May 2008
Greek position on the current evaluation of inclusion of creosote in Annex I of Council Directive 98/8/EC
General
The Greek Competent Authority for the implementation of Directive 98/8/EC in cooperation with Greek companies (impregnators and end users, particularly Electricity, Telecommunications and Railway) analyzed comprehensively the available National and European data and based on their long experience on the application of creosoted wood, strongly support the inclusion of creosote in Annex I of the Directive, since:
Ø Creosote as well as creosoted wood is used in a safe way, according to European and National legislative restrictions.
Ø Creosoted wood is considered a well-accepted environmental solution compared to other alternatives.
Ø Industrial applications of creosoted wood are the most effective, presenting significant advantages in terms of workability, long service life time and mechanical properties.
Ø No other alternative and effective wood preservative is available for the above mentioned major industrial applications. CCA, which has been considered as an equivalent to creosote wood preservative, is now banned according to EU Regulation 1048/2005, dated June 13, 2005.
Ø There is no substitute to wooden poles for the extensive applications in the hardly accessible Greek rocky mountainous areas.
Ø Increased demand for the rapid expansion of the electricity distribution network, necessary to accommodate the fast penetration of the new renewable energy power plants (mainly Wind Parks located in rocky mountainous areas) will not be satisfied, in case creosoted wooden poles are to be restricted.
An envisaged prohibition of creosote and creosoted wood would:
Ø Have severe adverse impacts, from financial, operational and environmental point of view, for all the interested Greek parties.
Ø Create significant social, safety and security of supply problems, since major companies-utilities would face huge difficulties in providing their required services to the public.
Ø Not contribute to a decrease of any adverse impacts on humans and the environment.
Ø Result in increased CO2 emissions, since there is no sustainable alternative to wood.
Practical and economic consequences of the phasing out of creosote
1. Directive 2001/90/EC (harmonized in Greek legislation with Ministerial Decision 491/2002/03) imposes restrictions to the maximum permitted benzo-a-pyrene and water extractable phenols content of creosote (0.005% and 3% by mass, correspondingly). The Technical Specifications of the Greek major industries for creosote, on which is based the impregnation of wooden poles for the Electricity Distribution, Telecommunications Networks and wooden sleepers for the Railway Network, fully comply with the imposed restrictions.
2. In Greece, there exist three private treatment plants impregnating wood with creosote. The Electricity, Telecommunications and Railway Companies are their major clients. Considering that alternatives are not readily available, a ban of the use of creosote is likely to have major implications for the producers of creosoted wood. It will lead to a strong reduction in their annual turnover, massive loss of employment and eventually threaten their viability.
3. Overhead lines of the Electricity Distribution Networks (Medium and Low voltage) amount to 91% of the total network length. The total length of overhead Distribution Networks is approximately 195,000 km. About 90% of overhead Distribution Networks’ poles are creosote impregnated wooden poles, while the rest 10% are concrete poles (there also exist a few old steel poles). All concrete poles are installed only at places accessible by heavy vehicles. Every year, about 80,000 – 90,000 new creosote impregnated wooden poles are installed in the Distribution Networks, in new lines or for replacement of damaged poles. There are about 4.5 million wooden poles installed in the Greek Electricity Distribution Networks.
Presently, there is an increased demand for the rapid expansion of the Electricity Distribution Network, necessary to accommodate the fast penetration of the new renewable energy power plants (mainly Wind Parks located in rocky mountainous areas), due to the requirements of the new EU Energy / Climate package – RES Directive. This demand will not be satisfied, in case creosoted wooden poles are to be restricted, since readily available alternative solutions do not exist.
4. The Greek Telecommunications Network accounts for 1.8 million wooden poles, purchases about 50,000 creosote impregnated wooden poles per year. New wooden poles are used for the implementation of the Annual Construction Plan of this Telecommunications Network, as well as for the substitution of damaged poles or poles that should be replaced with new ones.
Wooden poles are used mainly in the aerial subscribers’ network (edge network that reaches to the subscribers). Although there is a tendency in substituting current aerial network with underground lines mainly for reduction of faults, aerial network still continues to grow, as it is the best way for reaching rural or low-populated locations, both technically and economically.
Even the forthcoming development of Fiber (FTTx) technology does not provide an economical and viable solution in networking small numbers of subscribers’ in rural and low-populated areas.
5. The Railway Company manages approximately 2,500 km of railway network, of which 1100 km railway lines and 1898 switches, are equipped with creosote treated wooden sleepers. As a consequence, a ban of the use of creosote is surely expected to cause considerable operational and financial problems on the national Railway Network, because of the necessity for replacement of wooden sleepers, both in lines and in switches, in approximately 45% of the total capacity.
The replacement of all creosote impregnated items, even if it will be extended through a long period of time (e.g. 10 years), it is evident that it will provoke huge operational problems to industries, frequent and long interruptions of electricity, telecommunications and transportations and major impacts in security of supply of vital social services in Greece.
The replacement will burden Greek companies, which are major users of creosoted wood, with very high expenditures, estimated to approximately 4 billion €. These costs refer only to the end users and not to the costs for the impregnators or private service companies. The cost will be significantly higher, as it is difficult to estimate revenue losses due to the inability of offering services (from public service obligators and private service companies) during the substitution period.
Another significant problem which the Greek end users shall have to face, in case of prohibition of the use of creosote as a wood preservative, is that it is almost certain that following such a decision, a lot of pressure will be exerted upon the companies by the public for the replacement of the installed creosoted wood, even if said decision will not refer to the replacement of already installed creosote impregnated equipment.
It is also clear, that the impacts in European Union caused by the probable prohibition of the use of creosote will be considerable. Data show that Electricity, Telecommunications and Railway Utilities, as well as industries in EU will face severe problems, in case creosote would be prohibited as wood preservative.
Availability of less hazardous or non-hazardous alternatives to creosote or creosote treated wood – Advantages, disadvantages and practicability of possible alternatives
The envisaged prohibition of the use of creosote will lead to non-reliable alternative solutions. New generation alternatives lack experience and are expected to have significantly lower service life time and effectiveness, compared to creosote impregnated poles.
The extended operational life time of wooden poles impregnated with creosote, reduces wood-cutting of forests and the associated disturbance of the Greek forestall ecosystem, regarding that Greece is deficit in wood. Therefore, there is an important environmental benefit for the forest system, when creosoted wood is used.
It is internationally accepted, that there are no other appropriate products for application of preserved wood in ground contact, where long service life is needed. The operational life time of wooden poles impregnated with creosote is about 60 - 80 years, according to the Greek and international in situ experience, acquired during several decades. Creosoted poles are the only alternative, which can guarantee no corrosion to metal parts in contact with wood. This point is of great importance with regard to human safety.
The substitute solutions, such as composite, concrete and steel products, compared to wooden products have significant disadvantages regarding environmental benefits, costs, desired mechanical properties and safety performance. Furthermore, Greece has rough land morphology, with many rocky mountains and islands, a fact which makes access to several areas extremely difficult. These remote areas are impossible to be reached by heavy vehicles, which are necessary to carry, install and maintain heavy concrete or steel poles.
In view of the above, in practice, no available alternative solution exists.
Estimation of the time needed to develop and make available sound alternatives to the use of creosote
According to existing knowledge, there are not any sustainable alternatives compared to creosoted wood that can certainly satisfy heavy duty needs.
Regarding the estimation for the time necessary for the development and availability of alternatives, no predictions could be made. Creosote is the only wood preservative used by the interested Greek parties, with very satisfactory and safe results. All other alternatives that have been tested at laboratory or small scale are not promising for industrial uses due to much lower service life time and significantly higher costs.
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