Consultation Responses
Danish Ports’ Response to the Supplemental Public Comment Period on the Draft Bill on Infrastructure for Alternative Fuels for Transportation (the AFI Act)
Danish Ports would like to express its gratitude for the opportunity to submit comments on the supplemental public consultation regarding the draft bill for a new AFI Act.
General Remarks
- It needs to be clearer which ports are subject to which regulations
- Shore power must either be explicitly addressed in the bill or, alternatively, removed from it in order to establish a clear regulatory framework for the ports
Re. 1: Danske Havne interprets the draft bill such that Section 3 covers ports wholly owned by municipalities and organized as self-governing ports or municipal joint-stock companies, while Sections 4–6 apply to ports organized as municipal ports and Section 60 applies to ports. However, it should be made clearer which ports fall under which provisions.
Re. 2: The law appears to focus on charging stations for cars. However, it is clear that, pursuant to Section 1, the law also applies to “power supply from shore to vessels” and, pursuant to the definition in Section 2(6), “… power supply from shore to seagoing vessels …”—in other words, what is commonly referred to as shore power.
In addition to the fact that shore power is presumed to be covered by Section 3—and that agreements must therefore be entered into on market terms—it is unclear what other terms apply to installation on port premises and what conditions apply to shore power. In particular, it is unclear whether shore power in self-governing ports or municipally owned joint-stock company ports is covered by Sections 5–6 and whether the municipality and the regional council may provide payment to the operator of the charging station in connection with its installation.
Danish Ports is calling for shore power to be either explicitly addressed in the bill or, alternatively, removed from it, in order to establish clear framework conditions for the ports.
Further comments
It should be noted that the green transition plays a major role in Danish commercial ports, and that a green energy supply for shipping, in particular, is of great importance. Ports of Denmark’s green vision includes, among other things, ensuring that by 2030 at the latest, ports will be able to provide green power connections for ships at the berths. Shore power is a key element in this regard, and many ports are exploring its implementation, despite the fact that it is difficult to see how the substantial cost of establishing shore power will pay for itself. Danish commercial ports play a special role in this context, as they constitute heavy infrastructure of critical importance to society for the transport of cargo and passengers. In 2020, Danish ports handled 23,150 cargo ships and 59,279 fishing vessels. Cargo throughput totaled 91,270 thousand metric tons, of which 81 percent was international cargo and 19 percent was domestic cargo. In addition, Danish ports received 500,401 passenger ships and ferries in 2020, of which 82 percent were on domestic routes and 18 percent on international routes. These figures serve to illustrate how important it is to have clear framework conditions for the establishment of shore power, as well as support for this, at the ports in order to ensure a green energy supply for maritime transport, both nationally and internationally.
Sincerely,
Karina Lyngbak Sørensen
Business Policy Consultant
Danish Ports
