Mr. Matthew Anderson
16420 Park Ten Place
Houston, TX 77084
RE: The tariff classification of a floating storage re-gasification unit from South Korea
Dear Mr. Anderson:
In your letter dated July 7, 2007, on behalf of Broadwater Energy LLC, you requested a tariff classification ruling. You submitted a drawing with your request.
Broadwater plans to build and install a floating facility moored in the Long Island Sound to receive imports of liquefied natural gas (LNG). LNG is natural gas that has been cooled so that it becomes a liquid that can be economically shipped throughout the world in specially designed ships.
Physically, the subject merchandise would consist of a ship-like vessel moored in Long Island Sound. The vessel, known as a Floating Storage Re-gasification Unit, or FSRU, would be about 1,200 feet long and 180 feet wide and would rise about 75 to 80 feet above the water. LNG carriers will unload their cargo to the FSRU. The Broadwater FSRU's proposed location is at the widest point of the Sound and would connect with the existing sub-sea Iroquois Gas Transmission system pipeline via an underwater connecting pipeline that would be about 22 miles long.
The FSRU will contain the necessary equipment to receive, store and re-gasify the LNG and then pump the resulting gas into a pipeline system. The entire vessel, comprised of the top side, hull, LNG containment system consisting of 8 storage tanks, thrusters, nitrogen injection system, heat exchangers, generators, pumps, meters, control room, living quarters and more will be constructed and tested in South Korea. Upon completion of the testing the FSRU, which is not self-propelled, will be towed to the United States as one complete unit. Upon importation the FSRU will be connected to a Yoke Mooring System (YMS) and the Iroquois pipeline system. Once its location is fixed the FSRU will be capable of rotating 360 degrees around the YMS. The FSRU’s 2 thrusters are intended to assist the FSRU’s station-keeping and facilitate offloading LNG carrier berthing operations
Every two to three days, the FSRU would receive LNG shipments from ocean-going carriers that would enter the Sound and offload their cargo. The LNG would be stored in tanks in the hull of the FSRU. The LNG would be warmed back into a gas (re-gasified) so the natural gas can be delivered to the New York and Connecticut markets through the existing Iroquois pipeline.
The applicable subheading for the FSRU will be 8905.90.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for light-vessels, fire-boats, dredgers, floating cranes, and other vessels the navigability of which is subsidiary to their main function. The rate of duty will be Free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Patrick Wholey at 646-733-3013.
Robert B. Swierupski