Hearing response

Consultation response to the 4 secondary legislative acts for port reception facilities directives

Danske Havne thanks you for the opportunity to submit a consultation response to the 4 secondary legal acts for port reception facilities directives

General remarks

Danish Ports welcomes the idea that waste should not end up in the sea, but should be delivered to the ports.

Overall, Danske Havne's position is that it is generally important that all legal acts are designed as simply as possible. So that it does not result in a large administrative burden for ports and authorities to comply with the legal acts.

The 4 legal acts.

Art. 7.4 on defining the methods for calculating the sufficient dedicated storage capacity (i.a. relevant 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 fears 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 be done via Safe Sea Net, for example. Authorities and ports can then check the information in Safe Sea Net if there is suspicion of data fraud.

The calculations should also include the number of people on board, as this has a large impact on some of the amounts of 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") must be based on a simple system that is manageable - also for small ports - it could 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 hand over some of the fished 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 of the origin of the waste, the amount of fished-up waste and how it can best be 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