Audible response

Port Denmark's consultation response regarding the implementation of the Electricity Market Directive etc. - amendment of the Electricity Supply Act, the Gas Supply Act and the Criminal Code

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

Danish Ports has a particular interest in the part of the bill that describes a new opportunity to share consumers' surplus energy from a renewable energy plant that they do not consume themselves. "This is done specifically through the right to several electricity agreements under the same purchase number, a framework for the use of flexible grid connection agreements and the possibility of energy sharing".

• Danish commercial ports are not explicitly mentioned in the bill, so Danish Ports urges that it is actively ensured that these new opportunities also apply to commercial ports. This should be ensured both in the bill and in the subsequent implementing executive orders.
• At several commercial ports there is/is expected to be a local shortage of electricity to implement 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 at the port areas as possible, including solar energy. This can relieve the electricity grid in the surrounding area, and the commercial port can contribute to the goal of quadrupling RE production on land.
• The installation of solar panels on suitable roof areas in commercial ports and dry ports does not affect the limited commercial areas in the ports. However, it should also be possible to temporarily install solar panels on areas of the port that need to "settle" in connection with backfilling or similar and are therefore not part of ordinary port operations.
  
  Kind regards,
  Camilla Rosenhagen