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Sep 17, 2020
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Lockton Edge
Edge
Norway

IUMI 2020: Parts of ocean hull still unsustainable, but Chandran is optimistic

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

In his introduction to the ocean hull workshop yesterday September 16th, Rama Chandran, chair of the Ocean Hull Committee and Head of Marine for QBE Singapore, said that the ocean hull market had been “operating unsustainably for many years and is now at a level where premiums will cover attritional losses only”. However, he also said that, “although Covid-19 has introduced additional uncertainty into our sector we are observing signs of a market recovery.”

Chandran began by welcoming three new members to the committee – Edmund Kan from Hong Kong, Lone Scheuer Larsen from Denmark, and David Kim from South Korea. He also thanked the departing members, singling out Mark Edmondson for particular thanks.

Chandran noted that a number of international markets were reporting a stronger underwriting environment moving through 2019, but he said that pricing remained inadequate. The increase of 0.2% in 2019 to $6.9bn, was “somewhat disappointing”. Referring to the most recent numbers from the Facts And Figures Committee and early indications for 2019 (many of these events take several years to mature), Chandran said that an opening year gross loss ratio of 70% was not sustainable.

He noted that gross premiums had failed to keep pace with increases in gross tonnage, average age, and number of vessels. “We still have a long way to go”, he said, adding that “however, there have been indications of a more significant market development recently and I am confident that the ocean hull sector is now on an upward trajectory – although the current gradient of the recovery remains shallow”.

There had been an increase in inter-market competition and the Nordic sector had bucked the trend. Premium levels at Lloyd’s, meanwhile, reflected the closure of a number of syndicates, with gross premiums in the sector now third behind Singapore and Nordic, although all were now revolving around the $1bn a year figure.

Chandran said that the impact of Covid-19 needed to be monitored. Although claims activity this year was low, due to a decrease in vessel utilization in some vessel sectors, he warned that this sweet spot could be short-lived.

“The coronavirus situation has made it difficult for owners to commission on-board inspections, secure spare parts and perform routine maintenance. Once the situation normalizes, we are likely to see a sharp increase in attritional claims”, he warned, citing delayed inspections, more difficulty in effecting repairs, delays in putting vessels in for repair, postponements of maintenance, and the increasing danger of crew fatigue.

Chandran noted that “in general, total losses have reduced across all vessel types and this is extremely good news, but we are still seeing a worryingly high number of major on-board fires”.

Problems related to IMO 2020 compliance might have dropped out of the headlines, but they had not gone away. Chandran said that, while damage caused by fuel switching had largely been eliminated, there was significant cause for concern over an increased amount of engine damage as a result of accepting off-spec low-sulphur bunkers.

Of particular concern was a report from FOBAS of low flash points for gas oil. Chandran had already noted that fire danger was something of an outlier, because its frequency was not falling. From 2015 to 2019, fire was the cause of 14% of total cost claims, second after only machinery & grounding.

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