Ref: MG/RT/GG24068
19 September 2024
Zack Kennie
Operational Support
National Heavy Vehicle Regulator
PO BOX 492
FORTITUDE VALLEY QLD 4006
By email: operational.support@nhvr.gov.au
Dear Zack
Re: Intelligent Transport System Compliance Framework Industry Consultation 2024
AgForce is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & goat industries in Queensland generated around $10.4 billion in on-farm value of production in 2021-22. AgForce is the leading voice for Queensland producers and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,000 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
We thank the National Heavy Vehicle Regulator (NHVR) for the opportunity to provide feedback to the industry consultation draft of the Intelligent Transport System Compliance Framework. AgForce have a strong membership base of primary producers, many of which are owner operators of heavy vehicles or conduct business as contractors. There are not many aspects of agriculture that do not intersect with heavy vehicle use and therefore, the agriculture industry takes a keen interest in the work of the Regulator and its trajectory towards access programs and monitoring.
In principle, AgForce supports the NHVR’s monitoring and compliance activities that encourages and promotes safe and productive heavy vehicle practices. However, AgForce often receives feedback that there is confusion between NHVR’s programs and what Queensland’s road managers require. AgForce strongly encourages better alignment of monitoring and access requirements. Having multiple platforms to log in to and different systems to follow is time consuming, confusing and will ultimately lead to unintended non-compliance or regulation breaches.
AgForce would like to see significant advancements in how the data collected is being translated to better access and infrastructure improvements.
Acknowledging there is a state-based road manager being Transport and Main Roads (TMR) that does hold majority of responsibility for the quality of our roads, heavy vehicle operators are not seeing any benefit for the data currently being supplied to the regulator.
Given the significant costs involved in transport for agricultural enterprises, many of them seek to have access to improved productivity schemes. The NHVR’s portrayal of operators commercially benefiting from using intelligent access programs is large operator centric.
Agriculture operators tend to be small with a single or a few trucks. Reliance upon adoption on the basis it will give operators the ability to monitor where their trucks are, manage fatigue or optimise scheduling is short sighted and will likely leave behind an entire industry who want to take advantage of greater road access and higher mass limits.
AgForce seeks to ensure that agriculture has equitable access to road networks. The current trajectory of improved access to the road network in return for monitoring is idealistic and in many cases for agricultural vehicles, cost prohibitive.
AgForce welcomes the opportunity to participate in the industry adoption of intelligent access systems for Queensland to ensure Agriculture can take advantage of the opportunities presented in a logical and appropriate way. Perhaps the regulator could consider Agriculture specific incentives to help cover the disproportionate costs of telematic monitoring systems for those who do not operate commercial truck fleets.
Furthermore, AgForce welcomes the opportunity to resolve our list of roads that need desperate attention to ensure safe operations of heavy vehicles and public road safety.
Should you have any questions pertaining to this submission, or would like more information, please contact Ruth Thompson, Policy Director on 0427 472 467 or via email: thompsonr@agforceqld.org.au.
Yours sincerely
Mike Guerin
Chief Executive Officer