Branded case
Environment
Danish Ports works to solve environmental challenges in port operations such as odor, noise, smoke, water environment and waste, so that the best solutions are found based on the environment, economy and across borders. Danish Ports cannot solve the challenges alone, which is why Danish Ports also works with international environmental initiatives.
To ensure a clean port environment, we at Danish Ports therefore closely follow investigations of pollution from open scrubbers to ensure that water/sediments are not unnecessarily affected in the ports. Danish Ports works to reduce plastic in the ports/ports, we therefore participate in the Ocean Plastic Forum and collaborate with ports and environmental authorities to increase waste recycling.
The environmental impact of shipping is generally less compared to other modes of transportation, but with the help of cleaner technologies and better regulations, it can be made even better.
Danish Ports is therefore following the technological development of new and cleaner forms of energy, including shore power, but also the development of Power2X (hydrogen and ammonium are produced using surplus electricity).
We see ports as having a major role in a more sustainable transition.
Scrubbers
Background
On July 1, 2010, the revised Annex VI to MARPOL came into force, introducing stricter sulfur limits for marine fuels in the North Sea and the Baltic Sea. To comply with the requirements, many ships choose to clean the exhaust gases with open scrubbers that discharge the cleaning water into the sea.
A number of studies do not contribute to further clarity on the extent to which discharged wastewater from open scrubbers pollutes ports, but nevertheless, a number of ports in Germany and elsewhere have banned the discharge of wastewater into harbors.
The EU has pointed out to the IMO that the current guidelines do not regulate discharges in specific areas, including ecologically sensitive areas such as harbors where water flow is not very high, so it is expected that there will be a tightening of the IMO regulations in 2021.
Danish Ports Position
The studies to date on contamination from open scrubbers cannot definitively refute that there may be microorganisms affected by contamination from open scrubbers.
Danish Ports welcomes the further investigation of pollution from open scrubbers and the development of common international rules and guidelines.
Until definitive studies are available that refute the possibility of pollution from open scrubbers in ports and until common rules and guidance on the use of open scrubbers in ports are issued internationally, ports should be able to decide to prohibit the use of open scrubbers in the port on a precautionary basis.
Shore power
Background
Danish ports currently offer shore power, which primarily covers the energy needs of smaller ships, but with the ongoing green transition, the need for shore power (and energy supply) in ports will increase, making it necessary to expand the current capacity.
Today, shore-side electricity is tax-exempt until June 18, 2021. Similarly, ship fuel is also tax-exempt.
In the new Green Deal from the EU, there are plans for ships to be supplied with shore power when docked, which is also part of the climate partnerships.
Therefore, the following position on the role and challenges of ports in this development is proposed.
Financing
- The financing of large shore power facilities is a major challenge for Danish ports. Large facilities that will be used for cruise ships and/or other larger ships require large investments. This can be in terms of infrastructure, new power supply to the port and converters so that the port can accommodate both 50 and 60 Hz ships. In addition, cruise facilities are only used during the summer months and the amount of ships can vary from year to year.
- To promote the development of shore power, funding from the EU/state/municipalities is therefore necessary - a development that is also seen in our neighboring countries.
- The area is not economically interesting for private players and thus not open to competition, which is why subsidies can be granted from the EU/state/municipality. A scheme that has been used to promote wind energy, for example.
Legislation
- Danish Ports does not consider that there are any regulatory obstacles to ports being able to provide electricity to ships in port, make related investments and generate profits from these activities. Neither in relation to the Ports Act nor the Ports Ordinance, which makes it clear that TEN-T ports can offer bunkering (i.e. shore power) to ships.
- Danish Ports supports the introduction of EU rules on mandatory connection to shore power in ports that have invested in shore power and where it is technically/practically possible.
- Danske Havne, on the other hand, does not want all ports to be required to install shore power for all ships calling at the port. Shore power can be very expensive to install - e.g. for small ports with few ship calls. Similarly, in ports that receive many cruise ships, it can also be almost impossible to provide enough power for them in all cases. Therefore, a possible EU requirement for shore power should be combined with a requirement for zero emissions from ships in port, so that an alternative to shore power could be that the ship runs on its own batteries while in port.
- Danish Ports would also like to support an energy tax restructuring that provides a level playing field for different types of fuels and thus modes of transportation, with the exception that there should be the possibility of tax reduction (exemption) for new sustainable energy forms, so that the development and implementation of these fuels can be supported.
Specifics about electricity tax
- This is a special scheme that has been approved by the European Commission and is currently only valid until June 18, 2021.
- Danske Havne finds it crucial that this special scheme is extended beyond June 2021 (preferably it should be made permanent). A lack of continuation will destroy the business cases for many shore power facilities, as it will be cheaper for ships to produce their own power rather than connect to shore power.
Clapping
What is dabbling?
Dredging is an activity where material is dropped from a ship at sea onto the seabed. It is called dredging because it is usually done by opening some flaps in the bottom of the ship. The material usually comes from the bottom of harbors or shipping lanes where dredging has been necessary.
Cleaning up shipping channels is a necessity:
All Danish harbors must have their shipping channels cleaned to ensure that the harbors can continue to be navigated by ships.Some harbors need to be cleaned up almost all the time, as they quickly "sand up" - this applies, for example, to Hvide Sande Harbor, while other harbors need to be cleaned up every 3-4 years - for example, parts of the east coast of Jutland.
On the west coast of Jutland, there can be a lot of sediment (precipitation) transport, which means that some ports are almost constantly moving sediment/sand to keep the port open. As a general rule, when sediment is moved frequently, the sediment is clean, but if it is moved very infrequently, there can be environmental challenges, especially if the sediment is deposited in areas from previously contaminated activities such as boat maintenance (sanding and painting) that may have contaminated the sediment with TBT or from spills and rainwater outfalls where heavy metals and tars can be deposited on the seabed.
Dredging is often done with only a portion of the cleaned material
When harbors/sea channels are cleaned of sediment/sand that is deemed "clean", some material can be bypassed (passed on) downstream on the leeward side of man-made structures such as a harbor, some can be reused for other projects such as coastal protection or harbor expansions, while the last part is placed back on the seabed - dumped.
Some material is not flattened but landfilled
If contamination is detected in the sediments that is higher than the values set by the Danish Environmental Protection Agency, the sediment cannot be dredged and must be landfilled. This can be done via a flushing basin, where the sediment is pumped/flushed into a closed basin. The sediment will fill up the basin and will compact/settle over a number of years, so that clean materials can eventually be filled on top and the area can be used for a harbor/buildings/recreational area.
What kind of sediment is being dredged?
Some of the sediment that is dredged consists of clay, silt and carbon from plants and animals. When this material is cleaned up, it is not suitable for recycling.The sediment typically originates from rivers, streams and wastewater outfalls where it is transported with the water.The sediment that is dredged must comply with the threshold values set by the Danish Environmental Protection Agency. This means that the sediment contains the same amount of e.g. heavy metals, tar substances or TBT as the sediments at the site where it is dredged. In other words, the seabed is removed in one place and deposited in another without changing the chemistry of the seabed. The fact that this sediment is not recycled may be because the grain size is incorrect in relation to whether it is suitable for this purpose.
Keeping harbors/sea channels open is expensive
Today, some of the sediments from the cleaning of a harbor/sea channel are dredged. It costs an estimated DKK 25/m3 to clean up a harbor or shipping channel. In addition, there are costs for sampling/divers, analysis and consultants. If the sediment is to be handled on land instead, it costs approx. 5 times as much - DKK 125/m3. The prices listed are based on a specific offer to a port. It can of course vary from port to port.
Dredging requires permission from the environmental authorities
If a port wants to dredge sediment, it requires a permit from the environmental authorities. To obtain permission from the authorities to dredge sediments, the dredging permit application must explain the grain size and carbon content of the sediment and why it cannot be reused.If there are elevated values of environmentally hazardous substances, it must always be explained that the dredging does not pose a risk to the marine environment.In this connection, an overall assessment of the total environmental impact of the dredging is made. The Danish Environmental Protection Agency makes the overall assessment of whether the material can be dredged.
Studies from DTU Aqua show that dredging has no significant impact on the aquatic environment
When the sediment is dredged, there will be particles from the sediment (clay, silt, lime, etc.) floating in the water for a period of time (suspended material). On this basis, it has been investigated what impact this has on the seabed/light conditions/eel grass. In Lillebælt, the amount of suspended material from dredging/raw material extraction and fishing constitutes less than 0.5% of the suspended material. It has been assessed in DTU Aqua report no. 361-2020 that it is not of significant importance to the aquatic environment.
Clapping - Danske Havne thinks so:
Base the debate on facts - not emotions
Danish Ports welcomes any debate about our marine environment, but the debate must be based on facts.
Danish ports want a clean marine environment
Danish ports have committed to working with the UN's Sustainable Development Goals - including the goal of a cleaner marine environment. Danish ports want a clean marine environment and naturally want to comply with the requirements of the environmental authorities.
Channels need to be cleaned up
But it's also clear that Danish ports need to remove sediment from shipping channels to prevent them from silting up. This is a basic condition for keeping Danish ports open and functional.
Recycle cleaned material as much as possible
Danish ports recycle all the sediment they can for construction and new port expansions. But there is sediment that cannot be recycled and it needs to be placed somewhere. That's why dredging sites are needed.
Accessible petting zoos are a necessity
As a starting point, dumping grounds should be located close to the affected ports. If a dredging site is far from the port, transporting the sediment can be very expensive. And it also has an environmental and climate impact if the dredged material has to be shipped a long way before it can be dredged.
Danish Ports listens to the Danish Environmental Protection Agency
The Danish ports naturally comply with the decisions made by the Danish Environmental Protection Agency regarding dredging permits.
Case processing times are still too long
Danish ports are experiencing increasing case processing times with the environmental authorities. This is unsatisfactory and has major financial consequences for the ports and potentially also for the port's customers and Danish society. Some ports have experienced case processing times of up to a year. Danish Ports calls for the necessary resources to be allocated to ensure that case processing times are reduced to a maximum of 3 months.
A more transparent and clear approval process
Danish ports need clarity on what documentation is required when applying for a permit. The application process must be transparent for everyone.
- New requirements that only part of the year can be clapped should be justified and always take local conditions into account.
- In general, local history should be taken into account when taking samples. If there is no history of contamination, take this into account in the approval process.
- Danish Ports would like to be involved in the process for the dredging guidance that the Danish Environmental Protection Agency has started. We hope to be able to contribute to better guidance that creates clarity for the applicant and reduces case processing time.
- Investigate old dumping sites: When the Danish Environmental Protection Agency approves dumping sites, it does so based on an assessment of the environmental impact in the area applied for, including fauna and biodiversity. Danish Ports would like to contribute to investigating the environmental impact of dumping sites. This could be by examining previous dredging sites and seeing what long-term environmental impacts dredging has had on the areas. In this way, the whole discussion about dredging could also be based on facts to a greater extent.
- Various media outlets have published articles and features, accompanied by photos or videos of dumping sites that are still in use. Naturally, the seabed is covered with newly deposited sediment that contributes to muddying the water, making it difficult to see animals and fauna. In this situation, it makes the seabed look miserable without necessarily being miserable. Therefore, it is important to gain insight into the long-term effect, as this is also the basis for the dredging permit.
- Danske Havne thus encourages the authorities to initiate a study of old dredging sites to shed light on the environmental impacts, e.g. 10 years after dredging has ended. The study may be carried out together with relevant research institutions. Danish Ports would be happy to contribute to such studies to the extent possible.
- Find new dumping sites: Danish Ports urges the environmental authorities to think "out of the box" when it comes to the possibility of new dumping sites. Could it be possible to clamshell some of the places where new facilities are planned to be established at sea in the coming years, such as Lynetteholmen or the energy islands? Or are there other possibilities? Finding suitable dumping grounds is a common problem that society as a whole needs a solution to.