Memberships. The talks are concurrent with discussions between their managers, Thomas Miller and Tindall Riley, both leading international providers of insurance and professional services, which would also lead to a merger of the respective businesses should the Clubs decide to merge. The Clubs are now going through the process of discussions. Ultimately, the decision on whether to proceed with a merger will be decided by the Members at Special General Meetings to be convened later in the year.” UK Clubs announcement states: “Members will have seen that the Club has just issued a circular advising that it is in discussions with the Britannia P&I Club about a possible merger. This development results from an active process of the Club Board over recent months in which it has examined the Club’s strategic options for the future, and where the key drivers include the preservation of the mutual P&I system, and achieving a scale that enables the most efficient capital structure and cost effective insurance. The merger will also enable the new club to invest in people and resources for the direct benefit of members. The rationale and the benefits of a merger will be considered by the boards of both P&I clubs in the next few months. An additional board meeting is now scheduled for April, where the issues will be discussed in some detail. Then, after a period of further consideration, the boards of both clubs will decide at their Board meetings in May whether they are prepared to recommend the merger to their membership. If so, there would then be a Special General Meeting of each club towards the end of June. If the membership of both clubs votes in favour of the merger, then steps would be taken with a view to creating a single merged club in time for the 2017 renewal.”

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