Scrubbers

Background information

On July 1, 2010, the revised Annex VI of MARPOL came into force, introducing stricter sulphur limits for marine fuels in the North Sea and Baltic Sea, among other places. 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 help to clarify the extent to which wastewater discharged from open scrubbers pollutes ports, but nevertheless, a number of ports in Germany and elsewhere have banned the discharge of wastewater in ports.

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 ports where the water flow is not very high, so it is expected that the IMO rules will be tightened in 2021.

Danske Havnes Position

The studies conducted so far on contamination from open scrubbers cannot definitively refute that microorganisms can be affected by contamination from open scrubbers.

Danish Ports welcomes the investigation of pollution from open scrubbers and the development of common international rules and guidelines.

Until there are definitive studies 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 port based on the precautionary principle.

Shore power

Background information

Danish ports currently offer shore power that 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, which is why expansion of the current capacity will be necessary.

Today, shore power is tax exempt until June 18, 2021. Similarly, ship fuel is also tax exempt.

In the new Green Deal from the EU, it is planned that ships will 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

• Financing large shore power installations is a major challenge for Danish ports. Large facilities to 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 receive ships at both 50 and 60 Hz. In addition, cruise ship facilities are only used during the summer months and the number of ships can vary from year to year.
• In order 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 exposed to competition, which is why support can be provided by 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 legal obstacles to ports being able to supply electricity to ships in port, make related investments and generate profits from these activities. Neither in relation to the Port Act nor the Port Regulation, 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.
• However, Danish Ports do not want all ports to be required to establish shore power for all ships calling at the port. Shore power can be very expensive to establish - for example 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, any EU requirement for shore power should be combined with a zero-emission requirement for 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 entails equal conditions for different types of fuels and thus modes of transport, with the exception that there should be the possibility of tax reductions (exemptions) for new sustainable forms of energy to support the development and implementation of these fuels.

Special about electricity tax

• This is a special scheme approved by the European Commission and is currently only valid until June 18, 2021.
• Danish Ports finds it crucial that this special scheme is extended beyond June 2021 (preferably made permanent). A non-extension will destroy the business case for many shore power plants, as it will be cheaper for ships to produce their own power rather than connect to shore power.

Clapping

What is clapping?

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 ports must have their navigation channels cleaned to ensure that the ports can continue to be navigated by ships.Some harbors need to be cleaned almost all the time, as they quickly "sand up" - this applies to the Port of Hvide Sande, for example, while other harbors need to be cleaned approximately every 3-4 years - such as parts of the east coast of Jutland.

On the west coast of Jutland, there can be a lot of sediment (sediment) 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, while if it happens very rarely, there can be environmental challenges, especially if the sediment is deposited in areas by previously contaminated activities such as boat maintenance (sanding and painting) which may have contaminated the sediment with TBT or by spills and stormwater runoff where heavy metals and tar substances can be deposited on the seabed.

Clapping is often done with only a portion of the cleaned material

When cleaning harbors/channels 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 port, some can be reused for other projects such as coastal protection or port expansions, while the last part is placed back on the seabed - dumped.

Some material is not clapped 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 dumped and must be deposited. 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 over a number of years it will compact/settle 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 clapped?

Part of the sediment that is dumped 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 sewage outfalls where it is transported with the water.The sediment that is dumped must comply with the threshold values set by the Danish Environmental Protection Agency. This means that the sediment contains the same amount of, for example, heavy metals, tar or TBT as the sediments at the location where it is dumped. In other words, the seabed is removed in one place and placed in another without changing the chemistry of the seabed. The fact that this sediment is not reused may be because the grain size is incorrect in relation to whether it is suitable for reuse.

It's expensive to keep ports/sea lanes open

Today, some of the sediments from the cleaning of a harbor/sailing channel are dumped. 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 has to be handled on land instead, it costs about 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.

Dumping requires permission from environmental authorities

If a port wants to dump sediment, it requires a permit from the environmental authorities. To obtain permission from the authorities to dump sediment, 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 levels of pollutants, it must always be explained that the dredging does not pose a risk to the marine environment.In this connection, an overall assessment is made of the total environmental impact of dredging. 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 dumped, there will be particles from the sediment (clay, silt, lime, etc.) floating in the water for a period of time (suspended material). Against this background, the impact on the seabed/light conditions/eelgrass has been studied. In Lillebælt, the amount of suspended material from dredging/raw material extraction and fishing is less than 0.5% of the suspended material. It is assessed in DTU Aqua report no. 361-2020 that it has no significant impact on the aquatic environment.

Clapping - that's what Danish Ports believes:

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 are committed to working with the UN Sustainable Development Goals - including the goal of a cleaner marine environment. The 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 functioning.

Cleaned material is recycled as much as possible

Danish ports recycle all the sediment they can for building structures and new port expansions, among other things. But there is sediment that cannot be recycled and it has to be placed somewhere. That's why there is a need for tipping sites.

Accessible pet beds are a necessity

As a rule of thumb, tipping sites should be located close to the affected ports. If a dumping 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 transported a long way before it can be dumped.

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 permits for dredging.

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 urges that the necessary resources are allocated to reduce case processing times 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 can only be patted for part of the year should be justified and always take local conditions into account.
• In general, local history should be taken into account when taking samples. If no previous contamination has been detected, 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 contribute to better guidance that creates clarity for the applicant and reduces case processing time.
• Investigate old tipping sites: When the Danish Environmental Protection Agency approves tipping sites, it is based on an assessment of the environmental impact in the area applied for by looking at fauna and biodiversity, among other things. Danish Ports would like to contribute to investigating the environmental impact of tipping 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 pictures or films from the flap sites that are still in use. Naturally, the seabed has newly deposited sediment that contributes to muddying the water, making animals and fauna difficult to see. In this situation, it makes the seabed look miserable without it necessarily being so. That's why it's important to understand the long-term effect, as this is also the basis for the dredging permit.
• Danish Ports therefore encourages the authorities to initiate a study of old dredging sites to shed light on the environmental impact, e.g. 10 years after dredging has been completed. The study can possibly be carried out together with relevant research institutions. Danish Ports is happy to contribute to such studies to the extent possible.
• Find new tipping sites: Danish Ports urges the environmental authorities to think "out of the box" when it comes to the possibility of new tipping sites. Is it possible to use 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 completely different options? Finding suitable folding sites is a common problem that the whole of society needs a solution to.