Mr. Eugene Drennan:

I thank the Chairman and the committee for inviting us.

There is a buzzword phrase coming into our vocabulary in the past few weeks, and it is the "level playing field", which refers to fairness in competitive trading. It is more to do with the UK but it is what we are looking for as well. We are looking for a level playing field in order that we can still compete in Europe. We are an island off an island and we cannot change the time that ferries take but it leads to logistical nightmares and other issues with which we need some assistance to keep on that playing field.

The Irish road hauliers have responded over the years to the requirements of industry and customers, whatever they may be. They have given a very good and thorough service to the customers and by doing so, we may have somewhat inadvertently created an excellent, streamlined and efficient business to take the goods of Ireland to market and the requirements of Ireland home. We must do our best and perhaps go the extra steps in order to keep that streamlined service in place. That is why we are here today.

At the outset, I commend the committee on having us here today and it is vital that it retains its vigilance and interest in what happens to our freight and transport industry in the coming months. The committee has a particular role in holding the State and its agencies to account to ensure that they do their jobs properly and place the needs and well-being of our citizens to the fore of their consideration and focus. It is very important that the committee understands that the next four weeks will be a period of unprecedented disruption for the movement of goods in Ireland. The period might stretch longer than four weeks because of stockpiling, and there may be a quiet period in January. I can reassure the committee that the disruption is on the way nonetheless.

For the first time in nearly 50 years, we will be back with customs and import controls coming and going to the island. Even if a deal is reached and implemented between the EU and the UK on tariffs, the new arrangements involving inspections by the Revenue Commissioners, the Department of Agriculture, Food and the Marine, the HSE and An Garda Síochána will create hold-ups at our ports and airports. For hauliers, these disruptions and obstructions will have catastrophic consequences if the process is not streamlined as much as possible.

For a start we do not influence the scheduling of ferries, the opening of terminals or the management of traffic at our ports and approaching roads. We are entirely dependent on the people who run the ferries, control the ports and manage the traffic to ensure that they operate effectively and efficiently. Even without the new checks and controls, our ports are heavily congested at certain peak times. God only knows what the level of disruption will be in the weeks ahead. For our members, these new checks and controls will have huge implications and massive consequences.

As hauliers we are under considerable pressure to get our goods to their destination on time and in good condition for our customers. Our drivers also operate under strict tachograph rules, which tightly regulate their driving hours. If a driver goes over his or her hours, for example, while waiting for a customs or departmental check, he or she is hit by a mandatory rest period and can go no further. The driver would have to park up in the parking spaces of these authorities and cannot move if he or she is over that time. The disruption that this will cause is immense and has the capacity to slow the licensed haulage industry and introduce a logistical nightmare.

What can be done to ensure that we reduce the risks of delay, congestion and disruption to trade? First, it is vital that there is a single entity that takes responsibility for the free movement of traffic at our ports so that this does not fall between the cracks. For example, in Dublin Port, where any delays and congestion could be acute when the new system of checks and controls is introduced, the movement of traffic into and around the port falls to no fewer than six separate entities. These are Dublin Port Company, Dublin City Council, the National Roads Authority, Transport Infrastructure Ireland, An Garda Síochána and the Department of Transport. Some single entity needs to take overall control and responsibility for traffic into out of and around the port as otherwise, the ball will be passed from Billy to Jack and we will end up with unco-ordinated chaos.

Let us tackle the obvious pressure points which we can do something about. For example, it is completely insane that the main roll-on, roll-off ferry services in Dublin Port all arrive and depart roughly within 30 minutes, 45 minutes or an hour of each other. The main four services in the morning come in between 5.30 a.m. and 6.30 a.m., and they reload and get ready to go back out to sea within 45 minutes to an hour between 8 a.m. and 9.15 a.m. This schedule ensures that there is massive pressure on facilities and the road network at specific times rather than being spread throughout the day. It makes sense that in the context of the challenges that Brexit will present, the schedules for these ferries should be spread out and not so concentrated. It is plain that we are creating this congestion ourselves and something will have to change.

This is happening when the ro-ro depots are opening in the morning. If the ferry companies do not make these changes themselves, then the port authorities should force them to do so and use whatever statutory powers they have to control ships within the ports under the Harbours Acts. There is also an added concern that we need to be assured that the ferry companies are not acting in unison, talking to each other or doing anything uncompetitive. I am not saying they are but the regulatory authorities should keep an eye on this and ensure it does not happen.

We also need the Road Safety Authority, RSA, and the Department of Transport to observe that this is going on and that this is not business as usual. They must recognise that licensed hauliers will face unprecedented challenges due to obstructions and delays and as such, they require an element of flexibility in the application of existing rules. We are not talking about compromising road safety or driver welfare, but instead about taking account of the acute pressure and stress on the sector with a more purposeful enforcement regime. They should actively pursue the scope for any derogations that can be applied for the next extraordinary period. Some of the very tight rules around the tachograph can be adjusted, as was done at the start of the Covid-19 pandemic. It is not a very big adjustment but at least it allows flexibility and an easing of how we do business and allows us to get on with it a bit better.

Finally, it is imperative that the State agencies, including the Revenue Commissioners, the HSE, the Garda Síochána and the Department of Transport, which are going to be conducting the inspections and controls at our ports, deploy adequate resources and technology to allow them to do so with the least disruption possible. The inspection points need to be manned to meet demand, and IT should be used to the maximum to ensure that drivers can prepare for and minimise delays. A risk-based approach should be adopted to inspections.

The success or failure of Ireland’s preparation for Brexit will not be on the shoulders of us but rather it will firmly rest with the State and the different State agencies that have been asked by the Government to carry out the preparations. We are asking that this committee should be fearless and relentless in holding these entities to account to do their job as efficiently as possible. They may need to take some steps outside their own remit, by which I mean that the liaison between customs staff here and their counterparts in different countries must be to facilitate the bringing about of practical steps to facilitate the streamlined movement of freight.

For example, some of the direct ferries are now in operation for the Continent and the main hub of Europe. They will be the ship of choice for most people but there will be times, perhaps as a result of sea conditions or customs requirements, when we will have to go through the land bridge of England. We also have a great fisheries industry, including shellfish, and with what is called a groupage load, a number of small fisheries people may send to destinations across northern France and perhaps down to Spain. That groupage requires a set of papers to be declared. We accept that we have to declare this in Dublin or Holyhead but what is declared in Dublin should be accepted immediately by France.

Ireland is an EU country and we are only using Britain as a land bridge. Trucks are sealed and when they arrive in France, the register coming off the ship should be accepted. We should flow on simply with the paperwork.