Annex E Analytical Assurance Statement
Updated 20 February 2024
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Merchant Shipping (Prevention of Pollution by Sewage from Ships and Prevention of Pollution by Garbage from Ships) (Amendment) Regulations 2024
DfTDMA301
Consultation stage
Analytical assurance statement
The Merchant Shipping (Prevention of Pollution by Sewage from Ships and Prevention of Pollution by Garbage from Ships) (Amendment) Regulations 2024 requires that vessels between 100GT and 400GT purchase and use a Garbage Record Book (GRB).
The analysis is proportionate. Good quality data, such as actual market prices, data on the UK flag, internal data to the Maritime and Coastguard Agency (MCA), and the Annual Survey of Hours and Earnings, is used to estimate the impacts. Some assumptions have been made by policy experts in the MCA. The measure is within the de minimis threshold of +/- £5m EANDCB, and is not controversial, as it has already been agreed by member states of the International Maritime Organisation, including the UK. The risk of challenge is low.
The risk of error is low. The analysis has been produced and quality assured by MCA economists, reviewed by Department for Transport economists, and been through the Better Regulation Unit process of sign off and peer review. The analysis has not been constrained by time and uses standard appraisal processes, compliant with the Transport Analysis Guide, the Better Regulation Framework and the Green Book.
The level of uncertainty is medium. Some broad assumptions have been made, such as the time taken to update the GRB and the number of GRBs purchased a year. A low, medium and high range has been used to account for this, and conservative assumptions have been used to reduce the risk of underestimating the costs.
Overall, the analytical assurance rating is medium-high.