Audible response

Consultation on the draft executive order on the designation of competent authorities, digital communication, and disclosure of information pursuant to the CER Act (L 140)

Danske Havne would like to thank you for the opportunity to submit a consultation response to the draft executive order on the designation of competent authorities, digital communication, and the disclosure of information under the CER Act.

We would particularly like to highlight a challenge that arises from the cadastral responsibility of ports. Ports often lease land to very different types of businesses, and the same port may, for example, be home to critical entities that fall under the jurisdiction of both the Danish Energy Agency and the Danish Veterinary and Food Administration. This means that several entities in the same port area may fall under the jurisdiction of different sectoral authorities.

When a port as a landowner is also covered by the CER Act and falls under the Danish Transport Authority, this may in practice mean that several authorities may each demand supervision and information. This can create an increased administrative burden and uncertainty about responsibilities.

Danske Havne therefore recommends that a clear coordination mechanism be established between the relevant authorities and the Danish Transport Authority as the sectoral authority for ports. Without coordination, we risk overlapping supervision, conflicting requirements, and increased resource consumption. This can weaken the focus on actual safety and preparedness. Coordination therefore ensures a smoother implementation of the CER Act and avoids unnecessarily complex supervisory conditions for ports. In addition, it is appropriate to have a single communication channel for ports.

As a port with critical functions, it is essential to have clear lines of responsibility and supervision so that ports can maintain a high level of security without being bogged down in administrative processes.