National Productivity - Constrained by Process

FCL INTERSTATE TRANSPORT SERVICES PTY LTD

GREG GIBBINSGeneral Manager - FCL Interstate Transport Services

National Productivity - Constrained by Process


Not a PBS Vehicle

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FCL Champions PBS SMART Vehicles• Why do we need PBS SMART Vehicles?

– To improve productivity, in some cases up to 25%– To improve road safety, PBS compliance exceeds current statutory levels– To reduce truck trips, extra capacity reduces number of loads– To reduce greenhouse emissions, less trips = less emissions– To remain competitive on a domestic and global scale, supply chain cost

reductions– To align with current import / export productivity schemes

GOAL - PRODUCTIVITY & SAFETY

• Current FCL SMART Vehicles– 54’6” high cube container vehicle, Level 1 PBS compliance– Quad axle container trailer, Level 1 PBS compliance– Tridem prime mover, Level 1 PBS compliance

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Current FCL PBS Compliant Vehicles• 54’6” container• Quad axle trailer • Tridem prime mover

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PBS / SMART Vehicle Criteria• PBS process to permit

1. Transport operator determines productive vehicle combination2. PBS performance report cost from $8,000 carried out to establish compliance3. Complete SMART Heavy Vehicle Application4. Independent Review Panel (IRP) will only accept applications upon receiving

support on a case by case basis from CSLA (Case Study Lead Agency), ie State Road Authority

5. Current applications have to be submitted via the IRP. Any outstanding applications currently with State agencies now must begin process again under IRP

6. The IRP carries out required assessment of vehicle combination7. IRP makes recommendation to State Road Authority8. Under current arrangements, State Road Authorities continue to determine

final approval of the application

• Comments regarding process:– No firm time-lines are given nor accountability for commercial outcome– Still no National permit allocation exist even after this process

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PBS / SMART Vehicle Criteria

• However:

Quote… “A vehicle designed to operate in two or more States will

ultimately require a permit application in each State…” (NTC website)

‘ILLOGICAL’

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Constraints with PBS• Case Study Lead Agency (CSLA)

– Individual agencies (State Road Authorities) do not have any interest to achieve commercial supply chain outcomes

– Individual departments, within individual agencies, often fail to communicate internally

– Limited, if any, information fed back to the applicant– Rejections of applications often defy logic (example to come)– Even acceptance of an application by one agency does not give automatic

acceptance in any other state let alone nationally– For PBS to be successful CSLA’s need to be accountable for timing. They

should not be determining a commercial outcome without appropriate accountability for their decision

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Additional Constraints• Individual Stake Holders

– Permit timing can also be increased via the following assessments with:• Individual councils• Water authorities• Bridge departments

• No National PBS Road Network– PBS network should exist that allows all compliant PBS vehicles access on

designated routes, ie Level 1, 2, 3 and 4 gazetted routes– Individual route assessments are time consuming and have multiple delays– Each level of PBS should have adequate measures that allow all compliant

vehicles immediate access to this network (set the PBS bar adequately high to ensure absolute compliance)

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Logic and Compliance (should) = Acceptance

• Example of Current Shortfall in PBS in Victoria– Current Metro Container Vehicle Scheme exists in Victoria– These vehicles have to be Level 1 PBS compliant (FCL is compliant)– Vehicles have access to HML routes in Metro Melbourne upon route

assessment– Recent application to a regional icon manufacturer to increase productivity by

up to 25% was denied. Reason given – access already allowed to HML vehicles and BDoubles, FCL’s application would set an unacceptable precedence

– FCL’s application was only for an interim period until rail access into the region was available and workable

– FACT: FCL PBS vehicle has been denied access to assist the productivity and competitiveness of an icon manufacturer in a regional environment because that would “set an unacceptable precedence”. No other logical reason has been given by the State Authority

– Remember, this vehicle is Level 1 PBS compliant, is ultimately safe, provides productivity gains to a regional area and maintains intermodal focus

– Question: Why does State Authority not have to justify the rejection of PBS compliant vehicle?

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NIL

NIL

NIL54’6” Container

Quad

TridemQuad axle54’6” Container

Examples of Inconsistent PBS National Permits

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Victoria – PBS Approval

• Rural, Bandiana to Wygunya

• Metro, All HML routes (on application)

• Ballarat / Broadford

• Question: Why both national highways?• Question: Why inconsistent application of PBS?

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Tasmania – PBS Approval

• = zero

• Smithtown to Mainland via Devonport

• Economic value = domestic produce to Sydney• Cost to Australia = NZ export chips direct to NSW• Question: Why disadvantage domestic production and advantage

foreign producers?– Refer next slide

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Tasmania• Conditions on exemption of vehicles carrying overseas export freight

containers:– the combination must be a tandem drive prime mover with a single tri-axle trailer– all the axles of the combination except for the steer axle of the truck must be equipped

with road-friendly suspension– all axle groups, other than the steer axle, must be fitted with dual tyres– the freight container must contain perishable commodities being transported for the

purpose of export overseas– each freight container must be accompanied by documentation specifying –

• the origin and destination of the container• the nature of the commodity in the container• the container identification number

– the combination must not exceed the mass limits: FCL PBS Quad• Steer axle 6.0 tonnes limit 6.0 tonnes• Tandem axle 18.5 tonnes limit 17.0 tonnes• Triaxle trailer 22.5 tonnes limit 27.0 tonnes

(7.5 tonnes per axle)

(6.75 tonnes per axle)

• Aggregate axle mass 47.0 tonnes limit 50.0 tonnes

– the person to whom the exemption applies must be a member of an approved mass-management scheme

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Queensland• Quad axle:

– BDouble routes by application (Note: 19m long!)

– Vehicle 19m, why only use on BDouble?

– Question: Require IAP which has not been formally determined (cost $13,000 per vehicle)

• Queensland Inconsistency:– MEMS– 10% more weight per axle group, but must not exceed 46 tonnes– Question: Why disadvantage domestic?

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NSW• = zero PBS

• = 54’6” Regional

• = Quad axle Metro

• = Tridem

• Question: Disadvantage new manufacturers / producers for domestic and export?

• Globally accepted product eg, beef, can not get to the wharf cost effectively to be shipped into cities such as Philadelphia which have recently allowed an increase in GCM (gross combination mass) of 49.5 tonne specifically for imported Australian beef

– FCL PBS Quad

• 6.0 tonnes

• 17.0 tonnes• 27.0 tonnes (6.75 tonnes per axle)

• 50.0 tonnes

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Key Points and Solutions• PBS not recognised nationally at a regulators level

– Solution: IRP should have authority to assess and determine outcome

• PBS inconsistent recognition within states– Solution: IRP should have authority to deliver one permit for national

recognition

• PBS highly inefficient at regulator level– Solution: Leave the assessment and outcome at IRP level

• PBS still requires individual route assessment– Solution: Assess and determine routes for a national roll-out


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National Productivity - Constrained by Process

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