Audible response
Comments on the draft bill to amend the Emergency Preparedness Act (Strengthening of Operational Preparedness and Emergency Planning, etc.)
Danish Ports would like to express its gratitude for the opportunity to submit comments on the draft bill to amend the Emergency Preparedness Act.
Danish Ports represents Denmark’s commercial ports, which play a central role in security of supply, international trade, energy, military mobility, and transportation. Ports therefore constitute critical infrastructure and, in many cases, will be among the first places where the consequences of major accidents, extreme weather events, hybrid incidents, or acts of war become apparent. It is therefore crucial that emergency response legislation supports effective coordination between state authorities, municipalities, and ports, as ports are increasingly involved in the management of societal crises.
Against this backdrop, Danske Havne generally supports the bill’s aim of strengthening society’s overall resilience and preparedness in an era marked by a more complex threat and risk landscape. Danske Havne’s general comments are provided below.
Ports as Key Players in Crisis Management
Danish commercial ports serve as logistical hubs for supply, transportation, and energy. In crisis situations, these ports are often critical to civil emergency response, security of supply, and, in some cases, military logistics.
It is therefore encouraging that the bill emphasizes strengthened cooperation between emergency response agencies and other entities responsible for maintaining and ensuring the continuity of critical societal functions.
To ensure a robust and effective emergency response, it is important that this collaboration also includes the entities that actually operate the critical infrastructure.
Strengthened cooperation in emergency planning
The bill aims to strengthen emergency planning across the national, regional, and municipal levels. Danske Havne considers this appropriate.
Since many ports are municipally owned and also serve as critical infrastructure, it is important that municipal emergency planning be conducted in close consultation with the ports. Port areas often involve complex activities, including the handling of cargo, fuels, chemicals, and energy infrastructure, which can place special demands on emergency response and coordination.
Danish Ports therefore recommends the following:
1. Inclusion of critical infrastructure in emergency planning
Danish Ports recommends that contingency planning place an emphasis on involving operators of critical infrastructure—including ports.
This can be achieved, for example, by involving relevant ports in the development of municipal and regional emergency response plans, as well as in drills and collaborative forums in the field of emergency response.
2. Clear coordination between public authorities and infrastructure owners
For ports and other infrastructure owners, it is important that the division of responsibilities among state agencies, municipalities, and emergency management authorities is clear in the event of major incidents.
Danish Ports therefore recommends that the focus remain on clear cooperation and coordination structures between emergency response authorities and the owners or operators of critical infrastructure.
3. Focus on hybrid threats and societal resilience
The bill reflects a heightened focus on hybrid threats and a more complex security landscape. In this context, ports may be particularly vulnerable, as they serve as key hubs in supply chains. Several Danish commercial ports have already experienced incidents that can be characterized as hybrid threats, including cyberattacks and drone incidents.
Danish Ports notes that the term “hybrid actions” appears in several places in the bill but is not defined in detail in the text of the bill itself. To ensure predictability for the parties involved in emergency response cooperation—including owners and operators of critical infrastructure—consideration could be given to further clarifying the term, for example in the legislative notes or in subsequent guidance.
Concluding remarks
Danish Ports generally supports the bill’s aim of strengthening Denmark’s emergency preparedness and crisis management.
However, it is important that efforts to ensure emergency preparedness and societal resilience are carried out in close collaboration with the entities that operate and own critical infrastructure in Denmark.
Danish Ports is pleased to contribute to the ongoing dialogue on the role of ports in the overall national emergency response system.
