Mr. Aidan Flynn:

I thank the Chairman for that. The complexity of the issues faced by traders in a post-Brexit world in getting goods to market cannot be underestimated. Understanding customs union issues and Single Market issues is critical in developing effective contingency plans. The supply chain, as it currently stands, has incrementally adapted to the efficiencies the Single Market has afforded, however, a sharp shock like Brexit will have the consequence of creating significant friction in the supply chain that will result in increased costs, reduced product choice and loss of jobs. Being prepared and having flexible contingency plans will be very important in dealing with and mitigating risk in the changing trading environment. Time is also vitally important for business to prepare and adopt to the future trading environment. The EU and Ireland have publicly highlighted that protecting the integrity of, and competition within, the Single Market are of vital importance in any deal.

Future arrangements must deal not only with customs issues but with regulatory requirements such as mutual recognition of licensing for the movement of goods by road, driver licences, qualifications and insurance requirements. UK nationals living and working in Ireland are encouraged to transfer their driving licence to an Irish one, swap their UK issued driver certificate of professional competence, CPC, card for an Irish one prior to 31 October 2019 or face the prospect of driving illegally on our roads.

While road transport within the EU is harmonised and, thus, based on common EU rules, road transport between EU and non-EU countries - third countries - is still largely based on bilateral agreements between individual member states and third countries. That harmonisation will expire once the UK leaves the EU, unless and until there is an agreement between the UK and the EU. Currently, the movement of goods is taken for granted in that it happens seamlessly.

In the event of no deal, the EU Commission has agreed to extend access to the EU transport market for an additional seven months until the end of July 2020. However, cabotage will be phased out over this period.

Efficient logistics are derived from industry finding the path of least resistance to markets. The cheapest and the quickest route to the EU market that supports the just-in-time model of logistics is known as the landbridge. It involves a journey duration of 20 hours versus 40 hours on Ireland-EU direct routes and it is also three times quicker than container shipments. This is by no means the only route to market, but it relies on access to continental Europe via Great Britain. The Irish Maritime Development Office, IMDO, published a report in 2018 entitled, The Implications of Brexit on the Use of the Landbridge, which highlights that 150,000 trucks use the landbridge each year moving more than 3 million tonnes of product. Post-Brexit the landbridge will be compromised because of multi-agency checks at ports and new administrative red tape which, ultimately, will lead to increased costs and delays. In addition, Operation Brock, a newly proposed traffic management plan to reduce congestion at southern UK ports will further complicate the viability and efficiency of the landbridge.

To use the landbridge, hauliers will have to operate under the common transit convention, CTC. It requires a guarantee-bond to cover VAT and excise duties and will ensure that import and export declarations do not have to be completed while entering and exiting a third country - Great Britain - en routeto continental Europe. The CTC is closely aligned with the simplification process encouraged by Revenue for businesses to be authorised economic operator, AEO, accredited. To date, there are only 230 AEO registered companies, which is only up by 90 companies since the start of the Brexit process. Furthermore, it is taking more than nine months to attain AEO status.

There are more than 80 ferries per week between Dublin Port and Great Britain and an additional 28 per week from Rosslare to Great Britain. This compares to 17 ferries per week between Ireland and continental Europe for roll on-roll off and lo-lo. An issue for consideration post-Brexit in the event of no deal is the scheduling of ferries, particularly in Dublin Port. Currently, ro-ro ferries are arriving into Dublin Port with up to a 9.5 km lane of trucks starting at 5 a.m. every morning. The ferry companies in most instances are arriving in convoy with 30 minutes separating four ferry arrivals from time to time. In a post-Brexit world this will add strain on the system as all these drivers and trucks will have to be processed at the same time. This has implications for everyone, including the development of logjams in the system that perhaps could be avoided if the arrivals were staggered.

The importance of having contingency plans cannot be denied but this in itself will not result in 100% compliance at ports. The reality is that planning, training, upskilling, better procurement practices, consignor liability, shared responsibility and increased awareness of one's supply chain is a start in determining the best way to get goods into and out of the country as efficiently as possible.

FTA Ireland welcomes the supports for industry, such as the Clear Customs initiative, and Enterprise Ireland and InterTradeIreland supports. These solutions only cover some of the industry's needs. A more all-inclusive approach needs to takento support all in the supply chain, and one sector, in particular, that has been overlooked is the haulage sector. The burden of compliance will be levelled at the haulage operator which is at the mercy of its clients and consignors. Help and assistance need to be provided for hauliers as a matter of urgency to aid their Brexit preparations. Without hauliers, goods will not get moved and without compliance, hauliers goods will not get delivered on time. All must be working together to ensure the realities of a no-deal Brexit are understood.

Revenue advises that only 2% of vehicles will require physical checks and only 6% will require documentary checks, which will not take as long. This is predicated on there being 100% compliance with declarations and documents for the loads on the vehicles. Irish business will go from making 1.7 million declarations per annum to making more than 20 million declarations per annum. Revenue will be available to work 24-7 but it will expect to have access to customs agents 24-7 in the event of errors with declarations. That will be problematic as there is a lack of agents available and working in Ireland with the necessary resources and competencies at the moment. The burden for agrifoods is much more pronounced with 100% documentary checks and between 20% and 50% mandatory physical checks for meat, poultry, eggs, fish and even honey.

To assist industry preparation, regulatory bodies must consider doing dry runs in the ports to trial the new post-Brexit requirements of customs checks, driver routing - for instance, drivers need smart phones to access a Revenue routing site 20 minutes from docking at Dublin Port - and sanitary and phytosanitary, SPS, checks. Publication of routing and traffic plans in and around ports are long overdue and engagement with all stakeholders, including representative associations, is of vital importance to ensure industry has all the necessary information.

The recently announced Operation Purge, where in the event of congestion in Dublin Port trucks will be directed to park up at service stations and other areas off the motorway network that they normally use until congestion at the port eases has a sense of a half-baked plan. Given the fact that trucks travel from all over Ireland to Dublin Port, one would expect a more detailed and thought-out plan to take account of the lack of facilities currently available for drivers. Consideration should be given to how to communicate to the haulage sector effectively to notify drivers that the port is closed and to park up in designated parking areas until further notice.

Given the inevitability of delays on arrival at ports from Great Britain, welfare facilities and rest areas are needed for drivers. Drivers need to understand and be advised of the length of delays to expect from the outset and communication between regulatory authorities and drivers is very important to ensuring speedy processing and aid the efficiencies in getting products to market.

All Brexit preparation-related training should benefit from increased support through the likes of Skillnet. FTA Ireland calls on Government to categorise all Brexit training to include customs courses, preparation for distribution of agrifoods, supply chain adaptation and preparation for the haulage sector to receive up to 80% funding through Skillnet. This can be done by designating this training under the employment activation funding. Given the critical nature of Brexit and the implications for the Irish economy, designation through the employment activation fund will enable the level of funding required that will act as a vital incentive to aid the freight distribution and logistics sector to upskill, as necessary, in preparation for Brexit.

With regard to infrastructure, over 90% of all trade with the UK transits via Dublin Port. There is an over-reliance on Dublin for connectivity with the UK. FTA Ireland is calling on the Government to support investment and planning in our other strategic ports, such as Waterford and Rosslare, as this will result in reduced congestion in Dublin and facilitate rural economic development and new routes to market. It is vital that the obvious future pinch points are assessed now and that pre-emptive measures are taken that will facilitate dynamic growth and opportunity for both import and export activity in Ireland.

There will be many Government agencies charged with checking goods, paperwork and people. It is very important that there are inter-departmental synergies in areas such as shared intelligence, a pragmatic approach to dealing with traders, and even a helpful demeanour. Fact sheets and information and guidance must be produced for industry to aid engagement with these bodies. This will raise levels of awareness and help with the flow of traffic.

Ports must reach out to all stakeholders to communicate more effectively their plans for preparedness and to look for reasonable input in providing the best possible solutions. Space is an issue for most ports, with a finite amount of space available for parking and checking trucks. However, the haulage sector must be engaged to fully understand the new checking facilities and traffic management so they can plan for them efficiently. The infrastructure must take account of tachograph rules, welfare facilities must be provided for drivers in the event of delays, and the ports must be adequately staffed to manage traffic and traffic flow.

Finally, it is vital that there is a period of transition to the new trading environment. While we are working hard as an industry to prepare, the reality is there will be significant learning once Brexit happens. We need to respect the fact that the transition to the new training environment will not be easy for industry or for regulatory bodies. Mutual respect, clear communication, and stakeholder engagement will be vital in adapting to the new post-Brexit trading environment. I thank the committee for its time.