This submission details the views of the members of the Australian Trucking Association’s (ATA) Industry Technical Council (ITC) on the proposed changes to the Australian Design Rules (ADR) for Heavy Vehicle Braking Systems released for industry comment.
The ATA has recommended that any potential carbon price be altered only once a year with at least three months warning of any price changes in this submission to the Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education.
The ATA has expressed its support for the draft Transport and Other Legislation (National Heavy Vehicle Law) amendment bill 2013.
The ATA supports a smooth implementation of the HVNL across Australia through the use of state-based provisions in specific areas where the national framework does not yet operate, and says it is vital that industry remains confident that there will be no legislative derogations between states.
This submission provides recommendations on the NTC’s Heavy Vehicle Charges Review discussion paper, which examined the entire PayGo system and identified areas where the NTC intends to assess the accuracy and appropriateness of the system.
The ATA’s submission supports the review and calls for SCOTI to allow further investigation through a formal Regulatory Impact Statement process.
The National Transport Commission has proposed that the charges paid by trucking operators should increase 2.5 per cent from 1 July 2013.
In its submission, the ATA instead recommends that the road user charge and registration charges should increase by 2.25 per cent – the forecast inflation rate.
In Linfox Australia Pty Ltd v Commissioner of Taxation, the Administrative Appeals Tribunal ruled that the fuel used in the refrigeration units of refrigerated trailers is not subject to the 25.5 cents per litre road user charge.
This submission proposes changes to the ATO’s fuel tax ruling (FTR 2008/1) as well as changes to the guidance on record keeping and substantiation in the ATO’s fuel tax credits guide and internal administrative documents. It argues that one of the implications of Linfox is that the fuel used in sleeper cab air conditioners should not be subject to the road user charge. This would enable trucking operators to claim up to $300 in additional fuel tax credits per truck per year.
The ATA has called for the development of a better, objective test for sleep apnoea in a submission sent to NTC acting CEO George Konstandakos.
The submission calls for the development of an objective sleep apnoea test to be included in the NTC’s 3 year work plan as part of the driver fitness for duty standards.
The ATA has called for the NTC to prioritise safety benefits over enforcement opportunities in this submission on Co-operative Intelligent Transport Systems (C-ITS).
C-ITS refers to systems that enable communication between vehicles and infrastructure to improve road safety, traffic management or driver decision-making.
The ATA has expressed its support for the National Heavy Vehicle Law amendment bill, based on the commitments in the NHVR Forward Work Program.
The ATA supports a strong, but fair, approach to the chain of responsibility and executive liability provisions. It also supports the idea of the current penalty provisions being reviewed in the future so that more minor offence penalties are in line with deterrence theories.
The existing ADR 80/03 emissions standard should be maintained and the proposed ADR 80/04 made optional, the ATA has said in its submission to the Department of Infrastructure and Transport.
The submission is in response to the Departments review of Emission Standards for Heavy Vehicles Discussion paper, which is debating the merits of moving to the new Euro VI and equivalent standards.