U.S. Coast Guard Regulations “Making a difference”

1. U.S. Coast Guard Regulations “Making a difference” Jeff Lantz Director, Commercial Regulations & Standards U.S. Coast Guard 1

2. Why Regulate? • When required by law, to interpret the law, or to address “compelling public need” (Executive Order 12866: Regulatory Planning and Review) • Ensure activities of industry in keeping with broader societal objectives: safety, security, environmental protection • Provide enforceable policies for field • Provide reasoned, consistent, predictable policies for industry 2

3. USCG Regulatory Approach • Address risk in cost-effective manner • Consider economic impacts, with particular attention to small business impacts • Build international approaches where possible • Utilize industry consensus standards • Integrate regulations with policies to ensure reasoned, consistent enforcement Additional Requirements Consensus Standards International Standards Industry Voluntary Measures 3

4. LNG as Fuel - Interest in the U.S. TOTE RO/RO Container Ship LNG Retrofit 4

5. Gaps in Existing Regulations The Current Regulations Do Not address: • Design and construction of LNG fuel systems. • Operations, training, and general safety for personnel on vessels where LNG fuel systems are installed. • LNG transfer operations (Current procedures viewed in light of oil transfers). • Small scale LNG (e.g. bunkering) operations conducted from vessels and shoreside facilities (Currently viewed in context of large scale cargo transfer). • Barges transporting LNG in bulk. 5

6. U.S. Coast Guard Policy Letters Short Term Solution to Bridge Gaps: • Develop policy letters to address gaps in regulations until regulations can be developed. • Natural gas fuel systems on vessels • Base policy letters on existing regulations applicable to LNG cargo operations scaling down to fit needs and accomplish safety mission. • Ensure alignment with ongoing work of leading international organizations (e.g. IMO and ISO). 6

7. U.S. Code of Federal Regulations CFR Long Term Solution to Close Gaps •  Initiate rulemaking project. • Notice of Proposed Rulemaking • Final Rule • Use implemented policy to identify any additional areas to be addressed in regulation. • Incorporate standards and guidance developed by the international community and LNG industry where appropriate. 7

8. U.S. Coast Guard LNG Industry Association Standards Development • IMO - International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels (IGF Code) • IMO - International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) • ISO - International Guidelines for Bunkering LNG as a Marine Fuel (TC67 WG10) • NFPA 52 - Vehicular Gaseous Fuel Systems Code (updates to Chapter on Marine Vessels) • NFPA 59A - Production, Storage, and Handling of Liquefied Natural Gas (LNG) Advisory Committees / Interagency & Industry Workgroups • CGHQ Internal Natural Gas Workgroup • Federal LNG Interagency Roundtable (Washington, DC) • CTAC Subcommittee on LNG/CNG as Cargo and Use as Fuel (Federal Advisory Committee) • SIGTTO – LNG Fuel Safety Advisory Group (London, UK) • LNG Fuel Advisory Council (chaired by DNV, Houston) Other Industry Contacts • Great Lakes Maritime Research Institute • Center for LNG  8

9. Thank you – Questions? Additional Requirements Consensus Standards International Standards Industry Voluntary Measures 9