Audible response

Consultation response regarding the executive order on grants for green transition fisheries

Danish Ports thanks for the opportunity to comment on the draft executive order on grants for green transition fisheries. We find it fundamentally positive that the purpose is to promote climate and environmental improvement solutions in Danish fisheries to secure future employment and to generate knowledge about new fisheries and optimization of the value of existing fisheries.

General comments

• In general, Danish Ports notes that the pool's funds are allocated on a "first-come, first-served" basis in the order in which applications are received and based on a maximum amount of up to DKK 10 million, which represents approximately 1/5 of the total size of the pool. We note that the funds in the total pool will thus potentially quickly be exhausted before the pool's application deadline of September 15, 2024. With a "first come, first served" principle, it is not guaranteed that the pool goes to the best projects for society.
• We have noted that there is a difference between the Ministry's official guidance on grants, Green Transition Fisheries from May 2024, and the Executive Order. In the Ministry's official guidance, companies are no longer included in the list of who can apply. The Executive Order reads as follows "Section 2. Grants under section 1(2)(1) and (3) may be applied for by companies, producer organizations, trade associations, fisheries associations, analytical institutes and technical or scientific bodies." Where the guidance material states, among other things, that "Fishermen's associations,
  producer organizations, trade associations, analysis institutes and technical-scientific
  bodies" can apply for the funds. Should this be understood to mean that e.g. fishing ports,
  as a company, would thus have to cooperate with e.g. a scientific/technical body in order to apply for the pool?
  
  Best regards
  Danske Havne