GREG GIBBINS

1
National Productivity - Constrained by Process

• GREG GIBBINS
• General Manager - FCL Interstate Transport
  Services

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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
• 546 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

• 546 container
• Quad axle trailer
• Tridem prime mover

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PBS / SMART Vehicle Criteria

• PBS process to permit
• Transport operator determines productive vehicle
  combination
• PBS performance report cost from 8,000 carried
  out to establish compliance
• Complete SMART Heavy Vehicle Application
• 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
• Current applications have to be submitted via the
  IRP. Any outstanding applications currently with
  State agencies now must begin process again under
  IRP
• The IRP carries out required assessment of
  vehicle combination
• IRP makes recommendation to State Road Authority
• 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 CSLAs 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, FCLs
  application would set an unacceptable precedence
• FCLs 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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Examples of Inconsistent PBS National Permits
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Victoria PBS Approval

• p Rural, Bandiana to Wygunya
• p Metro, All HML routes (on application)
• r Ballarat / Broadford
• Question Why both national highways?
• Question Why inconsistent application of PBS?

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Tasmania PBS Approval

• p zero
• r 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
• p BDouble routes by application (Note 19m
  long!)
• r 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

• p zero PBS
• r 546 Regional
• r Quad axle Metro
• r 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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Questions?