5thSeptember 2016

Attn:Productivity Framework

National Transport Commission

Level 15/628 Bourke Street

Melbourne VIC 3000

Dear NTC:

Submission to NTC National Land Transport Productivity Framework Issues Paper, August 2016

I submit the following for consideration relating to the four questions posed in the Issues Paper:

Q1.1- Are Company averages required, or break-downs by task/route/vehicle type?

Q1.2- Yes

-Report every two years, with an in-depth topic every other year

Q2- ‘Kilometres travelled’ would assist calculating transport output, as noted in section 4.3

-‘Capital employed’ will aid MFP calculation

-‘Capacity utilisation’ is a key productivity measure for operators

-‘Number of vehicles’ may be useful, including prime movers, trailers, locomotives, wagons. Productive capacity also, i.e. B-Double, semi-trailer, rigid payloads

-‘Fuel litres’ will be assist assumptions when fuel prices are volatile

-‘Industry sector’ would help analysis, i.e. general freight, construction, waste…

-‘Routes’ travelled / regularly active

-‘Congestion’ impacts

-‘Alternative fuels’ use

-‘Intermodal hub’ use will assist network/system productivity contribution analysis

-‘Energy productivity’ may be calculated from fuel input/tonne-kilometre output data

Q3.1- Yes. Yes. Both Hire & Reward and Ancillary operators. Online and paper options

Q3.2- NTC-provided assistance for completing the survey will help the process and quality of information gathered, not only in clarifying requirements and answering queries, but also in aiding data integrity and establishing processes for future survey completion. Need to make it easy as possible for ongoing compliance and quality.

Q3.3- Independent/academic with input from industry, sponsored by government

Q4.1- The project is aimed at nationally significant investment decision-makers, so small, medium and most large transport operators will see no short/medium term benefit to balance their annual administration burden of completing the survey. To 99% of the 50,000 trucking businesses in Australia who have less than 10 trucks in their fleet, this will be viewed as another compliance burden, and these businesses are less likely to have the resources or data systems to complete the survey. Assistance with estimating activity in this sector may be best approached via industry associations or extrapolating other data collected by the Australian Bureau of Statistics.

Q4.2- To help transport companies and their customers identify opportunities for productivity improvement in their operations. The ‘Comparative Information’ benchmarking aspects of the project noted in section 3.2 appear best suited for a separate project, however, as confidentiality issues will be important for operators sharing competitively-sensitive information requested in the survey. They may expect only aggregated industry data will be reported before they decide to participate. If relative performanceof different operators is published, there will need to be some validation of self-reported information required to prevent deliberate over-stating or inadvertent under-stating of performance by respondents.

Thank you for the opportunity to make a submission to this project and I look forward to its progress. Please contact me should you require further information or explanation.

Yours sincerely

David Coleman

7 Norm Court, Wodonga VIC 3690

0455 777 551