b'The MSCs goal is to ter 01-23, Design Basis Agreement Submission Guidance. FOGHORN FOCUS To initiate a novel design review, request a concept review support maritime meeting with the MSC. Depending on the complexity of the design, the MSC may determine that it can be approved innovation, but we mustthrough equivalencies, or the MSC will engage CG-ENG if broader authorities and a DBA are warranted. Regardless proceed cautiously to of whether the novel system falls under an equivalency or ensure the safety of DBA, we recommend reaching out to the MSC early in the designprocesstomitigatepotentialdesignimpactsand passengers and maritimereduce the possibility of vessel delays. professionals, reliability ofALTERNATIVE FUELS Due to the lengthy process to update federal regulations, the marine transportationcoupled with increased prevalence and experience with the use of liquified natural gas (LNG) as fuel, a standardized system, protection of design approach has been established. In lieu of a DBA, designers may use the guidance in CG-ENG Policy Letter waterfront facilities, and01-12 Change 1 (PL 01-12), Equivalency DeterminationDesign Criteria for Natural Gas Fuel Systems, which in-conservation of the corporates industry consensus standards and is accepted marine environment.asanequivalentregulatorydesignframework.Other alternative fuels such as hydrogen or ammonia will still re-quire a DBA. For a thorough discussion on DBAs specific to alternatively fueled vessels, please see Standards De-velopment and Safety Considerations for Alternative Fuel Systems by LT Virginia Buys, published in the August NOVEL VESSEL DESIGNS2023 issue of Foghorn.The MSCs goal is to support maritime innovation, but we must proceed cautiously to ensure the safety of passen- LITHIUM-ION (LI-ION) BATTERIESgers and maritime professionals, reliability of the marineSimilar to PL 01-12, CG-ENG Policy Letter 02-19 (PL 02-transportation system, protection of waterfront facilities,19), Design Guidance for Li-ion Battery Installations On-and conservation of the marine environment. DBAs areboard Commercial Vessels, provides an equivalent regula-the primary mechanism leveraged to support the applica- tory framework for Li-ion installations, negating the need tion of novel technology to vessel designs. They typicallyfor a DBA.PL 02-19 references ASTM F3353-19, Standard incorporate portions of existing guidance, codes, and bestGuide for Shipboard Use of Li-ion Batteries, and delineates practicesfromotherindustriesorregulatingbodiestorequirements for the operating environment, fire safety, form a holistic regulatory framework which is best suitedbattery system design, testing, and maintenance.Please to the risk profile of the novel technology. For many ap- note that integrated Li-ion batteries will require plan re-plications, CG engineers perform independent research toview in accordance with PL 02-19 regardless of the total validate the risk profile associated with novel designs andenergy capacity or the end consumer. All Li-ion battery their safety mitigations, which is a rigorous and time-con- installations are considered vital systems for the purpose sumingprocess.Suchapplicationsrequireconcurrentof machinery regulations on the basis that a failure can review from varied CG offices resulting in approval timesendanger passengers. Additional interpretations of PL 02-beyond30daysandsometimesexceedingoneyear.For19 are being drafted; please keep an eye out for additional detailed information on the required elements of a DBAguidance which will be announced on the Maritime Com-and the DBA process, please refer to CG-ENG Policy Let- mons blog and reflected on MSCs website.FOGHORN 14'