Audible response

Danish Ports' Consultation response regarding proposed changes to "Questions and answers about discharge of certain pollutants"

Danish Ports acknowledges the opportunity to submit a consultation response regarding proposed changes to the guidance "Questions and answers on the discharge of certain pollutants".

Danish Ports recognizes the work and efforts of the Danish EPA to establish a sufficiently pragmatic and flexible interpretation of the Water Framework Directive so that socially beneficial projects are not prevented, delayed or made more expensive in a way that the costs do not match the environmental benefits, especially in water bodies where water quality is already not good.
Danish society is facing an extensive transition, both in terms of climate neutrality, energy transition and nature restoration, and it is crucial that time and money is not wasted on bureaucracy and obstacles without real benefits. Danish Ports assumes that the proposed changes should be read in this context.

It appears from the consultation letter that guidance on dredging will follow, and Danish Ports cannot emphasize enough that it is urgent to get the last guidance on port expansions and dredging. The draft guidance primarily addresses how to deal with dissolved substances that are discharged via streams and rivers to the sea. There is a need for a concrete position on how an applicant for a port expansion or a significant deepening of shipping channels can quickly and manageably obtain the necessary permits to carry out the work.

In the government's recently published 2030 plan, it is stated that, in light of the climate strategy, Denmark will work to maintain and expand its position of strength as a green pioneer in the maritime sector. In this context, they refer to the goal of climate-neutral global shipping in or around 2050, adopted by the International Maritime Organization in July 2023.

In chapter 2 on green transition, the government highlights the EU's great potential for the expansion of wind energy and that a number of steps have already been taken at EU level to realize the European plans for a massive expansion of renewable energy at sea and on land. The government will therefore work to ensure that the EU's full potential for renewable energy is utilized and that the framework for this is the most optimal. The government writes "When climate and energy regulation takes place at EU level, a green transition is ensured, while Danish companies get a level playing field with their European competitors. It also means that jobs and emissions are not simply moved from Denmark to other EU countries, but instead a real green transition takes place."

If the above is to succeed, the commercial ports in Denmark and their
infrastructure and companies must be optimally operated and adapted to handle the
many major tasks. This presupposes that the ports within a reasonable
timeframe can obtain the necessary permits for both port expansions and
cleaning/maintenance of shipping channels.

Attached to the consultation response is a memo on the special issues in
commercial ports. The memo has been prepared by COWI, at the request of specific
challenges in the port of Aarhus. COWI's memo provides relevant input to the
forthcoming guidance on dredging, etc. including proposals for
de minimis limits and proposals for higher limit values for, among other things, atracene, which is an
example of where the Danish requirements are very restrictive in relation to the latest knowledge,
also in the Agency, Helcom and Ospar.

In addition, a letter from the Port of Aarhus is attached which illustrates the current
related issues in this port.

Sincerely,
Camilla Rosenhagen