Ban on the provision of maritime transportation and associated services for Russian oil: RPC Opinion (Green-rated)
RPC’s Opinion on HMT’s Impact Association on the Ban on maritime transportation of Russian oil IA
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Details
The IA covers a ban on UK persons providing services, including brokering services and financial assistance, related to the maritime transportation of Russian oil and oil products. The proposal will also prohibit UK vessels from transporting Russian oil.
On first submission the IA received an initial review notice (IRN). The IA needed to:
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explain and justify its approach of calculating the EANDCB, in particular applying 7.5 per cent to £979 million (see summary below);
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address further the cost to shipping companies of having to ensure compliance and possible costs to ports;
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explain why familiarisation and training costs would be negligible and not proportionate to monetise;
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discuss further impacts on UK maritime service provision to non-Russian firms involved in the transport of Russian oil and why this cannot be monetised;
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explain further why an assumed 50 per cent of costs would occur in the counterfactual; and
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justify the five-year appraisal period.
In addition, the IA needed to discuss any data on likely numbers of SMBs affected and disproportionality of impact on these businesses.
The IA is now considered as fit for purpose. The assessment of direct impacts on business is proportionate, given the limitations in available data and relatively low impact of the measure. The assessment of impacts on small and micro businesses has been strengthened significantly. There are some areas where the IA could be improved, in particular on monitoring and evaluation plans.