Prepared by Alex Zecha November 27, 2012




  Washington State Ferries (WSF) has issued a request for proposals (RFP) for the retrofit of the six Issaquah class ferry vessels. The vessels will be converted from being fueled by diesel fuel to being fueled by liquefied natural gas (LNG). The RFP calls for six elements to be consolidated by a single proposer;
1-Provide new LNG-only fueled engines
2-Provide an LNG fuel system
3-Provide design services to support the conversion
4-Provide shipyard services to perform the conversion
5-Provide financing
6-Provide fuel delivery
  This report has been compiled in an attempt to provide a critical analysis of the RFP and its likely award recommendation.
  While an RFP isn’t a signed contract, it does provide a clear, accelerated, and well-defined pathway to one. An RFP can also provide a distinct and unambiguous demonstration of the issuer’s intent. The timing of this RFP is such that WSF will issue an award recommendation one month into the next legislative session. The workload for state legislators at a time like this is usually extremely high, with free time for objective analysis being more or less non-existent. Further, most legislators typically posses professional expertise in areas other than marine engineering and maritime operations. These facts combine to make it very difficult for legislators to accurately assess the pros and cons of the recommended award prior to being asked to vote on it.
  Legislators considering the proposal to be submitted by WSF for approval and funding will be defining a significant portion of their political legacy by the first moves made by WSF into what will most likely become the common fuel source of this century. While this may bring the promise of a public perception of wisdom and insight, it could also bring considerable political handicap should the effort not be well thought out and carefully planned.
  The existing RFP reflects a significant lack of thought, a noteworthy absence of planning, and no consideration whatsoever given to ensuring that the original basis for the conversion is adhered to. Although the effort is advanced on the basis of a promised reduction in fuel expenditures large enough to justify the cost of conversion, there has been no cost analysis yet performed which could be considered complete. There is slim chance that the financial objectives can be reached. The end result of the RFP as written will only ensure more frequent and longer service cancellations.
  Legislators are being asked to hold a bag. They and their constituents would be very well served to ensure the bag isn’t empty.

Executive Summary

  The basis provided for entering into this project is very real and very significant. WSF must find a way to address and control the rising cost of fuel for its vessels. Although not the only solution or even the best one in all circumstances, the conversion of vessels to the use of LNG as a fuel source is a very practical and reasonable way to address this.
  Risk is said to be the product of probability times consequence. Certain circumstances justify the assumption of risk, such as the threat of imminent dire circumstances or the promise of correspondingly high returns. Neither of these circumstances applies here. The RFP as written creates a very high risk environment surrounding the project, its overall financial benefit, and the successful integration of the delivered product into WSF’s existing operating program. There are a number of reasons for this, the more significant of which are outlined below.

  Poor Fuel Availability and Incorrect Engine Specification
  The Issaquah class vessels are the workhorses of the WSF fleet. The RFP commits these six vessels to a fuel source with only a single supplier currently available within an 1100 mile radius from Seattle. It then compounds the problem with an engine specification which makes WSF reliant on that fuel type exclusively, for any operations at all. Creating a scenario where the 30% of the fleet can be simultaneously removed from service so easily has no legitimate justification. This is the single worst element in a venture saturated with shortcomings. The risk here is beyond measure in financial terms. The degree of risk in this situation is particularly unjustifiable considering the ease with which this risk can be completely eliminated.

Poor Operational Planning
  The physical logistics of using LNG as a fuel source will require additional time out of service at the expense of existing revenue service and maintenance time. This time is not yet accounted for as an operational factor or cost factor. Legislators will need these impacts to be defined and quantified in order to make a meaningful assessment of any proposal.
  WSF has yet to produce the pre-design study required under RCW 47.60.385 and RCW 47.60.386. WSF defines their future operations with LNG fuel in a Concept of Operations document (CONOPS). One may assume that this document is to serve as a template for these pre-design studies, but that document fails in many respects to even live up to the objectives provided for itself in its introduction. There is no discussion of any operational risk consideration in WSF’s CONOPS report or any other available published documents. Judging from available documentation, WSF has given no thought whatsoever to the operational impacts associated with the use of the new fuel.

  This RFP is Essentially A No-bid Contract Worth Hundreds of Millions of Dollars
  The RFP has a unique aspect to it in that it combines multiple disparate elements together to be submitted as a single proposal. No basis is given for this merging of prospective vendors. The apparent intention here is to present a significant barrier to participation for prospective proposers. This barrier is compounded by the abbreviated period of time between when the RFP is advertised and when proposals are due. Any informed audience can look at this RFP and see it for what it is-an attempt at a no-bid contract. There is no legitimate reason for this. This will not be in the interest of ferry riders or the general public. The lack of a competitive bidding environment will ensure higher costs for taxpayers. The only party to realize any benefit from this RFP, as written, will be the successful proposing consortium (Rolls-Royce, et al).

  Is This Work Being Done To The Correct Class of Vessels?
The basis for selecting the Issaquah class vessels as candidates for a fuel conversion remains a mystery. A major capital refit such as this should be directed towards reducing the worst aspects of a problem and obtaining the greatest return on the investment. The RFP as written fails to do this. In many ways it does the exact opposite; it makes an investment which will yield the lowest margin of return. This is a very poor business practice.
  Other Options Are Available To Reduce Fuel Costs
Prior to performing a major refit to so many of their vessels, WSF should analyze existing operations and service levels to determine what options exist for non capital-intensive methods to reduce fuel expenses.
This Project Is Advanced On The Basis Of Unrealistic & Incomplete Financial Models
  There are no cost-benefit analyses presented which have a complete accounting of conversion costs. The most notable omission (although by no means the only one) is the cost of debt service. All of the cost benefit analyses presented fail to include these costs. Debt servicing is a very significant cost factor and should be accounted for as part of the project cost. When a complete accounting of project costs is performed, the project does not have the ability to pay for itself.

  This project is a no-bid contract with an enormous price tag. There has been no broad analysis of where the problem being addressed is most significant. The targeted vessels do not represent the most significant part of the problem being addressed-in some cases the opposite is true. There’s no explanation provided for the selection of vessels being refit. Other options for addressing the root problem have not been fully explored. There has been no meaningful analysis of, or planning for, how to address the operational impacts associated with using the new fuel. The engines specified for installation can only use a type of fuel with a single supplier in a 1,100 mile radius. To wrap it all up, the project is advanced on the basis of obviously incomplete financial models. This project has all the makings of a disaster about to happen.

Section 1- Extremely Limited Availability of Fuel Suppliers

  WSF quite literally puts all its eggs in one basket by proposing to convert the entire Issaquah class of vessels to the proposed new fuel source in spite of having no first-hand experience with it. Although the lack of local fuel suppliers in and of itself isn’t the biggest shortcoming of the proposal, it’s part of the biggest. When combined with the requirement for a gas-only engine it makes for a fatal shortcoming in the RFP.
  The most significant contrast between the availability of diesel fuel and the availability of LNG is that with diesel fuel, there are enough players on both the demand and supply side of the issue to ensure both market competitiveness and widespread availability. For LNG supply sources there’s neither market competitiveness nor meaningful availability. Even with the broad and varied infrastructure for diesel fuel distribution, WSF experiences frequent disruptions in fuel deliveries. The marginal storage capacity of LNG tanks eliminates the cushion WSF currently has with diesel-fueled vessels in the event of a missed delivery. Whenever there’s a supply disruption for any reason, you’ll see an immediate vessel service cancellation.
  Just as an army marches on its stomach, a ferry system sails on its fuel supply. In July 2011 the Joint Transportation Committee (JTC), acting under the direction of the Legislature, hired a consultant to investigate the use of liquefied natural gas as a fuel source for WSF. The consultant returned their report in January 2012. One of the subjects covered in the Cedar River Group (CRG) report to the legislature was the very poor availability of fuel sources in the Pacific Northwest. The report states; “There are six liquefaction and/or storage facilities in the Pacific Northwest, all of which are limited to supporting gas utilities”1 also; “There are very few liquefaction or storage facilities in the Pacific Northwest, and those that exist are supporting the gas utilities.”2 The report proceeds to describe existing resources and what their other commitments are. The end of the list identifies the one vendor who indicated that they anticipate having enough capacity to meet WSF’s initial requirements. Not only does this vendor (FortisBC) decline to make an explicit quantified commitment as to available capacity, but they happen to be located in Canada.
  No analysis is given to potential legal or political impediments to maintaining a consistent long term supply chain of LNG for WSF. There’s no analysis of future demands on FortisBC’s capacity. There’s no discussion regarding prioritization requirements that they may be subject to, or potential casualties that would impair the vendor’s ability or desire to deliver their fuel. There’s no discussion whatsoever regarding any potential delay or disruption of this fuel source. This doesn’t mean that no disruption is possible, not by a long shot. It only means that WSF has not exercised due diligence in ensuring that there’s a reasonable contingency in place that would maintain a reliable fuel supply or that sufficient suppliers exist to ensure competitive market pricing for the fuel.
Should the sole regional fuel source be interrupted or delayed for any reason the only alternative presently available is to truck the fuel up from Boron, California3 (just this side of Barstow). This is an 1100 mile trans-continental journey across three states and multiple mountain passes. With an expected need for 18 truckloads of fuel per week to keep the class running post-conversion, this is a remarkably impractical alternative. There’s also no consideration being given to whether or not this supplier would be willing or even able to provide sufficient rolling stock to transport the fuel for a customer that only needs it in an emergency. A fuel supply for six Issaquah vessels would require no less than 10 trucks and 14-16 drivers to maintain. No operator maintains this level of unallocated vehicle inventory and drivers standing by without a regular market for their services. As elsewhere, the true cost of this source (in the form of an actual quote from a vendor) isn’t factored into any cost benefit analysis used to justify the cost of the project.
  There may be verbal expressions of future availability regarding other potential regional LNG fuel sources since the Legislature received their report from the Cedar River Group, but this does not translate in any way into solid, contractually binding obligations based on installed and operational capacity.
  The lack of multiple fuel vendors eliminates any incentive to price the product competitively. In fact, the RFP language makes no mention of market rates for the portion of the proposal pertaining to fuel delivery. This fact isn’t accounted for in any of the cost benefit analyses performed to justify the projected $145 million capital cost of the conversion.
  This proposal is for a major capital modification of critical transportation infrastructure. The current lack of regionally available LNG fuel supplies coupled with not only the RFP requirement, but even the allowance of a single-fuel engine has the potential to completely shut down a large part of this infrastructure. This situation is completely unacceptable. This constitutes a fatal deficiency with the existing RFP.
  Should any event transpire that impacts the rather tenuous fuel supply, than you end up tying up the six most versatile vessels in the fleet. There’s no escape route available to provide for replacement vessel capacity such as would be needed in the event of a fuel supply disruption. The likelihood of such a disruption is quite high due to the scarcity of regional suppliers, plus the overall logistics associated with LNG transport (weather, traffic, plant casualties, border delays, competing contractual commitments from the suppliers’ other accounts, etc.). Creating a scenario where the six most reliable vessels in the fleet can simultaneously be removed from service so easily has no legitimate justification.
  This will impact not just the runs served by the vessels in question, but the entire ferry system. Every ferry run would see drastic reductions in service. Where service is provided you’ll see wait times that are unheard of today. There appears to have been no contingency planning for this, nor has there been any sort of analysis as to the costs associated with this. There’s lost revenue, and then there’s a significant economic hit associated with the lost infrastructure. In order to reasonably compare the risk to the claimed benefit, this needs to be considered, as well as the value and cost of efforts to prevent it.
  Referring back to the risk equation, the probability value of a fuel supply interruption is moderate, but the consequence is extremely high. This is an unnecessary risk that can and should be avoided, particularly given the ease of doing so.

1 Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. v
2 ibid, pg. 32
3 ibid, pg. 34

Section 2- Single-Fuel Engines vs. Dual-Fuel Engines

  This subject has been touched on earlier, but warrants further examination. The RFP and the budget language that funded the RFP both specify the use of a gas-only (single-fuel) engine.4 Natural gas fueled engines are generally of two types; gas-only and dual fuel. A gas-only engine has a spark plug as an ignition source and only burns natural gas for fuel. A dual-fuel engine uses a pilot charge of diesel fuel in a pre-combustion chamber to ignite the gas fuel and can burn diesel fuel or natural gas. A dual-fuel engine offers several very significant advantages over a gas-only engine; Responsiveness-A dual-fuel engine can be changed into a diesel-only engine on the fly when needed. Gas-only engines have better response times to load changes than dual-fuel engines using dual-fuel, but a dual-fuel engine running as a diesel-only engine has the best response time of all-essentially the same as a conventional diesel engine. This is very important on a vessel that spends most of its operating time in maneuvering situations in constricted and crowded waterways with a thousand or so passengers aboard.
  A ferry spends from 10 to 40 minutes per hour in a maneuvering mode, depending on the route it’s assigned to. When maneuvering a prompt and definite response to throttle commands is vital to both safety and on-time performance. WSF has built a service schedule that’s dependent on a certain period of time being allotted to dock a vessel. Due to the slower response time of a gas-only engine, the time required to make landings will be longer. This is because the Captain will need to slow the vessel at a greater distance from the dock than is currently done and then have to make a slower approach to land the vessel. These are factors which will likely require WSF to revise service schedules on runs with a high percentage of maneuvering time (Fauntleroy-Vashon-Southworth and Mukilteo-Clinton).
  If WSF were to make major engineering changes that required them to reduce service on certain routes, then they should examine the fuel savings to be had from just running the existing vessels slower, thereby saving the lost service and cost associated with the refit.
  The slow response time of a gas-only engine dramatically heightens the risk exposure in WSF’s operating environment. It does this not just for their vessels, but for other traffic and fixed objects in the area. WSF has developed an alternate compliance strategy regarding the implementation of the United States Coast Guard (USCG) Subchapter W lifesaving requirements. This strategy is based on accident prevention via risk avoidance and consequence mitigation, versus the reactive approach defined in the prescriptive Subchapter W language. Incurring a substantial burden of risk puts this compliance philosophy in jeopardy. Potentially this could lead to the USCG declining to renew the alternate compliance approval at the next review period. It would require WSF to outfit their vessels with full life raft capacity for all passengers and to increase manning on their vessels accordingly. The financial impact of this would be considerable, as recent USCG manning decisions have demonstrated.
  If WSF specified the use of a dual-fuel engine, this could all be avoided because the throttle controls can be configured to switch the engine to a diesel-only operating mode when operating conditions require it. This allows the WSF to retain both the cost-efficiency of an LNG-fueled engine and the responsiveness and safety of a diesel engine. You can get the best of both worlds with a dual-fuel engine.
  Not dependent on a single fuel source-A more important advantage of dual-fuel engines is that they can either burn natural gas (delivered to and kept in storage aboard the vessel as LNG) or they can burn straight diesel fuel. LNG may be readily available from a variety of local vendors someday, but isn’t currently. Diesel fuel is widely available, has a vast and varied distribution, storage, and delivery infrastructure, and is subject to very competitive market pressures for delivery pricing. This makes a dual-fuel engine an ideal hedge against the inevitable supply chain disruptions and cancelled deliveries that would otherwise shut down critical transportation infrastructure.
  The financial basis for selecting LNG as a fuel source is hinged on a price differential between LNG and diesel fuel. Given the volatile nature of energy markets, as well as the poor supply side conditions in the local market, it makes sense to hedge one’s position by using an engine which isn’t dependent on any one fuel type exclusively. A strategy of fuel-flexibility (via the use of dual-fuel engines for LNG powered vessels) to maintain operational cost-effectiveness is specifically recommended by industry experts at Lloyd’s Register5.
  No basis is established anywhere in any available documentation for the specified preference for a single-fuel engine over a dual-fuel engine. The reason for this is that there isn’t any such basis. A dual-fuel engine isn’t just a more practical choice or a better choice- it’s the only practical choice.
  WSF‘s track record for safety and reliability establishes the industry standard for excellence in marine passenger and vehicle transport worldwide6. This has been achieved through a variety of means, but a key element is the application of a design philosophy that emphasizes redundancy. Taking an extremely reliable class of vessels and converting them to a fuel source with scarce availability, while also pointedly and specifically excluding the only potential solution to the availability problem shows a reckless disregard for the public interest. This flies in the face of logic. The parties who dictated the language which drives this offer no justification for it whatsoever. To knowingly and willfully eliminate from consideration the engine type that provides the only viable solution to a potential major shutdown of six vessels is completely unconscionable.
  The protest filed by Wartsila7 over the terms of the RFP highlights other complications. RCW 47.56.030 requires procurements of this type to be subject to a competitive bid process. The exclusion of dual-fuel engines without a technical or operational basis for doing so is a violation of state law. Ironically, the exclusion of gas-only engines would be both lawful and appropriate in this RFP due to the lack of a meaningful supply infrastructure, not enough LNG vendors to ensure a competitive or reliable market and the cited operating characteristics.
  The requirement to use a gas-only engine, coupled with the lack of available fuel suppliers essentially guarantees more frequent, much more widespread, and longer service disruptions on WSF vessels than has ever been seen before. This requirement shouldn’t just be reconsidered, it should be reversed. There should be no gas-only engines on any WSF vessels using LNG.

4 Washington State Senate Transportation Committee, Technical Ammendments to SB5992, 4-2012, pg. 9
5 (LNG Bunkers Offer Greatest Potential For Costs Compliance, 2012)
6 Bennion, Michael Dean, WSDOT Office of Research and Library Services A Comparison of Operational Performance: Washington State Ferries to Ferry Operators Worldwide, 6-2010
7 Hernandez, Joaquin-Schwabe, Williamson, and Wyatt, letter to WSF director of legal services dated 10-29-12

Section 3-Poor Operational Planning

  There appears to be a notable lack of operational planning for implementation of the new fuel source. Part of this may be addressed during the risk assessment to be delivered to the USCG, but given the impact that these issues will have on operations and finances, they should have been considered as part of developing the proposal’s financial justification. Certainly they should be addressed in the Concept of Operations (CONOPS) document developed by WSF. The lack of their inclusion is a good sign of a substantial lack of operational planning on the part of WSF as well as a very casual or potentially disingenuous approach to the cost-benefit model used to justify the project. One of the key issues will occur when a vessel is taken out of service due to a fault with the main engines or some part of the fuel delivery system. Depending on a number of factors, but primarily the duration of the service disruption and the amount of fuel remaining in the tanks, a condition can develop wherein the fuel warms up enough that it undergoes a phase transition-turns into gas and begins to vent out the tank relief valves. This presents a problem. Not only does it create a potential fire hazard, but neighbors in surrounding areas may have some notable objections to it, and well they should. The reasonable solution here is to specify that some of the auxiliary machinery (generators or boilers) also be converted to using LNG as a fuel source. Another approach is to have a vendor, probably the vendor holding the fuel contract, be required per the terms of the contract to arrive at the vessel in a certain period of time in order to remove the fuel and gas-free the tanks.
  The reverse of this situation will also come into play when it’s time to refuel the vessel upon returning to service. When an LNG tank has fuel in it it’s kept at a temperature of -260 deg. F. When it’s been emptied, it begins to warm up. Prior to filling the tank after it’s been emptied, it must be cooled down so as not to flash the fuel into a gas when the tank is filled. The time required for this (2 or more days)8 and the location need to be accounted for as operational factors. There’s no indication that this has been done. There’s also a cost element at play here since this will require a truck with LNG to remain on site while this task is performed. This service will not be free, nor is it accounted for by WSF in any cost benefit analysis.
  This leads to another operational consideration. When LNG cargo vessels have to go to a shipyard, they are required by the USCG to empty and gas-free their fuel system (tanks, pipes, etc.) prior to entering the yard. One can assume that the potential exists for this same policy to be applied to LNG-fueled passenger vessels such as those being proposed for conversion. There appears to have been no correspondence with the Coast Guard on this as an operational consideration. It would have been appropriate for WSF to have obtained a position on the matter from the Coast Guard prior to moving forward with the issuance of an RFP. The Coast Guard’s determination on the matter will have a very significant effect on WSF, its operations, and as a result, on the cost of using the new fuel. This cost must also be factored into any cost-benefit analysis used to decide on the project’s viability.
  This effect can be felt in several different ways. The time required to have this service performed, either as a requirement to enter a shipyard or as a need in response to an unplanned vessel casualty, will have an impact on vessel availability and/or shipyard availability. This translates into more out-of-service time and/or a higher overall cost due to the need for more extra service capacity (spare vessel availability). The added out-of-service time will impact existing maintenance schedules, which are already only marginally able to support the needs of vessels expected to be in service for 60 years.
  When all six vessels are converted to using LNG, these factors will require a minimum of 18 additional vessel service days per calendar year to be removed from current vessel availability for revenue service. This will have to be accommodated either with service reductions felt system-wide or spare vessel time allotment. A spare vessel is a very expensive asset to procure, own, and operate, making service reductions the likely route to be taken here. WSF offers no description of any proposed service reductions to support these requirements, nor do they detail out the fiscal impacts associated with these factors.
  Training costs and credentialing costs for crewmembers who work on the LNG-fueled vessels will be a factor. For a variety of reasons, including the new use of the fuel, the new use of the fuel on passenger vessels, the lack of existing regulatory guidance on the matter, the lack of any meaningful history using the new fuel, etc., the Coast Guard may require credentialing for those personnel who handle the fuel. Such credentialing, as well as the training that it may require, will have an expiration date and both an initial and a recurring cost associated with it. The logistics of ensuring that employees are trained and credentialed (should the requirement be imposed) as well as the cost for this need to be both identified and planned for. This cost should be factored into the cost/ benefit analysis for the project. Although the requirement for this would depend on the position the Coast Guard takes on the matter, the potential for this is quite high and should have been considered and planned for prior to issuing the RFP. There appears to have been no dialog on this issue either within the organization or between the organization and the Coast
Guard. This potential cost is a component of, and derived exclusively from, the capital improvement project and it should be funded as a part of the capital expense.
  The timeline for the required risk assessment and the convening of the risk assessment review panel doesn’t allow sufficient time to address the existing operational obstacles or potential emerging obstacles in a responsible manner prior to an award recommendation being made. Since the findings of the risk assessment review panel will likely have an operational impact and consequent financial impact, these should be identified, planned for and factored into an ongoing cost-benefit analysis prior to making an RFP award recommendation. There is currently no indication that this has been, or is being, done. Legislators will instead be asked to contract for something and then find out later what the true cost and operational impact will be.
  The collective omission of the items cited above is far greater than the sum of their parts. It’s a clear indication that WSF hasn’t given the appropriate level of planning and thought to the operational implementation of the completed project. Once an award recommendation is made and approved, and then a contract signed, WSF and the taxpayers are contractually bound to the project. At this point, the emerging costs and operational impediments associated with a lack of operational planning will all have to be absorbed no matter what they cost.
  The Cedar River Group (CRG) report states that the project cost is close to the projected cost savings.9 Given the tenuous balance of the financial justification, not to mention the inherent volatility of energy markets, any or all of the contingencies cited above can and will tip the scale away from making the project financially legitimate.
  These issues are all relatively minor in the grand scheme of things, and probably fairly easily resolved. Their significance, however, isn’t in the ease with which they can be resolved. Their significance lies with the impediments that they will throw into an operation already underway and with substantial financial obligations for a very large capital contract already in place. Their significance also lies with the fact that obvious problems like this have apparently gone unaddressed in any operational or contingency planning prior to taking the organization down the pathway of converting such a significant portion of the fleet to LNG. That these scenarios exist at all as potential roadblocks which haven’t been addressed is a very good indication that WSF isn’t currently administratively ready to successfully deliver and put into operation a conversion of this magnitude.
  The RFP, if it’s to be awarded at all, should be changed so that one vessel is converted at a time. Options for others can be exercised based on satisfactory post-delivery service performance and ongoing operational feasibility assessments.

8 The Glosten Associates, LNG use for WSF, 3-2010, pg. 4
9 Cedar River Group/Boylston, John, Evaluating the Use of Liquefied Natural Gas in Washington State Ferries, 1-2012, pg. 59

Section 4- Consolidation of RFP Elements

  This project groups together multiple parts of a project in an apparent attempt at creating a no-bid contract. Combining the six elements of the RFP together is a novel practice at WSF. It consolidates a wide variety of vendors into a single group. This sort of consortium takes a fair amount of time for potential proposers to put together. The time from advertisement of the RFP to award is less than five months. The time from advertisement to initial proposals due is half this. This is an unreasonably short period of time even without the consolidation of vendors required per the terms of the RFP. The accelerated timeline presents a considerable obstacle and will further serve to diminish interest in the project from prospective vendors due to the logistical burden it imposes. The aim of this language is apparent to any informed and experienced observer. This provision is intended to eliminate competition amongst the prospective proposers.
  Eliminating competition provides no value to the taxpayer. This is the precise reason for existing legislation regarding bidding requirements in state procurement. Eliminating procurement competition eliminates the competitive pressures for project cost reduction and/or an increase in value. It also restricts the variety of potential alternatives that may be of great benefit to the WSF. Any person with experience in RFP and IFB (invitation for bid) development can see that this is a clear attempt at trying to draft a no-bid contract. A no-bid contract is not in the public interest, particularly one written (as this one is) to define a specific engine and engine type (gas-only) that’s contrary to any efforts at mitigating operational risk.
  The engine being targeted with this RFP is marketed by a vendor with a rather marginal history of customer service and responsiveness. There appears to have been no engineering analysis of the engine’s operating characteristics, no analysis of the life-cycle costs of using this engine vs. others, and no survey of other users regarding their experience or satisfaction with it. These are all standard items for analysis in situations like this. No reason is provided for not engaging in this sort of research prior to selecting the engine make and model. This project, given the RFP language, and in the absence of this type of research, will only benefit the successful proposer.
  An RFP does not bind the issuer to grant an award. It provides the issuer with several advantages in this situation. It allows them plausible deniability. If questioned on the no-competition nature of the language they can always claim that they’re just testing the waters and don’t intend to issue an award recommendation. The issuer also has an out in that the RFP in question allows for the terms to be changed at any time by WSF. The objective audience is left to trust that the people ram-rodding this through will act in the best interests of the public.
  When word got out at WSF that this report was being developed, access to the folder for the project on WSF’s server was locked down. Given this deliberate lack of transparency, particularly in the context of how the project development in general has all preceded, it’s safe to say that the public’s best interests are clearly not the ones being represented here, nor will they be when the winning proposal is announced.
  The problems with this RFP are magnified by the language in the legislation which funded the RFP development, which states “To the extent allowable under current law, the bidder awarded the design/build contract for converting the Issaquah fleet to liquid natural gas under this subsection shall be given bidding preferences in any future liquid natural gas related ferry proposals or projects.”10 Not only does the RFP target a single proposer in a non-competitive purchasing arrangement, it proposes to keep this vendor on the gravy train indefinitely. In essence, this grants a perpetual monopoly on the future of natural gas related projects and proposals to a party which was first selected in a no-bid procurement scheme.
  This is not a pretty picture.

10 Washington State Senate Transportation Committee, Technical Ammendments to SB5992, 4-2012, pg. 9

Section 5- Is This Being Done to The Right Boat?

  The overriding basis for this conversion is the potential reduction in fuel costs. Legislators will be asked to approve a capital improvement project that involves a very significant part of the WSF fleet. This project constitutes a major step into the operating environment that WSF will be working in for the next 50 years or so. With any project, once the planning and execution get moving, inertia develops. This may help to carry momentum forward, but it can also cause key project players to lose focus of the original need. When the time comes to be responsive and make critical decisions in order to keep the original objective in sight, this inertia and project “group think” work against you.
  Being able to view the project from a distance helps one to recognize this. What’s important here isn’t the conversion to the new fuel source. What’s important is the need to reduce the amount of money currently being spent for diesel fuel.
  While the current approach may ultimately prove to be feasible or even preferable, we should make a point of analyzing other options prior to committing ourselves to it irreversibly. Is there a way to reduce fuel consumption without the major capital expense to be incurred by a huge vessel renovation? Can a similar approach be taken that uses more of the existing equipment on the vessels, thereby reducing costs and providing a greater return on the investment? This would also provide other benefits such as reduced expenses for spare parts, capitalizing on existing engineering system familiarity for maintenance and repair purposes, etc. Has a reasonable survey of available engines and their performance characteristics been undertaken to ensure that we’re targeting the best available options? Are we making our decisions based on the original need for the project or have we let project inertia get the better of us and lost sight of the original objective, pursuing the project instead for the basis of effecting delivery on it?
  WSF should be focusing capital improvement efforts on the vessels that will provide the best return on the investment. It makes no sense not to do this. The Jumbo MkII vessels, as a class, use the highest amount of fuel out of all the vessels in the fleet. Refitting them to run on LNG would save WSF $500 million in fuel costs over the remaining service life of the vessels11. Compare this to the claimed projected savings of $190 million for converting the Issaquah class vessels12 and the obvious difference is more than substantial, it’s huge. The cost of the conversion would likely be on par with the Issaquah class conversion; the number of engines would be the same and other aspects such as tanks and piping would be reduced by half, due to there being half the number of vessels to convert. There doesn’t appear to have been any formal analysis of this cost.
  Factors affecting the cost effectiveness of a conversion to LNG; Vessel age-The benefit for converting any vessel is inversely proportional to its age. The longer it has to remain in service, the more time is available to realize a return on the resources expended on its conversion. For some vessels, the remaining service life is so low that there’s simply no point in making this sort of a commitment to them. They won’t be in use long enough to justify project costs. Exactly where the line is drawn depends on many variables, but some of the major ones include the actual cost of the fuel, cost of debt service, and the actual cost of the conversion (not projected costs).
  Route length-In some instances the run that the vessel serves would make a big difference in the economic viability of a major fuel source conversion. The Issaquah class vessels operating on the Anacortes-San Juan Island run and the Bremerton run use 60% more fuel per year than the same class of vessel operating on the Mukilteo or triangle runs13. In cases like this the biggest factor in determining the economic virtues of a major conversion is the route that the vessel normally serves. Other factors have a proportionally smaller influence on whether or not the end result will be able to pay for the conversion within the remaining lifespan of the vessel. Logic argues for prioritizing fuel cost control efforts where they’re needed most. This is not being done.
  Not a single cost-benefit analysis has been developed which takes route length into account. While the RFP may pencil out for the Anacortes and Bremerton routes, only under an unrealistically optimistic scenario will it do so for the Mukliteo and Triangle runs. These runs usually have the same specific vessel permanently assigned to them. They won’t justify the cost of the renovation with a reduction in fuel costs without being lumped in with sisterships on higher-consumption runs. Even then, instead of contributing to the overall economic benefit, they only dilute the economic value of the conversion to the other vessels.
  A meaningful cost-benefit analysis would incorporate a run-by-run survey of anticipated vessel assignments. This should be based on planned fleet deployment. This should be post delivery of the first two 144-car vessels, since they’ll be in service by the time any LNG conversions have been completed. This is especially important for an analysis of the feasibility of converting the Issaquah class vessels, since they’re not reasonably likely to be able to justify the cost of their conversion when subject to a complete cost-benefit analysis.
  Vessel fuel consumption-This is a big factor in whether or not a conversion would be cost-effective. The more fuel a vessel burns, the less time it will take to make the conversion pay for itself. While absolute fuel consumption per vessel may be one way to define this, another meaningful metric would be fuel consumption per car carried. A larger vessel carries more cars and passengers, but in some instances the smaller vessels burns a disproportionately large amount of fuel for their vehicle capacity. For example, a Jumbo MkII burns 4000 gallons per day, while the Kwa-di Tabil (KDT) class vessels only burn 1400 gallons per day. However, if you determine relative fuel consumption by dividing gallons of fuel burnt per hour by the number of cars carried, the KDT class vessels burn over 50% more fuel (per car carried) than the Jumbo MkII vessels burn (MkII-.865 gallons per car per hour versus KDT-1.367 gallons per car per hour). This makes the KDT vessels not only the most expensive car ferries ever built per car carried, but also the most expensive vessels in the fleet to operate per car carried. This would make them a preferred candidate for an LNG fuel conversion.
  All of these factors should be taken into consideration when attempting to determine where the best economic results for a fuel source conversion would be obtained. A prudent decision on the matter would weigh the relative value of each factor prior to deciding on an ideal candidate. How the Issaquah class vessels were arrived at as a candidate for conversion is anyone’s guess. Perhaps the original target was the was made to retain the existing design on the 144’s the bull’s-eye probably landed on 144’s and the Issaquah class was used for comparison purposes due to design similarities. When the decision the Issaquah by default. At any rate, they’re hardly the ideal candidate, nor are they likely to pencil out financially as LNG conversion candidates.
  Potential LNG conversion candidates; 144 car (Olympic Class) vessels-
  The CRG report recommends against building the second 144 as an LNG-fueled vessel, citing the need to improve capacity as soon as possible14, but makes no mention of how long this improvement would be deferred if the vessel is built for LNG. Nor is there any discussion entered into regarding the operational impacts of this move. This recommendation should be better quantified and better qualified prior to making a decision to approve any award recommendations for the existing RFP.
  The 144’s are the ideal vessel for this fuel for a number of reasons;
  1. They will be in service long enough to pay for themselves. Even with the unaccounted for variables, the increased cost of their construction as LNG-fueled vessels is lower than the cost to refit the Issaquahs.
  2. After the first two, they will all be delivered post-implementation of the EPA Tier 4 emission requirements and as a result will need either exhaust aftertreatment or a gas fuel in order to be in compliance.
  3. Their projected build schedule allows for the first to be put into effective use as a pilot. In the long run, the construction of one vessel as a pilot will probably be the single biggest cost-saving measure to be had with this project.
  4. The timing of their delivery facilitates an incremental expansion of LNG suppliers and users in the region. This will reduce the likelihood of supply disruptions to future LNG fuel deliveries.
  A conversion of the 144’s would eliminate a potential landmine lying in store for the RFP. The USCG may determine that the conversion being planned via the RFP is significant enough in scope that it qualifies as a “major conversion”. If such a determination is made WSF will have to bring the entire class of vessels up to current design standards as part of the retrofit. This would make the project cost-prohibitive15. This is more the case with the conversion of an older vessel than a newer one. An older vessel will have more outdated installations and design standards which need upgrading or replacing than a newer one, and will consequently present a higher fiscal impact in the event such a determination were made.

  Kwa-di Tabil Class vessels-
  No mention of the Kwa-di Tabil class vessels is made in the CRG report, but with the longest remaining service life, the highest cost of fuel consumption per car carried, and a moderately long run length, they seem like an obvious choice to maximize a return on investment.
  What’s important to take away from all this is that there has been no comprehensive survey done of where the need to reduce fuel cost is greatest, of what potential methods there are for doing so, or of where the highest potential benefit would be. Prior to engaging in a risk-laden and expensive effort to convert the Issaquah class vessels, we should at the very least conduct such a survey.

  A small-scale refit-
  Another option that should be considered is a retrofit of existing engines to use the new fuel source versus outright replacement. There’s at least one local firm (Energy Conversions Inc.) who has a conversion package designed, tested, and in production that converts existing EMD engines to dual-fuel engines. Approximately 75% of the engines used by WSF are EMD’s. These engines have an outstanding track record in terms of durability, affordability, spare parts costs, and top tier customer service from their regional distributor.
  A conversion to LNG fuel using existing EMD engines would be substantially cheaper than one involving all new engines and the associated costs for engine procurement, installation, spare parts inventory, training, etc. All vessels built for WSF in the last 30 years are powered by EMD engines, and as such are potential candidates for this type of approach. The smaller scope of work defined by this approach would reduce the likelihood of a major conversion finding by the USCG. If such a finding was arrived at, the scope of work required would be substantially less due to the vessels being newer than an Issaquah class vessel. A newer vessel is closer to being in keeping with contemporary design requirements, and therefore has a smaller financial impact should the project be determined to be a major conversion.

11 Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. 38
12 ibid, pg. 37
13 Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. 24
14Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. 56
15 Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. 48, 57

Section 6-Other Options for Reducing Fuel Costs

  Significant gains can be had in most vessels’ fuel consumption rates simply by reducing the operating speed. In many cases WSF runs vessels at speeds that the timing of the runs and service schedule don’t justify. Do we really need a 14-16 knot service speed on a run with a 12 knot service schedule? How much fuel can we save by simply running vessels x, y, or z percent slower? For many mid-life vessels, this will provide a much better return than subjecting them to a major refit.
  Legislators should require WSF to conduct a survey to see where advantages of this sort will yield a better return prior to engaging in a $145 million capital effort. This type of analysis is currently being conducted by BC Ferries as part of their initial surveys for a fuel-source conversion16. In some cases the results of such analysis would require changes to existing service levels on a run, but that doesn’t mean that such changes aren’t a better approach, particularly considering the lack of dedicated funding that WSF faces. Often a change during non-peak service periods would make for a substantial reduction in fuel costs without impacting ferry riders to any appreciable degree-why don’t we run vessels slower after say 7 P.M.? Do we really need to maintain peak service speeds when the vessel is operating at less than 10% of its passenger capacity? This sort of analysis should be conducted as part of any such survey. Data on this degree of ridership already exists. Let’s make some constructive use of it prior to marching off to the shipyard to refit our most reliable vessels.

16 Bellaart, D. 11-2012 B.C. Ferries Looks For Ways to Slash Fuel Costs

Section 7- A Closer Look At The Numbers

  In reviewing the array of cost-benefit analyses used to justify this project, it becomes clear early on that the work done by the Cedar River Group stands head and shoulders above the rest. Their research is more thorough, their analysis more detailed, and their projections are based on planned WSF vessel deployments and input from industry-accepted experts on fuel price changes. In spite of this, even the analysis performed in their study fails to consider some very meaningful factors. Cost of Debt Service –This is a big item, and one which should be and must be included when trying to determine the true cost of any such project, whether it amounts to a refit of an existing vessel or an alteration to a design for a new vessel. Depending on the cost and term of the financing, this could easily double or triple the stated cost. A cost-benefit analysis which excludes this cannot be considered complete. Why this hasn’t been cited is a mystery, since it can be such a huge cost factor. Operational Costs-A business model should be drawn up which allows WSF to accurately estimate operational costs as discussed earlier in this report. These costs are direct and exclusive consequences of converting vessels to LNG as a fuel source. They should be included in any cost-benefit analysis which is developed to decide on such a conversion. Real World Engine Maintenance Costs and Life-Cycle Costs-What a sales rep tells in marketing efforts is one thing, but what you hear from other users is something entirely different. A meaningful life-cycle cost analysis should be conducted which includes an interview of other users to determine what common failure items and intervals are. This should be based on the delivered price for spares required to perform all recommended service evolutions. Critical and objective analysis is paramount here. Spare Parts Outfitting-This can be a big item, particularly for a model of engine which doesn’t benefit from a significant economy of scale. European engines commonly marketed as marine engines can have significant lead times which would drive the need for a very large spare parts inventory in order to maintain the existing fleet reliability standard. Spare parts outfitting should reflect the consumption seen by other operators attributable to commonly observed failure rates, not simply what the manufacturer recommends. Crew Training and Credentialing-The cost of training WSF personnel should be developed. This should include the labor for trainees. This cost is easily underestimated. It should be identified as an initial cost, plus a recurring cost to account for workforce attrition, and an additional recurring cost to account for credentialing renewal.

Implausible Fuel Price Estimates
  WSF justifies the RFP by claiming that it will reduce fuel expenses enough in the long term that it will eventually pay for itself. This claim is based on cost-benefit analyses in reports submitted by multiple parties, only one of whom doesn’t have a potential financial interest in the outcome of the project. This one report makes a point of recommending that a fuel contract be in hand prior to letting a construction contract.17 The RFP ignores this suggestion and ties the fuel contract in with other non-related elements.  Each of these analyses has a different price estimate for fuel-currently and in the future. None of them use an existing long-term fuel contract which is linked to spot market prices for an estimate.
  A long-term contract (10 years or more) would reduce (though not eliminate) the likelihood of a scenario where WSF gets hoisted over a barrel by signing a contract based on a short-term competitive price, only to see their financial position eroded when the fuel supplier leverages market conditions and contractual obligations when it comes time to renew. By this point the agency would be contractually bound to the project, and therefore the use of the new fuel. WSF would have no choice but to pay the price demanded by the sole provider. So much for saving money on fuel expenses-at least it sounded good in the beginning.
  One energy consulting firm cited in the CRG report (Poten and Partners) suggested that LNG suppliers would be likely to peg the price of their fuel to what WSF’s alternative would be (ultra-low sulfur diesel)18. Were this to happen, there would be no chance of ever recouping the cost of the conversion. In all reality, this is a less likely scenario than one in which the poor supply side market conditions simply drive a higher than estimated price for LNG, one which is still less than diesel, but too high to justify the cost of the project, even on the unrealistically rosy projections used to support it. The extremely limited supply creates a virtual monopoly for the fuel supplier, along with the pricing situation a monopoly brings.
  The final proposal recommended by WSF to the legislature will be the empirical test of whether or not these items are included in a cost-benefit analysis, and consequently, how well the conversion concept pencils out. However, the financial justification used thus far lacks these items, although they are specified to varying degrees in the RFP technical specifications. If a proper cost-benefit analysis is performed which incorporates these elements, there’s little chance the project will pencil out economically. This doesn’t mean that these items shouldn’t be considered. It means that legislators should make a point of seeing proposals objectively and think critically about whether or not the facts being presented by agency officials are accurate and complete.
  LNG is the fuel of the future. It will no doubt figure prominently in WSF’s future plans, but it doesn’t have to happen today. Nor should initial projections of savings stop decision makers from exercising fiscal prudence via a careful analysis of facts presented and a careful survey of what doesn’t get presented. Frequently the facts that don’t get told speak much more about the value of a project than those that do.

17 Cedar River Group/Boylston, John, Evaluating the Use of Liquefied Natural Gas in Washington State Ferries, 1-2012, pg. 58
18 Ibid, pg. 34

Section 8-Safety

  The most critically important performance metric WSF currently enjoys is the record of safety aboard its vessels. Maintaining this should be identified as top priority for any future engineering or operational decisions. If we can’t move people safely, then we shouldn’t continue to move them. There’s nothing in the current spec that provides for any redundancy to leak prevention or detection. Although the more sensational danger associated with using LNG as a fuel source is the risk of an explosion, the much more likely danger is asphyxiation due to a gas leak. Too much faith is placed in the reliability of electronic methane detection to the exclusion of everything else. A more meaningful level of assurance and redundancy is called for here. Leak detection is an inherently reactive safety measure. There’s no emphasis on leak prevention or consequence mitigation.
  While the methods of operators in Norway are often cited by WSF and design/consulting firms, the existing specification takes liberties with measures used there to ensure the safety of passengers and crew on their vessels. The current RFP is lacking here in that it fails to call for an intrinsically safe engine room protection system. Norwegian operators use this as part of an approach that combines the most secure aspects of both the emergency shutdown philosophy and the intrinsically safe philosophy. Their plants are configured with the double-wall gas piping (to the engine) of the intrinsically safe system and the explosion-proof motors of the emergency shutdown system. WSF should also follow this model. Double-wall gas piping addresses gas-fuel safety as a preventative measure, one which also provides a high level of consequence mitigation.
  Domestic gas distribution systems use chemical odorization to provide for a basic level of safety in the event of a gas leak. Although fuel in the liquefied state can’t be odorized, the fuel in the gas state can and should be. This is easily accomplished and quite affordable in the overall picture of an LNG fuel source installation. Chemical odorization provides a redundant level of leak detection. This increases the likelihood of early detection, thereby mitigating potential consequences.
  Shore-side gas distribution systems are distinguished from maritime systems by a few fundamental characteristics; There’s a vast infrastructure of regulatory language which governs shore-side gas installations of all types. In contrast, installations on passenger vessels are in their infancy. They are characterized first and foremost by the current lack of meaningful regulatory governance.
  Even a very minor gas leak on a vessel can have consequences far exceeding those which may occur ashore for a similar sized leak.
  With shore-side systems, when a leak is detected you can simply turn off the fuel and leave the premises until the gas has dissipated. Maritime systems lack this feature. You can’t simply walk away from a vessel which is away from the dock. Gas fuel dissipation rates vary depending on many factors, but in no case are they instantaneous. Personnel on board a vessel are a captive audience. In the event of a casualty, this trait can quickly compound any initial effect on vessel personnel or passengers, resulting in consequences much more severe than would be realized if the same type of scenario were to occur ashore.
  Ashore, when there is a problem, first responders are able to reach the accident and effect a response in short order. A vessel underway is remote and isolated. Even when help does arrive, they are hampered by the fact that they can’t remove affected personnel from the scene with the ease and expediency that they can when ashore. Again, this results in a compounding effect on the consequences of any sort of accident.
  These characteristics require responsible operators to take steps which may exceed the bare minimum required of them. For WSF this is even more the case due to the preventative and pro-active approach to safety as defined in their Subchapter W alternate compliance strategy. If WSF is to retain this compliance approach with new engineering systems, then they will need to demonstrate a meaningful organizational commitment to safety which would be seen by regulators as a template for others. Given the existing lack of regulatory guidance, WSF must be a role model in this area. Failure to do so will eventually result in an incident with severe casualties. The first time this happens, regulators will be under the gun to modify any existing regulatory language. Ultimately, compliance with this language will be very expensive and may impede continued use of a fuel source that capital improvements or contractual obligations would already in place for.
  Gas installations aboard a vessel should have double-wall gas piping to the engine and the fuel should be odorized at the point of conversion from liquid to gas.

Section 9-Conclusion

This RFP is the end result of a solution in search of a place to land.

  As is often the case, this doesn’t mean that the problem doesn’t exist (it does) or that the solution has no merit (it may have substantial merit if applied correctly). The problem with using this RFP as a solution to the situation it’s intended to address, is that somewhere along the way from the initial conception to advertising the RFP, the original objective went off the radar. The project took on a life of its own and we ended up with the present dilemma. What we now have is a gross distortion of what was once a great idea. The time has come for a course correction.
  Implementing the use of LNG as a fuel source is an idea whose time has come. Let’s make a point of doing so in a way that constructively contributes to the need to rein in rising fuel costs without jeopardizing the record WSF has established for safety and vessel reliability.
  The selection of the vessels to be converted should be re-visited. A meaningful and objective analysis should be performed which identifies where the greatest need is to control fuel cost growth. Options for controlling fuel consumption should be examined for service impact, economic benefit, and operational feasibility. If a fuel source conversion is found to be what would yield the greatest benefit, then it should be applied where and in a manner that maximizes its impact and minimizes its cost. A decision on how many vessels to convert should be based on this survey, weighed against the risk created by such a move, and balanced against the potential benefit. Risk mitigation measures should be considered and incorporated into a plan prior to delivering a final recommendation.
  Above all else, there should be no consideration given to the use of a gas-only engine until such time as a meaningful LNG supply infrastructure exists in the Puget Sound region. Even then such a selection should be carefully scrutinized for its performance characteristics and the degree to which they work within the constraints of existing operations.

Section 10-Recommendations

1. Require the use of a dual-fuel engine in any LNG installation aboard WSF vessels. A dual fuel engine will benefit from the existing diesel fuel systems on board the vessel which will be retained to supply the auxiliary generators and boiler. Early planning on the project provided for the use of dual-fuel engines, but the funding for this was written specifically for gas-only engines. As was mentioned earlier, no reason was provided for this. A single-fuel engine comes with a very significant handicap and should not be considered for use in WSF vessels.
  2. Convert a single vessel to LNG as a pilot program. This will create demand for the fuel type, which may provide an incentive for construction of an LNG liquefaction plant in the region. This allows a corresponding incremental ratcheting up of both infrastructure and demand. It will have the added benefit of allowing WSF to develop a better organizational understanding of the technology and make what operational and service changes are needed in advance of the construction and/or retrofit of future vessels. This is a particularly appropriate decision in light of the impending implementation of EPA Tier 4 emissions requirements in 2014. These regulations will require either exhaust aftertreatment or gas-fueled engines in future new construction.
  3. Participate in a public-private partnership to develop a liquefaction facility in the Puget Sound region. This would preferably be on the west side of the sound (to reduce the need to drive around via the Tacoma Narrows Bridge or book a charter on a ferry in order to support fuel deliveries). This PPP would be structured so that priority for the product is assigned to WSDOT or other state agencies.
  4. The Legislature should heed the recommendation19 of its consultant and have a fuel delivery contract in place and signed prior to signing a construction contract. This allows for a determination of the cost-effectiveness of a proposal. There’s no other meaningful way to accomplish this.
  5. Fuel contracts for LNG should be structured so that they reflect market rates. The Sumas spot hub price (or other standardized market price for the region) should be quoted, plus a margin that accounts for liquefaction and delivery. This would help ensure that the market rates quoted in financial justifications for the project are, to some degree, adhered to. Under this type of pricing system, WSF will avoid being the victim of opportunistic pricing schemes which take advantage of the poor market for fuel supply in the region.
  6. For construction and/or retrofit of LNG-fueled vessels utilize a more deliberate design and engineering approach. Start with a needs analysis which can define in explicit terms exactly what the ultimate objectives are for any engineering modifications. This will help to prevent project inertia from impacting the delivery of a meaningful resolution to the problem being addressed.
  Following a needs analysis should be a survey of the existing fleet status to determine where the best place to address the problem is. A market analysis should be conducted which surveys and reviews equipment available which can remedy the needs being addressed. A list of potential solutions is then drawn up based on the work completed at this point. The fiscal and operational impacts should then be analyzed to see if potential engineering modifications present an advantage over non-engineered solutions. If so, than the project should proceed to development of an RFP or IFB.
  Nothing about this approach is novel in the field of design/engineering. That being said, it all bears repeating in light of the degree to which the existing RFP has gone so far off course from the meaningful and effective solution to the problem that it was intended to be.
  7. Safety is paramount. There’s no justification for implementing the new fuel source absent the ability to ensure the safety of people aboard the vessels. The new fuel distribution should utilize the double-wall piping of an intrinsically safe system, and the fuel should be odorized when gasified.

19 Cedar River Group, Boylston, John, Evaluating the Use of Liquefied Natural Gas in Wash. State Ferries, 1-2012, pg. 58


Bellaart, D. (2012, November 9). B.C. Ferries Looks For Ways To Slash Fuel Costs. Retrieved November 15, 2012, from
Bennion, M. D. (June 2010). A Comparison of Operational Performance: Washington Sate Ferries to Ferry Operators Worldwide. WSDOT Office of Research and Library Services.
Cedar River Group, Boylston, John. (Jan-2012). Evaluating the Use of Liquified Natural Gas in Washington State Ferries.
Hernandez, J. (2012, October 29). Wartsila protest. Letter of protest to WSF . Schwabe, Williamson, and Wyatt.
lng-bunkers-offer-greatest-potential-for-costs-compliance. (2012, November 13). Retrieved November 15, 2012, from
The Glosten Associates. (Jul-2011). 144-Car Ferry LNG Fuel Conversion Feasibility Study-Design Report.
The Glosten Associates. (Jul-2011). 144-Car Ferry LNG Fuel Conversion Feasibility Study-Life Cycle Cost Analysis.
The Glosten Associates. (Mar-2010). LNG Use for Washington State Ferries.
Washington State Ferries. (Aug-2012). Concept of Operations (CONOPS).
Washington State Senate Transportation Committee. (Apr-2012). Technical Ammendments to Seante Bill 5992.

The author;
This report has been prepared by Alex Zecha. Alex works for the Washington State Ferries as Chief Engineer aboard the M/V Evergreen State. Prior to working as a Chief Engineer, he was a Port Engineer for Washington State Ferries. In this capacity he was responsible for the engine department training program, engine room operations and all vessel maintenance planning for the nine largest vessels in the WSF fleet.
Alex has worked in the maritime industry for 29 years.
He can be reached by e-mail at