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Future Freight Networks : Yearbook 2011
64 ALC Advocacy and Policy Submissions In August 2010, ALC made a submission to the NTC in response to its draft National In-Vehicle Telematics Strategy: The Road Freight Sector and Policy Paper: Electronic Systems for Heavy Vehicle Driver Fatigue and Speed Compliance. ALC noted that the NTC proposes a government and industry partnership approach but that the emphasis is on the use of telematics for compliance purposes. If that is the approach, it would be appropriate to mandate the use of monitoring systems embracing telematics. ALC considers that the overall objective of the Strategy should be: safety and compliance with fatigue and speed regulations. Mandatory use of these systems to monitor speed and fatigue would assist in reducing loss of life in road accidents involving heavy trucks or buses. An EC study in 2005 came down heavily in support of the use of these technologies and estimated that benefits outweighed costs by a factor of seven. Consultations on Energy Efficiency In its 2011-13 Strategic Plan ALC has proposed some specific actions on energy efficiency. It will: Monitor and engage in Government actions on the » Report by the Prime Minister’s Task Group on Energy Efficiency. Develop an ALC position on energy efficiency and » the contribution by the freight transport and logistics industry to climate change and mitigation. The report of the Prime Minister’s Task Group on Energy Efficiency was released in October 2010. The Report states that transport represents more than one-third of Australian final energy use, and more than 40 per cent of all household emissions from energy use. Around 90 per cent of Australia’s transport energy and emissions come from road and rail passenger and freight transport. The Department of Climate Change and Energy Efficiency subsequently held consultation workshops in January and February, focussing on the proposed five foundation measures: An energy efficiency target — driving a step change 1. and positioning Australia at the forefront of the OECD An energy savings initiative — mobilising markets to 2. deliver energy efficiency Governance 3. Innovation, data and analysis — establishing a 4. continuum Building an energy efficiency culture — living and 5. working smarter. Performance Based Standards Draft NTC National In-Vehicle Telematics Strategy In May 2010, ALC wrote to the National Transport Commission to comment on its draft Regulatory Impact Statement on Performance Based Standards. ALC agreed with the proposal to use performance based requirements, with specified outcomes. It also supported the proposed move to a national assessment and access framework – with a National Heavy Vehicle Law administered by a national regulator. ALC believes that this arrangement, with a single regulatory standard, will allow the industry to develop innovative and cost-effective methods to meet standards without compromising public safety. The letter also noted the importance of ensuring that local governments are adequately resourced to identify and map routes suitable for SMART vehicles.