In BIC’s submission to the NTC, we support HVNL that recognises that one size does not fit all when it comes to HV law – different sectors have different needs.
- HVNL needs to recognise the difference between truck and bus and the task undertaken including technical issues with vehicles and contracted operations – including specific recognition of existing national minimum safety standards for accreditation for buses and coaches.
- The HVNL needs to have a stronger performance and risk-based approach, that provides operational flexibility, is less prescriptive and offers performance based /alternative compliance approaches for operators to meet the law. This should include incentives to do so and recognise good compliance performance. This should include greater acceptance of technology as a compliance tool. The HVNL should not prescribe the technology, only the compliance performance outcome, and establish an appropriate alternative compliance enforcement regime that allows on road enforcement resources to be better targeted and for good operators to get on with the job.
- The HVNL maintenance group is unnecessary. The law should be allowed to work and not be under constant scrutiny and review (generally by jurisdictions). Where there are issues raised or problems, due to things like idiosyncratic industry operational needs or state differences, this would be better dealt with through the NHVR and specific regulations. The HVNL maintenance group is a contributing factor to promulgating state-by-state HV laws and undermining national uniformity.
- The HVNL should be considered, when it comes to buses, in the context of the future passenger task and future impacts on the task such as population growth, congestion, automation and the efficient functioning, for example, of cities and the transport network, and not in isolation of these broader societal outcomes.
- The HVNL should become more focussed on the use of technology to manage legal access by different productive vehicles using the road network – the current arrangements are inadequate in managing and monitoring access.
- A PBS system for buses is required. The current PBS system is not suitable for buses, limits productivity for buses, and adds costs because it is based on “old school paradigms” about infrastructure, safety, environment rather than an approach that focusses on productivity and positive societal outcomes that passenger transport can deliver.
- Existing exemptions to the HVNL should be retained and only reviewed in the context of adoption nationally as part of the HVNL review. Plus, there needs to be an audit of all current exemptions to ensure that all are correctly captured.
Download the Submission Download