Hørringssvar

Behandling af cirkulær økonomi i Europa-Parlamentet

I fobindelse med Europa-Parlamentets behandling af Europa-Kommissionens forslag til cirkulær økonomi har Danske Havne nedenstående forslag til en nuanceret behandling af forslaget. Se desuden Danske Havnes høringssvar fra den 5. januar 2016 vedr. den intitiale høring af Kommissionens forslag. Danske Havnes kommentarer til Europa-Parlamentet behandling af forslaget: The waste material flow in the European and international transport chain often includes ports. Examples of valuable waste is the recycling of wind turbine parts, scrapping of offshore drilling rigs, offshore cables, collection of slop oil and gas from cargo ships. In addition, many other types of waste handled in companies at the ports. With targets set on reducing the waste created, EU should also be able to evaluate to which degree the waste volumes have decreased, incl. hazardous wastes. Ports receive limited amounts of hazardous waste like waste oil, paint residues or the like from the ships. With information from the delivered ship waste, as reported in via the Safe Sea Net, it should be possible to register the quantity, type and origin of all wastes incl. the hazardous waste delivered. Danish Ports encourages the establishment of additional BREFs (Best Available Techniques Reference Documents) for the receiving and handling of hazardous wastes such as slop oil, chemical residues, waste from gas treatment, scrubber sludge etc. The inclusion of new types of waste in the different provisions of the directive should be carefully considered in consultation with the industry. A new type of waste is scrubber waste. Guidance on the handling and discarding of the harmful scrubber sludge would be helpful for the sector. Most challenges lie upstream in the waste treatment chain and the ports are part of the solution and not of the problem:

1. A strong focus on reducing plastic and micro plastic in the environment should partly be solved at local sewage treatment facilities. HELCOM regulations push forward requirements for delivering all ship sewage (black and grey water) at port or discarding the sewage onboard on incineration facilities. The new requirements from 2019 for new built vessels or 2021 for existing vessels will create larger volumes of sewage to be handled at mainly cruise ports. A challenge up stream is disharmonized practice not only between member states but also from municipality to municipality within the member states.
2. There lies a potential in a reclassification of sediments from dredging projects from waste material to non waste. The aim is to reduce landfill and the burden of handling sediments as waste as soon as they are raised above the water level. Some member states (i.e. Denmark) define ports’ spraying fields as landfill, even though they in many ways differ from normal landfills. As increasing attention is paid to the environment and designation of Natura 2000 sites, it has become very difficult for ports to be allowed to handle the material at sea (dumping within a specified area). A spraying field is a coastal area, which is surrounded by dams that keep the sediment. The material flushed in at the area includes few environmental contaminants. There are no recorded negative effects on the environment from the spraying fields.

The acceptance of new types of port services could stimulate the reduction of waste and efficiency of energy consumed in local industry. The ports’ role as initiator to industrial symbiosis including industry within the port land could stimulate innovative industrial processes. Ports could for example, distribute surplus electricity and heat from industry located in the port area as well as trading reusable substances from the ports reception facilities and other local generated waste products. EU programs for repair and sustainability analysis. The port service of larger ships, and thus the need for efficient loading and unloading, requires investments in the maritime service vehicles, including conversion to electric motors, cranes which produce power during the lifting operation, etc. This shift to less resource-intensive operations can be facilitated by concrete programs in the Horizon 2020 program. Similarly, subsidies for sustainability analysis in ports in relation to waste streams, energy consumption, etc. can help to promote symbiosis projects. For nærmere orientering kontakt venligst erhvervspolitisk konsulent Bjarne Løf Henriksen