Audible response
Consultation response to the 4 secondary legislative acts for port reception facilities directives
Danish Ports thanks for the opportunity to submit a consultation response to the 4 secondary legislative acts for directives on port reception facilities
General remarks
Danish Ports welcomes the idea that waste should not end up in the sea, but should be delivered to the ports.
In general, Port Denmark's position is that it is important that all legal acts are drafted as simply as possible. So that it does not entail a large administrative burden for ports and authorities to follow the legal acts.
The 4 legal acts.
Art. 7.4 on determining the methods for calculating the sufficient dedicated storage capacity (relevant, inter alia, for the implementation of exemptions from waste delivery)
Art. 8.5 on the reduction of fees for ships (a "green ship scheme")
Art. 8.7 on guidelines for the collection of monitoring data on the extent and quantity of passively fished waste
Art. 11.2 on guidelines for the selection of ships for inspection ("Union risk-based selection mechanism"
In relation to Art. 7.4, Danish Ports fear that ships may bring very large amounts of waste to selected ports - waste tourism. These will typically be ports where it is easy and convenient to deliver the waste. This can mean very large extra costs for the ports in question. It is therefore important that it is easy to check whether the ships have sufficient storage capacity. This could, for example, be shown via Safe Sea Net. Then authorities and ports can check the information in Safe Sea Net if there is any suspicion of data fraud.
Calculations should also include the number of people on board, as this has a large impact on some of the waste produced on the ship.
In relation to Art. 8.5 (we have not yet seen a concept paper), Danish Ports believes that the reduction of fees for ships (a "green ship scheme") should be based on a simple system that is manageable - also for small ports - it could for example be a green ship scheme - labeling via Safe Sea net.
Art. 8.7 on guidelines for the collection of monitoring data on the extent and quantity of passively fished waste.
We have not yet seen a concept paper, but Danish Ports can inform you that the vast majority of Danish Fishing Ports already receive fished waste free of charge. They also deliver some of the waste for recycling at e.g. Plastix. Danish Ports believes that the system should be as simple as possible.
Danish Ports would like to welcome a study on the origin of the waste, the amount of discarded waste and how it is best recycled, but not at the expense of the ports. It is the ports that are cleaning up for other parties.
Sincerely yours
Kasper Ullum
Environmental consultant
Danish Ports