Statewide Policy for Industrial Land Use Submission

Executive summary

NatRoad supports the NSW Ports submission to the draft Statewide Policy for Industrial
Lands and provides this supplementary perspective to reinforce the critical importance of
protecting industrial land from the road freight operator’s viewpoint. While NSW Ports has
focused on port and rail freight infrastructure, NatRoad’s contribution anchors that case in the
daily operational reality of the road transport operators who connect that infrastructure to the
economy:

• Mandate road freight impact assessments for industrial land rezonings
• Include heavy vehicle road access as a classification and protection criteria
• Embed an Agent-of-Change principle and protect established freight operations
• Identify and protect industrial land for heavy vehicle parking, staging, and driver
  facilities
• Protect Western Sydney freight corridors and missing intermodals as state significant
  infrastructure

The National Road Transport Association (NatRoad) is Australia’s largest national representative of
road freight transport industry. NatRoad is informed by members from owner-drivers to large fleet
operators, general freight, road trains, livestock, tippers, express, car carriers, as well as tankers and
refrigerated operators. Our vision is to improve the operating environment for the road freight transport
industry.

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1. The road freight imperative: NSW road freight in numbers

Every container unloaded at Port Botany, every bulk shipment received at Port Kembla, and every pallet
moved through an intermodal terminal ultimately reaches its destination by road. The efficiency of that
road freight movement, and the viability of the businesses that perform it, depends directly on the
availability of well-located, accessible industrial land.

Industrial land is not simply where freight is stored. It is where transport operators base their fleets,
where drivers begin and end their shifts, where maintenance is performed, where loads are
consolidated and broken down, and where the logistics systems that keep supply chains moving are
coordinated. Losing industrial land in Sydney does not just affect warehousing. It degrades the entire
road freight network.

The Sydney Road freight task is at record levels, is forecast to nearly double over the next 40 years, and
the industrial land that underpins that task is already critically scarce. Weakening protections for
industrial land at this moment is directly contrary to the evidence.

1.1 NSW road freight is at record highs and growing

Source: BITRE Australian Infrastructure and Transport Statistics Yearbook 2025

NSW road freight reached a record 87.6 billion tonne-kilometres in 2024–25, the highest ever
recorded for any Australian state. Sydney’s metropolitan freight task has grown 12% in just six years,
from 13.2 billion tonne-kilometres in 2018–19 to 14.8 billion in 2024–25. NSW interstate road freight
has grown even faster up 27% over the same period, from 38.5 billion to 49.1 billion tonne-kilometres.

1.2 The NSW Government’s forecasts: The freight task will nearly double

Source: Transport for NSW, Strategic Freight Model 2022 (SFM22) Summary Factsheet, June 2025

The implications for industrial land are direct and unavoidable. A freight task nearly doubling in volume
cannot be accommodated on a shrinking industrial land base. Every rezoning of industrial land today
removes capacity that will be needed to serve the Sydney of 2040 and 2061.

1.3 The NSW Government’s independent panel has already identified this crisis

In June 2025, the NSW Government Independent Freight Policy Reform Advisory Panel published its
findings on NSW freight policy reform. Its conclusions on industrial land directly support both the NSW
Ports submission and NatRoad’s concerns:

• The freight sector contributes $74.3 billion in Gross Value Added (GVA) to NSW and employs
  approximately 330,000 people. By 2061, this is forecast to grow to $131.5 billion GVA and
  565,000 jobs.
• Severe shortages of serviced industrial land are identified as one of the four most critical challenges
  facing the NSW freight system, alongside population growth in Western Sydney, decarbonisation,
  and workforce shortages.
• Addressing industrial land shortages is identified as a high-impact priority
• Without decisive reform on land use, pricing, rail access and governance, inefficiencies will increase
  costs of living, emissions, and congestion across NSW.

1.4 The Sydney Plan confirms the crisis

The NSW Government’s Sydney Plan (December 2025) contains three findings that directly support
stronger, not weaker, industrial land protection:

Sydney Plan Finding	Implication
Industrial land is only 2% of Sydney’s land area but contributes $90 billion annually to the economy	The productivity per hectare of industrial land vastly exceeds any alternative use loss of even small areas carries outsized economic cost
Serviced industrial land supply is constrained to an estimated 2–4 years	Sydney is already at critical shortage. The appropriate policy response is protection and new supply. Not increased flexibility for rezoning
Around 80% of freight in Sydney moves by road	Road freight operators are the primary users of industrial land and the primary victims of its loss

The Sydney Plan targets approximately 250 hectares per year of new serviced industrial land supply.
NatRoad welcomes any commitment to new industrial land provision. However, a supply target is
rendered ineffective if the policy simultaneously permits unrestricted rezoning of existing industrial
land. If 250 hectares of new supply is added annually while existing industrial land which is particularly
well-located, port-adjacent, and intermodal-adjacent land, continues to be lost to alternative uses, the
net industrial land position can still deteriorate.

The supply target and the no-net-loss principle advanced by NSW Ports are not alternatives, they must
operate together. New supply in greenfield Western Sydney locations, however welcome, does not
replace the freight functionality of established industrial land surrounding Port Botany or within the
inner Sydney freight network. Location matters as much as total hectares. NatRoad supports
Recommendation 1 (no net loss by LGA) as the essential complement to any supply target, ensuring
that the industrial land base is both protected where it exists and grown where it is needed.

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2. Road freight specific concerns with the draft policy

NatRoad’s concerns are grounded in the operational realities of road freight operators. The following
five concerns go beyond the NSW Ports submission and reflect dimensions of the freight challenge that
only road operators can speak to.

2.1 Industrial land loss forces trucks further — creating measurable, ongoing costs

When industrial land close to ports, intermodals and urban centres is rezoned, freight operators are
displaced to outer metropolitan or peri-urban locations. The consequences translate immediately and
permanently into longer truck trips, higher operating costs, and more vehicle kilometres on the
congested Sydney road network.

Source: NSW Ports submission; BITRE Yearbook 2025, The Sydney Plan, Draft for Public Exhibition, NSW Department of Planning, Housing and Infrastructure, December 2025

The Independent Panel explicitly notes that inefficiencies in freight will increase costs of living. For road
freight operators, every kilometre added to a delivery route means more fuel, more driver time, more
vehicle wear, and more empty running. Operators do not absorb these costs, they flow through to the
price of every good delivered to every business, and household in NSW.

The Sydney Plan simultaneously targets delivery of 264,000 new homes by 2029 and identifies
industrial land protection as a priority. These are not in conflict, they are interdependent. Sydney cannot
house 6.5 million people without the supply chains that build those homes, deliver food and goods, and
service the city. Rezoning industrial land to residential does not solve the housing crisis; it raises the
cost of everything delivered to every new home built. The two percent of Sydney’s land area that is
zoned industrial is doing irreplaceable economic work that no other land use can perform.

The draft Policy’s criteria for assessing rezoning proposals (Technical Note 2) does not require
quantification of road freight impacts. NatRoad submits that this is a critical gap. Any assessment of
whether industrial land can be rezoned must include a Road Freight Impact Assessment that quantifies
the change in vehicle kilometres travelled, average truck trip distance, and estimated freight cost
increase attributable to operator displacement.

NatRoad Recommendation A: Mandate Road freight impact assessments for all industrial land rezonings

Any proposal to rezone or convert industrial land within the Sydney Region must include a Road Freight Impact Assessment, prepared by a qualified professional, that quantifies: (i) the increase in average truck trip distance resulting from displacement of freight operators; (ii) the consequent increase in vehicle kilometres travelled on the arterial and local road network; and (iii) the estimated increase in freight delivery costs. NatRoad should be formally consulted in the development of assessment criteria. This requirement aligns directly with the Independent Panel’s recommendation that industrial land shortages be addressed as a priority, and with the NSW Government’s own freight growth forecasts under SFM22.

2.2 Heavy Vehicle road access must be a classification criterion

The draft Policy’s classification framework assesses industrial land based on proximity to ports,
intermodals, and freight networks; however, it does not assess whether the land is accessible to heavy
vehicles. Industrial land that cannot physically accommodate B-doubles, or Performance Based
Standards (PBS) vehicles is of limited value to freight operators, regardless of how well-located it is on
a map.

NatRoad members regularly encounter industrial precincts where surrounding road networks cannot
support efficient heavy vehicle access: weight-restricted bridges, narrow turning radii, poor sight lines, and conditions that force operators to use longer routes or smaller, less efficient vehicles. The
Independent Panel identifies expanding high productivity vehicle (HPV) access as a priority reform for
NSW freight. The industrial land classification framework should reflect this directly.

NatRoad Recommendation B: Include heavy vehicle road access as a classification and protection criteria

The industrial land classification framework should require assessment of road network suitability for heavy freight vehicles as a criterion for State and Regional significance. Industrial precincts directly served by roads capable of accommodating B-doubles or larger, or with access to the High Productivity Freight Vehicle (HPFV) network, should receive elevated classification. Rezoning proposals must assess the impact on heavy vehicle access to remaining industrial precincts in the surrounding area.

2.3 Operational curfews and caps directly conflict with national transport law

NatRoad strongly endorses NSW Ports’ Recommendation 5 (the removal of operational caps and
curfews from industrial lands).

This matters for road freight operators as road freight operations are governed by the Heavy Vehicle
National Law (HVNL). The HVNL sets out mandatory fatigue management requirements for commercial
vehicle operators and drivers. When freight depots, distribution centres, and logistics facilities are
subject to night-time operational curfews it creates conflicts with these legal obligations:

• Drivers cannot legally extend their working day to compensate for restricted loading windows at
  curfewed facilities
• Operators are forced to concentrate all vehicle movements into constrained daytime periods,
  increasing peak-hour congestion and road safety risk
• Compliance scheduling becomes significantly more costly and complex, reducing the number of
  deliveries that can be completed in a compliant working day
• Owner Operators are disproportionately affected, as they lack the fleet flexibility to redistribute
  movements across multiple time windows

In research conducted by the Australian Logistics Council in 2021 into community sentiment survey into
the impacts and perceptions of delivery curfew times, more than 60 per cent of respondents said they
would be in favour of removing curfews to enable smooth movement of freight goods. In 2022, NSW
made changes to the State Environmental Planning Policy to keep the temporary planning measures
pertaining to curfews in perpetuity providing certainty for business and enabling more efficient
operations of distribution centres and the ability to optimise freight routes and modality.¹

NatRoad members have confirmed that this scenario is already occurring operational curfews have
been threatened or imposed on existing freight facilities as a direct result of residential development
approvals in adjacent precincts. The Policy must establish an explicit Agent-of-Change principle to halt
this pattern and ensure building design standards for noise and amenity (costs) are borne by sensitive
use proponents. This should exist as a mandatory state-wide condition.

NatRoad Recommendation C: Embed an Agent-of-change principle and protect established freight operations

The Policy must include an explicit Agent-of-Change principle: where sensitive land uses are proposed adjacent to established industrial or freight operations, all responsibility for managing amenity impacts lies with the proponent of the sensitive use. Mandatory building design standards for noise attenuation, vibration, and air quality must apply to all sensitive use developments within identified buffer distances of State and Regionally significant industrial precincts. Operational curfews must not be imposed on established freight operations because of subsequent sensitive use approvals. This directly implements the Independent Panel’s finding that NSW must address industrial land protection as a structural priority.

1. Curfews and Supply Chain Operability, Australian Logistics Council, https://austlogistics.com.au/media-centre/curfews-and-supply-chain-operability/ ↩︎

2.4 Sydney is facing a heavy vehicle parking and driver amenity crisis

The draft Policy does not address one of the most acute and immediate consequences of industrial land
loss for road freight operators: the disappearance of heavy vehicle parking, overnight rest areas, and
driver amenity facilities in Sydney.

As industrial land in inner and middle Sydney has been progressively converted to residential and
mixed uses, the sites that once served as informal, and formal, heavy vehicle parking and driver rest
facilities have been lost. This is a current, measurable safety problem:

• Drivers unable to find legal parking within compliant driving time are forced to park on local
  streets, creating community amenity impacts and road safety risks
• Inadequate rest facilities undermine HVNL fatigue management compliance, exposing drivers
  and operators to legal liability
• The shortage of staging areas near Port Botany forces trucks to queue on public roads, worsening congestion, and emissions in residential areas around the port
• The problem will intensify: SFM22 forecasts Sydney’s freight task growing at 1.7% per year,
  while the land base available for parking and staging is contracting

Industrial land immediately adjacent to Port Botany and key intermodal terminals is the most critical for
heavy vehicle staging and parking. Its loss cannot be substituted by provision in outer Western Sydney
— the geometry of port operations requires vehicles to be able to stage close to the port to meet
scheduling windows.

NatRoad Recommendation D: Identify and protect industrial land for heavy vehicle parking, staging, and driver facilities

The Policy should specifically identify heavy vehicle parking, staging areas, and driver rest and amenity facilities as protected uses within State and Regionally significant industrial precincts, with particular attention to land within 15km of Port Botany, Port Kembla, and key intermodal terminals. Any rezoning of industrial land that reduces the available heavy vehicle parking in these areas must demonstrate offset provision — equivalent capacity must be secured before land is released for alternative uses.

2.5 Western Sydney Freight Corridors Are the Future of NSW Freight

NSW Ports’ submission correctly identifies missing intermodal terminals in the draft categorisation
mapping — Minto, Yennora, and St Marys. From a road freight perspective, these omissions are critical
because these terminals are the primary interface between rail freight and road freight distribution
for Western Sydney, the region that will generate the majority of NSW’s freight growth over the next
40 years.

The Independent Panel identifies rapid population growth in Western Sydney as one of the four
defining challenges for NSW freight. SFM22 confirms that Sydney GMA freight volumes will grow at
1.7% per year to 2061. The Western Sydney Airport and Aerotropolis, combined with major residential
and employment growth in Penrith, Liverpool, and the outer west, will substantially increase the road
freight task on corridors connecting Port Botany and Port Kembla to Western Sydney.

The industrial land corridors along the Hume Highway, the M7, and the Southern Highlands freight
corridors are critical supply chain infrastructure in their own right. Their protection must be treated as a
matter of State significance under the final Policy.

NatRoad Recommendation E: Protect Western Sydney Freight Corridors and missing intermodals as state significant

The Policy should identify the key road freight corridors connecting Port Botany, Port Kembla, and Western Sydney intermodals (including Minto, Yennora, and St Marys) as State significant freight infrastructure and ensure that industrial land adjacent to these corridors receives commensurate protection. The classification of these corridors must reflect the NSW Government’s own SFM22 forecasts, which project the Sydney GMA freight task nearly doubling to 2061. NatRoad should be formally consulted in the development of Western Sydney freight precinct planning policy.

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3. NatRoad’s endorsement of NSW Ports recommendations

NatRoad formally endorses all five recommendations made by NSW Ports and provides the following
additional evidence-based commentary from the road freight perspective.

NSW Ports Recommendations	NatRoad endorsement and road freight evidence
1: No net loss of industrial land by LGA	Strongly supported. BITRE 2025 confirms NSW road freight is at record levels. SFM22 projects a 94.8% increase in Sydney’s freight task to 2061. Every hectare lost today removes capacity the freight network will need. The Independent Panel identifies industrial land shortage as a top-priority structural challenge.
2: Strengthened rezoning criteria	Supported, with the addition that Supply Chain Impact Statements must specifically quantify road freight impacts — including changes in vehicle kilometres travelled, average trip distance, and heavy vehicle access. The Independent Panel’s findings on freight cost of living impacts support this requirement.
3: Exclude sensitive uses from industrial zones	Strongly supported. The presence of sensitive uses adjacent to freight operations is the primary trigger for curfews that directly conflict with HVNL fatigue management requirements. The Independent Panel flags workforce and compliance conditions in the freight sector as already under stress.
4: Auto State Significant classification	Strongly supported. NatRoad adds that road freight depots and heavy vehicle facilities on large lots (2ha+) adjacent to State Significant freight infrastructure should receive automatic elevated classification. The road access standard of the surrounding network should also be a classification criterion.
Rec 5: Remove operational caps and curfews	NatRoad’s highest priority. Curfews on industrial operations directly conflict with HVNL fatigue management law and impose unrecoverable productivity losses on operators. The Policy must embed an explicit agent-of-change principle ensuring sensitive use proponents bear all amenity mitigation costs.

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4. Conclusion

The evidence presented in this submission is unambiguous:

• NSW road freight is at a record 87.6 billion tonne/kilometres and growing
• Sydney’s freight task is forecast to nearly double by 2061 at 1.7% growth per year
• The freight sector contributes $74.3 billion in GVA and 330,000 jobs to NSW, forecast to grow
  to $131.5 billion and 565,000 jobs
• Industrial land shortage has been identified as a top-priority structural crisis in NSW
• The draft Policy’s increased flexibility for rezoning will accelerate the loss of industrial land at
  the precise moment the evidence demands it be protected and expanded

Road freight operators are the connective tissue of NSW’s supply chain. They cannot be displaced to
outer metropolitan locations without increasing costs to every business and household in the state,
worsening urban congestion, and undermining the economically vital freight supply chain.

NatRoad urges the NSW Government to finalise the policy ensuring there are rigorous road freight
impact assessment for rezonings, protection of established freight operations from curfews through an
agent-of-change principle, safeguards for heavy vehicle parking near ports, and elevates Western
Sydney freight corridors to State Significant status.

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References:

• BITRE Australian Infrastructure and Transport Statistics Yearbook 2025 (December 2025)
• Transport for NSW, Strategic Freight Model 2022 (SFM22) Summary Factsheet (June 2025)
• Independent Freight Policy Reform Advisory Panel: Delivering Freight Policy Reform in NSW
  (June 2025)
• NSW Department of Planning, Housing and Infrastructure (2025), The Sydney Plan
• NSW Department of Planning, Housing and Infrastructure (2025), Statewide Policy for
  Industrial Lands
• NSW Ports, Statewide Policy for Industrial Lands Submission (2025)
• Curfews and Supply Chain Operability, Australian Logistics Council (2022)Contact

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Policy Manager: [email protected] (02) 62953000

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