Developing LNG Bunkering Facilities in Ports: Governance and Good Practice

The present Section highlights the role of Port Authorities and Administrations in the context of LNG bunkering, throughout the entire life-cycle of these projects, from concept to development and actual implementation, as differentiated Port Services.

How to incorporate LNG as fuel, and in particular LNG bunkering, into the different management policies for PAAs, is a fundamental aspect for the incentive and development of LNG bunkering. On a different formulation it is furthermore important to adapt management principles, policies and strategies to support the development of LNG bunkering projects.

The following aspects are covered in the present Section:

1. Different LNG bunkering scenarios (in the context of existing Port activities).
2. Good Governance and the role of port authorities in the development of LNG as a ship fuel, with a reference to the different implications of LNG bunkering for Ports managerial practice.
3. Directive 2014/94 on the deployment of an alternative fuel infrastructure implementation.
4. Suggested Best Practice for PAAs in the context of LNG bunkering development as a differentiated Port Service.

The present section does not prescribe any elements for port management, nor is it intended to qualify governance models and ownership structures. Diversity is an important feature of the European port system, with no two ports operating in exactly the same way. The present Guidance, in line with European Port Policy
COM(2013) 295 – Ports: An Engine for Growth.x respects that diversity and does not seek even to suggest a uniform model for ports.

LNG bunkering for Ports

The diagram in Figure 1, below presents the interaction areas between PAAs, LNG bunkering supply organizations and costumer LNG fuelled ships.

Ports are today characterized by fast-developing multi-operator environments, evolving increasingly to corporatized and highly specialized service portfolio, where LNG bunkering is now becoming a relevant addition.

Figure 1 identifies the general areas of interaction between the 3 (three) main stakeholders in the LNG bunkering service development and implementation. The areas of interaction are not mutually exclusive but, instead, they complement each other in the implementation of LNG bunkering projects and sustainable services. The following three-partite generic arrangement can be identified (some variations may occur in the context of different port management and organization models):

• LNG bunkering supply organization (other organizations can be involved or directly related, such as the gas supplier, liquefaction or storage services, transport and distribution. Cooling, inerting, or even gas recycling can be also provided by other parties).
• Port Authority & Administration (Port Authority and Port Administration can be the same or different entities – see section “Ports Good Governance for LNG Bunkering” below).
• Costumer LNG Fuelled Ship (representing ultimately the demand side for LNG bunkering)

The 3 parties have, different interests and their inter-relations are characterized by different levels of communications and potential partnerships. Safety is expressed as an objective by all parties, but how much commitment to safety must be defined in clear regulations. Also on the subject of Safety it is furthermore important to establish measures of acceptability but also of credibility and independency. If Risk Criteria is used to define an “acceptable level” of risk, other criteria could be used to ascertain credibility and independency of risk evaluation results. This example for Safety is relevant also for other aspects of the LNG bunkering, such as compatibility assessment and other. To help identifying the relevance of “independency“, figure 2 below, based in the diagram of 1, highlights the important separation vectors that must be observes to directly ascertain the adequate level of independency in LNG bunkering.

On the basis of the above, a fundamental principle that should govern the inter-relationship vectors in LNG bunkering is the one of “Transparency“. The distances “A“, “B” and “C” should always be observed, in the best interest of “Transparency“. In this sense, and following the same approach, whenever one of the distances could not be observed a potential conflict of interests could be claimed.

Figure 3, below presents a particular case where the LNG Bunkering Supply is totally or part-owned by the PAA. The absence of distance “A” leads to the potential conflict of interest situation when the Port Regulator function may be affected resulting in a less than ideal scenario that can affect transparency in the LNG bunkering process.

The situation below represents a case where BFO and RSO are the same company.

Situations like those presented in 3 and 4 are very specific in nature and, of course they do not immediately translate a situation where a conflict of interests could inherently result in a compromise, for instance, in safety. They represent however an illustration of the importance to keep the triangular formulation in LNG bunkering as an indicator (or measure) of transparency on the process.

Growing towards complex hubs in a multi-operator context, with management and organizational systems which differ significantly from port to port, PAAs should give a particular relevance to the need to ensure transparency in processes, with the involvement of the wider stakeholders’ community inside and in interaction with the port.

Examples of processes where transparency is a fundamental pillar in LNG bunkering:

• Vessel compatibility Assessment.
• Risk Assessment (whenever performed to ascertain ALARP Risk levels).
• Permitting.
• Simultaneous Operations.
• Safety Distances.

When deciding or intervening on any of the above aspects BFO, RSO and PAA will interact within a specific regulatory frame (see article “LNG Regulatory FrameworkLNG Regulatory Framework International and European Maritime Safety Overview“) which can only be enforced to an adequate level if the processes are conducted with the necessary independency.

Compliance with EN ISO 20519, as introduced in article “Regulatory Frame Best Practice – Applicability in the Bunkering Interface“, declared and inscribed as an objective within an appropriate Safety/Quality Management System should be the basis for the minimum requirement advisable as best practice. Enforcement is made easier through the provision of adequate “external audits” by a competent authority, whilst allowing planning and continuous development of processes by the Operators.

LNG small scale and bunkering scenarios

The above is even more relevant if we take into account the wide variety of Port activities that can involve LNG bunkering or, on a more widely scoped approach, small scale LNG applications and developments within the wider port area. Figure 5, below, and table 1 feature some of the possible LNG bunkering activities that may take part in a port, highlighting the need for good governance.

Ports Good Governance for LNG Bunkering

Good governance in LNG Bunkering development in Ports, like in other activities, has 9 major characteristics. It is participatory, consensus oriented, accountable, clear, transparent, responsive, effective and efficient, equitable and inclusive, and follows the rule of law. Good governance is responsive to the present and future needs of the organization, exercises prudence in policy-setting and decision-making, and that the best interests of all stakeholders are taken into account.

In the specific context of LNG as fuel PAAs will have the overall responsibility for the good governance and the safety framework for LNG bunker operations in the port. Decisions and requirements for LNG bunkering should be based on a risk analysis carried out in advance, and in the early-involvement of all parties. In this way the port can conduct public affairs and manage public resources. Again, as introduced in the previous section, transparency plays a major role as one of the Good Governance Principles listed.

Table 2, lists the relevant principles of Good Governance in LNG bunkering that should serve a safe, sustainable and harmonized development of this activity as an important multi-operator and relevant activity in the port area and service portfolio.

Good governance is an ideal which is difficult to achieve in its totality. Governance typically involves well-intentioned people who bring their ideas, experiences, preferences and other human strengths and shortcomings to the policy-making table. Good governance is achieved through an on-going exercise that attempts to capture all of the considerations involved in assuring that stakeholder interests are addressed and reflected in policy initiatives. It should be all-inclusive and drawn in respect to an existing regulatory frame which is well understood by all parties.

In the same way that different Ports will have different management models, also Good Governance is different for every port so the list of items above is just guidance. It depends on your customers’ needs and LNG availability. Some ports only will be in need of the distribution of LNG to Small River crafts, other ports only will have LNG fueled seagoing vessels to be bunkered at anchorage. Most ports will have a mix of customers, all with their own LNG bunker needs.

Port Authorities and Port Administrations

Definitions

Ports usually have a governing body referred to as the port authority, port management, or port administration. Port authority is used widely to indicate any of these three terms.

It is, in the particular context of this Guidance, important to underline the definition used for Port Authority & Administration (PAA). The concept contains, in practice, a “two-in-one” definition: The “Port Authority” and the “Port Administration”. Even though merged together in the present Guidance, the two concepts have distinct definitions, with one responsible for the enforcement of the applicable legal provisions, and the other for the management of the port. Today’s management models followed by some ports have however merged these two, in fact, allowing for the corporatization of port authorities, serving the interest of an increasingly dynamic port activities’ environment.

In Regulation (EU) 2017/352 Port Authority and Port Administration are defined, respectively, through the concepts of “competent authority” and “managing body of the port”. Definitions given as per table below.

Adequate implementation of LNG bunkering will depend on the good coordination of both Port Authority and Administration core activities, especially bearing in mind that other authorities play an important part also in facilitation, permitting, emergency response, amongst other aspects. From the adequate and well-structured regulatory frame, taking into account international, regional and local/port aspects, to the execution of different approval and control activities it is the responsibility of PAAs to coordinate the necessary efforts to allow the best development of LNG bunkering activity within the port area.

Good practice Guidance in this document is applicable to the different parts of the LNG bunkering activity, throughout the different stages of its life cycle.

Port Roles and Responsibilities in LNG Bunkering

Table 4, below, outlines the main Port Roles and responsibilities, in the context of LNG bunkering, integrating both “competent authority” and “administration” aspects and highlighting the challenges that should be met by PAAs.

As indicated in table 4, above, PAAs, either in the Port Authority or in Port Administration context, take stake of a considerable amount of roles and responsibilities. The listed elements in the table include the main aspects that need to be to be considered by PAAs. Different aspects can be taken either by the Port Authority or Administration, depending on the specific port management model and on specific national contexts. Table 4 provides only for an indicative structure of different port roles and responsibilities in LNG bunkering.

It should not be the role of the Port Authority to interfere with the normal operations during LNG bunkering. Once the adequate Authorization procedure (see section Strategies for Effective LNG Bunkering Operations and Their Execution“LNG Bunkering Process”) is concluded, for a given LNG bunkering operation, PAAs should implement a suitable inspection and verification model (see section Navigating the Complexities of an LNG Bunkering Permit“Inspections”) to ensure that the conditions established during the permitting procedure are kept in-service, throughout the life-cycle of the LNG bunkering facility.

Spatial Planning

From table 4, in the previous section, one of the most relevant responsibilities of PAAs is the proposal and approval of spatial planning within the port area, accounting for the development of a new LNG bunkering facility or operation.

To approve a bunker location for an LNG bunkering among other things PAAs can consider different elements that collectively may contribute to the definition of the most suitable location for the LNG bunkering operation:

• the different types of ships to bunker with LNG;
• the expedience of the terminal with LNG bunker operations;
• the planned simultaneous operations during the LNG bunkering;
• the water depth;
• availability of proper anchoring, mooring and fendering appliances;
• double banking possibilities (dolphins, buoys or bollard loads);
• nautical accessibility;
• nautical safety, including maneuvering basin area’s;
• frequency and type of passing vessels (collision risk);
• the space for the passing of vessels taking into account safety zone and ship exclusion zone.
• Water movements due to tidal amplitudes, swell, passing ships etc.
• the quay maximum admissible load in case of a truck to ship bunkering;
• enough safety distance to populated areas (in line with national legislation).
• Impact on other activities, both waterborne or on the shore side.
• Security, accessibility by public.

In order to minimize the risk of a collision during bunkering, the bunker location should ideally not be located in waterways with high vessel traffic intensity levels or complicated nautical situations, including basins dedicated to maneuvering; In addition to the elements above it is also important to note that Spatial Planning is done to incorporate the possibility of LNG bunkering in the existing spatial layout of a given port. Different concurring factors may contribute for this, some safety related and others of a more operational and economical nature.

This would be the case of Safety Distances and proximity of LNG, respectively. Notwithstanding this fact, planning for a new LNG bunkering location will be an exercise that will be done concurrently with already existing factors, within sometime restricted boundaries and in a context which may present several challenges.

Figure 6, below, presents a graphical image of the spatial planning in the Port of Rotterdam, an extreme example of a very large port, dealing with a large variety of ship types and cargoes.

Assuming that LNG bunkering can be a potential operation for any ship type it can be easily concluded that it will be very likely to have LNG bunkering areas superimposed with other areas with necessary judgement to be taken into account, not only in the context of potential SIMOPS but, most certainly, in those cases where hazardous substances other than LNG are present.

The Role of Ports in the development of LNG bunkering facilities

Whilst the previous section outlined the more operational roles for PAAs, in the context of LNG bunkering, the present Section aims to provide the same entities with options to promote and support the use of LNG as a marine fuel and develop bunkering facilities in full length. The elements contained in this particular section are based on a study published by the World Maritime University in 2015, where 8 (eight) relevant Ports, recognized as first-movers for LNG bunkering, were analysed with regards to the aspects related to direct or indirect support to this activity. The study, based on questionnaires and evaluation of the different Ports (all inside ECA) allows a summary of the different initiatives to support the development of LNG bunkering.

Regardless the management structure of a port and the corporatization level of both port authority and administration bodies, the development of LNG bunkering can be characterized across the four main functions of a Port:

1. Landlord function;
2. Regulator function;
3. Operator Function and, finally,
4. Community Manager Function.

These are outlined below to provide PAAs a generic Menu-Portfolio of the policy-vectors and strategies that are available to support development of LNG bunkering potential.

Landlord function

The typical landlord function of port authority in the development of LNG bunkering facilities refers to the provision of land for an LNG bunkering terminal, the construction of quay walls, jetties, or other possible basic infrastructure for maritime access, and the associated development policies. Most port authorities go beyond the traditional landlord function by adopting “proactive” and “cooperative” policies to speed up the development progress of this new application. These policies relate to:

1. a proactive coordinating role in conducting feasibility studies on LNG bunkering in cooperation with various stakeholders (i. e., local government, competent authorities, private actors, etc.),
2. the development of a comprehensive location selection policy,
3. the forging of strategic partnerships with private industrial players and even with other ports for developing LNG bunkering and, finally,
4. the adoption of an adequate infrastructure investment policy.

The above policy-vectors are structured in the diagram of figure 6, showing the main trends on how PAAs enact the landlord function in order to play a proactive coordinating role in performing feasibility studies on LNG bunkering (e. g., technical, regulatory, and market dimensions) together with various stakeholders in order to obtain confidence among market players to kick-start the business. The selection of a location for LNG infrastructure currently is a key problem faced by the ports. The LNG bunkering facilities would be better built close to the customers (e. g., shipping lines), while considering the safety issue of handling LNG as a dangerous cargo, some ports prohibit LNG operations in populated port area. Other ports are however developing dialogue platforms with the general public on the construction of LNG facilities near residential areas.

Regulator function

The traditional regulator function of port authorities is to apply and enforce rules and regulations set by regulatory bodies. The current scenario for LNG bunkering in ports is however characterized by the lack of a set of unified harmonized rules and standards for a number of different aspects in this activity (Safety Distances, SIMOPS, Permitting, Risk Acceptance criteria, amongst others). In this particular context, the development of relevant rules and standards for such new application is a key for the wide diffusion of the LNG technology. Below is presented a summary of the regulatory role of that may be followed by ports in the development of LNG bunkering. Port authorities mainly adopt a stronger regulatory role in the following ways:

1 By actively assisting regulatory authorities to enforce air emission standards, underlining the relevance of an adequate control that mitigates the risk of non-compliances, also promoting in that way the option for EAMs such as LNG as fuel.

2 By proactively coordinating and facilitating the development of regulations on the maritime use of LNG and by setting corresponding port bylaws. Relevant regulations and rules on LNG bunkering have already been developed by a significant number of ports, remarkably by those located in ECA areas. The challenges, whilst developing such instruments, are diverse and PAAs should be prepared to develop the relevant port regulations in a collaborative manner with other ports and competent authorities.

3 By developing LNG bunkering checklists and establishing appropriate Risk Criteria. Initiatives like the World Ports Climate Initiative (WPCI) – have allowed the participation of Ports in a dedicated working group to jointly develop an LNG bunkering checklists Check-lists included in Annex-A, adapted to include relevant aspects to Port Authorities and Administrations. The baseline check-lists used are IAPH and ISO.x for different significant bunkering solutions (e. g., ship to ship, truck to ship, etc.). The definition of adequate risk criteria is further relevant in the context of LNG bunkering allowing risk evaluation studies to be properly assessed, promoting transparency and defining clearly the acceptance frame.

4 By setting a differential port tariff on ships fuelled by LNG or other clean fuels.

Operator function

Looking at the three traditional functions of port authorities, i. e., the landlord, regulator, and operator functions, it can be concluded that, as operators, port authorities gradually moved away from providing services of cargo handling, stevedoring and bunkering, etc. These have in most cases been privatized. A common best-rated strategic option for port authorities is today to enact an active control and supervision of concessions to stimulate intra-port competition and market contestability as well as sustainable and efficient operations of private operators. Thus, LNG bunkering services are supposed to be mainly operated by private actors, although at the beginning of market development, the port authorities might adopt incentive policies promoting investments in the maritime application of LNG.

The Operator function by PAAs, in the context of LNG Bunkering, similarly to the example of other relevant port services, is not expected to be privileged. Exception to this may however be considered in the cases where the business case for LNG bunkering is not yet fully developed or secured, leading in the extreme situation where PAAs may take the lead in the development of an LNG bunkering service infrastructure.

Community manager function

The function of community manager assumes a coordinating role of the port authority to solve collective problems in and outside the port perimeters, for instance, marketing and promoting innovations, etc. It is a common function of port authorities today acting as community managers in promoting LNG as a ship fuel.

1. Marketing and promotion on the maritime use of LNG. PAAs may use different ways to promote and market the maritime use of LNG by organizing conferences, seminars, and workshops or by sending handbooks or arranging meetings with the interested parties.
2. Learning and sharing knowledge and skills with port stakeholders and even other ports. Possibility to enhance interactive learning and knowledge sharing with port stakeholders by establishing various workshops or stakeholder platforms or developing strategic alliances with other ports in/or across the regions.
3. Establishing a close dialogue with government and raising public awareness.

Ports Good Practice approach for LNG bunkering

Sections “LNG bunkering for Ports” to “Spatial Planning” addressed several and different aspects related to Ports in the context of LNG Bunkering. In “LNG bunkering for Ports” the main principles that should assist PAAs in the development of control mechanisms for LNG bunkering are derived and discussed, with a triangle established with the following vertices:

• LNG Bunkering Facility Organization (BSO).
• Port Authority & Administration (Port Authority and Port Administration can be the same or different entities – see Section “Ports Good Governance for LNG Bunkering”).
• Receiving LNG Fuelled Ship (Receiving Ship Organization – RSO).

In addition, contained in the same section and making use of a generic port layout, different LNG bunkering scenarios are presented. For each scenario different considerations are outlined, highlighting some of the main particulars for each situation. Table 1 provides this list of possible LNG bunkering scenarios, including some particular small scale LNG cases possible within ports. No such thing as “Good Practice” can be indicated for the presented scenarios. They are typically developed in the operational context and, notwithstanding the list in Table 1 being considered extensive, it will still be possible to have new concepts for LNG Bunkering, or even small-scale LNG bunkering solutions being developed. For this reason it is important to note that good practice should not be derived from the list of possible LNG Bunkering Scenarios. Instead, a sound Good Practice approach for Ports to deal with LNG bunkering operations should be supported by adequate Good Governance principles (Section “Ports Good Governance for LNG Bunkering”), clear definition of the responsibilities falling on PAAs (on both Port Authorities and Administrations) (Section “Port Authorities and Port Administrations”) and, finally, by adequately defining the position of PAAs regarding the development of LNG bunkering (Section “The Role of Ports in the development of LNG bunkering facilities”). Spatial Planning, one of PAAs responsibilities also included in Section “Port Authorities and Port Administrations” is also mentioned separately accounting for the details and complex port-specific considerations that can be derived in this particular point.

LNG bunkering for Ports – Good Practice for Transparency

Transparency is, in the context of LNG Bunkering as in others related to relevant port services, a primary principle that should be privileged by PAAs.

Accounting for the three main vertices of a triangle, mentioned above and in “LNG bunkering for Ports” (BFO, RSO and PAA) it is, in the best interest of transparency, important to ensure that adequate separation and absence of conflict of interests is ensured between all parties.

Different interests can be derived for all parties and their inter-relations may be characterized by different levels of communications and potential partnerships. Safety can be expressed as an objective by all parties, but how much commitment to safety must be defined in clear regulations.

Growing towards complex hubs in a multi-operator context, with management and organizational systems which differ significantly from port to port, PAAs should give a particular relevance to the need to ensure transparency in processes, with the involvement of the wider stakeholders’ community inside and in interaction with the port.

Examples of processes where transparency is a fundamental pillar in LNG bunkering:

• Vessel compatibility Assessment/
• Risk Assessment (whenever performed to ascertain ALARP Risk levels).
• Permitting/
• Simultaneous Operations.
• Safety Distances.

In Section “LNG bunkering for Ports” a specific approach is presented to determine adequate independency of all parties involved in LNG Bunkering. Independency between all the parties identified has there been identified as a marker for transparency. It is however important to note that other stakeholders may also be involved in ancillary tasks (such as inerting, cooling, amongst others) from service providers other than the BFO.

PAAs should have a clear overview of all the parties involved in the LNG bunkering operations, looking for the identification any less transparent situations and questioning, in particular, how, and by whom, are provided the elements for safety of operations (risk assessment, supervision, compatibility assessment, definition of safety distances, etc, as listed above).

PAAs may, as and when appropriate, require the involvement of a third-party independent experienced professional to ensure transparency. This may be particularly useful in the cases where a Risk Assessment is being proposed by any of the parties who have any type of perceived economic interest or financial return from the LNG bunkering operation (as it is typically the case with the BFO or RSO).

Notwithstanding it can be reasonably assumed that Safety is of primary importance for all parties involved in LNG bunkering, it is important to define transparency and independency as pillars of all risk & safety related elements. This is to be considered at the level of first principles governing LNG bunkering for PAAs.

When deciding or intervening on any of the above aspects BFO, RSO and PAA will interact within a specific regulatory frame (see article “LNG Regulatory Framework International EU ComplianceLNG Regulatory Framework International and European Maritime Safety Overview“) which can only be enforced to an adequate level if the processes are conducted with the necessary independency.

Compliance with EN ISO 20519, as introduced in Section “Regulatory Framework”, declared and inscribed as an objective within an appropriate Safety/Quality Management System should be the basis for the minimum requirement advisable as best practice. Enforcement is made easier through the provision of adequate “external audits” by a competent authority, whilst allowing planning and continuous development of processes by the Operators.

Good Practice in the evaluation of LNG small scale and bunkering scenarios

Table 1 list (from “A” to “X4“) different possibilities in the context of LNG bunkering or LNG small scale realizations that can potentially take place within the port area. Not all situations represent LNG bunkering strictu senso, including a few which are related to small scale LNG elements. These are included in Table 5.1 as relevant elements that are either likely to be part of the LNG bunkering chain, distribution or local storage.

PAAs are encouraged, in a good practice approach, to include the whole context of LNG small scale elements within the port area. This, in practice, means that, apart from LNG Terminals, all elements of storage and distribution, directly or indirectly related to bunkering of LNG fuelled ships, should be considered. In addition, also small break bulk LNG cargo facilities, should be taken into account in the context of the overall LNG bunkering scenarios. This is particularly relevant if and when considered to define LNG bunkering locations, or in the context of spatial planning.

From a good practice perspective PAAs should consider to work closely with all the possible stakeholders involved in prospective LNG bunkering in order to determine at the earliest stage all the possible technical and operational implications from a given specific LNG bunkering solution. How these would affect port activities or spatial planning are some of the aspects that should be considered at the earliest stage.

Table 1 list notes and particular recommendations for different LNG bunkering and small-scale scenarios within the port area. They are not extensive, looking in particular to distinguish some of the relevant elements that may guide PAAs in the assessment of different situations. It is in particular important to distinguish the elementary differences between bunkering, fuelling, use, storage and distribution of LNG within the port area.

Table 5, in the next page, presents these different main groups to be considered, with a main focus on LNG bunkering.

LNG Fuelling represents today an increasingly offered port service. Despite not being exactly an LNG bunkering operation PAAs should regard this service in the same regulatory framework as LNG bunkering. To this end all provisions in the relevant ISO Standards and existing Guidance should be referred to, as applicable.

The main differences, as mentioned above, in Table 5, will be essentially on the much lower LNG flow rates passed onto the RSO (mainly dictated by the DF/gas engine consumption.

For a ship with no onboard LNG storage, but with engine(s) that are prepared to run on natural gas/dual fuel, it is possible, at berth, to feed in this fuel from an external LNG storage unit.

Even though it may look like normal LNG bunkering, involving the transfer of LNG to a receiving ship, there are a few distinctive features that should be taken into account:

1. Transfer of very low LNG fuel volumetric rates, mainly dictated by the onboard engine fuel consumption rate. Unless a buffer tank exists onboard the rate of transfer will correspond to the engine consumption. When compared to the volumes transferred in bunkering this should be much less.
2. Delivery unit (LNG truck, barge or ISO container) stay close to the ship for longer periods. In fact the presence of the LNG supply/storage will last for the whole visit of the ship, with the energy at berth coming from the LNG fuelled onboard generator. Regasification can occur either at the delivery or inside the ship, through a dedicated evaporator. Different configurations are possible depending on how technically prepared the ship is to undertake such type of operation.

PAAs should take into consideration particular elements for this type of operation, such as:

1. Regulatory frame. Even though not a typical LNG bunkering operation it is important to frame LNG fuelling into the existing instruments for LNG bunkering (EN ISO 20519, ISO/TS18683, IACS Rec.142).
2. Risk Assessment to be conducted, as indicated in the diagram in figure 4.21, where agreed possible hazardous scenarios must be reflected.
3. Safeguards to implement, derived from RA above, or others, such as:

   1) physical barriers;

   2) Detection and Alarm;

   3) access restriction;

   4) Emergency response measures;

   5) Dispersion mitigation measures, amongst others.

4. Manned attendance of the LNG delivery point. Taking into account that this is a type of operation that may extend for several hours, it is important to have consideration for the possible need to ensure manned attendance of the LNG delivery point/storage. This should be an important point focused at the RA.
5. Credible release scenarios. In the context of the RA it is important to determine what would be a credible release scenario from such an LNG fuelling operation.

Ports Good Governance for LNG Bunkering

In the specific context of LNG as fuel PAAs will have the overall responsibility for the good governance and the safety framework for LNG bunker operations in the port.

Decisions and requirements for LNG bunkering should be based on a risk analysis carried out in advance, and in the early-involvement of all parties. In this way the PAAs can conduct public affairs and manage public resources.

Table 5, below, summarizes the Good Governance principles, with a focus on the principles that should guide PAAs in the context of LNG bunkering.

Port Roles and Responsibilities in LNG Bunkering

Definitions of Port Authority and Port Administration, in the present Guidance coalesced in the term “PAA” should be referred to Regulation (EU) 2017/352. Port Authority and Port Administration are defined, respectively, through the concepts of “competent authority” and “managing body of the port”. Definitions given in section “Definitions”.

Where PAAs are, in practice, two separate bodies it is important that Port Authority and Administration sides clarify their individual roles and responsibilities in the specific frame of LNG Bunkering. The definition of responsibilities amongst the competent authority and the management body of the port will be decisive in the adequate coverage of the LNG bunkering frame. Coordination between all parties contributing to risk & safety evaluation, permitting and authorizations will be essential for the development of LNG bunkering services within a specific port.

Table 6 lists the relevant responsibilities for Port Authorities and Administrations in the context of LNG Bunkering, outlined from section “Port Roles and Responsibilities in LNG Bunkering”, including a brief description of the main elements to consider in each role.

Should there be more than one entity sharing the different roles/responsibilities it is important to distinguish clearly who is responsible for what, giving privilege to the principle “one role, one responsible entity”, allowing for a complementary arrangement of responsibilities and for clarity in the decision-making structure.

The Role of Ports in the in Developing of LNG Bunkering Facilities

From current references it is possible to determine/summarize a set of good practices in promoting the maritime use of LNG, making it possible to further develop a set of port implementation policies. Cooperative Development, Financial Incentive or Coordinating communication are the selected policies available to Ports for the support to development of LNG bunkering facilities.

1 Cooperative development policy:

Port authorities should establish various forms of cooperation with stakeholders in or outside of the port perimeter (such as industrial players, governmental authorities, research centres, and other ports in the region and even cross-region). The cooperation can focus on the development of LNG port infrastructure (e. g., location selection), the assessment of the safety risks of the use of LNG in the port environment, and the development of a set of bunkering standards or guidelines. In addition, close partnerships with industrial actors in conducting commercial feasibility studies (e. g., market demand, logistics, price, etc.) is also a key to success. It is believed that cooperation can enhance interactive learning and knowledge sharing which can reduce the market uncertainty and improve the confidence among market players.

2 Financial incentive policy:

The infrastructure investment is the crucial issue in the process of developing LNG as a ship fuel. Port authorities should use various types of financial instruments to promote the market development of LNG facilities, for instance:

• (a) by building joint ventures or PPPs with private actors to invest in bunkering facilities;
• (b) by providing funding or applying for subsidies from the EU or local government to support investment;
• (c) by developing a differential port tariff favouring ships powered by clean fuels, like LNG (e. g., ESI and Green Award), or by providing funding for ship conversion (e. g., in port of Stockholm);
• and (d) if applicable, by establishing pilot projects, for example, owning LNG-powered port vessels, to kick-start LNG market development and solve the chicken-and-egg problem.

3 Coordinating communication policy:

Port authorities should take a proactive coordinating role in view of maintaining a good communication within the port community regarding the development of LNG facilities, for instance:

• (a) by launching a promotion campaign or by organizing conferences, seminars, or workshops;
• (b) by building a “stakeholder platform” to share knowledge and skills among various stakeholders;
• and (c) by lobbying the government and raising public awareness to facilitate the permit process.

Author

Olga Nesvetailova

Freelancer

Literature

1. Study on the completion of an n to the case represented in framework on LNG-fuelled ships and its relevant fuel provision infrastructure, LOT 1 Position paper: Towards harmonized EU LNG bunkering guidelines, DNV-GL, 2016.
2. Study on the completion of an EU framework on LNG-fuelled ships and its relevant fuel provision infrastructure, LOT 1 Final Report, DNV-GL, 2016.
3. LNG Bunkering Guidelines IACS Recommendation n. 142, on LNG Bunkering, IACS, 2016.
4. ISO/TS 18683:2015. (15-Jan. 2015). Guidelines for systems and installations for supply of LNG as fuel to ships. Technical Specification.
5. Society for Gas as a Marine Fuel (SGMF). (2015). Gas as a marine fuel, safety guidelines, Bunkering. Version 1.0, February 2015.
6. ISO 20519:2017. Ships and marine technology – Specification for bunkering of gas fuelled ships. (International Standard).
7. IEC 60079-10-1. (2015). Explosive atmospheres – Part 10-1: Classification of areas – Explosive gas atmospheres.
8. Directive 1999/92/EC – ATEX of the European Parliament and of the Council of 16 December 1999 on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres (15th individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC).
9. API RP-500. 1997. Recommended practice for classification of locations for electrical installations at petroleum facilities classified as CIass 1, Division 1 and Division 2. Washington. D.C: API.
10. API RP-505. 1997, Recommended practice for classification of locations at petroleum facilities classified as Class I, Zone 0, Zone 1 and Zone 2. Washington, D.C. API.
11. NFPA 497. 2012, Recommended practice for the classification of flammable liquids, gases or vapours and of hazardous (classified) locations for electrical installations in chemical process areas. Quincy, MA: NFPA.
12. IEC EN 60079-10-1 Ed.1.0, 2008. Electrical apparatus for explosive gas atmospheres – Part 10-1: Classification of areas – Explosive gas atmospheres. International Electrotechnical Commission.
13. Commission Decision 2010/769/EU of 13 December 2010 on the establishment of criteria for the use by liquefied natural gas carriers of technological methods as an alternative to using low sulphur marine fuels meeting the requirements of Article 4b of Council Directive 1999/32/EC relating to a reduction in the sulphur content of certain liquid fuels as amended by Directive 2005/33/EC of the European Parliament and of the Council on the sulphur content of marine fuels (OJ L 328, 14.12.2010, p. 15).
14. USCG CG-OES Policy Letter 02-14 – Guidance Related To Vessels And Waterfront Facilities Conducting Liquefied Natural Gas (LNG) Marine Fuel Transfer (Bunkering) Operations.
15. ADN – European Agreement concerning the International Carriage of Dangerous Goods by Inland waterways (Update version ADN January 2017).
16. ADR – European agreement concerning the International Carriage of Dangerous Goods by Road (Update version ADR January 2017).
17. Rhine Vessel Inspection Regulations (RVIR).
18. EU general risk assessment methodology (Action 5 of Multi-Annual Action Plan for the surveillance of products in the EU (COM(2013)76) – Document 2015-IMP-MSG-15 – 16 October 2015.
19. Safety Study, Chain analysis: Supplying Flemish ports with LNG as a marine fuel, Analysis of safety aspects, June 2012.
20. EN 1160 – Installations And Equipment For Liquefied Natural Gas – General Characteristics Of Liquefied Natural Gas, NBN, 1st edition, August 1996.
21. ESD Arrangements & Linked Ship/Shore Systems for Liquefied Gas Carriers, SIGTTO First Edition 2009 – SIGTTO.
22. M. Kofod & S. Hartman, T. Mundt – Review of Recent Well-to-Wake Greenhouse Gas Studies evaluating the use of LNG as a marine Fuel, IMO MEPC/INF.15.
23. LNG Access Code for Truck Loading for The Zeebrugge LNG Terminal – Based on version approved by the CREG on September 19th 2013 – Applicable as of January 1st 2014 – FLUXYS.
24. Guidance for the Prevention of Rollover in LNG Ships – SIGTTO – First Edition 2012.
25. Wang, Siyuan & Notteboom, Theo – The role of port authorities in the development of LNG bunkering facilities in North European ports, 14 January 2015, World Maritime University 2015.
26. Verhoeven P (2010) A review of port authority functions: towards a renaissance? Marit Policy Manag 37:247-270.
27. Society for Gas as a Marine Fuel (SGMF). (2017). Gas as a marine fuel, safety guidelines, Bunkering. Version 2.0, February 2015.
28. COM(2003) 515 final – Communication from The Commission concerning the non-binding guide of good practice for implementing Directive 1999/92/EC of the European Parliament and of the Council on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres, Brussels, 25.8.2003.
29. Davies, P. (2016) – Bunkering LNG: Setting the Safety Zone, 7th Motorship Gas Fuelled Ships Conference, November 2016.
30. International Association of Oil & Gas Producers. (1-Mar 2010). Risk Assessment Data Directory – Process Release Frequencies. Report No. 434 – 1, 1 March 2010). Pertinent data from this report is summarised in: Davies & Fort, (Sept 2012), LNG as Marine Fuel – Likelihood of LNG Releases, Journal of Marine Engineering and Technology.
31. PGS2 – TNO Yellow Book – Methods for the calculation of physical effects, due to releases of hazardous materials (liquids and gases) – CPR 14E (3rd Edition, 2005) – TNO – The Netherlands Organization of Applied Scientific Research.
32. OECD Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Guidance for Industry (including Management and Labour), Public Authorities, Communities, and other Stakeholders – 2nd Edition (2003) – OECD Environment, Health and Safety Publications.
33. DNVGL-RP-G105 Edition October 2015 – Development and operation of liquefied natural gas bunkering facilities, Recommended Practice, DNV GL, 2015.
34. USCG CG-OES Policy Letter No. 01-17 – Guidance for Evaluating Simultaneous Operations (SIMOPS) during Liquefied Natural Gas (LNG) Fuel Transfer Operations.
35. LGC NCOE Field Notice 01-2017 – 14-Aug-17 – Recommended Process For Analysing Risk Of Simultaneous Operations (SIMOPS) During Liquefied Natural Gas (LNG) Bunkering.
36. An Overview of Leading Software Tools for QRA, American Society of Safety Engineers – Middle East Chapter (161), 7th Professional Development Conference & Exhibition, March 18-22, 2005.
37. Walter Chukwunonso Ikealumba and Hongwei Wu (2016) Some Recent Advances in Liquefied Natural Gas (LNG) Production, Spill, Dispersion, and Safety School of Chemical and Petroleum Engineering, Curtin University.