TFCA recently responded to the National Transport Commission’s draft position paper on reducing paperwork on the road.  A copy of TFCA’s submission is reproduced below.

Electronic Systems for Heavy Vehicle Driver Fatigue and Speed Compliance: Draft Position Paper

 

The Tasmanian Forest Contractors Association (TFCA) represents a number of businesses responsible for transporting wood products throughout Tasmania.  TFCA’s members and their employees are primarily involved in transporting timber from coupes to various processing facilities and, as such, operate on many of Tasmanian’s urban and rural road networks.  The majority of TFCA’s members are small to medium business owners.

 

TFCA certainly welcomes the debate about any efforts to reduce paperwork on the road.  This debate though must be underpinned by a detailed cost-benefit analysis that takes into account various heavy vehicle users and where they operate.  In simplistic terms, efforts to impose electronic arrangements onto the forest products transport sector in Tasmania will not be welcomed by the many small businesses that are struggling in a ‘price taking environment’.  Whilst TFCA appreciates that many of these businesses may benefit from paperwork changes in the long term, the short term cost is still difficult to comprehend. With this in mind, not every business is able to take advantage of economies of scale either, neither are they able to simply pass costs on.  It seems as if the regulators and even some of the policy people are quick to pass costs onto the heavy vehicle sector without really analysing the full effects of their decisions.

 

It is worth noting as well that Tasmania is yet to adopt the national work diary provisions and is still very much operating on State based arrangements.  Therefore Tasmanian operators could feasibly be confronted with two significant record keeping arrangement changes, that is, adoption of national arrangements followed shortly thereafter by electronic requirements.  TFCA encourages the NTC to fully consider the potential ramifications of this ‘double change’.

 

 

Within the Tasmanian forest industry, many of the stakeholders have had to come to terms with electronic sawlog docket arrangements.  It is TFCA’s personal experience that this process has taken many years to effectively implement and we are still confronted with various technical problems.  One of the key learning outcomes from this process has been the need for backup arrangements if technology ‘breaks down’.  Such alternate arrangements must be flexible enough to limit downtime and cost.

 

TFCA notes the discussion within the position paper about electronic signatures and password arrangements.  TFCA has not developed any firm policy in this area but we recognise its importance and strongly submit that any arrangement must be both user friendly and secure at the same time.  TFCA also acknowledges the ongoing need for driver input and we support the proposed change to the ‘counting time method’.  TFCA also welcomes further debate into the sanctions policy especially given the ability of telematics to readily identify and flag minor speed breaches.

 

Whilst TFCA is generally supportive of options that may make record keeping easier, we certainly could not support a mandated electronic arrangement.  In our view, the position paper does not readily identify the short and even long term benefits for the various groups of heavy vehicle users and this is critical going forward.  It is also our view that, in the same way that creating a suitable environment for electronic use is important, so to is the maintenance of an efficient manual record keeping environment.  TFCA though would consider supporting the creation of a suitable transitional scenario providing it was accompanied by the implementation of Government funded incentive grants to assist small to medium operators move to an electronic system.

 

TFCA welcomes the opportunity to participate in any further debate about this matter.

Tagged as: TFCA submission re electronic paperwork