But something has not been considered. What if you were lifting B100 not to be compliant, but to generate a surplus? What if you factor in the profit from selling it?
B100 quoted at 1,360 USD/pmt becomes around 1,223 USD/pmt after EUAs, energy density and FuelEU Maritime. Sell the surplus each tonne creates, count that profit as a saving, and 1,223 becomes around 961.
So what is the value of the biofuel: 1,223 or 961?
Surplus has three uses. It can cover the fossil fuel the same vessel burns, and 100 mt of B100 covers around 4,500 mt of MGO before a penalty is incurred. It can be banked for a later year. Or it can be pooled to another vessel, and when that vessel is someone else's, the surplus converts to cash. The 961 assumes that conversion happens. But pooling is one of three options, and a company can spread surplus across its own fleet where the benefit is cost avoided rather than revenue earned. Building the sale into the abatement cost assumes an intention to sell that many buyers do not have.
A quieter problem inside the 961: which pooling price? Prices come through many sources, the spread is wide, and the reader rarely knows which one sits inside the number.
