Consultation Responses

Danish Ports’ Response to the Public Comment Period on the Draft Bill on State-Designated Energy Parks

Danske Havne acknowledges the opportunity to submit comments on the proposal for government-designated energy parks. The government, together with a broad majority, has entered into the “Climate Agreement on More Green Energy from Solar and Onshore Wind in 2023 – Framework Conditions for Promoting the Expansion of Onshore Renewable Energy.” Danish Ports welcomes the agreement and the ambition to streamline legislation so that the green transition can occur more quickly and climate change can be addressed. Among other things, the new renewable energy parks are to produce green energy for the transition of maritime value chains, whether through various green marine fuels or increased electrification. In this context, it is crucial to incorporate the entire value chain into the solutions.

• As a key element of this consultation, Danske Havne recommends that commercial ports that can or are expected to be part of renewable energy fuel chains and the production of, for example, wind turbine components, also be granted special designations or terms that allow for rapid and streamlined processing of cases in relevant areas, in line with energy parks. In many cases, ports serve as the physical foundation for the green transition in relation to, for example, the production, installation, and storage of offshore wind components, piping, etc.; therefore, ports must be viewed as part of the overall renewable energy chain.
• This will ensure that commercial ports can best support the important societal activities that the new energy parks, among other things, are intended to facilitate, thereby helping to enable a fourfold increase in total electricity production from solar and onshore wind power by 2030.

In the follow-up legislation, government-designated energy parks are to be granted special conditions that, among other things, relax land protection requirements and thereby make it easier and faster to obtain permits and exemptions for the installation of renewable energy facilities, including with regard to the location of PtX plants and businesses associated with the energy parks. By permitting the siting of large PtX plants in open countryside, one is deviating from a fundamental principle of Danish land-use planning, which is precisely to keep open countryside free of such facilities. It would therefore be advantageous, as far as possible, to locate the facilities near or adjacent to existing industrial areas, preferably at or near a port where the green fuels are to be used and shipped from.

From a safety perspective, there may be advantages to locating PtX companies in industrial areas where the necessary environmental permits may already be in place, along with an active and effective emergency response system in the event of an accident. This includes ensuring adequate safety distances, among other considerations.

The following option may also be relevant in very exceptional cases in connection with port expansions: “The proposed law will ensure that the respective ministers have the authority—in matters concerning or otherwise relevant to the realization of the energy park—to assume the municipality’s powers under the Planning Act, the Environmental Impact Assessment Act, the Nature Conservation Act, the Environmental Protection Act, and the Museum Act, respectively. The relevant minister may, upon request from the municipal council and in other special cases, decide to assume the municipal council’s powers.”

Sincerely,
Camilla Rosenhagen
Danish Ports