Ref: MG/RT/GG24095
31 October 2024
Heavy Vehicle Productivity Plan Team
National Heavy Vehicle Regulator
PO Box 492
FORTITUDE VALLEY QLD 4006
By Email: brayden.soo@nhvr.gov.au & joshua.forrest@nhvr.gov.au
Dear Brayden and Joshua
Re: Draft Heavy Vehicle Productivity Plan 2024-29
AgForce Queensland Farmers Limited (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 Draft Heavy Vehicle Productivity Plan 2024-29. AgForce has a strong membership base of primary producers, many of which are owner operators or conduct business as contractors. There are not many aspects of agriculture that do not intersect with heavy vehicle use and therefore take a keen interest in the regulator and its vision to simplify and streamline road access.
With transport being the largest single cost for most broadacre agricultural enterprises, it is paramount we improve heavy vehicle efficiencies to reduce costs, enhance global competitiveness of Australian products and deliver savings for farmers. According to the CSIRO 2022 National annual livestock movements report, approximately 25% of gross production value of livestock equates to transport costs, equalling a staggering $12.4b. The CSIRO TranSIT modelling indicates transport costs for the grains industry is $2.1b annually.
It is with these figures in mind that AgForce makes the following comments on the actions listed in the Draft Heavy Vehicle Productivity Plan 2024-29. We have not responded to all 22 individual actions, but have chosen to address the ones most relevant to primary producers.
1. Deliver a notice development and maintenance program that adopts a priorities approach to permit elimination.
AgForce strongly supports efforts to remove permits and transition to notices and gazetted routes.
Permit applications are a cumbersome and time-heavy process that destroys productivity for farmers and inhibits the quick turnaround often needed when weather conditions change, or surge capacity is required during harvest seasons.
3. Partner with industry and road managers to harmonise, rationalise or consolidate access conditions within and between states and territories.
AgForce has been a strong industry supporter of the NHVR and will continue to work alongside them and the Queensland road managers to find a balance between industry requirements and common sense. Queensland and the northern part of Australia have vastly different heavy vehicle requirements to the southern states and whilst we understand the importance of harmonisation across states, it cannot be to the detriment of Queensland producers.
6. Establishing an enduring Emergency Access Notice which can be operationalised during declared disasters and managed in near real time via the NHVR Portal and National Network Map.
Queensland is a state of natural disasters and often suffers from cyclones, floods, bushfires and drought. AgForce strongly endorses this measure to remove the red tape burden when an agile and fast response is required.
8. Deliver Phase 3 of the Strategic Local Government Asset Assessment Project (SLGAAP) to determine the potential freight-carrying capacity of local government access roads.
AgForce strongly endorses this action as Queensland has significant last-mile access issues, with many local governments being understaffed and under resourced. Currently AgForce are working with 3 southern Queensland local governments to improve last-mile access issues and look forward to assisting the NHVR throughout the rest of the state.
10. Work with transport agencies and third-party rail asset owners to better understand and address risks at level crossings to improve safety and efficiency of heavy vehicle movements across these assets.
It is crucial for transport agencies and third-party rail asset owners to explore more efficient technological solutions that maintain safety while reducing red tape. While AgForce strongly supports the need for safe rail crossings, the current regulations and processes create significant inefficiencies and added costs for transport operators. Technology advancements could eliminate the need for costly manual interventions and deliver better efficiencies and safety, particularly in the cane production districts of Queensland.
18. Work alongside stakeholders to reform the PBS scheme in alignment with Ministerially endorsed review of the HVNL.
AgForce strongly supports efforts to reform the PBS scheme. PBS vehicles offer clear productivity gains for growers, with the National Transport Commission (NTC) finding that for commodities using PBS vehicles, productivity increased by 15% to 35%, with grain transport achieving an average productivity gain of 28.9%. Despite the potential benefits however, agricultural operators often face significant challenges in accessing the PBS framework, including navigating complex permit processes and lengthy approval times.
The relationship between productivity, safety and sustainability is widely recognised. AgForce supports the NHVR’s ambition to deliver freight efficiencies within Queensland, but does hold concerns with its ambitious task of reaching zero net emissions by 2050. This zero emissions target cannot be forced upon the industry by integrating vehicles that are not fit for purpose.
We look forward to future collaboration with the NHVR and should you have any questions pertaining to this submission, please contact Ruth Thompson, Grains Policy Director on 0427 472 467 or via email: thompsonr@agforceqld.org.au.
Yours sincerely
Michael Guerin
Chief Executive Officer