Audible response
Safe coexistence – Strategy for civil drones in Danish airspace
Danske Havne would like to thank you for the opportunity to comment on the draft Strategy for Civil Drones in Danish Airspace.
Danske Havne is the trade association for Danish commercial ports, which play a central role in security of supply, export/import, and the green transition. Ports are critical infrastructure and operating environments with close interaction between ship traffic and land transport.
Danske Havne welcomes the strategy's ambition to both strengthen public safety and create better conditions for drone use. We believe that drones offer considerable potential for commercial ports – for example, in relation to facility inspection, monitoring of quays and areas, environmental tasks and, in the long term, logistics and emergency response. However, this requires a clear and practical framework.
Developments in drone technology are moving rapidly, and it is therefore positive that a drone strategy is now being introduced that can provide a clearer framework and support development.
In this connection, we would like to highlight the following comments:
Ports as critical infrastructure
It is crucial that the implementation of the strategy takes into account that commercial ports are critical infrastructure with high requirements for security and operational stability. Danske Havne therefore supports measures that strengthen ports' ability to identify drones in the airspace above port areas. This is to rule out the possibility of potentially uncooperative drones. This is well balanced in the strategy.
Furthermore, it is positive that requirements for reporting flight plans for drones are being established. Over time, this will increase safety and reduce illegal drone flights over port areas, as drone pilots will be warned before carrying out an illegal flight.
Section 6.1 on access to registered flight routes and contact details of drone pilots for authorities and companies is therefore also very positive. It can resolve a number of issues relating to registered drones that go astray, as it is possible to verify the drone and contact the pilot directly.
Specific comments:
- With regard to Box 4 on geographical drone zones, commercial ports should be specifically mentioned under the blue zone.
- With regard to section 3.2 on the implementation of powers to neutralize uncooperative drones, it is positive that the scheme is voluntary and is highlighted as a supplement to the work of the authorities. In line with this, it is essential that the relevant authorities, such as the Armed Forces, the Police, and the Danish Transport Authority, have the necessary resources to handle the strategy's increased focus on controlling drone flights and intervening against uncooperative drones.
Need for clear and flexible frameworks for legal drone use over port areas
Many ports have a specific desire to use drones in their daily operations, for example for inspection, surveillance, and emergency response. It is therefore important that rules and systems (including flight plan notification and electronic visibility) are designed in such a way that they also work in practice for commercial users. Digital solutions should be intuitive, reliable, and support repetitive, planned operations.
Potential for innovation and green transition
Drones may eventually become an important tool in the work with efficient operations, climate adaptation, and green transition in ports. It is therefore positive that the strategy also focuses on supporting drone innovation. Danske Havne calls for the creation of opportunities for pilot projects and test environments in collaboration with ports, where new solutions can be tested under controlled conditions.
