Expert event on LNG bunkering regulations
Experts from various fields discussed a nationwide guideline for uniform LNG bunkering regulations
On September 24th the online event “Guidelines for the uniform regulation of LNG bunkering in German seaports” organized by the German Maritime Centre took place. Representatives of authorities, port operators, shipping companies and bunker suppliers spoke about different aspects and problems of LNG bunkering.
“The issue at hand is to promote the expansion and use of the water and land-based LNG bunker infrastructure in German seaports. That’s why it is important to get the stakeholders from different areas around one table”, says Claus Brandt, Managing Director of the German Maritime Centre. “We want to help create transparency and contribute to simplifying the legal regulations for the bunkering of LNG as fuel for ships. The results of today`s workshop will be incorporated into the study”, he continued.
“We are pleased that experts from relevant fields have come together to consider joint solutions”, said Bärbel Kunze, Regulations and Standards Adviser at the German Maritime Centre, because “harmonizing the different regulations and guidelines in the individual federal states will lead to a significant facilitation of all processes for LNG bunkering”.
Dr. Steffen Lüsse, Ministry of Economics, Transport, Labour, Technology and Tourism of the State of Schleswig-Holstein, emphasized the relevance of uniform procedural rules for LNG bunkering in German seaports: “In Schleswig-Holstein and also in Germany as a whole, an individual case permit has almost always been required for bunkering LNG. I see a need to revise our rules and regulations here.”
Thomas Rust then explained the current status of the study that Ramboll is preparing on behalf of the German Maritime Centre. This was followed by keynote speeches by the DEME Group and the Lübeck Port Authority, which provided practical information.
The following three parallel workshops dealt with questions 1) of the risk and hazard analysis, 2) of the regulatory texts and references and 3) the process of bunker request and SIMOPS (simultaneity of transshipment and LNG bunker process).
In Module 1, the focus was on the identification of security zones to ensure the safety and efficiency of vessel traffic and to protect the affected groups of people, such as crews and passengers, and infrastructure, such as bridges or floodgates. The participants advocated the use of existing best practice guidelines (especially EMSA Guidelines) in the preparation of risk analyses and interpretations of rules for constructions for LNG bunker ships and receivers.
The treatment of LNG bunkering (Module 2) in regulatory texts was discussed, only some explicitely reference LNG. For this reason, case-by-case regulations must almost always be applied for implementation of bunkering operations in practice. An exception is the port regulation in Mecklenburg-Western Pomerania, which explicitly permits the bunkering of refrigerated liquefied gases.
The participants made it clear that generally applicable requirements at the port level within the port use regulations should not affect the port’s sphere of influence when issuing permits. The port-specific characteristics of German seaports should be taken into account in the final version of the guidelines.
Module 3 dealt with the process of bunkering, namely the information provided by the ports on the one hand and the documents to be provided by LNG bunker customers and suppliers on the other hand. For the ports, LNG bunker maps showing port areas approved for LNG bunkering is particularly helpful. The information to be provided by the bunker receivers and suppliers (e.g. class certificates of the ships, proof of technical approvals) could form the basis for a catalogue of requirements that determines the qualification criteria for bunkering.
The module also exchanged experiences on the simultaneity of, among other things, the transshipment and LNG bunkering process (SIMOPS) and emphasized the necessity of establishing a procedure for the approval of SIMOPS that is as uniform as possible.
The results from the three modules were presented and discussed in the second plenary session. In a short survey: “LNG bunkering in regulatory texts – How should it be made possible in the future?” 49% of those questioned voted for a “may”-regulation: state law contains a paragraph on making LNG bunkering possible in principle.
At the end of the event Claus Brandt said: “There are still many open points – but I have seen many approaches to harmonization today. I would be pleased if we could remain in close communication, because I am sure that this will enable us to achieve a good result for the preparation of the guidelines.”
In early summer, the German Maritime Centre commissioned a study on the “Incorporation of legal regulations for refuelling ships with liquefied natural gas (LNG) and the development of a nationwide guideline for uniform LNG bunkering regulations in seaports”.
The aim is to develop a proposal for a harmonized legal and procedural situation in order to promote the expansion and use of the water and land-based LNG bunker infrastructure in German seaports. For this purpose, an inventory of existing regulations and proposals for LNG bunker regulations in seaports will be drawn up and the regulatory framework (relevant for LNG as a marine fuel) consisting of internationally binding conventions and applicable international/national and regional/local regulations will be examined.
The aim of the study is to identify missing elements for creating legal certainty and to define possible solutions. Furthermore, a nationwide guideline with uniform regulations for bunkering LNG in German seaports is to be developed. This guideline can create more certainty of assessment for those involved in the preparation and implementation of concrete projects (such as licensing procedures under the Hazardous Incident Ordinance).