The Bus Australia Network (with significant input from BusVIC and Professor John Stanley), submitted its response to the NTC’s public consultation on its heavy vehicle charging determination for 2022-2023.
The cost allocation methodology proposed by the NTC included significant changes from the previous approaches of the NTC. The BAN identified 2 particular high impact changes in the charging principles put forward:
- changes in the assessment of equivalent standard axle (ESA) impacts of different vehicle classes on HV road
- costs and
- changes in the way regulatory costs are allocated (such as funding the NHVR).
The NTC points out that current heavy vehicle charges have fallen short of recovering all allocated costs since 2017-18. However, the NTC report also shows that charge revenue exceeded the HV cost base from 2012-13 to 2016-17. Evidently, the cost-recovery rate varies over time which questions any obligation to improve that cost recovery rate.
In our response, the BAN also made the point that given the good safety record of buses, the justification for a relatively large cost for bus to fund the operations of the NHVR is an unreasonable burden; the NHVR does not typically work as hard for bus as compared with truck-work. The BAN argues that the costs of running the NHVR should be more costdriven, determined by the work that is required across different sectors and vehicle classes.
It is evident that as the vehicle fleet electrifies, the RUC will become increasingly irrelevant. Any future alternative road pricing model should be based on (telematics driven) mass/distance/location (MDL) pricing, an approach that is also better suited to incorporate charges for external costs of HV road use. The BAN also put forward to the NTC, the noticeable absence of external costs in the current pricing model. Efficient road use needs to also recognise, as part of the pricing model, the externalities (ie., congestion mitigation, environmental gains, road safety savings, social inclusion benefits).