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Consultation Responses

Danish Ports’ consultation response regarding “Availability of Electricity and Green Fuels in Ports.” Appendix to the Danish Transport Authority’s Port Atlas

Danish Ports acknowledges the opportunity to submit comments on the draft energy appendix to the Port Atlas.

General Remarks

The Energy Annex reflects a thorough and systematic approach. It is encouraging that the Annex highlights this important area as a foundation for further electrification and the green transition of commercial ports and the ships that dock there.

It is considered a strength that the report draws on readily available factual information, statistics, counts of, for example, ships, and interviews with the ports. Overall, it is a useful appendix in relation to the future dialogue on the construction of shore power facilities in Danish commercial ports. The appendix provides a snapshot of the current situation.

  • Several members have informed Danske Havne that the specific offers they have received from companies regarding the possible installation of a shore power facility at the port are significantly higher than the prices listed in the appendix.
  • One reason for this may be that the grid connection fee is not included in the prices. The fee is set specifically by the grid operator, but can account for a very significant portion of the total cost of the facility. It should be made clearer that the grid connection fee must be added on top, and examples of the fee’s magnitude should be provided. At the shore power facility located in Skagen Harbor that supplies large fishing vessels, the amount of the grid connection fee was an obstacle. In this case, the project design was modified because the cost of grid connection would otherwise have made it impossible to build the facility.
  • In other selected areas, the government intervenes and actively determines the size of the grid connection. This approach could also be considered in this important area to ensure faster implementation.
  • It is good that the appendix provides an estimate of the need for shore power at the dock, both in relation to AFIR requirements and the broader electrification of the shipping sector.
  • At the same time, the rest of the port’s operations and the other businesses at the port are being electrified. The port’s overall electricity supply must take this into account. This is not explicitly included in the energy chapter at this time. Including some specific hypothetical examples in the appendix can illustrate the significance of this parallel need. Several commercial ports are already facing this issue, and it is important that Energinet and the electricity distribution companies have as solid a foundation as possible for proactive planning and expansion.
  • It would be interesting if the energy appendix were to take a more analytical and cross-cutting look at the needs and opportunities for using batteries and other alternative storage solutions as part of the port’s provision of shore power and other electrical services to businesses, port operations, and, potentially, the mitigation of power peaks in urban areas. The appendix only mentions this briefly.
  • Locally produced renewable energy in and around the port area can directly supplement the energy supply and will be particularly valuable in the “red zones,” where the energy supply is already strained. It would be interesting if the energy appendix provided some scenarios or examples of this.
  • This is defined as falling outside the scope of the task outlined in the appendix, but what happens when ships want more electricity than is needed to simply cover their needs while they are in port? It would be highly relevant to put this into perspective, as it is the assessment of Danske Havne and other experts that this will occur in parallel with the expansion of shore power facilities over the next 10 years. Shore power is, in many ways, an attractive and competitive alternative to other green e-fuels. Shipowners with vessels in the European region will need to optimize their operations in light of the EU ETS, requirements for clean fuels, reduced noise, customer demands for green logistics chains, and so on. All of this points toward increased demand for shore power, even from non-electric ships.
  • The section of the AFIR Regulation concerning shore power and the EU FuelMaritime initiative is scheduled to be reviewed by the EU as early as 2026 with a view to potentially tightening the rules. It would be appropriate to specify in the Port Atlas that the energy annex will be updated in, for example, three years, as developments in this area are progressing relatively quickly.

Specific comments

Tables showing electricity supply and demand at each port:

With regard to the content of the individual port forms, please refer to the consultation responses from the individual ports. Each port conducts quality control on its “own” form.

The prices in the tables are theoretical minimum prices, as connection fees are not included.

Although power is available in the port area, it may be more than a kilometer away from where the shore power facility is to be built. This would result in significant additional costs. Therefore, it is important that the distance to the grid connection point be specified in the forms.

There is an inconsistency in the text under “activity,” for example regardingCO2 and offshore vessels:

CO2: All ports must transition to CO2-neutral operations over time, and at Danske Havne, we share a common goal in this regard and expect support from the government.

For some ports, this is mentioned as a strategic goal—for example, the Port of Odense—while for others it is not. Does the goal need to be somewhat binding in order to be mentioned, and if so, how is this defined?

Shore power and offshore. For example, the text mentions a possible desire for shore power for offshore vessels at the Port of Køge, but makes no mention of this for Grenå and Hvide Sande, for example.

E-fuels. It is important to indicate in the form whether the port has space for e-fuel storage. However, this will rarely be a simple yes or no answer. It will depend on quantities, types, and any potential expansion of a pier, etc. The shorter the distance, the greater the number of safety measures required, so that storage remains fully safe at all times. This will depend on a specific assessment and possible adjustments.

Page 4, bottom paragraph: It states here that the bunker infrastructure is not expected to change with regard to the location of the new e-fuels. Isn’t it likely that new ports could be added? For example, the Port of Aabenraa due to Kassø. In that case, the wording of the paragraph is a bit too “restrictive.”

Sincerely,

Camilla Rosenhagen