Specialised container transport
Submission to National Competition Council Specialised container transport application for declaration of a rail service and freight support service provided by Westrail, August 1997
Prepared by Marjory Bollinger on behalf of the Highway Safety Action Group
Executive Summary
Comments contained in this Submission from the Highway Safety Action Group of NSW Inc are derived from comments made to members of our group and by concerned citizens who have identified the need to maintain, and, in many instances, restore, a coordinated transport system making greater use of rail to service the needs of Australian communities.
Rail services are essential. An effective, efficient, cost effective, coordinated transport system, making better use of rail must be in place to encourage regional development and employment in inland Australia for rural communities to survive, and hopefully prosper into the future.
To justify the maintenance of rail infrastructure it is imperative that maximum levels of traffic be encouraged to operate on the rail network, taking advantage of all possible opportunities to increase usage.
The difficulties encountered by SCT are not unique to SCT and by no means encourages greater use of existing rail infrastructure, but rather places rail in a further state of decline which will eventually result in the total failure and closure of the system.
Reductions in usage of rail services for the transport of heavy freight have forced huge volumes of freight onto the national road network with infrastructure totally incapable of coping with existing levels of freight, let alone increasing it.
Should this trend continue we will arrive at the point where there is no alternative to road, creating a transport monopoly eliminating alternatives.
Closure of rail services have had catastrophic results at a community level.
The economical, environmental and social cost benefit gains to the community through increased use of rail can not be measured in dollar terms. The real cost of road accident trauma cannot be measured in dollar terms, nothing can replace a human life.
The steel on steel alternative is proven more cost effective and environmentally friendly than rubber on tar, it eliminates the need to replace and dispose of rubber tyres as well as providing huge reductions in fuel consumption and emissions.
In making its judgement it is imperative that the Council consider:-
Background
The Highway Safety Action Group of NSW Inc is a high profile, non profit voluntary community organisation promoting safe road travel for the benefit and welfare of the community at large.
Aiming to encourage a realistic balance of road and rail haulage of goods and passengers.
Acting as a community group to achieve our aims by liaising with other bodies with similar objectives promoting local community awareness on road safety.
The HSAG was formed in Orange in May 1992 at a public meeting attended by some 400 people following a spate of fatal road accidents in the Central West.
During the five year life of the HSAG we have successfully obtained many benefits for the community which include major construction works to the Great Western Highway between Bathurst and Lithgow and increased volumes of flammable fuel transported by rail.
Our group has representation on many Community Consultative Committees, both Government and non-government.
Objective
Our comments to the National Competition Council regarding Specialized Container Transport's Applications for declaration of rail service and freight support services provided by Westrail are made with the intention to demonstrate to Council the need to maintain and encourage patronage on the infrastructure referred to in the SCT submission for the benefit of the community at large.
Rail infrastructure must be made available to operators and maintained to ensure these services are available to meet the needs of the community.
In assessing rail services and infrastructure, all aspects must be considered, not simply the dollar value and dollar profitability of providing services, but also the economic and social costs to the community by placing additional traffic on roads if rail infrastructure is not maintained and utilised to its fullest potential.
Methodology
This submission has been compiled from general comments representing views passed on to the Highway Safety Action Group of NSW Inc by members of the community, many of whom have not had the opportunity to read the detailed information as set out in the issues paper.
Broadly speaking the comments are not based on technical or statistical data, they are a common sense view from average members of the community as they see the need for the provision of rail transport to service and meet their needs, both now and into the future.
Past and present experience by the Highway Safety Action Group of NSW Inc, indicates to us that the perception of opening up the rail network to private operators by government agencies is little more than a 'Claytons' offer.
To us there appears to be a permanent staff of bureaucratic 'brick wall builders and door slammers' employed to deter all efforts by private operators who propose to run trains.
Members of our group agree that Government decisions should not be made based on the balance of statistics and the dollar profitability of each individual Government service or department, but the balance of profitability should also be balanced against the costs and benefits to the community IF services are not provided.
It is our view the real cost to communities not serviced by rail far outweigh the dollar savings of failing to provide or increase services.
The intent of this submission is in support of rail transport as opposed to road, taking into account the costs and benefits of both modes.
Past practices by government agencies towards private operators gaining access to the rail network and providing a commercial community service have been very negative.
Quotes from the issues paper are shown in bold Italic print.
Quotes from SCT's Application are shown in Italic print.
Highway Safety Action Group of NSW Inc comments follow in standard print.
Public Hearing
The Highway Safety Action Group of NSW Inc hereby requests notification of any Public Hearings in relation to SCT application and would appreciate the opportunity to appear at any such Public Hearing which may be held in order to expand on this submission.
Criteria
1. Criterion
Access (or increased access) to the service would promote competition in at least one market (whether or not in Australia), or other than the market for the service
"Access for an SCT freight train service on the Sydney-Perth route would promote an entirely new freight train service on this route, in addition to the only existing freight service on the route, which is by National rail Corporation. Thus such access for SCT would introduce rail competition on the route. Access for SCT would also promote competition as SCT would be an additional service to road and sea services between Sydney and Perth."
1.1 Highway Safety Action Group of NSW Inc comment
There could be little comment other than to agree with the statement by SCT IF the intent is to promote competition.
1.1.1 The Service
The service should promote competition in the market by providing an alternative freight service Sydney-Perth as this market is currently restricted to either road or one single rail operator.
1.1.2 Market Participation
Market participation is restricted to one rail operator, road transport or sea. A professional private road transport industry and improved road conditions has taken large volumes of freight from rail to road.
Assuming SCT could inject the same professionalism and service into a rail transport system it could do nothing other than reduce government costs by reduced road maintenance costs and community costs due to road accidents.
1.1.3 Service Features
Service features such as price, transit time and reliability would largely be out of the hands of SCT unless there is improved government cooperation.
2. Criterion (b)
It would be uneconomical for anyone to develop another facility to provide the service
"railway construction and extension is extremely protracted and costly (as the VFT proposal showed and as the current Speedrail and Alice Springs-Darwin railway proposals show)
there is no practice in Australia of competing vertically integrated railways servicing the same centres ; and
the development of another railway line could not be financed / the railway network and associated infrastructure and facilities on and related to this."
2.1 Highway Safety Action Group of NSW Inc comment
In support of SCT's above comments, it is completely beyond our comprehension for the Council to ask "Is the rail track used to provide the service uneconomical to duplicate"
It is the experience of the HSAG of NSW Inc that little doubt exists that Government of either political persuasion are intent in following the recommendations of Booz Allen and Hamilton to close down rail services in Australia.
2.1.1 Duplication of Infrastructure
Surely it would be uneconomical to duplicate infrastructure which already exists and is not being utilised to capacity.
The Government by further splitting the atom and creating corporations simply eat up even more revenue in administration and is counter productive to the needs of Australian communities.
The more different departments or corporations which are created, the harder it is to arrive at a consensus or agreement to get anything done, it simply creates another link in the chain to be able to pass the buck from one to another so as no one has to make a decision.
2.1.2 Common Sense
Common sense alone should be all that is needed to determine it uneconomical to duplicate this infrastructure.
Why are these costly stalling processes continuing to deter operators wishing to productively utilise infrastructure which in many instances is being left to rust and deteriorate beyond repair?
2.1.3 Community Service
As rail was intended to provide a community service, it should remain just that, with the Government ensuring best management practices are in place.
Government claimed rail was not cost effective (as per Booz Allen Hamilton) and should withdraw from providing rail services due to the financial losses being experienced by Government in continuing rail operations.
Thus the Government process of downsizing rail commenced and the community is informed the SRA has become several Corporations supposedly enabling private enterprise to operate trains, it was claimed private enterprise could be more cost effective in providing rail services.
As the Government is not prepared to provide rail services, and if it is genuine in its commitment to have private operators provide these services to meet the needs of the community, private operators should be assisted and encouraged wherever possible to do so.
2.1.4 Competition
How can there be competition if infrastructure use is limited to one or two providers, surely this is a monopoly situation.
Traditionally, rail opened up inland Australia and it has the ability today to sustain or destroy inland Australia if rail closures continue. As it appears government is not prepared to provide these services, surely they should be encouraging participation and expedient processing of applications such as SCT.
2.1.5 SCT's Freight Support Services Application
SCT states at page 8 of its application that the support services require a suitable terminal, shunting locomotives, crewing and a locomotive fueling pad. SCT acknowledges that it is possible to duplicate these services but not immediately. SCT commenced developing such facilities at Canning Vale in late 1995 but does not anticipate that they will be commissioned until late 1998. SCT states that:
2.2 Highway Safety Action Group of NSW Inc Comment
As SCT only require interim access to facilities currently in place which have the capability and capacity to provide services to SCT, denial of access to these facilities would indicate Westrail hold a monopoly, restricting fair competition.
2.2.1 Duplication of Freight Support Service
SCT have clearly stated it would not be possible for anyone to duplicate another such facility in less time than they propose to do so.
Certainly it would appear the 'associated infrastructure and facilities' would be an integral part of the facilities, trains need fueling opportunities to operate.
3. Criterion (c)
The facility is of national significance having regard to:
(i) the size of the facility; or
(ii) the importance of the facility to constitutional trade or commerce; or
(iii) the importance of the facility to the national economy
"The existing railway Sydney/Melbourne to Perth is of national significance because it forms part of the railway which links the major cities, at the eastern and western extremities of the nation.
The railway carries an estimated 70% of all freight on the east-west corridor.
A transcontinental railway, of which the subject Kalgoorlie-Perth portion forms part, has been of national significance as shown by the Australian Government's construction operation and financing of a substantial part of this railway."
The railway line Kalgoorlie/Perth must be considered as having significant national importance as stated by SCT.
It also provides an important link in the defence mechanism of Australia in time of conflict and should be maintained. SCT's application would assist in maintaining the viability of this infrastructure during periods of non conflict.
3.1.1 National Importance
One has only to reflect upon times of flood or derailment when this transport link is out of commission and recognise the inconvenience and chaos cause on a national basis to recognise the degree of importance nation wide.
4. Criterion(d)
Access to the service can be provided without undue risk to human health or safety.
4.1 Highway Safety Action Group of NSW Inc comment
It is difficult to see how there could be anything other than improvements to human health and safety by the provision of this service.
By transferring freight from road to rail there would be significant improvements to environmental aspects due to less emissions from road vehicles.
4.1.1 Community Benefits
Reduced community costs due to reductions in road accident trauma.
5. Criterion (e)
Access to the service is not already subject of an effective regime.
5.1 Highway Safety Action Group of NSW Inc comment
As Western Australia has no effective regime at this point in time, there can be no comment other than common sense should prevail and provide access to facilities.
6. Criterion (f)
Access (or increased access) to the service would not be contrary to the public interest.
6.1 Recent Developments
As discussed in Section 2 of this paper, the Federal Government has recently announced a proposal to establish a new government owned national track entity to manage the interstate rail network. In determining whether access would be contrary to the public interest, the Council needs to consider whether to take account of these forthcoming access arrangements.
6.1.1 SCT's Rail Service Application
"As a result of access that SCT has had for over 2 years and that other operators have over the Perth/Kalgoorlie line, the dominant operator on the line, NRC, has lowered its prices by 36% to 56% from those mooted as applying 2 years ago. On the Brisbane-Melbourne corridor, where there has been no such access, NRC has not lowered its rates.
Westrail, as a statutory corporation, should be taken to be acting in the public interests
It would protect the environment, by keeping SCT's customers' goods off the road. One wagon on SCT's freight train would require 2.5 trucks on Western Australia's roads.
It would promote the use of the most direct east-west rail link, thereby: contributing to its availability to other train operators; lessening the need for government support for the link and reduce the threat of closure of the NSW portion of the link."
6.2 Highway Safety Action Group of NSW Inc comment
As a community group the HSAG cannot see any disbenefits to the community if this service is granted but rather see only community advantages through this service.
The Highway Safety Action Group of NSW Inc does not consider the 'forthcoming access arrangements' should be considered at the point in time of this application, as government instrumentalities are renown for the length of time taken to arrive at a conclusion.
6.2.1 Judgement on Merit
This application should be judged on its merits, under the rules currently in place governing such applications. Failure to take this action could well see this service not proceeding due to time lag caused by government indecision.
6.2.2 Cost Benefits
Environmental and social cost benefit savings would be derived due to less use of road transport by way of reduced fuel consumption, road maintenance and road accident trauma.
This service would enhance the future viability of the Sydney/Broken Hill line which is currently under threat of closure and is the most direct route between Sydney and Perth.
7. SCT's Freight Support Services Applications
"The Forrestfield yard is the only terminal available in the Perth metropolitan area for full length trains, apart from the terminal of NRC. NRC is not prepared to allow other operators to arrive their trains at their terminal. It is essential that Forrestfield be maintained and accessible to train operators, at least until other terminals are available such as the one we are developing at Canning Vale.
Perth needs a full length train terminal additional to that of NRC so that it will attract train operators that will compete with NRC. The benefits of competition are shown from the access that SCT has had for over 2 years and that other train operators have to Forrestfield.
In that time the dominant operator on the line, NRC, has lowered its prices by 36% to 56% from those mooted 2 years ago. On the Brisbane-Melbourne corridor, where there has been no such access, NRC has not lowered its rates."
7.1 Highway Safety Action Group of NSW Inc comment
The Highway Safety Action Group of NSW Inc would not support Council waiting to have the results of the 'forthcoming' Transport Ministers meeting, as government instrumentalities are renown for the length of time taken to arrive at a conclusion.
This application should be judged on its merits, under the rules currently in place governing such applications. Failure to take this action could well see this service not proceeding due to time lag caused by government indecision.
7.1.1 National Access Agreement
It is our understanding that it would be most unlikely for the subject of each of SCT's applications to be covered by any forthcoming national access arrangements.
8. SCT's Freight Support Services Application
"Declarations are sought for items (i), (ii) and (iv) for the period until full commissioning of SCT's proposed freight terminal at Canning Vale and, for Marshalling and Shunting Services, until SCT is accredited to undertake its own shunting and financial arrangements have been finalised between SCT and Westrail with respect to reductions in Westrails' charges for bundled services to take into account the removal of the shunting service from the " bundled" service."
8.1 Highway Safety Action Group of NSW Inc comment
It would be reasonable to assume the duration of this declaration should be the length of time requested by SCT to enable them to establish an economically viable service to the community.
9. Conclusion
If there is a genuine commitment by government to encourage competition within the transport system, rail in particular, from a community perspective the Council could not arrive at any decision other than to grant this application.
