NSW Shift From Preservation To Optimisation On HV Access

Transport for NSW has unveiled a complete refresh of its heavy vehicle access policy under the NSW Freight Policy Reform Program, in recognition of the need to respond to changing markets, emerging technologies such as LZEVs, and the demands of the increasing freight task.

TfNSW is the state government body responsible for strategy, planning, policy, regulation and funding allocation for all modes of transport in NSW, including the movement of freight by heavy vehicles.

Currently, a draft of the refreshed Heavy Vehicle Access Policy is available for public comment until Friday, May 31, 2024. More information is available here.

At more than 50 pages, the draft policy is a lengthy and complex read. However, at face-value, it appears to represent a significant shift in attitude by the NSW Government to recognising it has a positive role to play in enhancing the productivity of the road transport system.

The draft policy is based on five policy ‘pillars’: road network infrastructure; heavy vehicle configurations; access; telematics and data; and partnerships. Each of those pillars are aligned to a guiding policy principle, and one of three strategic outcomes for the freight transport industry.

Underpinning the policy is the recognition that the two key elements in improving productivity, safety and sustainability are to expand access to the road network for high-productivity vehicles and to increase the number of new, safe and efficient high-productivity vehicles using the network.

Overall, HVIA believes this is a refreshingly comprehensive strategy from the NSW Government and is keen to see other regulators adopt a similar set of principles.

While the core principles are sound, some of the details needs to be developed further if this approach is to be extended to a national strategy.

Preservation to optimisation

The transport industry has long called for a shift in the mindset of road infrastructure managers.

Remarkably, it seems this message is finally getting through, with the policy paper noting: “The development of agile and resilient networks requires a shift in focus from network preservation to optimisation.

“This means that the basis for access decision-making must move from preserving assets to optimising the use of those assets by safe, productive and sustainable vehicles whilst minimising the impact of ageing and polluting vehicles on those assets.”

HVIA applauds the recognition of this reality by the NSW Government but the task of ensuring other states and in particular local government will also embrace this philosophy will be the real test of the success of the strategy.

Relaxed regulations for decarbonisation

NSW was one of the first states to announce a trial network of increased steer and drive axle masses to support next-generation LZEVs and appears committed to expanding on that work.

The draft policy flags an upcoming network-wide analysis to understand the impacts of both increased vehicle mass and dimensions, and specifically references the needs of future vehicle technologies. This could mean greater access for LZEVs at higher load limits.

HVIA is keen to see further discussion around the roles of both LZEVs and high-productivity combinations in meeting Australia’s freight transport needs over the next quarter of a century.

In particular, it is important to recognise magnitude of the infrastructure investments required to meet these needs while also pursuing government emissions targets.

A template for success

The paper proposes 16 high-productivity vehicle design templates catering to the general freight, livestock, logging, refrigerated and container sectors, and including B-doubles, A-doubles, B-triples, and a BAB-quad.

While this may be the most expansive attempt at smoothing the pathway for PBS applicants, it is by no means the first, and previous efforts by regulators have achieve mixed success.

The difficulty lies in the need to balance the vehicle’s design with the access constraints that infrastructure managers wish to apply to it. If the vehicle’s design is too revolutionary, its access becomes restricted.

Conversely, maximising access tends to increase restrictions on the vehicle’s design and ultimately limit its value to industry. The extent to which this is balanced will likely determine the eventual success of the templates.

Pleasing the masses

One of the actions under the ‘Access’ pillar is to investigate opportunities to allow vehicles to operate at Concessional Mass Limit (CML) as per General Mass Limit (GML).

It is a somewhat clumsy phrase that is not expanded upon anywhere in the paper, but it appears to indicate that general access (ie ‘as of right’) vehicles operating at the HVNL GML axle loads will be allowed the same level of access at the higher CML axle loads.

If that is indeed the case, it would be a welcome incremental productivity improvement, as CML generally translates to a five per cent mass increase above GML.

This was also proposed as part of the current HVNL review. It does, however, necessitate participation in the National Heavy Vehicle Accreditation Scheme (NHVAS), and carried a number of other conditions. It is unclear whether participation in the NHVAS, and/or any of the other conditions would apply.

Notices and schemes

The ‘Access’ pillar includes an action to explore opportunities to extend notices and schemes to streamline access, which unfortunately isn’t directly discussed in the paper.

Without any detail, it could be interpreted in one of two ways: either that TfNSW is expanding its range of regulatory instruments for access, such as schemes and permits; or that it is removing the need for permits by transitioning to gazetted notices.

The difference is particularly important, as additional permits and special access schemes can often add administrative burden and cost to the industry.

Encouragingly, the policy includes a few examples of transitioning access from permits to access by gazettal (i.e. as-of-right access) in its list of TfNSW’s prior achievements, so the latter of the two interpretations may be a safe assumption.

Notwithstanding, the transport industry already has to contend with dozens of gazettes, notices and schemes. The NHVR’s webpage lists almost 40 notices under the HVNL, many with additional supporting documents and conditions that vary between jurisdictions.

On its own, NSW has almost 30 HVNL notices, most of which provide exemptions to mass, dimension and loading requirements of the HVNL.

Simplifying and eliminating the need for these documents would be the most effective way of achieving the ‘Best First’ policy principle of the paper, which is described as ‘making it easiest for the safest, most productive and sustainable vehicles to access the network’.

Increased oversight

The telematics and data pillar of the paper briefly touches on the use of improved data to improve planning and investment in the road system but does not explore that issue in any depth.

HVIA is of the view that improved decision making on road infrastructure investment and management is key to improving productivity, safety and emissions and should have been the focus of this section.

However, the draft strategy is explicit in stating that telematics will be included as a condition of access for all restricted access vehicles under notice and permit in NSW and that sharing this data with state and local road managers is a critical link to increased network access.

This change is somewhat undefined and vague, but if implemented at face-value, would have substantial implications for the industry, as many notices do not currently require any form of telematics.

This approach seems to be focussed more on compliance than on improving productivity safety or emissions.

HVIA supports the use of telematics to improve safety, productivity and environmental outcomes, and as such is aware there are many different types of telematics systems and capabilities available, each of which can address a specific regulatory concern.

In that context, an appropriate question is, which telematics requirements do TfNSW propose to apply to which notices/permits, and to what benefit?

End-to-end networks

The draft policy proposes to collaborate with industry, local councils, rail infrastructure managers, Commonwealth and State agencies to develop end-to-end networks.

That initiative is without doubt a positive step, as certainty of access amongst decision-makers has been the enduring limitation of heavy vehicle productivity in Australia.

But the obvious question that must be asked is, where is the ‘end’ of the network? It’s a tricky question, and it might be easier to answer it in the negative rather than the positive: freight networks do not end at state borders.

Perhaps unsurprisingly for a NSW-focussed document most of the discussion is around freight movements within the state.

However, it is worth remembering that inter-state freight movements represent more than 50 per cent of road freight movements in NSW (Bureau of Infrastructure and Transport Research Economics 2022).

Despite this, harmonisation between states does not get much coverage in the report.

Conclusion

This draft policy demonstrates the NSW government has tried to take a leadership role in access policy and it should be commended for that effort.

However, to be truly effective this policy needs to be scaled up to a national approach and needs to be endorsed by governments at all levels.

Naturally, HVIA staff will review it in-depth and provide a formal response guided by discussions with members over the course of the consultation period.