The Utility Trap: Who Carries the Risk When Europe's Ports Plug In?

Its authors are EOPSA President Roland Teixeira de Mattos, Professor John Prousalidis of the National Technical University of Athens, Syb ten Cate Hoedemaker of the Maritime Battery Forum and Dr Alex Papalexopoulos of ECCO International.

Their argument is economic rather than technical. Europe has decided that ports will electrify. The open question is who takes the financial risk while they do.

A trap defined

The paper defines the Utility Trap as "the progressive transfer, whether by design or by default, of electricity system functions" and their commercial risks to port authorities, simply because the point of delivery sits inside the port perimeter.

It rarely happens in one decision. A port installs shore power infrastructure. That requires a grid capacity commitment. The commitment becomes a long term financial obligation. The obligation needs cost recovery, which means tariffs. Tariffs mean buying electricity and carrying price exposure. Price exposure means forecasting demand and owning the risk of getting it wrong.

Step by step, a landlord becomes a utility. Nobody chose it.

The missing middle in EU law

The regulation is precise at both ends of the cable. Under AFIR, Member States must ensure shore side electricity in TEN-T maritime ports. Under FuelEU Maritime, qualifying ships must connect at berth from 2030.

Between those two obligations sits everything that makes a project bankable: grid connection, procurement, power purchase agreements, storage, metering, tariffs and the risk of low utilisation. The paper calls the rules "materially less prescriptive" on that commercial architecture. In practice, what is not assigned tends to land on the party holding the land.

Why the port ends up holding the risk

The economics of shore power favour this drift. Capital costs come first and arrive in full. Utilisation starts low and builds slowly. Capacity must be sized for the peak, often a single large cruise call. And demand depends on vessel schedules the port does not control.

Those features make the port authority the natural residual risk bearer. That is the core concern. A public body with a constrained balance sheet carrying grid, price and utilisation risk is a recipe for a higher cost of capital, slower decisions and smaller projects.

The authors draw a clear line. A port can become an energy hub without becoming a utility. In their words: "A port can orchestrate an electricity ecosystem without owning every asset within it."

The numbers behind the argument

• 6 to 13 TWh: EOPSA's estimate of annual OPS electricity demand across European ports.
• Over €100 billion: EOPSA's estimate of the wider investment opportunity in port electrification.
• 23% to 46%: electricity's share of EU final energy consumption today, and the 2040 target under the Electrification Action Plan.
• 50%: the renewable share of EU electricity generation in 2025, according to ACER.
• More than 10 TWh: renewable electricity curtailed in the EU in 2024 because of grid congestion.
• Five times: how much larger daily wholesale price swings were in 2025 than in 2020.

The last three figures explain why the paper treats ports as part of the power system, not just as consumers of it.

A capital market, not a grant queue

The strongest section of the paper is about money. Renewable generation in Europe grew on the back of tools that removed specific risks: auctions, contracts for difference, power purchase agreements and feed in support. Port electrification competes for the same capital with no equivalent tools.

The authors do not ask for identical treatment. "A level playing field does not require identical support. It requires comparable attention to comparable investment risk." The candidates they list include long term offtake, capacity based tariffs, guarantees, concessions, availability payments, blended finance and CfD type instruments.

The other lever is scale. A berth serving occasional cruise calls is a weak investment on its own. Add home based tugs, pilot boats, crew transfer vessels, terminal equipment and potentially hydrogen production, and the demand profile smooths out. Value comes from bundling demand. Bankability comes from unbundling risk, so each risk sits with the actor best able to price it.

What EOPSA is asking for

The paper sets out five priorities:

• Coordinate. DG MOVE, DG ENER, DG CLIMA and Europe's finance and industrial functions should act together, with the same coordination in each Member State.
• Allocate. Assign each responsibility and risk explicitly, so nothing migrates to port authorities by default.
• Build a market. Turn port electrification into propositions that utilities, infrastructure funds and institutional investors will finance.
• Level the field. Address utilisation, grid capacity and revenue risk with tools suited to ports.
• Count the system value. Treat flexible port demand, storage and local generation as part of the answer to curtailment and grid congestion.

Alongside the paper, EOPSA has proposed a European implementation group spanning sectors, mirrored in each Member State. It would bring policymakers, academia, industry and investors together to remove barriers and accelerate delivery towards 2030. Whether it sits within an existing structure such as EMS or ESSF is left open. The association's point is that it needs leadership with "the authority, determination and clear mandate to deliver."

Bigger than decarbonisation

EOPSA frames the prize widely. Producing clean marine fuels will need large volumes of electricity. Electrification creates skilled jobs. Local generation and storage make ports more resilient to disruption. Surplus renewables, curtailment and negative prices become economic opportunities. And communities get cleaner air and less noise.

Delivering that, it argues, means joining four worlds that rarely work together: electricity, sustainability, logistics and infrastructure.

The question still open

The paper is persuasive on diagnosis. It is lighter on the final bill. Moving risk away from port authorities does not remove it.

It has to land with ship operators through tariffs, with grid users through network charges, with investors through returns, or with taxpayers through guarantees. The headline estimates are EOPSA's own, and the full methodology is not set out in the paper.

That is the next conversation. It is also the right one. Clear risk allocation is what turns a policy obligation into an investable market.

Europe has set the destination for shore power. The Utility Trap asks it to decide who pays for the journey.

Read the full paper: The Utility Trap, EOPSA, October 2026 (link below).