Guidance for bunkering operations

German Maritime Centre presents “Guide to Harmonized Regulation of Bunkering of Alternative Fuels in German Seaports”.
23 February 2021

Worldwide, it is necessary to reduce emissions of pollutants and greenhouse gases in order to be able to implement the emission standards for decarbonisation. In shipping, plans are underway to replace fossil liquid or gaseous fuels with alternative fuels (including methanol, ammonia, hydrogen) in the future. “They make it possible to substantially reduce the pollutant emissions caused by shipping, especially by using electricity-based production processes or by mixing in bio-fractions,” said Claus Brandt, managing director of the German Maritime Centre.

So far, the approval practices for bunkering alternative fuels have been very heterogeneous in Germany’s federal states. In almost every German seaport, individual permits have to be applied for – often from different approval authorities. The introduction of new alternative fuels means that this abundance of regulations and the need for information will continue to increase for the involved stakeholders.

In the summer of 2020, the German Maritime Centre commissioned Ramboll Deutschland GmbH to conduct a study on the “incorporation of legal regulations and development of a nationwide guideline for harmonised regulations on the bunkering of compressed and liquefied gases as well as low flashpoint fuels in German seaports”. “With the guideline, we want to create greater assessment certainty for all parties involved in the preparation and implementation of approval procedures for bunkering operations from the sea and land side”, says Bärbel Kunze, the project manager at the German Maritime Centre.

“In discussions with experts, such as infrastructure and terminal operators, LNG bunker suppliers and buyers, approval and port authorities, etc., we obtained extensive and valuable information on LNG bunkering and licensing processes, which was incorporated into the guidance that was produced”, explained Thomas Rust, who is leading the study at Ramboll.

The guide and the resulting recommendations for action were presented and discussed at an expert event not open to the public on 23 February 2021. Around 100 people from port and other public authorities, shipyards, shipping companies and government representatives took part in the event.

“Maritime Germany must understand its responsibility in climate and environmental protection. We are helping to shape the global energy transition with our know-how. This requires targeted regulatory measures and market-based incentives. The federal government is already making a significant contribution to this”, said Achim Wehrmann from the Federal Ministry of Transport and Digital Infrastructure (BMVI) in his keynote speech.

The guide is intended to help simplify and harmonise the different regulations and approval procedures of the individual federal states’ port locations. It contains proposals for the safe and efficient bunkering of LNG and other alternative fuels in German seaports. This was very positively received by the members of the federal states and ports participating in the expert event. The proposals leave enough leeway for particular location-specific requirements. One thing is clear: we need harmonisation!

Claus Brandt concluded: “The results of the study show that there is a need for action. It would be conceivable to set up a ‘Centre of Expertise’ for bunkering alternative fuels. On a common digital platform, experts could provide information on the process steps for bunker approval, risk analysis, approval of storage facilities, safety zones, etc. and make the information and documentation to be provided by bunker buyers and suppliers accessible to all ports.”

The complete study (only in German) is available here.

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The recommendations for action addressed in the guideline are:

1. Dialogue across the federal states regarding harmonised regulations and guidelines
Germany’s federal structure gives rise to particular features compared to other states. For successful implementation, the study identified all the specialised authorities to be involved in the dialogue. These are: a.) the competent port/approval authorities and the state governments and b.) the port/environmental authorities, consumer protection agencies and other stakeholders.

2. International initiatives
Developments in the international environment, such as the new Future Fuels Network, an initiative of the ports of Rotterdam and Singapore, show a willingness to cooperate.

3. Accreditation of bunker suppliers (platform solution)
In addition to the established bunker suppliers, there will be a mix of suppliers in the future. The number of bunker suppliers will increase.

In addition, there will be recommendations for action that address, among other things, bunker management plans to reduce the administrative burden, checklists and online forms, mapping of berths, risk analyses, etc.