Submission

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View the feedback we have received on the Reforms to Heavy Vehicle National Law Consultation Regulation Impact Statement paper.

Are there any additional impacts you think should be considered? If so, why? Do not standardise heights to 4.6. There will be many more bridge strikes and incidents as a result.

Do you agree with the key impacts that changes to the scope of FRHVs may have on buses, as described above? Do you foresee any additional impacts? No

Do you support one or more options to change enforcement of fatigue-related breaches? Please give reasons for your preference(s). Spelling mistakes, the day of the week not ticket or forgetting to sign a work dairy is not a fatigue related breach and there should be no fine for it. There should also be a good behaviour program with drivers that haven’t had a offence for more then 5 years. That’s a million kms that driver hasn’t had a offence in.

If some of the proposed changes to enforcement of fatigue-related breaches were adopted, would this give you confidence to transition your business to EWDs? No. In all honesty we make our work dairies look good but continue to suffer tight time restrictions or delays at DC’s or warehouses and a EWD would only result in more time spend sitting on the side of the road counting minutes

Taken as a package, would these reforms to fatigue management create a fairer regulatory approach overall? No

Given increased vehicle height limits already available to operators through existing laws and notices targeted at specific supply chains, would a general increase in vehicle height allowances provide material productivity benefits (i.e., reductions in heavy vehicle trips)? No, hell no. Standardising night to 4.6 will lead to many more incidents involving bridges and telephone lines. More investment in lower trailer decks would be a far better use of money

Could reforms that make it easier for operators to operate at increased vehicle height limits lead to any adverse outcomes to road safety or road infrastructure? Are there options (e.g., vehicle or load type limitations) to mitigate any increased risk of adverse outcomes? All I’ve mentioned above. And there’s soo many drivers on the road now that don’t know local streets or roads of the main highways

Given increased vehicle length limits already available to operators through existing PBS scheme and notices, would a general increase in vehicle length limits provide material productivity benefits (i.e., reductions in heavy vehicle trips)? Through our company, no. Our pallets are already stacked as high as possible and that isn’t to the top of our 4.3 trailers. Trying to stack pallets to fill that space would lead to them
Being unstable and a risk of shifting during travel with the current poor state of our roads

Could an increase in vehicle length limits enable newer, more innovative vehicle/trailer designs? What types of supply chains could benefit? Standard dollar door hights at workshops and warehouses is 4.5 metres to accommodate a 4.3 metre trailer. There would be a significant cost to business increasing access hights to buildings

ould reforms that make it easier for operators to operate at increased vehicle length from 19 to 20m lead to any adverse outcomes to road safety or road infrastructure? Which risks would any regulatory conditions mitigate and what controls could be put in place? No, because an extension to the length will only Result in a longer trailer when the increase should be to the prime mover for driver comfort and liveability while working. If the overall length is increased it should be under the restriction that the extra metre must be added to the prime mover and not the cargo space of the trailer