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Audible response

Proposal for an Act to amend the Act on the Promotion of Renewable Energy, the Act on Environmental Assessment of Plans and Programs and of Specific Projects (EIA), the Act on Public Roads etc. and the Railway Act

Ports of Denmark acknowledges the opportunity to submit comments on the proposed Act amending the Act on the Promotion of Renewable Energy, the Act on the Environmental Assessment of Plans and Programmes and of Specific Projects (EIA), the Act on Public Roads, etc. and the Railway Act.
General Notes:

  • Ports of Denmark agrees that there are cases where it makes sense to change the minimum period for public consultation on environmental impact reports in the Environmental Assessment Act, the Railway Act and the Public Roads Act from at least 8 weeks to at least 30 days. Here it is important that the change in the minimum periods for consultation on environmental impact reports also applies to re-examination of projects at sea and on land and to minor extensions and changes to already proposed/known projects where there has been a public consultation. Fast permits are important to get the green transition up to speed.
  • Ports of Denmark is positive about the bill's possibility of reserving a separate right over solar cell systems on roof areas of commercial buildings, etc. This originally follows from the Climate Agreement on Green Electricity and Heat from June 2022, but Ports of Denmark cannot explicitly see whether this right also applies to solar cells on the roof areas of commercial ports. It is important that this is the case so that good areas for green conversion do not remain unused.
  • The bill transfers the EIA competence for floating solar cell plants at sea from the Minister for Green Tripartite to the Minister for Climate, Energy and Utilities. The layout and design are very important for how much such a plant takes up, casts shadows and affects the surroundings. Therefore, it may be beneficial in the future to prepare a guideline for small plants that only require a screening approval. Small plants may be relevant as a supplement to the energy consumption of commercial ports.
  • Danish Ports supports better opportunities to install solar cell systems on roofs with a separate right that can protect the robustness of the investment and make it more attractive for specialized companies to design, optimize and install this type of system on the roofs of commercial buildings. Including roof areas in commercial ports, where ownership etc. may be mixed, but where it can be an advantage for an efficient project that the installation and operation take place as a single project.
  • It is a good idea to enable more forms of financing for solar cell systems, including on rooftops. This should be possible with public-private partnerships, for example between a commercial port and an energy company.

Specific comments:

  • Re. Section 15. “Notwithstanding Section 38 of the Land Registration Act, separate rights may be reserved over solar cell systems established on roof areas of commercial buildings, etc., which are connected to the public electricity grid.”
  • It should be added here: This also applies to combined projects that are set up on buildings that are located relatively close together in a commercial area or commercial port area, regardless of whether these have different owners or are located on different cadastral plots.

Regarding acceleration areas, §1:

  • The EU's concept of "acceleration areas" is important for realizing a rapid and effective green transition. Ports of Denmark emphasizes that the Danish implementation is flexible and does not limit the possibilities of Danish projects compared to similar projects in other EU countries.
  • Since the concept includes designated areas, including close to where there is a landfall of high-power electricity from offshore wind turbines, the areas must be able to include all or parts of a commercial port area. In these areas, it must be easier to build storage facilities and PtX production, as it is an obvious physical location, in relation to the overall value chain.
  • The option should also include areas where work is being done to create CO2 reception facilities in an area where storage capacity is/is being built close to on/offshore. Here, the more flexible and efficient permitting process is also needed.


Sincerely yours,

Camilla Rosenhagen
Danish Ports