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.
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.
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.
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.
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.