BUNKERING

LNG Bunkering is a particular type of operation where LNG fuel is transferred from a given distribution
source to a LNG fuelled ship. It involves the participation of different stakeholders, from the ship-side,
LNG supplier, ports, safety personnel, administrations and policy makers.

The main challenge with LNG Bunkering is the interfaces created during LNG delivery moment.
These challenges can be either of a regulatory or technical nature, but not only. In fact, on top of
particular standards and technological needs for LNG as a marine fuel to be bunkered safely, it is
important to acknowledge the relevance of harmonization. The creation of interface environments in
LNG bunkering raises the concern about how different regulatory frames (land side vs ship side,
road vs port, road vs ship-side, etc.). Ideally regulations and requirements should tend towards
harmonization and non-conflicting regimes, but this is not always the case. On top of this the interface
can also unveil potential training discrepancies, equipment mismatches and other factors that can,
ultimately, influence safety.

LNG SUPPLY CHAIN

Before understanding the challenges behind LNG Bunkering it is important to have a general
overview of the LNG supply chain. A very simplified diagram is presented below.

LNG BUNKERING METHODS

Delivering LNG fuel to a ship can be done in different ways, following different methods, depending on
different logistic and operational factors. Various LNG bunkering methods are available, with Truck-to-
Ship (TTS) being the most commonly used. Todays choice for TTS method has been a result of
different aspects and difficulties that concur in the development of the business case for bunkering
LNG as a marine fuel. On one hand the operational flexibility and limited infrastructure requirements
for TTS and, on the other hand, relatively low initial investment to establish business readiness, have
driven the option for this LNG bunkering method. This table covers the relevant possible methods of
bunkering LNG fuelled vessels.
The categorization follows closely the Technical Standard ISO/TS 18683:2015 Guidelines for systems
and installations for supply of LNG as fuel to ships. The diagram below shows a simplified integration
of the relevant bunkering methods, integrated in the wider LNG supply chain, as presented in EMSAs
Study on Standards and Rules for bunkering of gas-fuelled Ships.

All LNG bunkering modes share several fundamental aspects of concern that need to be carefully
addressed in order to have safe and successful operations:

Risk Analysis and Safety Management, intrinsically different depending on the method
chosen for bunkering.
Permitting, which will be needed for the different operations, from the relevant competent
authorities
Training of all personnel involved, both onboard and ashore.

SHIP-TO-SHIP LNG TRANSFER

Apart from bunkering LNG as a marine fuel, other LNG operations take part where LNG delivery
occurs. From all possible operations a specific one is here underlined: Ship-to-ship transfer.

A ship-to-ship (STS) LNG transfer operation can be defined as the transfer of LNG cargo between
seagoing LNG cargo ships positioned alongside each other, either while stationary or underway. A
clear distinction should be made between this and the LNG ship-to-ship bunkering operation, where
LNG as a marine fuel is delivered to an LNG fuelled vessel by a refueling barge or ship.
STS transfer deals with LNG as cargo (not fuel) and the relevance of this transfer mode has been
particularly highlighted, in addition to lightering operations, with the function of FSRUs (Floating
Storage and Refrigeration Units) and other LNG cargo floating platforms.

Another potential relevant application of STS operations is the break-bulk distribution of ship-to-ship
LNG transfer has been an area of gradually increased interest with the following aspects considered
to be particularly relevant:

Understanding of ships motion interaction, both stationary and underway, with a

particular interest in transient condition arrival and departure.
Weather forecasting and sea state prediction (most relevant for pre-planning)
Communications throughout operations
Emergency procedures
Training of all personnel involved in both platforms.

LNG BUNKERING STANDARDS & REGULATIONS

The regulatory frame for LNG bunkering is, at first, characterized by significant environmental related
legislation. The relevance of this is that by imposing stricter air emission regulations the demand for
LNG as an alternative fuel will, as a consequence, grow (as part of a wider set of technical options for
compliance). At international level (IMO) MARPOL revised Annex VI (IMO Resolution MEPC.176 (58))
and Resolution MEPC.203 (62) regarding Energy Efficiency) set the frame for restricting air emissions
of both Greenhouse gases and other substances.

On the European side, the legislation with highest potential to incentivize LNG bunkering initiatives
are: firstly, the Directive on sulphur content in marine fuels (2012/33/EU) which allows the use of LNG
as an alternative fuel to comply with more stringent emission standards. Secondly, the Directive on
deployment of alternative fuels infrastructure (2014/94/EU) which aims at ensuring minimum coverage
of LNG refuelling points in main maritime and inland ports across Europe by 2025 and 2030
respectively, with common standards for their design and use.

The relevance of shipping environmental/air emission regulations for LNG bunkering is central and,
even if indirectly; they set the driver for the growth in the demand side. For a number of years the
chicken-and-egg problem has been alleged as an issue arising from the fact that ship operators and
LNG bunker suppliers were reluctant to take the investment risk initiative of going for LNG as marine
fuel. Today the picture is framed in a somewhat different context. The initiatives are taking place and
the LNG as a marine fuel market is growing beyond Baltic-niche paradigm.

Regulations, and their adequate implementation and enforcement, are fundamental to set a fair level
playingfield, whilst promoting a more sustainable shipping approach that has the potential to create
added value even with stricter environmental requirements. Together with legislative instruments, and
their associated acts, Standards and Guidelines assume also a very important role in the
development of LNG as a marine fuel. International Standards ensure that adequate technical
references exist for equipment and operations, allowing for the development of harmonized industry
initiatives and construction of LNG equipment meeting uniform requirements, functional and technical.
Industry guidance/guidelines is, in addition to standards, represent important references to operation,
contributing to the dissemination of good practices and safety culture, proposing procedural options
and setting a reference line of understanding that, ultimately, facilitates the safer and harmonized
development of LNG as marine fuel.

It is moreover important to realise that shipping is an international business. LNG as fuel for shipping
will need international harmonization. Policy makers, industry, shipowners, administrations, all play an
important role. The first steps with LNG as a marine fuel are already in the past. It is now time for
consolidation. Regulations, standards and guidelines, all need to be continuously adapted to new
needs, new risk perception or even to be adjusted following their implementation experience.

The table below presents the relevant standards and guidelines for LNG bunkering as a marine fuel,
mostly relevant to the shore-side and bunkering interface.
LNG BUNKERING DRIVERS TO DEVELOP SUPPLY OF LNG
BUNKERING

The following 9 (nine) aspects are important in assisting the decision to develop the LNG bunkering
offer at Ports. All factors contribute in a very specific way, depending on the port, on its location, the
operational profiles of the ships calling that port and many others.

Is it safe to invest in the development of LNG Bunkering? Replying to this question is a construction of
evaluating all this aspect.
LNG BUNKER WHERE IN EUROPE?

In a period where LNG bunkering developments and initiatives take place at an increasingly higher
rate, it can be difficult to have an updated picture on where this alternative fuel becomes available for
shipping. Now that initiatives to promote and develop LNG as a marine fuel start to take place also in
the Mediterranean it becomes noticeable that the proximity to an Emission Control Area (such as the
North Sea/Baltic) is no longer the only driver to push for investment.

Information and visualization of the current LNG infrastructure, services and facilities throughout
Europe becomes particularly important. Gas Infrastructure Europe (GIE) is a possible and reliable
source where this information can be sourced. GIE is a representative organisation towards the
European Institutions (European Commission, European Parliament, and Council of the European
Union) as well as the European bodies of regulators (ERGEG, CEER) and other stakeholders.

It is possible to download European Gas Infrastructure maps, including Small Scale LNG and LNG
bunkering facilities from their institutional website here.