- New USCG Policy Letter No. 01-25 establishes a unified risk assessment framework for bunkering LNG and alternative marine fuels in U.S. waters.
- Fuel suppliers must submit a detailed proposal and risk assessment to the Captain of the Port (COTP) before any transfer operation.
- Guidelines replace earlier LNG-only rules, expanding requirements to methanol, ammonia, hydrogen, and LPG bunkering activities.
The United States Coast Guard (USCG) has introduced comprehensive guidelines covering bunkering of liquefied natural gas (LNG) and other alternative marine fuels, requiring a prior risk assessment before any transfer can take place. Issued on July 24, 2025, Policy Letter No. 01-25 creates a standardized, risk-based approach applicable to bunkering operations involving LNG, methanol, ammonia, hydrogen, and liquefied petroleum gas (LPG) in U.S. waters. The policy replaces earlier LNG-specific guidance under Policy Letters 01-15 and 02-15, closing gaps in regulations that were previously tailored to conventional petroleum-based fuels.
Mandatory Pre-Operation Submissions
Under the new policy, vessel owners and operators must work with their fuel supplier—who bears the responsibility for submission—to provide the Captain of the Port (COTP) with a complete bunkering proposal and risk assessment plan ahead of the operation. These documents must be submitted in sufficient time for review and must detail:
- Fuel type to be delivered, expected delivery dates, location, and facilities involved
Company details, vessel technical specifications, and risk assessment participants - Methodologies to be used, preferably ISO/IEC 31010
- Personnel qualifications and training requirements
- Operational assumptions, identified hazards, and protection measures for infrastructure, waterways, personnel, and the environment
Hazards must be addressed across all operational stages, including mooring, docking, anchoring, connection and compatibility testing, fuel transfer (with pressure management and vapor return), disconnection, emergency response capacity, and simultaneous operations (SIMOPS).
Enforcement and Compliance
The COTP has authority to halt any bunkering activity if required documents are not provided in time or if the operation deviates from the approved plan. While fuel suppliers are formally responsible for submission, vessel operators and owners must collaborate closely to ensure all required information is complete and accurate.
No Fixed Template, but Clear Expectations
The USCG has not mandated a specific submission format. However, it advises stakeholders to use a comprehensive checklist during procurement to prevent delays. This checklist should be adapted to the vessel type, fuel type, and port-specific requirements, ensuring all safety and operational considerations are addressed before the bunkering process begins.
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Source: NorthStandard
