Audible response

Danish Ports' consultation response regarding "Availability of electricity and green fuels in ports". Appendix to the Danish Transport Authority's port atlas

Danske Havne acknowledges the opportunity to submit comments on the draft of the Port Atlas Energy Annex.

General remarks

The energy annex bears the hallmarks of thorough and systematic work. It is good that the appendix focuses on this important area as a starting point for further electrification and green conversion of commercial ports and the ships that call at them.

The use of available factual information, statistics, counts of ships and interviews with the ports is seen as a strength. Overall, it is a useful appendix in relation to the future dialog on the construction of shore power plants in Danish commercial ports. The appendix shows a snapshot.

  • Several members have stated to Danske Havne that the specific offers they have received from companies regarding the possible establishment of a shore power plant at the port are well above the prices stated in the annex.
  • This may be because the grid connection fee is not included in the prices. The fee is determined by the grid company, but can make up a very significant part of the total cost of the installation. It should be made clearer that the grid connection fee must be added on top, and examples should be given of its size. The size of the grid connection fee was an obstacle for the shore power plant in the Port of Skagen, which supplies the large fishing vessels. Here, the project design was changed, as the cost of grid connection would otherwise destroy the possibilities of building the plant.
  • In other selected areas, the government steps in and actively decides on the size of the grid connection. This 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 both in relation to AFIR requirements and other electrification of the shipping sector at the port quay. AFIR requirements and other electrification of the shipping sector at the port quay.
  • At the same time, electrification of the port's other operations and the other companies at the port is taking place. The overall electricity supply at the port must take this into account. This is not explicitly included in the energy chapter now. The inclusion of some concrete examples in the appendix can show the importance of this parallel need. Several commercial ports are already experiencing this problem now, and it is important that Energinet and the electricity distribution companies get as good a starting point for proactive planning and expansion as possible.
  • It would be interesting if the energy appendix in one section took a more analytical and cross-cutting look at the needs and opportunities for using batteries and other alternative storage as part of the port's supply of shore power and other electricity services to companies, activities at the ports, and possibly relieving power peaks in urban areas. This is only briefly mentioned in the appendix.
  • Locally produced RE in and around the port area can supplement the supply directly, and will be particularly valuable in the "red areas" where the energy supply is already strained. It would be interesting if the energy layer provides some scenarios/examples of this.
  • It is defined as outside the scope of the task defined in the annex, but what happens when the ships want more electricity, but what just covers the need while they are in port? It would be highly relevant to put this into perspective, as Port Denmark and other experts believe that this will happen in parallel with the expansion of shore power systems over the next 10 years. Shore power is in many ways an attractive and competitive alternative to other green e-fuels. Ship owners with ships in the European area will have to optimize both in relation to EU ETS, requirements for clean fuels, less noise, customers' wishes for green logistics chains, etc. All of this is pulling in the direction of increased demand for shore power, also from non-electric ships.
  • The shore power part of the AFIR regulation and EU FuelMaritime will be revisited in the EU as early as 2026 for a possible tightening of the rules. a possible tightening of the rules. It would be relevant if the port atlas were to state that the energy layer will be updated in, say, three years, as developments in this area are moving relatively quickly.

Specific comments

Charts of demand and demand for electricity in each port:

In relation to the content of the individual port forms, please refer to the individual ports' consultation responses. The individual ports quality control their "own" form.

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

Even if power is available at the port area, it may be more than a kilometer away from where the shore power installation will be built. This will result in a significant additional cost. Therefore, it is relevant that the distance to the grid connection point is indicated in the diagrams.

An inconsistency is noted in the texts under "activity, e.g. regardingCO2 and offshore vessels:

CO2: All ports must transition to CO2-neutral operations over time, and in Danish Ports we have a common goal and an expectation that this will be supported by the government.

For some ports this is mentioned as a strategic goal, such as the Port of Odense, and for others it is not. Does the goal have to have a certain binding character 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 for the Port of Køge, but this is not mentioned for Grenå and Hvide Sande.

E-fuels. It is relevant that the form states whether there is space for e-fuels storage at the port. However, it will rarely be a yes/no answer. It will depend on quantities, types and possible expansion of a pier, etc. The smaller the distance, the greater the amount of safety elements so that the storage is fully safe at all times. It will depend on a specific assessment and possible adaptation.

Page 4 bottom paragraph: It states that the bunker infrastructure is not expected to change in relation to the location of the new e-fuels. Is it not likely that new ports may be added? For example, the Port of Aabenraa because of Kassø. Then the paragraph is a little too "tight" in the wording.

Sincerely yours,

Camilla Rosenhagen