Audible response

Danish Ports' consultation response regarding the law on implementation of VE III and green transport measures

Danish Ports acknowledges the opportunity to submit comments on the proposal for a law on the implementation of VE III and green transport measures. Danish Ports are generally positive about the new improved framework for the green transition in the maritime sector.

General remarks

• In general, Danish Ports recommends that this law offensively ensures sufficient and sufficiently spacious legal framework for the green transition to be implemented quickly and efficiently, and that Danish
  implementation and legislation do not put Danish companies and commercial ports at a disadvantage compared to our neighboring countries, where we often see higher levels of support.
• Positive Danish incentives are welcomed. Danish Ports agree that it is appropriate to insert a broad authorization in the law that could be used to implement any other future political initiatives aimed at promoting green fuels in the transport sector on land and at sea, and to reduce the derived climate effects of fuels in the transport sector. Danish Ports supports the introduction of a legal basis that takes into account any future and as yet undecided political wishes and agreements on support targeted at promoting these areas.
• The bill contains a legal basis to provide support for green aviation. In this context, it is important to include the necessary associated infrastructure, such as space at Copenhagen Malmö Port, Prøvestenen, and their facilities for piping fuel to the airport. The facilities can also include the supply of green aviation fuels.
• The scope of the Biofuels Act is extended to include aviation and maritime transport. This requires careful consideration to achieve good implementation and avoid sub-optimization in favor of certain types of "old-fashioned" biofuels at the expense of more sustainable green e-fuels, for example.
• In the event of extended nationally determined requirements for the installation/use of shore power for ships, in addition to the common obligations in the AFIR regulation /FuelEU Maritime, it is important that any new obligations for Danish commercial ports do not negatively affect Danish competitiveness compared to other ports in the Northern European region. On the contrary, it should be seen as an investment and benefit for the port's customers and neighbors, and a contribution to the spread of green transport chains.

Sincerely,
Camilla Rosenhagen