Audible response
Draft bill amending various laws within the remit of the Ministry of Transport (Strengthened preparedness in the transport sector)
Danske Havne would like to thank you for the opportunity to comment on the draft bill amending various laws within the remit of the Ministry of Transport and hereby submits its comments.
Danske Havne considers the proposed legislative changes, which aim to strengthen preparedness in the transport 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 a high level of preparedness in port areas. Danish commercial ports wish to play a role in supporting this work.
Comments on new authorization provision in the Port Act
The amendment to Section 6(3) means that, if an agreement cannot be reached on market terms, the Minister of Transport may require ports to prioritize specific areas for military or civil emergency purposes in return for full compensation. Danske Havne 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 there can be no doubt.
The fact that commercial ports may be required to allocate areas for military, security, and emergency response purposes can have significant consequences for a port's business and development projects. If, for example, a port has invested significant funds in an expansion where the planned businesses have not yet been established, an order to set aside land could undermine both the investment and the port's finances. It is therefore crucial that the compensation covers the full economic value in order to avoid disproportionate damage to the port's operations and future development.
In addition, we would like to emphasize that the inclusion of port areas must be proportional, so that the port's other important tasks, such as ensuring supplies, are also taken into account.
Comments on amendments to the Aviation Act
Danske Havne acknowledges that the bill provides for the neutralization of uncooperative drones. The proposal emphasizes 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 is appropriate for each individual port.
It is crucial that any future guidelines clarify the responsibilities of ports, including what ports are and are not allowed to do. This is also a question of resources and competencies. It is therefore positive that a voluntary scheme is being proposed.
Finally, we look forward to further clarification of what exactly is meant by "neutralizing an uncooperative drone," including the methods associated with this.
The comments raised reflect experiences and views that Danske Havne has gathered from a wide range of Danish commercial ports. It is therefore our overall assessment that the bill should be amended on the points mentioned in order to ensure a clear framework that enables ports to continue to perform their essential role in both security of supply and emergency preparedness.
