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 sustainable development, where Europe must be climate neutral from 2050. 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 there must be the possibility of getting shore power in many places when the ships are at berth.

Ports of Denmark's general comments on the "Fitfor55 package", including in particular 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 that there is a focus on the goal of reducing greenhouse gases 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's objectives.
  • 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 there is a possibility of supporting shore power for other than ferries, cruise ships and container ships. A number of offshore service vessels for e.g. wind energy, construction and bridge building vessels, oil drilling rigs can also be supplied with shore power. These ships use large amounts of energy when calling at port. They may not come that often, but are typically at anchor for a long time and can also use shore power when they are in port to their advantage.

Special on the Commission's proposal for AFIR
The proposals state the following in relation to the establishment/connection to shore power - applicable to ports on the TEN-T network (comprehensive and core ports) and for ships over 5,000 gross tons from 2030:

1) Ports that are visited 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 they are at anchor
quay. Similarly, container ships calling at TEN-T ports must be able to receive
shore power (or could have another 0 emission solution while in port).

DH note: This will have immediate major consequences for a number of Danish core and comprehensive ports. CMP (Copenhagen and Malmö ports), Aarhus port, Aalborg, ADP (Fredericia and Nyborg ports) and Kalundborg are ports that will immediately have to make major investments before 2030 in order to be able 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 mean that it will be very expensive for the ports to establish shore power. This can ultimately mean that “green ships” sail to ports with shore power, while ships that do not wish 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 opportunity to seek support for "green solutions" such as shore power.

2) Ports that receive a minimum of 40 Ro/ro ships or passenger ships (ferries) per year (average over 3 years) must be able to supply a minimum of 90% of the ships' energy needs with shore-side power when they are at berth. Similarly, Ro/ro ships calling at TEN-T ports must be able to receive shore-side power (or have a zero-emission solution while in port).

DH comment : This will have immediate major consequences for a number of core and comprehensive ports. CMP, Aarhus Port, Esbjerg Port, Rønne Port, Hirtshals Port, Frederikshavn Port, Kalundborg Port and Køge are ports that will immediately have to make major investments before 2030 in order to be able 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 Ro/ro 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 mean that it will be very expensive for the ports to establish shore power.

Danish Ports therefore believes that ports outside the TEN-T network should have greater opportunity to seek support for "green solutions" such as shore power.

3) Ports that are visited by at least 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 they are at berth. 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 have immediate major consequences for a number of core and comprehensive ports. CMP, Aarhus Port, Aalborg Port, Rønne Port and ADP are ports that will immediately have to make major investments before 2030 to be able to supply cruise ships with shore power. Shore power for cruises 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 is no requirement to establish/receive shore power. There are also not many support options today, which can mean that it will be very expensive for the ports to establish shore power.

Danish Ports therefore believes that ports outside the TEN-T network should have greater opportunity to seek support for "green solutions" such as shore power.

It should be noted that ships that are berthed for less than 2 hours are not covered by the shore power requirements, the same applies to zero emission ships and ships that are berthed for safety reasons. Ports of Denmark agrees that there should be such exceptions to the requirements.

LNG infrastructure

In relation to LNG, Danske Havne 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 for refuelling 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 if there should be a possibility for LNG bunkering in a Danish port.

It is important to remember that LNG bunkering can also take place from ship to ship, so you do not necessarily have to go to port to refuel LNG.

Sincerely yours

Danish Ports

Kasper Ullum