AgForce Response to the Austroads, National Access Framework for Heavy Vehicles, Consultation Survey, September 2022

Dear Sirs

• AgForce Background Position

• Response To Shared Principles

Principles

Description

Access should be enabled unless by exception (Critical Area 1)

AgForce supports improved access in other jurisdictions as well the promotion of a ‘right to access’ along identified freight corridors - in support of more efficient transport outcomes without the need for permits. We do so with driver safety and animal welfare at the forefront of decision making. Opportunity We welcome targeted investment for infrastructure improvements.  We equally encourage immediate upgrades to existing roadways and bridges to allow for efficient flow through of supply chain traffic.

 

Principles	Description
	Risks Unless jurisdictional fees and charges are revised and streamlined, many of the objectives of the NAFHV will be difficult to achieve because of competing interests, unless a separation exists between how fees are collected versus best practice methods of heavy vehicle freight transportation. International best practice is a worthy comparison, though not withstanding our initial comparison to Australia’s well develop transport system and  our unique landscape. Registration fees, fuel surcharges and other revenue sources contribute funding to the road network.  Road managers should provide access to the road network unless a safety or amenity risk has been established.
Fostering collaboration and coordination between state and local road managers, third parties and industry (Critical Area 2 and 3)	AgForce supports harmonisation of cross border access, where vehicles are mutually recognised; where vehicles legal in Queensland are recognised in other states (State of Origin) and vice versa. We support the proposal for NAFHV to foster state and territories and industry members to establish single national definitions, with the aim to remove barriers to cross-border transport. Opportunity We would support a nationalised system management approach, rather than a cross-collaboration of jurisdictional and intermediary organisations with different systems and applications sharing information. Risk Some of the permitting applications offered by road managers are not user friendly and the permitting systems are often not in real time.  This  together with jurisdictional variances complicates otherwise efficient transportation . We acknowledge varying positions exist with that of workplace health and safety laws, animal welfare laws and the HVNL general safety duty. These need integrating into an effective and efficient policy. We are cautious of any program of a national license (identification) and penalty system without due consultation with road users and industry. Road manager practices can be continuously improved by collaborating with other state and local road managers and road authorities, to build capacity, share information and transfer knowledge. This collaboration offers the opportunity for road managers to unlock opportunities, such as increased automation, information sharing improved harmonization of practices.

 

Principles	Description
Harmonised access decision-making practices while encouraging innovation (Critical Area 2 and 3)	AgForce favours the development of a national strategy, including a fully developed alternative route (during crisis) or contingency plans. Also, a centralised recording resource to give local governments greater transparency of road access decision making, in a timely manner, that favours a reduced need for permits, empowerment of road managers, and ensuring producers can move product to market more efficiently and effectively, through reduced costs and compliance. AgForce strongly supports a harmonisation of the HVNL notices, or their discontinued use where reform changes improve cross-border access and reduces duplication for operators to comply with differences in notices, driver licencing or driver training and cross-board accreditation requirements. Opportunity We seek the further development of policy principles that consider the broader impact on Queensland livestock producers and the relationship between an animal’s welfare and transport operator safety and the productivity benefits of an efficient road transport system. Risk The delivery of a national approach to transport reform that does not result in any disadvantage to the tried and proven Queensland livestock transportation system that has been developed and improved for the last 38 years (since reform in 1983) and that has been specifically formulated to suit our unique distances and climatic environments.  Road managers, third parties and industry benefit from access decision making based on consistent approaches and outcomes reflected in permit conditions, network development, cross-border connectivity and data sharing and access. Road managers should continue to develop new tools, innovate their own practices – including through automation – and share lessons with their state and local counterparts to support harmonization of good practice to meet safety, productivity and sustainability outcomes.
Encourage the use of safe, productive and sustainable vehicles (Critical Area 2 and 3)	AgForce broadly supports the development of a national notice for a uniform set of eligible vehicles for cross border access.  Acknowledging that advances in Performance Based Standards (PBS) vehicles and other technology means capacity improvements are probable and should be considered for benefit of greater efficiencies, reduced number of trips causing wear and congestion, still within the minimum impacts on road infrastructure. Eligible (livestock) transport vehicle types vary between state and territories and impede cross border access.  While volumetric loading (for transporting livestock) does not apply a prescriptive mass limit, it does specify a maximum unladen mass.

 

Principles	Description
	AgForce does not support an alternative to volumetric loading scenarios that consider floating mass limits, or low and high loading scenarios that are limiting to a minimum, but rather the extension of Queensland’s already proven volumetric loading system to apply across the borders.   Opportunity AgForce broadly supports the harmonisation of driver training and education as a professional trade, where this recognition is nationally consistent, improves cross-border access, is fit for purpose, raises the levels of safety and skill and ensures an animal’s welfare. We are in favour of ensuring driver and road user safety and animal welfare as a priority. Any expansion of heavy vehicle nationalisation training programmes must be fully considered in the context of the driver labour market shortages, and the difficulties in keeping drivers in the industry due to the onus of compliance complexity and industry pressures because of distances or cross-border infringements. In lieu of a nationalisation program, drivers in Queensland, should be adequately accredited to meet eligibility in other jurisdictions and vice versa. Risk The cost of new technology to operators be weighed against the direct investment and development of infrastructure to support greater access improvements for operators. New heavy vehicle technology be weighed against existing investment and equipment life cycles to allow operators time to recoup investments.  Further, adoption of new technologies be supported by the larger market economy, with access to power running source, repair networks, parts, and disposal of post product life. More productive vehicles fitted with modern safety and environmental design features can be used by road managers and the transport sector to drive a further downward trend in the number of fatal and serious crashes on the network as well as deliver emission reductions.  For instance, conditions for Restricted Access Vehicles can be used to drive sustainability outcomes where allowable under the HVNL.
Automate access assessment decision-making (Critical Area 1 and 4)	AgForce seek a harmonisation of first and last-mile access and efficiencies in the permitting system, by reducing the need for permits and gazetting more roads under notice.  This gives producers and drivers greater access to livestock markets, while increasing productivity and profitability. Opportunity Open to consider alternatively permitting system without glitches, such as supply chain mapping and logistic system dedicated to transport operators, with clearly defined transport routes and for access, approved by selection and GPS mapping.

 

Principles	Description
	Risks Attempting to refine existing systems or mesh cross board jurisdictional providers, third party systems or transport regulators to attempt to agree to a transparent automated approach may prove futile, as noted in past reviews conducted by National Heavy Vehicle Regulator (NHVR).   An automated approach to submitting, assessing and access decision making ensures the process is replicable, transparent and timely for both road managers and industry.  This includes re-using the outcomes from previous applications to guide decision-making, where appropriate, to provide much needed certainty.
Facilitate the exchange of information and open data (Critical Area 4)	AgForce is broadly supportive of data exchange, benchmarking and indicators to establish better decision-making frameworks, providing these are achieved in consultation. Any exchange of data between parties be mutual, open and transparent data sharing; with data and privacy protections implemented for the agriculture industry and relevant parties involved.  We seek for data ownership to remain that of sourced data origin and that the data held be de-identified. Further, cost of data monitoring systems be borne by data collectors, and cost of servicing by data providers. Opportunity An opportunity exists to create a central data base, for all transport users to access.  AgForce seeks to be part of the journey, with access to its own member data on roads access, Grains Management Harvest Scheme Data (GMHS), access to mapping and disaster management tools which are beneficial in telling a story and developing alternative planning strategies. Risk Should the flow of data not return to the parties involved, they are prevented from improvement within their own frameworks, which will limit progress of the capability of the NAFHV frameworks.  Smaller operators will not have capacity to adequately make use of data received and may require assistance in coordinating data into a meaningful and useful tool for use. The voluntary exchange of data by road managers and industry helps ‘paint a picture’ of traffic journeys and volumes that allows for improvement and maintenance of the road asset critical to ensuring ongoing access for heavy vehicles.  It can also support transparency by demonstrating progress towards more consistent access decision-making and improved access on the network.  Telematics, in particular, offers opportunities for the generation and sharing of data for non-regulatory purposes to benefit road managers and industry.

  https://www.abs.gov.au/statistics/industry/industry-overview/australian-industry/latest-release