Listening response
Danish Ports Association's consultation response regarding proposed changes to "Questions and answers on the discharge of certain pollutants"
Danske Havne 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 Association recognizes the Danish Environmental Protection Agency's work and efforts 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 are not commensurate with the environmental benefits, especially in water bodies where the water quality is already poor.
Danish society is facing a comprehensive transition, both in terms of climate neutrality, energy transition and nature restoration, and it is crucial that time and money are not wasted on bureaucracy and constraints 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 include the last guidance on port expansions and dredging. The published draft guidance primarily addresses how to handle dissolved substances discharged via watercourses and rivers to the sea. There is a need for a specific 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.
The government's recently published 2030 plan states 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, which was 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 towards realizing 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 the EU level, a green transition is ensured while Danish companies get a level playing field with their European competitors. This 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, it requires that the commercial ports in Denmark and their
infrastructure and companies can be operated and adapted optimally to handle the
many large tasks. This presupposes that the ports can obtain the necessary permits within a reasonable
timeframe for both port expansions and the cleaning/maintenance of shipping channels.
The consultation response is accompanied by 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 guidelines on dredging etc., including proposals for
de minimis limits and proposals for higher limit values for e.g. 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.
Also attached is a letter from the Port of Aarhus illustrating the current
related issues in this port.
Sincerely,
Camilla Rosenhagen