Erhvervsudvalget 2019-20
ERU Alm.del Bilag 29
Offentligt
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Boulevard du Régent 43/44
1000 Brussels
Belgium
T +32 2 430 25 78
[email protected]
17 October 2019
www.empa-pilots.eu
Erhvervsudvalget
Danish Parliament, Christiansborg
1240 COPENHAGEN K
Denmark
email:
[email protected]
RE:
“MARKET
ACCESS” IN DANISH STRAIT PILOTAGE
Dear,
We are writing to you in order to explain our concerns regarding the planned reform
to open up the Danish strait pilotage to full market access on 1
st
January 2020.
EMPA, the European Maritime Pilots’ Association, is a professional, non-profit
organisation, with office in Belgium since 1963. EMPA represents about 5.000
maritime pilots from 25 European countries with the aim of promoting efficient and safe
pilotage in European ports and fairways. EMPA has been appointed by the European
Commission as a member of the European Ports Forum.
We enclose our hearing response letter of 17 January 2014, in which EMPA advised against
the amendments proposed to the Danish pilotage act at that time. We still emphasize that
pilotage is a service of public interest,
that involves safety of life, port infrastructure,
navigation and protection of the environment. Open competition will compromise the
professional integrity that is essential for service providers performing these critical tasks in
a safe and highly qualified manner, thus endangering safety at sea. Our understanding is
that the legislative process in 2014 was based on the presumption that the EU would compel
pilotage to be open to market access. As we expand on in the following paragraphs, this
presumption was not correct.
Across Europe, maritime pilotage is carried out by professional pilots operating with full
integrity, on behalf of the society. All other nations recognise that their domestic pilotage
services represent
important safety critical infrastructure, which is regarded as
imperative to retain under full national sovereignty.
The European Union has recently emphasized this public service role of maritime pilots, by
rejecting proposals to introduce commercial market philosophies to pilotage.
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EUROPEAN MARITIME PILOTS’ ASSOCIATION
 ERU, Alm.del - 2019-20 - Bilag 29: Henvendelse af 17/10-19 fra EMPA, vedrørende lodsning
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The justification tabled by European lawmakers in the legislative process of the Port
Services Regulation explains this very clearly:
“Pilotage
provides an essential and unique service to the shipping industry, which if
open to competition would jeopardize maritime safety and security, the protection of
the environment and the efficiency of ports”
1
.
These same principles of indispensable professional integrity, and the public service role of
maritime pilots that apply to port pilotage in Europe under the scope of the Port Services
Regulation, should of course also apply to the challenging strait pilotage in the important
fairways of the Danish territorial waters; the straits and the belts.
On this background, EMPA has written to Minister Simon Kollerup and advised the
Danish government to reconsider the implementation of market access of the pilotage
services in the Danish straits and belts.
With reference to the ongoing service check of the pilotage act, we kindly ask you to
consider our arguments and assist us in finding an appropriate and sustainable
solution for this Danish critical infrastructure.
EMPA remains at your disposal if additional information or dialogue is required on these
subjects.
Sincerely,
EMPA
– The European Maritime Pilots’ Association
Capt. Stein Inge Dahn
President
Aileen Van Raemdonck
Secretary General
CC: Danske Lodser,
email:
[email protected];
Liza Christensen, email:
[email protected];
Signe Bruunsgaard, email:
[email protected]
1 enclosure: Hearing response from EMPA, 17
th
January 2014
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Justification Amendment 533
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EUROPEAN MARITIME PILOTS’
ASSOCIATION