Consultation Responses
Danish Ports' Response to the Public Comment Period on the Environmental Impact Report for Metro Line M5
Danske Havne acknowledges the opportunity to submit comments on the draft Environmental Impact Report for the new M5 metro line in Copenhagen. Danish Ports supports the southern route of the planned M5 (purple) metro line in Copenhagen, as the line will improve mobility and accessibility in the city, benefiting both residents and businesses once the metro line becomes operational.
Introductory Remarks
Danish Ports is aware that intensive efforts have been made to find a solution for Prøvestenen so that, going forward, there will be room for both a preparation and maintenance center for the M5 metro (KVC) and Prøvestenen’s current operations.
Copenhagen is expected to see an increased need for bulk-handling businesses near the port in the future, particularly in connection with raw material imports and recycling, as there are insufficient raw materials in the Capital Region to support construction goals and population growth. Therefore, it is essential that the capacity for increasing imports of raw materials by sea to Copenhagen be maintained, and that the environmental impact assessment take into account the consequences for imports (e.g., increased land transportation and land reclamation) resulting from the closure of port areas. There are very limited commercial sites in the City of Copenhagen with an environmental classification suitable for the type of business operated at Prøvestenen. Prøvestenen also supplies Copenhagen Airport with aviation fuel.
One of the airport’s largest operators—the partially state-owned SAS—has just significantly expanded its route network out of Copenhagen Airport, underscoring the continued commitment to developing the airport for the benefit of both citizens and the business community in Denmark and southern Sweden. Combined with the expected increased need for handling new and recycled raw materials, the planned reduction in the available space at Prøvestenen could pose a challenge for Copenhagen and Denmark.
Certain types of future green fuels are also expected to take up more space, since a greater amount of green fuel (e.g., methanol) is required to generate the same propulsion as fossil fuels. Furthermore, the green transition will lead to the handling of new types of cargo at ports, such as CO2, which also takes up space and requires safety zones.
The project involves the temporary and permanent closure of key port areas that support maritime transport. This is an undesirable development for an active port area such as Prøvestenen, which supports vital community activities such as Copenhagen’s
Airport, which serves as the foundation for a great deal of essential business activity in Copenhagen. Prøvestenen is the only area in the 2019 Finger Plan designated for this type of business.
In light of this, Danske Havne believes it is fundamentally wrong for Prøvestenen to cede land to KVC, and therefore we do not support the establishment of KVC at Prøvestenen.
The environmental impact report must therefore still examine the environmental benefits of constructing the KVC on land along the coast in the new urban development area, as the center will then be located in close proximity to the rest of the route, and there will be no need to build a new bridge, etc. The onshore KVC could potentially be built partially underground and possibly covered with solar panels. This would minimize noise and shadowing/obstruction of views.
Located on land facing Prøvestenen rather than on Prøvestenen itself, the facility can also help create the necessary distance between residential areas and the businesses on Prøvestenen that fall into the most stringent environmental categories.
General Remarks
The construction phase will span many years and will cause significant disruption to businesses and residents along the way. The environmental report should serve as a basis for minimizing this disruption as much as possible and also outline how this can be achieved.
During the construction phase, the project should prioritize water transportation as much as possible to reduce traffic congestion on the roads.
Specific comments
- If work on the M5 project’s land use in the Prøvestenen commercial area is to continue nonetheless, it must be reduced as much as possible, since this area is crucial for serving Copenhagen’s business community and there are no alternative locations in the metropolitan area (as documented by NIRAS in 2023 and as stated in the 2019 Finger Plan).
- “The southernmost commercial area at Prøvestenen will be permanently closed, and the businesses must relocate their operations elsewhere.” (p. 42): The project should specify how the operations of the directly affected businesses can be maintained during the construction and operational phases at Prøvestenen or (specifically) elsewhere.
- The project’s environmental impact report should also outline how indirectly affected businesses and areas can continue to operate during the construction and operational phases. Other businesses will be affected by increased traffic, utility line relocations, and closed roads at Prøvestenen.
- The planned commissioning and maintenance center (KVC) must be designed so that it does not limit the operational and development opportunities of the businesses in Prøvestenen. For example, the center must not be susceptible to dust or noise.
- KVC’s proposed location requires an alternative access road to the docks at Prøvestenen. The road must be constructed for use during both the construction and operational phases of the M5 and must be located within the currently outlined area for KVC.
- The implementation and management of port security (ISPS) must be included in and funded by the project, as the KVC construction site affects areas that are currently subject to ISPS security measures.
- The project is intended to ensure that there is sufficient capacity for heavy traffic via one or more access roads to the Prøvestenen industrial park during the construction and operational phases.
- Storm surge protection, amphibian fences, etc., must be located within the KVC area. Storm surge protection to the north and east should consist of sheet piling in order to take up as little space as possible.
- Uninterrupted operations at the businesses in Prøvestenen must be ensured during the utility line relocation associated with the M5. The utility line relocation must be coordinated with Sund&Bælt in relation to the potential “Eastern Ring Road” construction project.
- The cumulative/total significant effects on Prøvestenen of the Eastern Beltway, the M5, and nearby urban development (zoning) must be included in the environmental impact assessment.
- The CO2 and traffic impacts resulting from the potential closure of dry bulk operations—and the resulting increase in land transport—must be included in the environmental impact assessment (calculations regarding this are available in the 2023 NIRAS report).
- “The southernmost commercial area at Prøvestenen will be permanently closed, and the businesses must relocate their operations elsewhere.” (p. 42): The project should specify how the operations of the directly affected businesses can be maintained during the construction and operational phases at Prøvestenen or (specifically) elsewhere.
Sincerely,
Tine Kirk, Director of Danske Havne
