by S M G | Jul 6, 2012 | QTLC At Work
The Queensland Transport and Logistics Council (QTLC), as the peak industry body for the freight transport and logistics industry in Queensland, acknowledges that this document represents a unique opportunity to formalise and participate in the shaping of our industry’s future for many years to come. Our constituents, many of which you have heard from already, are concerned to ensure that freight, for once, is not treated as an afterthought when it comes to planning the Region’s future and that it does, indeed, form a central plank of the SEQ 2031 strategy and planning membrane.
At the outset, let me say that the QTLC is impressed with the quality of the document and the virtues of having a well-considered and strategic approach for network planning. It is also reassuring that freight has been given a higher profile than that afforded in similar planning instruments which have been developed in the past.
That said, however, we are concerned that SEQ 2031 falls short of identifying some key issues impacting on the efficiency of freight movement within the region, not only now but in years to come. In short, there is a demonstrated lack of vision for the freight network in a document that purports to provide a framework for planning over the next 20 years.
For instance, only projects which are underway or currently being planned are mentioned. (The Port of Brisbane Motorway upgrade is inexplicably not listed). It would be of great assistance to industry and future planning if there were some aspirational targets included as part of the strategy other than those which are currently stalled for lack of investment or mired in planning approval processes.
To put this another way, the freight section of SEQ 2031 should outline a vision as to how the policy ambitions are going to be achieved. At the moment, the freight network strategy suggests that the industry just has to make do with the infrastructure that passenger transport outcomes dictate. SEQ 2031 should also make reference to the Integrated Freight Strategy for Queensland as a key point of reference in formulating the policy framework adopted for setting the response to freight issues which permeate the study area.
Rail
There is little doubt, either statistically or commercially, that rail freight in and out of SEQ is under pressure from road transport and has been for many years. One of the largest failings we see in the document, as currently drafted, is the homage paid to the undisclosed benefits of moving more freight on rail; both into and around the region. These benefits are neither well articulated nor supported by actions within SEQ 2031. It is commonly understood that passenger services are planned to increase substantially across the Citytrain network with contracts having already been let for more rolling stock and track capacity for commuter services. Yet somehow the concept of a rail shuttle service for containerised freight is being proposed without any consideration of how such a service could operate in this commuter led rail planning environment.
Moreover, how could a rail shuttle service compete with a heavily Government subsidised passenger railway operation with the added protection of legislated passenger priority?
The bulk rail freight traffics into the Port of Brisbane are also in danger of becoming obsolete unless there is a commitment to upgrade the rail link to Toowoomba and beyond to capture this traffic for rail, however, SEQ 2031 is silent on both these issues. Is there a plan to at least keep bulk traffics to the port on rail? Is the Government pinning its hopes on the South Burnett Rail going ahead and bulk traffic being diverted to Gladstone? Industry needs certainty on these issues to both garner investment or avoid investing in stranded assets.
If the idea is to facilitate intermodal terminals at Ebenezer and to the north of Brisbane in an as yet undisclosed location as a means of circumventing the impending rail impasse to the POB then SEQ 2031 needs to acknowledge this with an appropriate plan to increase road freight capacity to the port.
In short, the Government must make a call as to how it proposes to manage rail freight in SEQ; it must either be facilitated or abandoned in favour of another strategy to fill the void. The QTLC’s fear is that, without an emphatic vision, scarce resources will be consumed to support unsustainable outcomes.
Intermodal
The Intermodal terminal strategy, whilst robust in its conception and choice of locations, is not backed up with a strategy to facilitate the linkages required to make these terminals attractive for private sector investment. An intermodal terminal which can’t be accessed by high productivity vehicles is doomed to fail, especially if the ultimate destination of the freight is in the Brisbane City LGA.
Road
There is no mention of the need for high productivity vehicles to be given a broader range of movement within SEQ even though the Queensland Government has signed up for various reforms/ initiatives at a National level. There seems to be a culture developing whereby Queensland, and indeed other states, pay lip service to the National Agenda but then shy away from providing access due to untested political consequences.
We note that the decision to run PBS approved A-Double combinations between Toowoomba and Brisbane for the haulage of grain failed to ignite any public backlash against the Government, yet there seems to be some instilled fear of broadening the use of PBS vehicles except in a crisis.
You must admit that there is a glaring irony in the fact the HPVs can traverse some of the poorest roads in the state but cannot operate on our few priority freight routes (arguably some of the best roads in the country) within SEQ.
The QTLC recognises that the Government is aware of the scarcity of breakdown areas available to support the policy of excluding HPVs from the so called priority freight network, however, there is a distinct disconnect between the timeliness of delivery and the volume of traffic needing to access these facilities. Again, the government must make a choice between pursuing a policy of exclusion for HPVs or facilitate a workable interface between access restrictions. SEQ2031 does not countenance this important issue.
The same can be said of the need to accommodate higher mass limits (HML) and permitted road use on SEQ roads. As approval is granted for major infrastructure and mining projects there does not appear to be any correlating consideration of the need to move machinery or plant components into and out of the region for installation or repair in order to facilitate these core economic activities.
The QTLC strongly believes that a route or routes to the west and north of the region should be identified for such movements and funded accordingly to provide an unambiguous plan for the movement of such freight for both users and regulators.
Planning
The QTLC is encouraged by the fact that freight is being afforded at least some consideration in land use planning. Yet we see potential conflicts emerging from planning documents which, while physically separating transport and logistics hubs from residential encroachment, require both freight and personal transport to share scarce transport infrastructure. Proposed developments at Flagstone (residential) and Bromelton (T&L) being a case in point.
It is also clear from reading the document that decisions are being made about the freight network based on some very old data and projections. Some of the unique studies referenced in SEQ 2031 are based on more timely data, however, the bulk of the assumptions used to highlight potential growth are based on figures which are well out of date. The QTLC would like to see a commitment from the Government to improved data collection and would be happy to support efforts to garner industry support for such an initiative.
by S M G | Jul 6, 2012 | QTLC At Work
Submission in response to the Draft Rail Safety National Law
The Queensland Transport and Logistics Council welcomes the opportunity to comment on the Draft Rail Safety National Law and the Draft Rail Safety National Regulation. The QTLC has reviewed these documents and I, as chair of the QTLC recently attended the forum concerning the proposed legislation hosted by the NTC in Brisbane.
The QTLC, whilst highly supportive of this very necessary move to harmonise regulation of the industry, considers that the legislation meets all of its objectives bar one; reducing the compliance burden.
Whilst the legislation clearly reduces the number of bodies an interstate operator must report to, it is clear that every state has had a hand in ensuring their particular nuances on what must be reported on have found their way into the national legislation.
This has led to 30 items requiring detailed consideration in order to comply with the demands of safety management alone (including unspecified “human factors”). The concern being that the compliance burden may deter smaller operators entering the market whom might only seek to operate on single line or on a hook and pull basis for specific seasonal traffics. Whilst it is acknowledged that there is some scope within the legislation to accommodate circumstance and moderate the regulatory burden, this is highly discretionary.
The “one size fits all” approach will inevitably create winners and losers (ie. Large operators win, small operators lose) in terms of their ability to absorb compliance costs, however it is felt that this is preferable to the current malaise.
Other general comments are as follows:
The requirements to provide data on freight movements are very modest and amount to just the number of kilometres travelled by freight trains on a particular network. It would be good to see tonnages (NTK) at least included and ideally the commodities being hauled to facilitate better rail planning and safety reporting.
The QTLC is not sure why QLD’s extensive crane rail network, which commonly encounters incidents during the cutting season, is excluded from the legislation.
Thank you again for the opportunity to provide comment on this important initiative.
by S M G | Jul 4, 2012 | QTLC At Work
Thank you for the opportunity to provide comment on the Environmental Impact Statement (EIS) for Cross River Rail (CRR).
The Queensland Transport and Logistics Council (QTLC) is the peak body for the freight industry in Queensland and is affiliated with the National Freight Council Network. As such, the QTLC is financially supported by both State and Federal Governments but relies heavily on voluntary industry participation to inform Government decision making and to procure outcomes which benefit the industry and hence all Queenslanders in their pursuit of efficient freight services.
The QTLC is “modally agnostic”; meaning we have no clear preference for any particular mode other than the one which can procure the most sustainable and economically efficient freight transport outcomes. We remain assured that freight rail has a significant and growing role to play in the growth of SEQ and indeed the state of Queensland.
We have reviewed the EIS for this significant project, part of which falls within the QTLC’s remit as it purports to also improve rail freight access to the SEQ network. In addition, the sheer scale of this undertaking also requires that the QTLC voice a clear opinion as to its projected outcomes for the freight and logistics industry as a whole.
We would, of course, have preferred that a project predicated on developing a dedicated rail freight network and attendant infrastructure such as intermodal terminals and roads were being considered alongside CRR. However, we accept that, as usual, passenger transport remains the focus of the Government and that only incidental benefits may accrue to the freight sector.
At the outset let me say that it is evident that significant resources have been applied in developing and planning the project and that we are confident that it will deliver significant improvements to the Citytrain network and rail commuters in general. However, we are less confident that the few concessions afforded to rail freight in and out of SEQ will be realised in the absence of a broader strategy to ensure that rail freight remains a viable alternative to road transport.
Whilst the project will undoubtedly free up some surface train paths for freight there is no guarantee those paths will prove viable if the rail network is constrained elsewhere. It is well understood that rail freight is only viable over long distances and where freight volumes can be consolidated to achieve some benefit over and above the more ubiquitous, but congested, road network.
We maintain the view that encouraging more freight on rail, and the access charges which would accrue as a result, would help defray the cost of the passenger driven and heavily subsidised CRR investment. However, this cannot occur in the absence of a broader investment strategy to grow rail freight as a viable alternative to road transport in and out of SEQ.
In the absence of such an investment strategy, we believe the freight train demand for paths as depicted in Table 3.7 and 4.6 may well be overstated if those paths cannot be utilised due to constraints elsewhere on the network such as the Western Corridor including the Toowoomba Range and points beyond, the mostly single track NCL (particularly on the Citytrain network between Nambour and Beerburrum ) etc.
Conversely, the figures used to depict “demand” in the above table for the base case (2009) would appear to represent actual usage of train paths. Demand for grain haulage, for example, are considerably higher than the number of services actually provided with the balance spilling onto road in unprecedented quantities. New mining ventures, both for coal on the Darling Downs and CSG in the Surat basin will also increase demand for rail services on the Western Corridor with or without construction of the Surat Basin Railway. In short, the rail freight demand might well be understated for the western corridor both now and in the future.
We also note that future demand forecasts for rail freight are identical to the capacity afforded by CRR. It would be useful to depict the maximum number of paths available in outlying years in order to get some appreciation of the redundancy CRR could afford in the event demand forecasts prove incorrect.
Another issue which the EIS neglects to mention, but which is fundamental to the consumers of rail freight services is the time of day goods can be received at their destination. Regrettably, not all freight and logistics businesses can afford to run on a 24/7 basis but may be forced to approximate that model due to limitations on train paths and must pass these costs on to consumers.
We would find it instructive if the EIS could depict the time of day the claimed slots would be available in order to better gauge the usefulness of this newfound capacity as well as gauge public reaction to these slots actually being utilised in a sustainable manner.
We were particularly concerned to note that the EIS makes no mention of the Southern Rail Freight Corridor nor the contribution that corridor would have in terms of exploiting the train paths to the Port and Acacia Ridge that CRR would potentially open up. Increased infill density along the existing western corridor and planning ambitions to increase settlement in green field areas of the Western corridor will conspire to ensure that rail freight is constrained by both passenger movements and a common aversion rail freight services due to noise and time of operations.
Inland rail need not be the catalyst for the SFRC to proceed, nor the frankly absurd assertion that it will not be required until 2031. A burgeoning western corridor will need access to rail freight from overseas, interstate and north Queensland if it is to prosper.
Without the EIS stating as much, we presume that the planning for the future of freight infrastructure in SEQ is based on a strategy to build capacity from the core (in this case the port and Acacia Ridge) to outlying origins and destinations progressively following the implementation of CRR. We would be interested to learn what the current strategy is
While we appreciate that the CRR EIS is focussed on an infrastructure solution to rail capacity constraints, has any provision been made within the project scope to accommodate:
- Longer freight trains?
- Any change to rail operations to provide less separation of trains to increase capacity without reducing speed?
Have any undisclosed presumptions been made about construction of:
- The Surat Basin Railway; or
- Inland Rail?
We enquire as to these points as they could have a significant impact on the stated forecasts for freight demand and the effectiveness that CRR can afford the rail freight sector.
An abiding concern is the potential for narrow gauge passenger services to be introduced to the interstate track from Flagstone via a dual gauging solution. This would be disastrous for interstate freight.
Also, would it not be possible for a significant quotient of the spoil removal to be undertaken by rail? This is a rail project after all. Railing spoil to Swanbank would be a great opportunity for the Government to show its commitment to rail as a viable alternative to road freight and to avert the inevitable public complaints about excessive heavy vehicle traffic created by the project; be it real or perceived.
In conclusion, we are encouraged that the rail freight industry might still have a future in SEQ if CRR proceeds. We are equally confident that rail freight will cease to be a viable alternative to road transport should CRR, or a robust freight inspired alternative, not proceed in the near future.
Yours sincerely
Neil Findlay
Chairman
by S M G | Mar 22, 2012 | Newsletter
by S M G | Dec 22, 2011 | Newsletter
