Audible response

Consultation response to report no. 6 from the Transport Committee on the establishment of a parliamentary working group on efficient processes for the approval of construction and building projects

Danish Ports thanks for the opportunity to submit a consultation response to the above-mentioned report, which we find extremely important and relevant to the port area and society's opportunities for green transition.

Delays in processing permits jeopardize the timely achievement of energy and climate targets and increase the cost of the projects needed to reach those targets. Delays can also hinder dynamic innovation, leading to less efficient construction for renewable energy.

At the moment, there are many activities going on that have to do with processes for construction and building projects, which highlights the need for the committee's work. These include:

Danish Ports' report on port potentials, January 2024

In connection with efficient processes for the approval of construction and building projects, Danish Ports wishes to draw attention to the report Erhvervspotentialer for danske havne - analyse af potentialer for den videre udvikling og omstilling af de danske erhvervshavne, januar 2024, which was commissioned by Danish Ports in connection with participation in the work with the Port Partnership.  

Based on interviews with the ports and supporting analysis, the report highlights nine actions in particular that the responsible authorities can implement to enable ports to realize the identified potentials. One of the most important actions is:

Faster case processing and approvals so that expansions of port areas and deepening of shipping channels are completed faster. Fast-track schemes for energy-related projects should be explored as an option.

The report is attached for information.

The upcoming Port Partnership Report

It is also expected that the upcoming report from the Port Partnership will focus on the importance of faster case processing times, which is why the partnership's future messages will be important for this work.

Commission Recommendation (EU) 2024/1343 of 13 May 2024 on speeding up the permitting procedures for renewable energy projects and related infrastructure

At the European level, there are also several attempts to streamline procedures - in this document, it's about permitting procedures for renewable energy projects and related infrastructure.

Among other things, it recommends that Member States ensure that the planning, construction and operation of renewable energy projects and related infrastructure projects can be processed under the most favorable of their planning and permitting procedures.

In addition, Member States should set clear deadlines, which are as short as possible, for all steps in the granting of permits for the construction and operation of renewable energy projects and the related infrastructure projects. Furthermore, Member States should establish timeframes and specific procedural rules to ensure the effectiveness of legal proceedings related to access to justice for projects. Furthermore, Member States should establish a single, unified application process for the entire administrative procedure for applying for and granting permits for renewable energy projects.

Danish Ports can fully endorse the considerations and proposals in the above-mentioned reports, documents etc. Namely, that case processing must be fast, efficient, transparent - and with an overall prioritization of environmental considerations. In addition, there must be coordination between the authorities involved. All this must be done without compromising environmental considerations, which of course must continue to be taken care of.

Faster case processing will be attractive to the ports, and will not least be a crucial prerequisite for the ports to be able to contribute to society's green transition quickly enough.

Suggestions for consideration:

In future work, the working group can explore the following:

  • Will setting a maximum limit on processing time for large projects result in faster processing times?
  • Especially in the environmental area, the processing time for complaints is very long compared to other areas. Can this change?
  • Resistance to projects can be found both in established NGOs, but recently, in relation to port projects, citizen communities based on opposition to a specific project have also emerged and established. The working group can explore how these two very different groups and their different expectations can best be included in projects through early involvement.
  • Can you make sure that large projects are covered with NGOs, etc. before you start, so that new things don't constantly crop up that need to be turned around and delayed, for example. For example, you can get the Nature Conservation Society and core stakeholders on board from the beginning so they don't keep blocking.
  • It can be difficult to involve citizen groups/movements. For example, who represents the groups? They may also be established late in the process, so you have come a long way in the preparation of material etc.
  • Municipalities work with citizen panels, where a representative selection of citizens are involved in decision-making processes. It's representative, but is it also exclusionary for those who want to contribute but are not included? Is there a good way to involve the "silent majority" so that not only opponents are heard?
  • There will also be issues that cannot be agreed upon regardless of early stakeholder involvement.
  • It can also be examined whether there is a basis for reassessing/clarifying the rules for who is entitled to complain/consult. For example, citizen groups formed against individual projects are not nationwide and thus not necessarily eligible for consultation. Citizens may not always be aware of this, and it can create expectations that are not met by citizens. In these situations, the authorities must also individually decide on the right to appeal, which can further delay case processing.
  • If possible, the work should point to specific legislation that needs to be changed to reduce case processing time.
  • The report should address the fact that the green transition is necessary for the sake of the climate, and that both renewable energy and infrastructure projects are the foundation of the society that has made Denmark one of the best countries in the world to live in. We can continue this development in an environmentally responsible way.