Consultation Responses
Draft Bill to Amend Various Laws Within the Jurisdiction of the Ministry of Transportation (Strengthened Preparedness in the Transportation Sector)
Danish Ports would like to express its gratitude for the opportunity to provide comments on the draft bill to amend various laws within the Ministry of Transport’s purview and hereby submits its comments.
Danish Ports considers the proposed legislative changes, which aim to strengthen emergency preparedness in the transportation sector, to be significant. Ports constitute critical infrastructure and play a central role in ensuring security of supply in Denmark. It is therefore crucial to ensure strong emergency preparedness in port areas. Danish commercial ports wish to play a role in supporting this effort.
Comments on a New Authorization Provision in the Port Act
The amendment to Section 6, subsection 3, provides that the Minister of Transport—if an agreement cannot be reached on market terms—may require ports to set aside specific areas for military or civil emergency preparedness purposes in exchange for full compensation. Danish Ports interprets this as a guarantee of full compensation in the event of an order to reserve areas, for example for military use. This should be clearly stated in the text of the law so that no doubt can arise.
The fact that commercial ports may be required to set aside land for military, security, and emergency response purposes can have significant consequences for a port’s business and development projects. For example, if a port has invested significant funds in an expansion where the planned businesses have not yet been established, such a mandate could undermine both the investment and the port’s finances. It is therefore crucial that compensation cover the full economic value to avoid disproportionate harm to the port’s operations and future development.
In addition, we would like to emphasize that the use of port areas must be proportionate, so that the port’s other essential functions—such as ensuring the supply of goods—are also taken into account.
Comments on the Amendment to the Aviation Act
Danish Ports acknowledges that the bill provides for the neutralization of non-cooperative drones. The proposal underscores the role of ports as critical infrastructure and the importance of protecting them. It is positive that the scheme is designed to be voluntary, as it is essential that the framework be appropriate for each individual port.
It is crucial that any future guidelines clearly define the responsibilities of ports—including what ports are specifically permitted and prohibited from doing. This is also a matter of resources and expertise. Therefore, it is positive that a voluntary scheme is being proposed.
Finally, we look forward to a more detailed clarification of what exactly is meant by “neutralizing a non-cooperative drone,” including the methods involved.
The comments raised reflect the experiences and views that Danske Havne has gathered from a broad range of Danish commercial ports. It is therefore our overall assessment that the bill should be amended on the points mentioned to ensure a clear framework that enables the ports to continue fulfilling their vital role in both security of supply and emergency preparedness.
