| The submission acknowledges the importance of long-term planning but raises concerns about a lack of clarity, enforceability, and industry accountability in key areas of the draft strategy. Key recommendations include: - Commit to Webb Dock rail delivery or refund Rail Infrastructure Fees to port users.
- Introduce a sunset clause and transparent project funding model, supported by annual public reporting
- Guarantee cost neutrality and operational compensation for Tasmanian trade if relocation proceeds.
- Implement dynamic pricing and volume-linked incentives to support a modal shift to rail.
- Clarify integration between PoM-led terminals and the Port Rail Shuttle Network to ensure compatibility and commercial alignment.
- Publish a 24/7 landside operations strategy with defined performance targets and supporting infrastructure.
- Protect key freight corridors, including Lorimer Street, through planning overlays and transport policy safeguards.
- Embed industrial zones into planning schemes and introduce freight buffer protections against incompatible land uses.
- Ensure transparency in pricing and infrastructure charges, including annual public reporting of container levies and co-designed post-2032 tariff regulation principles.
- Develop a dedicated workforce strategy, focusing on standardised training, skill shortages, and emerging technologies such as alternative fuels.
- Introduce a measurable sustainability framework, including emissions targets, modal share benchmarks, and annual environmental performance reporting.
Sal Milici - Licensed Customs Broker General Manager Trade Policy & Operations - FTA / APSA
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