2023 Submissions

NatRoad’s role includes making formal submissions to various government bodies on a wide range of policy issues affecting the road freight industry, with the aim of improving the business environment for our members and the industry in general.

Submitted To: NHVR

Date Submitted: 31 May 2023

Summary: The National Road Transport Association (NatRoad), Australia’s largest national representative road freight transport operators’ association, is keen to contribute to the National Heavy Vehicle Regulator (NHVR)’s Review of Low-Speed Swept Path (LSSP) and Tail Swing (TS) Standards in the Performance Based Standards (PBS) Scheme. In line with our mission of improving road safety, we appreciate the opportunity to engage in dialogue concerning the proposed amendments to the Australian Design Rules (ADRs) to increase vehicle width beyond the current 2.5m limit.
Our submission underscores the necessity to account for the impact of these changes on two essential parameters of the PBS Scheme: the LSSP and TS. These standards manage the safety risk associated with vehicle movement and turn, especially in the context of the proposed changes to vehicle width. We caution that the scope of the review, as presented in the Options Paper, may be too narrow and encourage considering other vehicle types outside the PBS scheme.
While we acknowledge the Options Paper’s contribution to the dialogue, our analysis of its contents reveals a substantial oversight. Specifically, a more detailed discussion of the implications of the proposed changes to PBS classifications on road access networks needs to be discussed. Increasing vehicle width allowances could dramatically alter the road access landscape, potentially causing operational challenges, particularly for specific vehicle types.
Further, the NHVR’s Options Paper’s findings, grounded in simulations, suggest that increasing width may necessitate additional road space on networks. We concur with this observation and call for a broader exploration of the issues raised. As such, we propose reviewing the current performance levels and comprehensively re-examining all regulations and turning templates reflecting LSSP and TS requirements in the context of greater vehicle width.
Finally, as the NHVR considers a review of the PBS Network Classification Guidelines and adopting alternative standards based on European legislation, we urge caution. Given the limited available information, assessing the potential impact on the Australian fleet is challenging.
In conclusion, we commend the NHVR for initiating this meaningful conversation. However, we propose a more comprehensive and detailed review that extends beyond the PBS standards, and this broader perspective will ensure better safety and performance outcomes while maintaining productivity levels.

Document Submission

Submitted to: NHVR

Date Submitted: 17 March 2023

Summary: The recent growth of the national land freight task has presented significant challenges to the road freight industry, exacerbated by labour shortages and extreme weather events.
The National Road Transport Association believes these challenges can be more easily addressed through the widespread adoption of telematics.
In line with this, the NHVR Discussion Paper aims to improve the uptake of telematics and regulate the issuance and enforcement of mass and dimension access conditions transparently and equitably.
NatRoad firmly supports these efforts and has partnered with Teletrac Navman to promote the adoption of telematics among its members throughout Australia.
While NatRoad recognises the potential benefits of data collection through telematics, it has concerns about the need to maintain a clear separation between law enforcement and data collection.
Our members have expressed concerns about government agencies’ potential misuse of collected data, highlighting the need to address trust issues to alleviate these concerns.

Document Submission

Submitted to: NHVR

Date Submitted: 17 February 2023

Summary: The National Heavy Vehicle Regulator (NHVR) Discussion Paper, “Performance Based Standards 2.0”, is a mixed bag.
While the National Road Transport Association believes many aspects of the reforms proposed are an improvement on current arrangements, reducing regulator and members’ costs and expanding as-of-right access to agreed networks need to be high priorities.
The NHVR has heard the industry message that the regulatory and administrative burden the access regime imposes has caused innovation to stagnate, and there is no path for PBS vehicles to exit the PBS scheme into the ‘as-of-right’ fleet.
NatRoad understands the paper’s focus on notices and appreciates that governing legislation prevents the NHVR from amending PBS standards or network access guidelines without reference to the National Transport Commission (NTC).
But the PBS scheme needs to be changed to deviate from traditional regulated requirements, subject to confidence in performance and safety. We need a scheme founded on performance requirements, not prescriptive requirements.
NatRoad has members who have spent significant amounts in having PBS vehicles designed and approved, only to be forced to store this costly equipment at the depot because route access has not been granted.
This is a disincentive to the rollout of PBS vehicles generally and hampers industry efficiency.
NatRoad supports the rapid development of a fast-tracked PBS approval for heavy vehicles built with safety features (such as side underrun protection, blind-spot sensors, electronic stability control, and anti-lock brakes) to allow a maximum vehicle width of up to 2.6 metres as-of-right access to the road network.
This reform will assist with uniformity of manufacturing standards of overseas vehicles, even if the vehicles needed to meet the relevant PBS straight-line tracking standard and non-width related ADRs.
NatRoad supports any move that allows manufacturers to take on assessor and certifier functions to minimise time and cost barriers to the industry.
NatRoad also backs the NHVR proposal for a High Performance Fleet as a separate, quasi-prescriptive heavy vehicle category, allowing mature PBS vehicles to transition out of the PBS scheme.
Having a designated High-Performance Fleet could achieve this, although allowing further access without requiring a permit is NatRoad’s preferred path.

Document Submission

Submitted To: National Transport Commission

Date Submitted: Feb 2023

Summary: The road freight transport sector is under enormous cost pressure, especially in the light of
escalating diesel prices and the impact of widespread flooding.
NatRoad remains wedded to its position that if governments are going to increase the road user
charge (RUC) and registration charges, a small percentage increase should be adopted.
We believe this should remain in place until a revamped cost model is implemented.
NatRoad believes that it is futile to base increased RUC and registration charges on past State and
Territory road expenditure which gives insufficient attention to needed road maintenance.
NatRoad agrees that a fixed percentage charge increase is better than reliance on outmoded
economic modelling. Plans to increase heavy vehicle charges by 6 or 10 percent are inconsistent with
industry’s ability to pay (which is diminishing for a broad range of economic reasons, recently added
to by the effect of widespread flooding.) If Transport Ministers insist that this is the required
acceptable range then NatRoad seeks for the figure to be 6%, not higher and asks for a consideration
of a zero increase in the first of the three years.

Document Submission

Submitted To:

Portfolio Committee No. 6 – Transport and the Arts, NSW Legislative Council

Date Submitted: 18 September 2023


The heavy vehicle industry in New South Wales is experiencing its most difficult economic and regulatory operating environment in living memory.
NatRoad Members report that they are operating on wafer-thin profit margins of about two percent.
The pandemic’s lingering impacts, high fuel prices, inflation, unfairly high motorway tolls, natural disasters, a disrupted global supply chain and a chronic shortage of drivers and mechanics are all imposing a burden.
So are increases in registration and the Road User Charge, the snail’s pace of reform of the Heavy Vehicle National Law, and the heavy-handed and punitive nature of the enforcement of even minor breaches of those laws, are putting extreme pressure on road transport.
The costs are being passed on, where possible to customers. This means that every man, woman and child in this state is paying a price in the form of higher costs at the supermarket check-out, fuel bowser or pharmacy counter.
New technology like telematics and electronic work diaries have the potential to make our industry safer, more efficient and more viable but many drivers are suspicious that data may be used to target them retrospectively.
These economic and social pressures are national and, in some cases, global. New South Wales is where most of the freight task occurs and where most operators are based.
This state must adopt a leadership position and drive regulatory and economic reform to ensure a viable future for our supply chains.

Document Submission

Submitted To: 

2023 NSW Independent Toll Review

Date Submitted: 28 July 2023

Summary: Sydney’s motorway tolling system is broken. The pricing approach has lost sight of achieving outcomes for public benefit.
The pricing of toll roads has shifted significantly to now being set with a three times multiplier on most toll roads.1
There is no transparent link with cost recovery, with the heavy vehicle toll multiplier set well above the cost of road damage.
There is no priority placed on transport planning outcomes and creating liveable urban communities by seeking to incentivise goods movement on motorways.
There is no understanding of commercial realities – higher tolls on trucks are justified by claims of the higher value of time savings, which do not stack up to scrutiny.
Despite the lessons of the pandemic and related supply chain crisis, there is no recognition that trucking is an essential industry.
Piling on costs to a small business industry, private toll road operators (with government agreement) are directly contributing to making a difficult business environment even worse, with impacts on the viability and safety of small business operators.
The new NSW Government should act to restore the public benefit from the operation of private toll roads.

Document Submission

 The nation’s leading national representative road transport organisation is calling on the Federal Government to commit $3.5 billion to a fund to kick start truck decarbonisation.

The National Road Transport Association (NatRoad) call for a Clean Transport Fund comes in an Australian road freight transport decarbonisation industry whitepaper issued today. It draws on local and global research, and experience on the shift to low emission road freight vehicles, and operations.

It advocates for a mix of financing and direct incentives to drive the move towards alternative fuels like electricity, hydrogen, and low emission trucks.


Submitted To: 

National Transport Commission

Date Submitted: 24 November 2023

Summary: Australia’s national truck laws need reform to improve safety, productivity and reduce red tape, but the review of the Heavy Vehicle National Law (HVNL) has gone on for too long. There have been multiple issue papers, workshops, proposals and regulatory impact statements (RIS). The latest consultation RIS is not the first, the entire reform agenda appears to have become an end it itself with outcomes always over the horizon.
NatRoad shares the widely held disappointment in the review and the lack of ambition in the overall reform agenda.
That said, the consultation RIS proposals present an opportunity to reduce the administrative burden of the HVNL, provide some improvements to enforcement, and improve general access conditions. This would represent a clear reform step in the right direction.

231124 HVNL CRIS NatRoad

Submitted To: 

Department of Infrastructure, Transport, Regional Development, Communications and the Arts

Date Submitted: 27 September 2023

Summary:Australia’s National Freight and Supply Chain Strategy should be recalibrated with a stronger focus on delivering outcomes.
The recalibrated strategy should recognise that financially viable road freight operators are critical to achieving multiple goals of the strategy. Decarbonisation, innovation, productivity and safety outcomes will not be achieved without a financially viable industry to drive investment in these priorities.
The existing goals of the strategy have provided a strong foundation but should be reset to provide a stronger focus on key priorities for the remainder of the decade. The new strategy goals should be—

Safe operations and networks

Increasing freight productivity

Skilled, professional and resilient workforce

Enabling decarbonisation and improving sustainability

Fit for purpose regulation

Financially viable operators

Backing innovation

Planned, accessible and resilient freight precincts and networks.
Whilst the strategy has provided welcome national strategic direction on improving our freight and supply chains, success is ultimately dependent on the decisions of governments across a range of issues and reform programs.
The next five-year action plan will take us to the eve of the 2030s. The recalibrated strategy should set clear outcomes to be achieved. For the next five-year action plan this should include—

the new Heavy Vehicle National Law should be legislated and operational

major decarbonisation pathways should be cost effective for road transport businesses

the road network should be funded on the basis of system-wide outcomes of improving safety, productivity, sustainability and connectivity. The proposed National Service Level Standards Framework (NSLSF) for Roads should be operational and guiding investment decisions by no later than 2025, underpinning a fair go for all Australians

non-legislative reforms to improve heavy vehicle access should be implemented and operational

all state, territory and local governments should have published freight plans which align with the national strategy and the national urban freight planning principles

the focus of connected and automated vehicles should be to improve safety, productivity and increasing job choice through new career pathways.
Finally, the governance of the strategy should also be recalibrated to better engage and represent the industry.

Document Submission