FTA / APSA submission to the Independent Review of the Victorian Ports Systems

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) have made the below formal submission in response to the 'Independent Review of the Victorian Ports System – Discussion Paper July 2020' focussing on the proposed Port Pricing and Access Review (PPAR) and Voluntary Port of Melbourne Performance Model (VPPM) as outlined in Section 5 titled 'Economic Regulation' (questions 6 and 7). Based on extensive member feedback, the submission makes the following seven (7) recommendations: 1. the Victorian government to include into the PPAR two-way disciplines between stevedores and transport operators to minimise adverse operational delays and provide predictability in shippers' landed costs; 2. the Victorian government align the PPAR to PBLIS to mandate that stevedores must provide free storage for the day the container is returned from the CEF and for the next two days after that; 3. the VPPM to measure truck turnaround time from entry within the port precinct to account for queuing times outside the stevedore gate; 4. Freight Victoria to engage with Transport for NSW to establish 'best practice' empty container park practices; 5. the Victorian government extend the PPAR to force shipping lines to start the container detention clock from after CEF processing and Border Hold has been released; 6. the Victorian government extend the PPAR to force empty container parks to recover all operating costs from their commercial client (shipping lines) rather than booking fees imposed on third-party transport operators; and 7. the Victorian government extend the PPAR to force stevedores to recover all operating costs from their commercial client (shipping lines) rather than Infrastructure Surcharges / Terminal Access Charges imposed on third-party transport operators.

Victoria has world class manufacturers and producers who are supported by skilled logistics specialists including customs brokers and freight forwarders. The Victorian government needs a paradigm shift in priorities in favour of exporters, importers and logistics providers to facilitate the efficient movement of goods to lead our economic recovery and generate wealth into the future. We look forward to ongoing engagement with the review panel. Paul Zalai -  Director and Co-Founder, FTA / Secretariat, APSA