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Future Freight Networks : Yearbook 2012
30 COAG Road Reform Plan ALC expressed a range of concerns in its detailed response to the COAG Road Reform Plan (CRRP) discussion paper on charging for heavy-vehicle road use. The paper looked at more direct charges, including charges based on mass, distance and location on the road network -- MDL. In theory, the more damage to a road the higher the charge. Heavy vehicles do more damage to smaller roads than main roads, and that is taken into account. MDL is superficially attractive, but has a number of problems. Overall, changing the pricing mechanism will not necessarily change operator behaviour, such as moving heavy vehicles to more suitable main roads, because often there are simply no alternative routes. Another major concern is that road charges received by jurisdictions will not necessarily be spent on roads. Also, any reform must ensure that externalities are only charged for once. So if charges for things like air pollution, greenhouse gases, crashes and congestion are charged for elsewhere, they should not be charged for again in an MDL system. MDL has some problems in the detail. It would almost certainly need universal in-vehicle telematics. A national approach is needed and the private sector should be encouraged to develop the technology. There are also questions of cost and compulsion to be clarified. Another problem in the detail is that mass might not be the best measure of road damage in the future, as new technologies will reduce the impact of heavy vehicles on roads. For example, larger rigs will be able to use steerable axles, which reduce tyre and road wear. ALC will continue to advocate for a national approach and for greater efficiency in the COAG road-reform process. Tax Summit ALC was invited to attend the Tax Summit in October 2011, with the carbon tax and road pricing dominating ALC's submission and contribution. The Henry Report on the tax system put transport taxing on the agenda. ALC stressed that the tax system should not distort consumers' choice of transport. ALC said it was committed to looking at all areas of road pricing, but stressed its aim of efficient provision and use of roads, and that users should not be subjected to double taxation, particularly taxes on the use of carbon. ALC said that better cost-benefit analysis of infrastructure projects and linking them to long-term volumes would improve confidence and help financing decision-makers. Workplace health and safety In September 2011, Safe Work Australia released for public comment 15 draft model Codes of Practice to support the new national model work health and safety legislation. Included in these Codes of Practice is the Preventing and Managing Fatigue in the Workplace Code of Practice. ALC is satisfied with the contents of the draft code, as outlined in our submission provided to Safework Australia in December 2011, as it includes a reference to the National Transport Commission Guidelines for Managing Heavy Vehicle Driver Fatigue, which industry spent considerable time helping to develop. Economic regulation of airport services In September 2011, ALC provided a submission to the Productivity Commission on its draft report on the economic regulation of airport services. It suggested amendments to the Airports Act to achieve better planning outcomes at airports as they relate to freight. On infrastructure, the submission re-stated ALC's call for a national partnership between Australian governments to ensure the position of freight is better recognised in the planning process (including airports). ALC recommended that the proposed Bureau of Infrastructure, Transport and Regional Economics study into ports and dedicated freight infrastructure be extended to include airport access issues. Local government ALC made a submission to the Productivity Commission study into the role of local government as a regulator, making the point that local councils could be inconsistent and capricious in making decisions about road access by heavy vehicles. ALC called for a stocktake of local government regulations impacting the transport and logistics sector.