Audible response
Danish Ports' consultation response to the EU Commission's proposal for Alternative Fuels Infrastructure Regulation
Danish Ports welcomes the Fitfor55 package. We support the sustainable development, where Europe from 2050 must be climate neutral. This means, among other things, a 90% reduction in transport emissions. Of course, shipping must also contribute to this. This means that requirements must be set for ships' emissions, but also that in many places it must be possible to get shore power when the ships are docked.
Danish Ports' overall comments on the "Fitfor55 package", especially the proposal for Alternative Fuels Infrastructure Regulation (AFIR).
- It is very important that the different legislative packages under Fitfor55 are aligned, as they are interlinked
. - It is important to focus on the goal of greenhouse gas reduction and a technology
neutral solution. There is no "one size fits all" solution. Different ports and different ships should be able to use different solutions to achieve the EU targets. - Danish Ports fully supports more onshore power supply (OPS) where it makes sense; it must be a cost-effective reduction of emissions.
- It is important to focus on the competitiveness of port and shipping in DK/EU in relation to countries outside the EU.
- It is important that the fitfor55 package does not create large administrative burdens for ports, so that ports are not burdened with complicated climate calculations on behalf of the shipping sector.
- It is important that there are grant and funding opportunities to expand the infrastructure for alternative fuels. This applies to hydrogen, ammonium and other possible fuels, but also shore power for ships. This applies not only to ports in the TEN-T network (comprehensive and core ports), but also equally importantly to ports outside the network. These ports currently find it very difficult to apply for EU subsidies.
- It is also important that support for shore power is available for more than just ferries, cruises and container ships. A number of offshore service vessels for e.g. wind energy, construction and bridge building ships, oil drilling rigs can also benefit from being supplied with shore power. These ships use large amounts of energy when calling at ports. They may not come very often, but they typically stay in port for a long time and can also benefit from shore power when they are in port.
Specifically about the Commission's proposal for AFIR
The proposals state the following in relation to the establishment/connection to shore power - applies to ports on the TEN-T network (comprehensive and core ports) and for ships over 5000 gross tons from 2030:
1 ) Ports served by a minimum of 50 container ships per year (average over 3 years) must
be able to supply at least 90% of the ships' energy needs with shore power when at
berth. Similarly, container ships calling at TEN-T ports must be able to receive
shore power (or have another 0 emission solution while in port).
DH comment: This will have major consequences for a number of Danish core and comprehensive ports. CMP (Port of Copenhagen and Malmö), Port of Aarhus, Aalborg, ADP (Port of Fredericia and Nyborg) and Kalundborg are ports that will have to make major investments before 2030 in order to supply container ships with shore power. It is therefore important that there are opportunities for public support for the establishment of shore power for these ports.
For container ports outside the TEN-T network, such as Skagen, there is no requirement to establish/receive shore power. There are also not many support options today, which can make it very expensive for ports to establish shore power. Ultimately, this could mean that "green ships" sail to ports with shore power, while ships that do not want to receive shore power can sail outside the TEN-T network.
Danish Ports therefore believes that ports outside the TEN-T network should have greater opportunities to apply for funding for "green solutions" such as shore power.
2 ) Ports visited by at least 40 Ro/Ro ships or passenger ships (ferries) per year (average over 3 years) must be able to supply at least 90% of the ships' energy needs with shore power when docked. Similarly, Ro/Ro ships calling at TEN-T ports must be able to receive shore power (or have a 0 emission solution while in port).
DH comment: This will have major consequences for a number of core and comprehensive ports. CMP, Port of Aarhus, Port of Esbjerg, Port of Rønne, Port of Hirtshals, Port of Frederikshavn, Port of Kalundborg and Køge are ports that will have to make major investments before 2030 in order to supply ro-ro passenger ships with shore power. It is therefore important that there are opportunities for support for the establishment of shore power for these ports.
For RoRo passenger ships outside the TEN-T network, such as the Port of Grenå, there is no requirement to establish/receive shore power. There are also not many support options today, which can make it very expensive for ports to establish shore power.
Danish Ports therefore believes that ports outside the TEN-T network should have greater opportunities to apply for funding for "green solutions" such as shore power.
3 ) Ports visited by a minimum of 25 passenger ships per year (not Ro/ro, but e.g. cruise ships - average over 3 years) must be able to supply at least 90% of the ships' energy needs with shore power when docked. Similarly, ships calling at TEN-T ports must be able to receive shore power (or have a 0 emission solution while in port).
DH comment: This will immediately have major consequences for a number of core and comprehensive ports. CMP, Port of Aarhus, Port of Aalborg, Port of Rønne and ADP are ports that will have to make major investments before 2030 in order to supply cruise ships with shore power. Shore power for cruise ships is currently very expensive to establish. It is therefore important that there are opportunities for support for the establishment of shore power for these ports.
For cruise ports outside the TEN-T network, such as the Port of Skagen, there are no requirements for establishing/receiving shore power. There are also not many support options today, which can make it very expensive for ports to establish shore power.
Danish Ports therefore believes that ports outside the TEN-T network should have greater opportunities to apply for funding for "green solutions" such as shore power.
It should be noted that ships at berth for less than 2 hours are not covered by the requirements for shore power, and the same applies to zero emission ships and ships at berth for safety reasons. Danish Ports agrees that there should be such exceptions to the requirements.
LNG infrastructure
In relation to LNG, Danish Ports is satisfied that no further measures are planned to promote LNG, cf. Article 11, as we believe that LNG is only a transitional fuel. According to the provision, Member States must continue to ensure that there is "sufficient" infrastructure to refuel LNG.
Danish Ports believes that there is a very small market for LNG today and that it is important that any LNG infrastructure is only established where it makes sense and that it is up to the market to decide whether LNG bunkering should be possible in a Danish port.
It's important to remember that LNG bunkering can also be done from ship to ship, so you don't necessarily have to go to port to refuel LNG.
Sincerely yours
Danish Ports
Kasper Ullum