Audible response

Danish Ports Association's consultation response regarding executive order on targets for case processing times in the Environmental and Food Board of Appeal, the Planning Board of Appeal and the Energy Board of Appeal

Danish Ports acknowledges the opportunity to submit consultation responses to the draft executive order on targets for case processing times in the Environmental and Food Complaints Board, the Planning Complaints Board and the Energy Complaints Board.

Key notes:

• Danish Ports fully agrees that it is a prerequisite that there are sufficient employees for the Complaints Boards to comply with short and reasonable case processing times.
• A case processing limit of half a year should apply to all cases in the three appeal boards, as the permits in these appeal boards in particular support the green transition, business development and
  competitiveness. The Minister of Business and Industry has repeatedly highlighted the need to reduce case processing times here, as it is bad business for Denmark as the current case processing takes place. In particular, the case processing times for environmental cases are unsatisfactorily long.
• Ports of Denmark notes that there is a relatively broad definition of which projects fall under the case processing ceiling: “A complaint about a decision that has significance for the establishment of renewable energy in the form of wind turbine or solar cell projects”. Ports of Denmark interprets this as meaning that it can also apply to complaints about planning and environmental permits at commercial ports, as the port infrastructure is a necessary prerequisite for the establishment of wind and/or solar cell projects. For example, the ports are the shipping and production facility for many offshore wind turbine projects around the world. In commercial ports, we have examples of very long case processing times in the Complaints Boards, which delay green projects in the ports. We are particularly
  affected by the long case processing times in the environmental area, which has the longest average case processing time of 20 months, which we find deeply unsatisfactory.