August 4, 2025
USCG informs that, in the absence of specific prescriptive regulations for LNG and alternative marine fuel bunkering, a comprehensive bunkering proposal and risk assessment should be submitted prior to any such operation.
Bunkering proposal
As explained, due to the absence of specific prescriptive regulations for bunkering LNG and other alternative marine fuels, the Captains of the Port (COTPs) should use their authority to require that an initial bunkering proposal be submitted. The bunkering proposal should be initiated by the fuel supplier with sufficient time for the COTP to review for any areas of concern prior to the bunkering operation. The proposal should include information on:
- the fuel to be bunkered,
- anticipated date ranges,
- location,
- facility,
- vessel(s), and company(ies) that will be involved in the bunkering operation.
In return, the COTP should provide, at a minimum, a copy of this policy letter for guidance about facilitating the bunkering operation.
Risk assessment
COTPs should use their authority to require that a risk assessment be conducted for the proposed alternative fuel bunkering operation.
The COTP should require the fuel supplier to submit a risk assessment plan for review prior to the risk assessment being conducted. The plan may be submitted in conjunction with or combined with the bunkering proposal and should include a list of proposed participants, the standards and methodologies to be used for assessment of risk, technical details on the bunker supplier vessel or facility and receiving vessel, qualification and training of personnel directly involved with the transfer, assumptions to be used throughout the risk assessment, and any pre-identified hazards to be discussed. Additionally, the plan should at a minimum identify that hazards associated with the following subject areas will be addressed:
- Mooring/docking/anchoring
- Connection and testing to include compatibility assessment
- Fuel transfer operations to include pressure management and vapor return
- Completion and disconnection
- Unmooring/undocking/weighing anchor
- Critical infrastructure, waterway, people and environment
- Port emergency response capabilities
- Simultaneous operations
The COTP should review the submission and address any concerns prior to the risk assessment being conducted. When a subject area or hazard is suitably addressed in regulations, requirements, or in static portions of a previous risk assessment, these must be clearly identified and the submitter may request the scope of the risk assessment be reduced to only account for changes to dynamic items such as marine traffic, weather, bunkering location, etc. If a previous risk assessment report is cited, it must be made available to the COTP for review.
When selecting a standard or methodology, consider those that align with the principles outlined in ISO/IEC 31010. For questions regarding the suitability or acceptance of specific standards, the Office of Operating and Environmental Standards can provide further guidance.
The COTP or their designated representative should make efforts to participate in the risk assessment. Once the risk assessment is complete, the final report should be submitted to the COTP for review. The report should be reviewed to validate that all subject areas listed in this section have been adequately addressed to the satisfaction of the COTP.
Once the review is complete, the COTP should issue a statement of “no objection” to proceed with the bunkering operation per the submitted risk assessment and final report.
Compliance and enforcement
The primary authority for operational control over LNG and other alternative fuel bunkering operations is found in federal statute and implementing regulation. The COTP should not hesitate to issue a COTP order to halt bunkering operations if adequate time has not been given to the COTP to review the risk assessment prior to the operation or if bunkering operations are not being conducted in accordance with the submitted risk assessment and final report.
Advance notice of transfer
In accordance with regulation, COTPs may require advanced notice of transfer at least 4 hours before operations begin. The COTP should require this notice for the bunkering of vessels using LNG and other alternative marine fuels under their authority. This requirement may be included when issuing the statement of “no objection” or through other appropriate means such as a marine safety information bulletin.
Transfer monitor
Transfer monitors may still be conducted at the COTPs discretion in accordance with regulated bulk liquid transfer monitors guidance. For transfer monitors conducted for LNG or other alternative fuel bunkering operations, the team should review the submitted risk assessment and final report when planning the transfer monitor.
Alternative fuel bunkering facility policy
There may be LNG and other alternative fuel bunkering operations from land-based or mobile waterfront facilities where Coast Guard facility regulations for oversight and compliance do not exist. If a proposed bunkering assessment involves a facility of this type, COTPs and industry should use applicable policy guidance in addition to this policy.
Other risk assessment tools
During the COTPs determination of “no objection,” there exist other risk assessment tools and reports which could assist in providing context and additional insight to the overall threat of a particular operation to the marine transportation system.
