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Permit process

Permit process

Past experience shows that the permit process for LNG bunkering facilities in ports took an average of four years. Factors explaining this long period are the novelty and complexity of the installations and the required stakeholder acceptance. Permits for LNG bunkering facilities are relatively new: Most experience has been gained in permits for large-scale LNG import terminals.

 

Today, Norway has by far the most experience with permit processes for small LNG facilities. The country has about 40 LNG bunker terminals with a capacity of 20 to 3,500 m3. Experience shows that in Norway it takes approximately 12 months to complete the permit process. 

Relevant EU Directives

Two EU Directives govern and affect the permit process at the national level:

  • The EIA Directive (85/337/EEEC), through its Environmental Impact Assessment provisions and its minimum requirements for the public consultation procedure;
  • The Seveso Directive (96/82/EC), on the prevention of onshore major accident hazards with dangerous substances involved. This Directive defines minimum requirements for operators to prevent accidents and includes control measures aimed at limiting the impact of potential accidents. Depending on the size of the facility, a safety report needs to be written. The Seveso Directive identifies two tiers of control:
    • Seveso I: the lower tier, covering facilities with storage capacities over 50 tonnes of LNG annually
    • Seveso II: the upper tier, covering facilities with storage capacities over 200 tonnes of LNG annually.                                        

For the upper tier, an extensive safety report illustrating the potential risks of the installation and how these risks are mitigated must be submitted to the authorities for approval. Furthermore, the terminal operator must show that design, construction, operation and maintenance are sufficiently safe, and is obliged to maintain an effective safety management system.

For the lower tier, a simpler notification to the authorities suffices.  

National level

Although there are differences between countries, there is a degree of overlap between the type of permits required at the national level. The following permits are often required: 

  • environmental permit
  • storage permit
  • handling permit
  • building permit

National authorities are free to determine when an Environmental Impact Assessment (EIA) is required prior to construction of a LNG storage facility. In several countries an EIA is only obligatory for facilities where over 200 tonnes of LNG is stored. The number of permits and the number of authorities involved in the permit process also vary. The duration of the overall process can be shortened significantly by integrating the number of processes into a single process. This requires authorities to work closely together.

Public consultation

The EIA Directive requires early consultation of stakeholders to enable them to participate in the procedure and provide feedback at a stage prior to any decision-making. As the EIA specifies no further requirements, there are differences in implementation among between Member States.

The Danish Maritime Authority (2012) established three stages at which public consultation can be provided:

  • Screening phase: to determine whether an EIA is required
  • Scoping phase: to identify the environmental issues to be studied in the EIA
  • Consultation phase: a public comment period following publication of the environmental report, prior to project finalization.

Not all countries involve stakeholders in the scoping phase, but doing so strengthens the environmental report. Stakeholder consultation generally takes four to eight weeks in most countries.

Further reading

Environmental legislation

LNG is a proven technology for complying with the upcoming MARPOL Annex VI regulations. At the moment, LNG is the only available option that is able to meet both the SECA and NECA requirements without the need for using marine gas oil.