Consultation Responses

Danish Ports’ Response to the Consultation on Proposed Amendments to “Questions and Answers on the Discharge of Certain Pollutants”

Danish Ports acknowledges the opportunity to submit comments on the proposed changes to the guidance document “Questions and Answers on the Discharge of Certain Pollutants.”

Danish Ports acknowledges the Danish Environmental Protection Agency’s work and efforts to establish a sufficiently pragmatic and flexible interpretation of the Water Framework Directive, so that projects that benefit society are not prevented, delayed, or made so costly that the expenses are disproportionate to the environmental benefits—particularly in water bodies where water quality is already poor.
Danish society is facing a comprehensive transition—in terms of climate neutrality, energy transition, and nature restoration—and it is crucial that no time or money be wasted on bureaucracy and red tape that yield no real benefits. Danske Havne assumes that the proposed changes should be viewed in this context.

The consultation letter states that the guidance document regarding dredging will be issued at a later date, and Danske Havne cannot emphasize enough the urgency of receiving the final guidance document on port expansions and dredging. The draft guidance that has been issued primarily addresses how to handle dissolved substances discharged into the sea via watercourses and streams. There is a need for a concrete position on how an applicant for a port expansion or a significant deepening of navigation channels can quickly and efficiently 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 strong position as a green pioneer in the maritime sector. In this context, the government refers to the goal—adopted by the International Maritime Organization in July 2023—of achieving climate-neutral global shipping by or around 2050.

In Chapter 2 on the green transition, the government highlights the EU’s significant potential for expanding wind energy and notes that a number of steps have already been taken at the EU level toward realizing 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 realized and that the framework for this is as optimal as possible. The government states: “When climate and energy regulation takes place at the EU level, a green transition is ensured while Danish companies are provided with a level playing field with their European competitors. This also ensures that jobs and emissions are not simply shifted from Denmark to other EU countries, but that a genuine green transition takes place instead.”

For the above to succeed, it is essential that Denmark’s commercial ports and their
infrastructure and businesses be operated and optimized to handle the
many major tasks. This requires that the ports be able to obtain the necessary permits within a reasonable
timeframe for both port expansions and
dredging and maintenance of navigation channels.

Attached to this consultation response is a memo on the specific issues at
commercial ports. The memo was prepared by COWI in response to specific
challenges at the Port of Aarhus. COWI’s memorandum provides relevant input for the
upcoming guidance on dredging, etc., including proposals for
de minimis limits and proposals for higher limit values for, among other substances, atrazine—which is a
example of how Danish requirements are very restrictive compared to the latest scientific knowledge,
as recognized by the Danish Environmental Protection Agency, HELCOM, and OSPAR.

Also enclosed is a letter from the Port of Aarhus, which illustrates the current issues related to
at this port.

Sincerely,
Camilla Rosenhagen