Audible response

Consultation response to the proposal to amend the Planning Act and the Act on the Rental of Real Estate for Holiday and Leisure Purposes etc. and Camping etc.

Danish Ports would like to thank you for the opportunity to provide comments on the draft executive order on the proposal for an act amending the Planning Act and the Act on the letting of real estate for holiday and leisure purposes etc. and camping etc.

General remarks
Danish commercial ports perform important societal tasks of local, regional and national importance. The ports play an important role as regional and national transport hubs for import and export, security of supply, energy supply, ferry traffic, military activity and, not least, the green transition. In addition, there is a wide range of traditional port industries within transport, logistics and production, which create growth and jobs in and around the Danish commercial ports.

With the current geopolitical situation and in line with society's green transition and the ports' contribution to the expansion of offshore wind and green technologies, there is a need for greater focus on the fundamental and principled protection of national interests in and around Danish commercial ports. There is a need for uniform and long-term protection that provides an adequate starting point for the many and costly investments in and around the port areas in the coming years.

If commercial ports are to increasingly contribute to the development of green industry, energy transition and sustainable production, while at the same time supporting the growth of traditional port industries, it is crucial to protect the port areas and ensure the ports' national interests.

Specific comments on the bill
S22, episodes 1-3
Section 29, subsections 2 and 3 are repealed and replaced by the following: The Minister of Defence and the Minister of Transport may object to local plan proposals on the basis of special considerations for which each of these ministers is responsible.

When the bill amending the Planning Act and the Summer House Act thus contains a proposal that the authority to object to proposals for municipal planning that are not in accordance with national interests will be transferred from the Minister for Urban and Rural Affairs to the sector ministers, including the Minister of Transport and the Minister of Defence, then Danish Ports would like to highlight the importance of the sector ministers submitting objections with veto effect when a conflict is discovered with regard to national interests, unless these can be documented to be of a completely subordinate nature in relation to the development of the ports.

With the agreement Denmark in better balance – Better framework for municipalities, citizens and businesses throughout the country between the Social Democrats, the Liberal Party, the Danish People's Party and the Conservative People's Party, a number of amendments to the Planning Act were adopted in 2017.

As a follow-up to the evaluation of the Planning Act, the government (Social Democracy), the Liberal Party, the Danish People's Party and the Conservative People's Party entered into a political agreement on June 15, 2022, in which the protection of national interests regarding commercial ports is stated:  

"Protection of commercial ports: To better protect commercial ports, national interests regarding commercial ports will be defined in the upcoming overview of national interests in municipal planning. The national interests in commercial ports will be handled by the Ministry of Transport with a view to ensuring sufficient port capacity and location options for companies with special needs for port location, security of supply and maritime transport."

Kind regards
Danish Ports