Consultation Responses

Danish Ports’ Response to the Public Consultation on the Implementation of the Electricity Market Directive, etc. – Amendments to the Electricity Supply Act, the Gas Supply Act, and the Criminal Code

Danish Ports acknowledges the opportunity to submit comments on the public consultation regarding the implementation of the Electricity Market Directive, etc.—amendments to the Electricity Supply Act, the Gas Supply Act, and the Criminal Code.

Danish Ports has a particular interest in the section of the bill that describes a new option for sharing consumers’ surplus energy from a renewable energy facility that they do not consume themselves. “Specifically, this is achieved through the right to multiple electricity contracts under the same customer number, frameworks for the use of flexible grid connection agreements, and the option for energy sharing.”

• Danish commercial ports are not explicitly mentioned in the bill, so Danske Havne urges that active steps be taken to ensure that these new opportunities also apply to commercial ports. This should be ensured both in the bill and in the subsequent implementing regulations.
• At several commercial ports, there is—or is expected to be—a local shortage of electricity needed to carry out a full green transition, and it is important that the bill and related legislation make it attractive to produce and share as much green electricity as possible within port areas, including solar energy. This will relieve pressure on the power grid in the surrounding area, and the commercial port can contribute to the goal of quadrupling onshore renewable energy production.
• Installing solar panel systems on suitable roof areas at commercial ports and dry ports does not affect the limited commercial space available at the ports. However, it should also be possible to install solar panels temporarily on areas of the port that, for example, need to “settle” in connection with landfilling or similar activities and are therefore not part of regular port operations.
  
  Sincerely,
  Camilla Rosenhagen