Mr. Richard O'Connor:

That is one of the difficulties with the transition. Creosote has been allowed in four key use classes up to this point: telecommunications and electricity poles; railway sleepers; marine timber, historically, for marine ports; and fencing for equine, agricultural stakes and fruit stakes that would typically be used across Europe in vineyards etc. The ban that is taking place affects fencing only and there is an extension for another seven years until October 2029 with respect to sleepers and poles. From my perspective, we will face this issue again for the utility sector in Ireland because it will not have an alternative to creosote for pole infrastructure at that point in time. That is a significant issue in its own right for that period.

Returning to fencing, with the approvals of the two new oils, there has not been sufficient time to go through the regulatory process for treaters. Treaters, such as ourselves, if you consider what we need to do in Ireland, need to work with the local authority that we are affiliated with to make sure that the pressure treatment that we do fits within the environmental constraints of our industrial emissions licence, which means engaging with the Environmental Protection Agency, EPA, directly to ensure that we are treating to the correct parameters of the licence. Because the oils are relatively new and the biocides within the oils are relatively new, we have to go through a significant process to understand, in terms of treating the oil and what residue might come out of the product at a local level, how we deal with that within the physical environment where we are treating. We have a wastewater treatment system in PDM at the minute that deals with any by-product or run-off from creosote on the site. We have to get to an emissions standard with respect to that water, which we do, and we are compliant in that regard. However, we have to go through the same process now with the new oils. Because they are only available and approved relatively recently, we are only beginning to get an understanding of what it will take to treat those chemicals to the industrial emissions standards required by the EPA. It is the same issue right across Europe for those treaters which are choosing to stay in creosote or to move beyond creosote into the new oil. All of them have to go through the same process. That does not happen in six months. That is a much longer process.

On top of that, with best available techniques now required under European legislation, we, in upgrading our facilities, must apply best available techniques. The technologies used to treat today are very different to the technologies that exist in most creosote producers, including PDM, which have been treating for the past 45 or 50 years. The technologies are different and they require significant capital investment.

From our perspective, having a 180-day period from the end of October 2022 up to the end of April 2023 to consider the transition that we need to make is far short of the time required to go through that process. On top of that, post pandemic, in upgrading new facilities, the lead time on the infrastructure needed to build a new plant is significant. From planning and commissioning to endgame is a minimum of 18 months to get a new plant in place if we were to start the process tomorrow.