The use of ships within a CCUS system: Regulation and liability

The transport of CO₂ by ships for storage or utilisation is a component of CCS/CCUS systems which has been considered based on existing ship designs and on the assumption that the internationally agreed standards are always applicable and always constrain the ship and storage designs that can be used. This paper demonstrates that, for systems developed to be used within one or two jurisdictions, novel ship and storage designs can be considered irrespective of the international regulatory system. Significant discretion also exists within the international regulatory system for novel designs. Thus, the consideration of cost and efficiency of CCUS systems need not be constrained to existing ship designs. In addition, the established limitation of liability regime, which protects shipowners, charterers, managers, and operators of ships, provides an upper limit for the financial exposure for losses during transport by ships, an aspect which is not well defined when pipelines or other modes of transport are considered.