Submissions

NatRoad is your voice to government and regulators

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Submissions


2021


2020


2019


2018

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: National Transport Commission

Date submitted: 20 November 2020

Summary: This is the final submission lodge in the formal submission making process on the Consultation Regulation Impact Statement (CRIS) for the current HVNL review. NatRoad does not believe that there are sufficient benefits to outweigh the costs to industry associated with the models set out in the CRIS for operator enrolment or licensing.

Outcome: Awaited

Document: NatRoad Submission – NTC re CRIS – Assurance

Attachment A: HVNL reform assurance and accreditation models

Submitted to: National Transport Commission

Date submitted: 9 November 2020

Summary: This is an initial NatRoad submission to the NTC in its review of a document Assessing Fitness to Drive (AFTD) that is a pivotal element of driver fitness assessment.

Outcome: Awaited

Document: NatRoad Submission – Review of Assessing Fitness to Drive Guidelines: Initial Comments

Submitted to: National Transport Commission

Date submitted: 9 November 2020

Summary: This submission on vehicle design is critical of the limited scope of reform suggested in the CRIS for the HVNL review and seeks a broader Commonwealth examination of the Australian Design Rules associated with heavy vehicles.

Outcome: Awaited

Document: NatRoad Submission – Consultation Regulation Impact Statement: Vehicle Design

Submitted to: National Transport Commission

Date submitted: 9 November 2020

Summary: This submission indicates tentative support for a single regulatory system for inspections focused on areas of highest risk not on the idea of  ”registration renewal means an inspection must happen.”  The submission outlines areas of work needed to be explored before that step is taken.

Outcome: Awaited

Document: NatRoad Submission – Consultation Regulation Impact Statement: Roadworthiness

Submitted to: National Transport Commission

Date submitted: 30 October 2020

Summary: NatRoad has asked that this area of the law be fundamentally overhauled, as it is currently dysfunctional. We have indicated that there should be an acceleration of this area of reform that could proceed ahead of the main restructuring of the HVNL. NatRoad has a vision that the future HVNL will support quick, simple and transparent access decision making.

Outcome: Awaited

Document: NatRoad Submission – Consultation Regulation Impact Statement: Access

Submitted to: Department of Infrastructure, Transport, Regional Development and Communications

Date submitted: 28 October 2020

Summary: NatRoad provides feedback on ways that the HVRR should proceed but emphasises that in the short term establishing service level standards that categorise roads, with a range of service for each category should be a Government priority.  We point out that in considering matters like safety and road condition, engineering standards are central. The assessment of roads without engineering criteria being in play should not occur  but the assessment process should be a priority task for Government.

Outcome: Awaited

Document: NatRoad Submission – Heavy Vehicle Road Reform Consultation Paper

Submitted to: National Transport Commission

Date submitted: 30 September 2020

Summary: The fifth submission on the consultation regulation impact statement issued in the HVNL review process.

Outcome: Awaited

Document: NatRoad Submission – HVNL Review: Consultation Regulation Impact Statement: Fatigue, including Fitness to Drive

Submitted to: Joint Standing Committee on Road Safety, NSW Parliament

Date submitted: 21 September 2020

Summary: NatRoad made a submission to the StaySafe Committee of NSW Parliament emphasising that PBS vehicles despite being over-dimension are involved in fewer crashes.  It also reinforces the NatRoad stance that more frequently placed rest areas with better amenities must be government priority as a means to lift safety.

Outcome: Awaited

Document: NatRoad Supplementary Submission – Inquiry into reducing trauma on local roads in NSW

Submitted to: Department of Infrastructure, Transport, Regional Development and Communications

Date submitted: 16 September 2020

Summary: NatRoad favours freight data that supports evidence-based policy, improves transparency and accountability and provides support for innovation.

Outcome: Awaited

Document: NatRoad & ATA Joint Submission – National Freight Data Hub Options Discussion Paper

Submitted to: National Transport Commission

Date submitted: 2 September 2020

Summary: NatRoad supports the option where the HVNL would recognise a standard-setter and assurance provider for telematics technologies and associated data. How this would be actioned should be placed in the hands of an Australasian Data Taskforce. There should be a term of reference in respect of referrals to that Taskforce which requires the separation of data and assurance systems used for enforcement and other data and assurance systems. Plus NatRoad urges a move away from a paper-based system.

Outcome: Awaited

Document: NatRoad Submission – HVNL Review Consultation Regulation Impact Statement Technology and Data

Submitted to: National Transport Commission

Date submitted: 18 August 2020

Summary: In relation to the primary duties discussion set out in Chapter 4 of the HVNL Review Consultation Regulation Impact Statement (CRIS), NatRoad seeks an extra category to be added to the chain of responsibility list of parties in the HVNL. This would be to the effect that a primary safety duty should apply to all parties with influence on transport activities.

Outcome: Awaited

Document: NatRoad Submission – HVNL Review Consultation Regulation Impact Statement Primary Duties and Responsibility

Submitted to: National Transport Comission

Date submitted: 18 August 2020

Summary: NatRoad has made a submission relating to Chapter 5 of the HVNL Review Consultation Regulation Impact Statement (CRIS). We support the proposed regulatory structure that would permit the National Heavy Vehicle Regulator (NHVR) and others to make statutory codes of practice.This structure would permit the performance-based or outcomes based focus that should be at the heart of Commonwealth regulation.

Outcome: Awaited

Document: NatRoad Submission – HVNL Review Consultation Regulation Impact Statement Regulatory Tools

Submitted to: National Transport Commission

Date submitted: 31 July 2020

Summary: NatRoad has made a submission on the HVNL Review Consultation Regulation Impact Statement (CRIS) responding to some of the issues raised about the effectiveness of the HVNL.

Outcome: Awaited

Document: NatRoad Submission – NTC RCRIS Preliminary Issues

Submitted to: NSW Treasury

Date submitted: 31 July 2020

Summary: NatRoad has made a submission commenting on the Draft Report of the NSW Review of Federal Financial Relations entitled Supporting the Road to Recovery. Our submission concentrates on three of the Review’s fifteen recommendations including transformation of road funding, fuel tax and stamp duty.

Outcome: Awaited

Document: NatRoad Submission – NSW Review Federal Financial Arrangements

Submitted to: National Transport Commission

Date submitted: 3 July 2020

Summary: NatRoad made comments on the discussion paper entitled Government access to vehicle-generated data (Discussion Paper)1 released by the National Transport Commission (NTC) in May 2020.

Outcome: Awaited

Document: Submission to National Transport commission – Government access to vehicle-generated data

Submitted to: National Transport Commission

Date submitted: 3 July 2020

Summary: This submission comments on the Issues Paper entitled Examining the legal framework for the land transport of dangerous goods (Issues Paper)1 released by the National Transport Commission (NTC) in June 2020.

Outcome: Awaited

Document: Submission to National Transport commission – Examining the legal framework for the land transport of dangerous goods: Issues Paper

Submitted to: Queensland Ministerial Freight Council

Date submitted: 15 June 2020

Summary: This submission summarises a number of policies that will assist the heavy vehicle industry in Queensland to better recover from the COVID-19 pandemic.

Outcome: Awaited

Document: Submission – Template for Roads and Transport Functional Recovery Group members feedback

Submitted to: NHVR

Date submitted: 17 April 2020

Summary: There should be a targeted, funded education campaign about COR responsibilities aimed at all parties in the livestock chain. That campaign should be followed by increased enforcement measures.

Outcome: Awaited

Document: NatRoad Submission – NHVR Livestock supply chain

Submitted to: NHVR

Date submitted: 13 March 2020

Summary: NatRoad has reinforced the means to achieve greater productivity from the industry, particularly the issue of better access processes where permits should be seen as an exception rather than a rule.  NatRoad seeks greater reform measures in a number of areas especially in measuring compliance costs, better access to data from the NHVR registration database and binding rules on local governments in assessing access permits.

Outcome: Awaited

Document: NatRoad Submission – NHVR Productivity Plan

Submitted to:  Submission to the Treasury

Date Submitted: 12 March 2020

Summary: This submission outlines a number of unfair contract practices in the road transport industry and calls for a strengthening of the law to give better protections to small business.  Unfair contract terms law should be re-examined so that it has a real impact on these unfair practices in the industry.

Outcome: Awaited

Document: NatRoad Submission – Enhancements to Unfair Contract Term Protections

Submitted to: National Transport Commission

Date submitted: 28 Feb 2020

Summary: Heavy vehicle charges consultation report (Consultation Report) was released by the National Transport Commission (NTC) in December 2019. This submission responds to the problematic nature of an increase in heavy vehicle charges at a time of debilitating drought and bush fire devastation that have added to already fierce cost pressures on heavy vehicle operators.  The proposed cost increases even at the level of 2.5% per annum would compound these problems as well as underlining the fundamental unfairness of the current basis of heavy vehicle charging.

Outcome: Awaited.

Document: NatRoad Submission – Heavy Vehicle Charges Consultation Report

Submitted to: Productivity Commission

Date submitted: 15 Jan 2020

Summary: NatRoad has made a submission on the Draft Report entitled National Transport Regulatory Reform released by the Productivity Commission (PC) in November 2019. The submission responds to a number of the issues raised in the Draft Report, focusing on the heavy vehicle sector including:

  • Heavy Vehicle National Law (HVNL)
  • Fatigue Laws
  • Chain of Responsibility
  • Accreditation
  • WHS Laws
  • Transport Technology

Outcome: Awaited

Document: NatRoad Submission – PC Draft Report – National Transport Regulatory Reform.pdf

Submitted to: Joint Select Committee on Road Safety, Federal Government

Date submitted: 31 Jan 2020

Summary: In this submission NatRoad outlines a number of factors affecting heavy vehicle safety, focusing on light vehicle driver education, upgrading infrastructure and better data collection and analysis

Outcome: Awaited

Document: NatRoad Submission – Inquiry into reducing Australia’s road accident rates, trauma and road deaths

Date submitted: 31 Jan 2020

Summary: NatRoad has made a submission to the NSW Joint Standing Committee on Road Safety (StaySafe) relating to its inquiry into road trauma in NSW launched at the end of November 2019. The submission highlights the need to rebuild after bushfires taking into account the infrastructure needs for rural and regional roads.

Outcome: Awaited

Document: NatRoad Submission – Inquiry into reducing trauma on local roads in NSW