Audible response
Danish Ports' consultation response to supplementary consultation on draft bill on infrastructure for alternative fuels for transport (AFI Act)
Danish Ports thanks for the opportunity to provide a consultation response to the supplementary consultation on the draft bill for a new AFI Act.
General remarks
- It needs to be clearer which ports fall under which regulations
- Shore power must either be explicitly addressed in the bill or alternatively taken out to create clear framework conditions for ports
Ad. 1: Danske Havne reads the draft law in such a way that §3 covers wholly municipally owned ports organized as autonomous ports or municipal limited company ports, while §§4-6 apply to ports organized as municipal ports and §60 ports. However, it should be made clearer which ports fall under which provisions.
Re. 2: The focus of the Act seems to be on charging stations for cars. However, it appears that the Act, cf. §1, also applies to "Power supply from land to vessels" and, according to the definition in §2, paragraph 6 "... Power supply from land to seagoing ships ...", in other words, what is called shore power.
Besides 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 the port's land and what circumstances apply to shore power. It is also unclear whether shore power in self-government ports or municipally owned limited company ports is covered by §5-6 and the possibility for the municipality and the regional council to make payments to the operator of the charging station in connection with establishment.
Danish Ports urges that shore power is either explicitly addressed in the bill or that it is alternatively removed to create clear framework conditions for the ports.
Elaborating remarks
It is noted that the green transition plays a major role in the Danish commercial ports, and that a green energy supply for shipping is particularly important. Danish Ports' green vision is, among other things, that by 2030 at the latest, ports will have the possibility of green connection of ships at the jetty. Shore power is an essential element that many ports are looking into establishing, despite the fact that it is difficult to see how the large cost of establishing shore power will be recouped. Danish commercial ports have a special role in this regard, as ports are heavy infrastructure of critical importance to society for the transportation of goods and passengers. In 2020, 23,150 cargo ships and 59,279 fishing vessels called at Danish ports. Cargo turnover was 91,270 thousand tons, of which 81% was international cargo and 19% domestic cargo. In addition, Danish ports received 500,401 passenger ships and ferries in 2020, of which 82% were on domestic routes and 18% 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 it, at the ports in order to ensure a green energy supply for maritime transport, both nationally and internationally.
Sincerely yours,
Karina Lyngbak Sørensen
Business Policy Consultant
Danish Ports
