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Future Freight Networks : Yearbook 2011
66 ALC Advocacy and Policy Submissions In August 2010, ALC made a submission to this Productivity Commission inquiry based on the related Issues Paper. The Submission called attention to the need for planning instruments to ensure the preservation of freight corridors and avoid residential intrusions and congestion near logistics infrastructure. It referred to a number of state planning documents that have addressed this issue and noted that ALC believes that land-use decisions must prioritise the efficient use of infrastructure over other land uses. The Submission included several recommendations for the PC’s consideration. It proposed: Mapping all documents that influence planning » decisions published by governments and COAG. ALC called for decisions to be made from a whole- of-government perspective. To give investors certainty, the frequency of changes » to these documents should also be mapped. The Commission should ask the COAG Reform » Council to set out, as soon as possible, the tests it will apply to assess whether high level national planning criteria have been satisfied. ALC recommended that COAG should recommend: Development of a National Partnership to prioritise » the efficient operation of ports and other nationally significant infrastructure. Creation of a fund to assist state and local » governments that incur expenses by giving priority to the provision of nationally significant infrastructure. NTC Review of Australian Dangerous Goods Code NTC Discussion Paper on: The Role of Government in Rail Freight Investment In December 2010, ALC wrote to the National Transport Commission on its review of the 7th Edition of the Dangerous Goods Code. ALC’s main concern was the need for Australian requirements to be compatible with the International Maritime Dangerous Goods Code (IMDG). Around 90 percent of containers transported by road are continuing from a journey as sea cargo – these containers must comply with the IMDG. COAG’s Guide to Best Practice Regulation suggests that, wherever possible, Australian requirements should be compatible with relevant international standards. A new update to IMDG was released at the end of November 2010; consequently, it is important that any substantial international changes in that release are taken into account when revising the Australian Code. ALC noted that rather than being presented as ‘model’ legislation, to be picked up by Australian jurisdictions according to its drafting protocols, it should be an ‘applied legislation model’. One jurisdiction would then make the Code and the others would then apply it – this is similar to proposals for the national rail/marine safety and Heavy Vehicle Law consolidation. ALC agreed that the paper generally identified the important issues relating to government rail freight investment. It also identifies the policy instruments that could facilitate rail investment. It is essential, however, in ALC’s opinion that those policy instruments do not distort the pattern of use between the various transport modes – i.e. there must be competitive neutrality between road, sea, air and rail. That can only be achieved if rigorous cost-benefit analysis is applied to the application of those instruments. ALC recognises that this could mean that the costs of externalities may be factored into government investment decisions. ALC also believes that rail investment made for community service reasons should only be made if: it would not have been made commercially; » the method of funding is transparent; and » outcomes are clearly identified and capable » of being benchmarked. Productivity Commission Study into Performance Benchmarking of Australian Business Regulation: Planning, Zoning and Development Assessments