Audible response

Danish Ports' consultation response to the proposal for an Act to amend the Act on the Environmental and Food Appeals Board, the Act on the Planning Appeals Board, the Act on the Promotion of Renewable Energy and various other acts (Streamlining of case processing in the Planning Appeals Board, the Environmental and Food Appeals Board and the Energy Appeals Board etc.)

Danish Ports acknowledges the opportunity to submit comments regarding the bill to streamline the case processing in the Complaints Boards for renewable energy (RE) cases. Danish Ports finds the focus on shorter case processing times for environmental and energy permits in the Boards of Appeal important and a crucial prerequisite for streamlining the ongoing green transition.

Danish Ports supports an efficient and thus faster case processing of appeals against decisions regarding RE projects in the Environmental and Food Board of Appeal, the Planning Board of Appeal and the Energy Board of Appeal within the existing case processing ceiling of 6 months.

Ports are a fundamental foundation for the green transition, e.g. in relation to wind turbine production, collection, shipping, storage, service, etc. and it is therefore crucial that the shorter processing times also include environmental and energy-related permits for commercial ports.

For the green transition to be competitive and work in practice, the Danish Parliament and the environment and planning administration must focus on the overall value chains and plans, and on the overall need for permits. Both in the complaints boards and in the primary administration.

The commercial ports are some of Denmark's largest and most attractive business areas, which in addition to wind turbines also house the production of other technical renewable energy parts, are logistics hubs in the coming PtX production, CCUS implementation, CØ, etc. Therefore, complaints regarding commercial ports, including operation and maintenance of maritime infrastructure, on land and at sea, should be subject to a maximum processing time of 6 months. This should include the initiatives described in the proposal for more efficient case handling such as:

• Limiting review to the specific grievance
• Deadline for disclosure of cases to the complaints boards, including authority to reject preliminary appeals
• Temporary hiring of additional staff.

At EU level, similar ideas are being considered and proposals are being discussed on how areas for green energy transition and the like should be covered by rights that include processing times of max one year overall. One example is the European Commission's Wind Power Action Plan, which contains 15 immediate measures, of which a focus on faster and more efficient permitting processes is an essential element.

For Danish Ports, it is important that green Danish commercial companies and commercial ports are not disadvantaged compared to our European competitors.