Executive summary
- NatRoad welcomes and broadly supports the National Heavy Vehicle Regulator’s Draft Heavy Vehicle Productivity Plan 2024 – 2029
- Improving heavy vehicle access is critical to improving productivity and boosting prosperity, handling a growing freight task, improving safety outcomes and reducing emissions
- The NHVR and road managers should commit to eliminating at least 90 percent of access permits by 2028.
Submission to the NHVR Productivity Plan 2024-2029 (heavy vehicle road access)
Road freight is critical to Australia’s supply chains and keeps our economy moving. It underpins our prosperity as a nation. Improving the productivity of the heavy vehicle sector is vital for enabling economic growth, improving safety outcomes and reducing emissions.
NatRoad welcomes the clear focus on actions under the draft NHVR Productivity Plan with a focus on improving access and permit elimination. We support the NHVR productivity vision, identification of Australia’s priorities and challenges, which have been well developed.
Ultimately, eliminating permits and bringing the National Automated Access System online should be the core goal of the next NHVR Productivity Plan. The actions in the plan should be firmly centred on achieving this goal, in collaboration with the states, territories and the Australian Government.
“Heavy vehicles are the backbone of our nation. The heavy vehicle industry not only sustains our quality of life, but underpins Australia’s prosperity and international influence, providing essential support to our community and the world in times of need. ” – NHVR, Draft Heavy Vehicle Productivity Plan 2024 – 2029
The economic benefits from improving heavy vehicle access have been well established. Deloitte has found that reforms to improve heavy vehicle access would save the average consumer $452 per annum.[1]In light of the current cost of living crisis, governments should do everything in their power to reduce cost pressures on households and improve economic security for all.
National Automated Access System (NAAS)
The 2022 Kanofski recommendations called for an automated access system to be established within three years and a reduction of permits by 50 percent within three years. Access permits for all classes of heavy vehicles were to be reduced by 90 percent within 5 years.
We welcome work which is underway towards a NAAS, but it is clear that the Kanofski timeline is not on track.
NatRoad has repeatedly called[2][3] for clear funding commitments from governments to ensure the work towards a NAAS is prioritised and achieved. NatRoad’s recommended $3 billion Clean Transport Fund included a provision for providing funding certainty for improving access decision making from a $500 million efficiency fund within the overall recommended program. The efficiency fund would also provide funding for research, information and practical tools for decarbonisation.
As has always been the intent, the NAAS should be built on the success of the Tasmanian HVAMS model. The system should provide a move away from permits to network based access. It is critical that the future NAAS is not just a layer of automation over the top of an existing, broken permit system. Design and development of the NAAS should enshrine the 90 percent permit elimination target.
All governments should commit to eliminating at least 90 percent of access permits by 2028 across all heavy vehicle classes. This should be supported with a clear delivery plan, including resourcing required to establish the NAAS.
Proposed NHVR actions
NatRoad recommends the actions of the NHVR Productivity Plan should be centred on achieving the elimination of 90 percent of access permits by 2028. Some further comments on selected actions are below.
Notice development and permits
Proposed NHVR action NatRoad position Deliver a notice development and maintenance program that adopts a prioritised approach to permit elimination. We welcome the focus on permit elimination and shifting to notices. It is important the success is measured by improved access and permit elimination, and not the number of notices developed. Notices should be broad and minimised, with access ultimately granted by the NAAS powered by a notice. Use data and decision-making tools to identify, target and prioritise expansion of end-to-end pre-approved and gazetted networks. We welcome an evidence-based approach to improving access, noting pre-approved routes should only be an interim solution as they do not eliminate permits (and as such, will not achieve the 90% elimination by 2028 target). De-identified data should be shared transparently, including by the NHVR. For example, permit application information which reveal specific infrastructure constraints should be shared with both governments and industry. Partner with industry and road managers to harmonise, rationalise or consolidate access conditions withing and between states and territories. NatRoad members experience difficulty with access connectivity across state borders. We support moves to increase consistency, noting that again these should have the ultimate aim of developing a NAAS powered by a notice. Deliver Phase 3 of the Strategic Local Government Asset Assessment Project (SLGAAP) to determine the potential freight-carrying capacity of local government road assets. This project should ensure it is progressing towards delivery of the NAAS. Emergency access
Proposed NHVR action NatRoad position Establish an enduring Emergency Access Notice which can be operationalised during declared disasters and managed in near-real time via the NHVR Portal and National Network Map. Supported, as an interim measure. A resilient network is one which seeks to optimise access, through a NAAS powered by notice arrangement. Industry should be able to adapt routes in real time to changing circumstances. If alternative routes can handle vehicle types during disaster times, then they should ultimately be brought into a notice for permanent access. Create a suite of alternative networks to promote network optimisation, efficiency and flexibility when traditional supply chains are out of action due to declared disasters. Performance Based Standards
Proposed NHVR action NatRoad position Embrace research and innovation to finalise the review of the standards in the PBS scheme NatRoad supports reform to the PBS scheme. Whilst PBS has commendable objectives, the practical experience of industry has been more mixed. Reform should be a priority. Adapt PBS engineering principles and methods to uplift the productivity, safety and sustainability performance of the non-PBS fleet. Digitise the PBS scheme, including the information contained within design approvals and vehicle approvals. Work alongside stakeholders to reform the PBS scheme in alignment with the Ministerially endorsed Review of the HVNL. Focus on improved safety and core responsibilities
NatRoad recommends that the NHVR should ensure that it is prioritising three key objectives:
- Eliminating 90 percent of permits by 2028 for all heavy vehicle classes
- Improving safety outcomes
- Shifting to risk-based enforcement.
Safety is critical for productivity. It is estimated that the cost of road crashes (across the community, not heavy vehicle specific) ranges between $22.2 and $30.3 billion, including costs to workplaces, households and governments.[4]
Similarly, punitive enforcement approaches that focus on catching people out instead of reducing risk ultimately lead to increased time that a vehicle and driver cannot earn a living.
Contact
Samuel Marks, Head of Policy, samuel.marks@natroad.com.au
[1] Deloitte, 2019, Economic benefits of improved regulation in the Australian trucking industry, 46.
[2] NatRoad calls for access to head government’s transport agenda.
[3] Fixing heavy vehicle access is the key for a growing freight task.
[4] ANU, 2022, Social cost of road crashes. 4.
