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
