Audible response
Port Denmark's consultation response regarding the consultation of the Environmental Impact Report for Metro Line M5
Danish Ports acknowledges the opportunity to submit comments on the draft Environmental Impact Report for the new metro line in Copenhagen M5. Port Denmark supports the southern version of a future metro line in Copenhagen, M5 purple, as the line will promote mobility and accessibility in the city for the benefit of citizens and businesses when the metro line comes into operation.
Introductory remark
Danske Havne is aware that a lot of work has been done to find a solution for Prøvestenen to accommodate both a preparation and maintenance center for metro M5 (KVC) and the current activities of Prøvestenen.
Copenhagen is expected to have an increased need for port-related bulk businesses in the future, e.g. for raw material imports and recycling. raw material imports and recycling, as there are not enough raw materials in the Capital Region to support construction ambitions and population growth. Therefore, it is essential that the possibility of increasing imports of raw materials by sea to Copenhagen is maintained and that consequences for imports (e.g. increased land transportation and land reclamation) from the closure of port areas are included in the environmental impact assessment. There are very limited commercial areas in the City of Copenhagen with environmental classification for the type of business carried out at Prøvestenen. Prøvestenen also supplies Copenhagen Airport with aviation fuel.
One of the airport's largest operators - the partly state-owned SAS - has just significantly expanded its route network out of Copenhagen Airport, which underlines the continued focus on developing the airport for the benefit of both citizens and businesses in Denmark and southern Sweden. Combined with the expected increased need for handling new and recycled raw materials, the planned reduction of areas at Prøvestenen may become a challenge for Copenhagen and Denmark.
Certain types of future green fuels are also expected to take up more space, as it requires a larger amount of green fuel (e.g. methanol) to get the same propulsion as fossil fuel. Furthermore, the green transition will lead to the handling of new types of goods at ports, such as CO2, which also take up space and require safety zones.
The project involves the temporary and permanent closure of important port areas that support maritime transportation. This is a wrong development in an active port area like Prøvestenen, which supports essential social activity like Copenhagen's
Airport, which is the foundation for a lot of necessary business activity in Copenhagen. Prøvestenen is the only area in the 2019 Finger Plan that is zoned for this type of business.
Against this background, Danske Havne finds it wrong in principle that Prøvestenen should give up area to KVC, so we do not support KVC being established on Prøvestenen.
The environmental impact report must therefore still look at the environmental benefits of building KVC on land on the coast in the new urban development area, as the center will then be located in the immediate vicinity of the other alignment and a new bridge etc. will not have to be built. KVC on land can be partially buried and possibly covered with solar cells. This will minimize noise and shadow/loss of view.
Placed on land facing Prøvestenen instead of on Prøvestenen itself, the facility can also help to create the necessary distance between homes and Prøvestenen businesses in the heaviest environmental classes.
General remarks
The construction phase will extend over a number of years and will cause significant inconvenience to businesses and citizens along the way. The environmental report should be a starting point for minimizing these inconveniences as much as possible, and also indicate how this can be done.
During the construction phase, the project should prioritize sea transport as much as possible to reduce traffic congestion on the roads.
Specific comments
- If the M5 project's land consumption on Prøvestenen's commercial area is to be continued, it must be reduced as much as possible, as this area is crucial for serving Copenhagen's businesses and as there are no alternative locations in the metropolitan area (documented by NIRAS in 2023 and as stated in the Finger Plan 2019).
- "The southernmost commercial area on Prøvestenen will be permanently withdrawn and companies will have to move their activities elsewhere." (p. 42): The project should indicate how the operations of the directly affected companies can be maintained during the construction and operation phase at Prøvestenen or (specifically) elsewhere.
- The project's environmental impact report should also indicate how indirectly affected companies/areas can function during the operational and construction phases. Other businesses will be affected by increased traffic, re-routing of power lines and closed roads on Prøvestenen.
- The planned preparation and maintenance center (KVC) must be designed so that it does not restrict the operational and development opportunities of Prøvestenen's businesses. For example, the center must not be sensitive to dust and noise.
- KVC's proposed location requires an alternative access road to the quays at Prøvestenen. The road must be established for use during both the construction and operational phases of M5 and be within the current outlined area for KVC.
- The redesign and handling of port security (ISPS) must be included in and financed by the project, as the KVC construction site touches areas that are currently under ISPS security.
- The project must ensure that there is sufficient capacity for heavy traffic via one or more access roads to the Prøvestenen business area during the construction and operational phases.
- Storm surge protection, mushroom fences, etc. must be kept within KVC's area. Storm surge protection to the north and east should be in the form of sheet piles in order to take up as little space as possible.
- Unhindered operation of Prøvestenen's businesses must be ensured during the re-routing of cables in connection with the M5. The relocation must be coordinated with Sund&Bælt in relation to the possible construction project "Eastern Ring Road".
- The cumulative/total significant effects of the Eastern Ring Road, M5 and nearby urban development (zoning) on Prøvestenen must be included in the environmental impact assessment.
- CO2 and traffic consequences of possible closure of dry bulk companies and thereby increased land transportation must be included in the environmental impact assessment (calculations of this are available in the NIRAS report from 2023).
- "The southernmost commercial area on Prøvestenen will be permanently withdrawn and companies will have to move their activities elsewhere." (p. 42): The project should indicate how the operations of the directly affected companies can be maintained during the construction and operation phase at Prøvestenen or (specifically) elsewhere.
Kind regards,
Tine Kirk, CEO of Danish Ports
