Mr. Eugene Drennan:

We are very happy to be here. We thank the committee for the invitation. I know many of the faces at the committee from other lobbying engagements and delegations and trying to get different things done over the years. I am a long time at this. At the outset, we in the Irish Road Haulage Association welcome the new look and easements that have been given to the Northern Ireland protocol and the great work that has been done on it. As built into my speech, it is necessary for all commentators, especially the elected ones and the State to separate the political from the commercial. In our statement we will focus more on the commercial impact of the protocol and what we seek in order to move forward.

I am the president of the Irish Road Haulage Association. Mr. John Nolan is a long-serving member of the management team and is the secretary of the association. The introduction of Brexit has faded to a degree for the public but it is still part of our lives all day every day and has caused us much grief. Covid-19 and Brexit disrupted freight and the movement of goods. The changes brought about by Brexit remain significant and enduring. Licensed hauliers are to the fore in dealing with the outcome and consequences. We are the people who have to take longer routes to the Continent, queue at the checkpoints, produce the declarations, endure extra expense in administration and deal with the various side effects of Brexit and with increased costs in the main thrust of bringing freight to and from Ireland. To put it in perspective, we have endured delays of up to four days. Hauliers and drivers have experienced disruptions.

This is due to the many checks imposed by the different agencies who do not have an integrated, efficient approval system. We have the possibility of being delayed by these agencies. This delay is then multiplied by two for the UK side if a haulier is travelling to or through the UK. These impacts are coming at a time of unprecedented challenge for our members, with a mix of driver shortages, hugely inflated operating costs, extremely stiff competition and the regulatory regime which seems to target the compliant rather than the non-compliant.

A strong, competitive, dynamic and versatile indigenous national road transport fleet is imperative for Ireland as it is for any island because of the nature of islands. As an island state, Ireland requires a reliable national haulage fleet to keep the wheels of commerce moving. The disruption inflicted by the pandemic and Brexit have emphasised just how important a function Irish Road Haulage Association, IRHA, members play in the efficient and timely delivery of goods throughout Ireland and to our major trading partners Any interference in the efficiency of our haulage sector will lead to shortages in the availability of basic goods, damage to the interests of trade and industry and significant interruption to our international mercantile trade.

I will detail some of the biggest changes Brexit has brought about for our sector. In many senses, the changes that Brexit has brought have been revolutionary for our sector, primarily as a consequence of the changes in direct connectivity between Ireland and continental Europe. For instance, before Brexit there were four operators between Ireland and continental Europe, offering 17 sailings per week. Post Brexit, there are in excess of six operators offering more than 70 sailings per week. This accommodates more than 180,000 roll-on and roll-off journeys that previously used the UK land bridge and are now a direct ferry journey to and from continental Europe. This is certainly well in excess of the six additional sailings suggested as being sufficient by a body of the State, the Irish Maritime Development Office, which had statistics but these were flawed.

With direct ferries to the Continent now the norm rather than the use of the UK land bridge, there are a number of significant impacts for hauliers. The cost of getting to the Continent is higher, with an average cost increase of more than €300 per journey. That average cost takes account of the cost of diesel and the cost of going through the UK. The driver shortage is exacerbated by the fact that drivers are now at sea for between 18 and 48 hours a week. This has changed the pattern of driver hours to 36 hours, plus sailing, and 20 hours to 35 hours driving in the totality of hours drivers are allowed to work or to drive. Some 60% of loads are now travelling to the Continent unaccompanied to reduce costs and to use drivers and vehicles more effectively. This has increased the need for additional trailers, given the amount of time the trailers are at sea. There are also significant restrictions for drivers due to cabotage limitations, tachograph restrictions and mandatory closures of many EU countries' roads to HGVs during the weekend or part of the weekend. The absence of capacity to backfill empty trailers, which has become more relevant in the UK recently, places significant additional costs on hauliers which need to be met.

Brexit has introduced lasting cost, logistical and operational challenges for licensed hauliers. A question worth asking at this point is whether Ireland was well prepared for Brexit. At this juncture, are there measures we can take to improve connectivity between Ireland, Britain and Europe? This is very important in light of the events of recent days. The Brexit stakeholder consultative committee did some great work in preparing our ports for the impact of Brexit. However, there are lessons to be learned. We need further integration and upgrading of systems across Departments and Government agencies to reduce the administrative workload on the road haulage sector and produce better efficiencies.

Regarding delays at the ports, we need the Departments and agencies to review the processes to alleviate delays. For example, communications to drivers needs to be terminal specific. We also need to see checks that are risk-based rather than reactive and we need to see the State use robust technology to reduce delays and red tape and improve connectivity. Specifically, we would like to see the use of any IT arrangements governing goods travelling between the ports in Northern Ireland and Britain applying to the ports in the Republic of Ireland.

There are a number of measures and initiatives that would assist connectivity and trade if embraced by the Irish and EU customs. The pre-Brexit trans-European transport network, TEN-T, route was the UK land bridge. The TEN-T comprises the longer road corridors of Europe, part of which is the Ghyvelde corridor area in northern France. This corridor needs to be extended from Calais to Dunkirk and Cherbourg, where the direct ferries arrive from Ireland. As a result, it could include all of Ireland's 1,000 km of motorway, along with Dublin and Rosslare. That is the totality of TEN-T.

The impact of EU-UK negotiations on freight movements across the Irish Sea will need to be kept under review to ensure obligations and requirements do not end up being imposed on licensed hauliers arriving at ports in the Republic of Ireland which are not present for hauliers arriving in Northern Ireland and intending to bring their goods south of the Border. We are aware that some significant distribution chains in the Republic of Ireland were being serviced from Northern Ireland ports because of the absence of checks or more simplified checks at these ports heretofore.

Considering the importance of Britain for Ireland from a trade supply chain and road transport perspective, we also believe a permanent public-private body should be created at the Irish level to monitor the situation, send early warning signals and make recommendations to both the Irish Government and the specialised committee on road transport created under the EU-UK Trade and Cooperation Agreement. As the most representative industry organisation, the Irish Road Haulage Association would be interested in being part of such a body. In addition, it is of strategic importance that Ireland is represented permanently on the specialised committee on road transport under the co-operation agreement to increase efficiency of the Irish input. The Irish Road Haulage Association could also be granted an observer status as we are one of the main bodies representing the industry.

To address ongoing challenges posed by Brexit, the Government should review the existing checks imposed by the relevant authorities at Irish ports to determine if a different approach can be implemented, which would reduce daily red tape and costs. This has never been more significant than in the light of this week's news. If the State facilities at ports are not needed, then the land should be handed back to the port so that it can be used for the transit storage of goods, for parking for hauliers and serviced as waiting areas to get to different parts of the port. From what I have just said, I am supportive of what the management of Dublin Port said previously, if not on all points, then certainly on getting the land back if it is not needed. We need to look at measures to re-establish the level and extent of connectivity between Ireland and Great Britain. A new seamless approach to transiting through Britain needs to be implemented instead of the reduced services and increased delays that exist at present. This is particularly important for fresh food and other fresh goods There also needs to be a review of the IT platforms being used by the Irish statutory authorities to increase dependability, reduce delays and ensure reliability. We also need to maximise the use of IT to provide proper risk-based approaches to checks and inspections. The recent agreement between the EU and the UK on sharing information should be extended here. We should adopt a consistent approach to addressing the challenges posed by the Border with Northern Ireland. Users of ports in the Republic of Ireland should be in a position of equivalence with licensed hauliers arriving into northern ports with goods destined for the Republic of Ireland.

In summary, the Irish Road Haulage Association believes Brexit has had a significant impact on connectivity between Ireland, Britain and the EU.

We can and should do more to reduce and mitigate these impacts, and we hope this committee will seek to ensure the State authorities remain active to ensure the negative consequences of Brexit on the transport of goods between Ireland and the EU are minimised to the greatest extent possible.