Tom Ewing’s Regulatory Update

Coast Guard / LNG: The CG proposed last week to revamp regulations to allow quicker decision making regarding new LNG/LHG harbor fueling facilities.  Current rules require a lengthy Waterway Suitability Assessment (WSA).  Under the new proposal a WSA would not be required if an LNG terminal facility is built just to store and provide fuel for a facility’s vessels.  The CG says that’s different than storing fuel as cargo to be transported on tankers via a waterway, thereby requiring a WSA.  With the change, a business would need an ORA – “operational risk assessment” – to meet regulatory demands.  The CG’s proposal comes after meetings with three businesses which argued that a WSA is unnecessary since they will not be transporting LNG for shipment and waterway risks are beyond their operations.  Additionally, the CG will require the nationalities of all vessels and crew providing service to new LNG facilities.  Finally, the CG comments that this less burdensome regulatory pathway will be an incentive for more companies to use LNG as maritime fuel.  Comments are due by 12/4.

DOE and trucks: The Department of Energy’s Office of Energy Efficiency and Renewable Energy (EERE) announced a request for information (RFI) on issues related to medium- and heavy-duty freight trucking.   DOE writes that there are “new opportunities in all commercial vehicle classes to increase efficiency and to introduce alternative fuel sources such as electricity, natural gas, biofuels, and hydrogen.”  DOE lists five focus areas: (1) Freight Operational Efficiency and Systems; (2) Internal Combustion Engine, Powertrain, Fuels and Emissions Control; (3) Batteries, Electrification, and Charging of Medium- and Heavy-Duty Trucks; (4) Hydrogen and Fuel Cell Trucks; and (5) Other Important Considerations.  Watch for a public workshop to share key findings.  DOE’s goal: to “help identify gaps and barriers to commercializing new technologies,” and help inform DOE’s 10-year competitive funding strategy.  Comments are due by 11/9.

Offshore wind – California:  One picture’s worth a thousand words.  See those skinny, frail utility poles (aka “transmission infrastructure”)?  That’s inland from Humboldt Bay in northern CA.  Those mighty structures are all that’s available to carry a gazillion new gigawatts (and don’t forget telegraph signals) from possible offshore northern wind generation areas to distant load centers, i.e., keeping LA running.

The picture (and text) is from a 2019 North Coast Offshore Wind Studies report.  This transmission challenge came to mind after reviewing some of the documents linked within a  recent CA announcement about an offshore wind workshop next week.  Consider another challenge: “The average time in vessel days for foundation construction for projects between 2014 and 2017 is 2.56 days, leading to an average total vessel cost of $362,560 – $592,800 per foundation.”  Note foundation, not floatation devices.  Also unclear: Are those vessels Jones Act compliant?  (Think that’s important…?)

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