The Australian Federation of International Forwarders (AFIF) and Freight & Trade Alliance (FTA) have prepared a detailed submission in response to the NSW Draft Freight and Port Strategy focusing on key operational issues.
Port expansion
The FTA and AFIF have expressed concerns that the NSW Draft Freight and Port Strategy does not provide a clear vision as to how port growth will be managed across the state, specifically what will be the triggers for expansion and overflow capacity between the ports.
Port Botany Landside Improvement Strategy (PBLIS)
The decision of the NSW Government to provide long term commercial leases to manage Port Botany operations gives rise to doubts as to who will manage ongoing compliance with Port Botany Landside Improvement Strategy (PBLIS) regulation.
FTA & AFIF are of the view that the SPC PBLIS team has the necessary rapport with industry, background and operational expertise to maintain a compliance role and to implement ongoing statutory reforms.
New Port Botany Container Movement Coordinator
FTA & AFIF see merit in expanding PBLIS to take on the recommended tasks associated with the proposed Port Botany Container Movement Coordinator (CMC), with an increased focus on rail reforms and addressing issues associated with the current mis-match of operating hours that exist in the international trade sector. The existing SPC personnel managing PBLIS should evolve to take on the role of the CMC driving operational enhancements.
Freight corridors
FTA & AFIF agree with the principle of securing freight corridors, however, the NSW Draft Freight and Port Strategy appears to lack adequate detail on protection of existing buffer zones.
Rail reform
The NSW Draft Freight and Port Strategy appears to lack adequate detail on how to achieve rail mode share increase.
FTA & AFIF appreciate the need for increased rail utilisation to meet the projected increase in containerised trade. To that end, FTA & AFIF see merit in the development of new intermodal terminals, improved infrastructure and services to support these facilities. Impediments to increased utilisation are identified within the Draft Freight & Ports Strategy. It is essential that these issues are addressed, providing commercial incentives for industry to spread the transport task more evenly across both rail and road.
FTA & AFIF agree with the SPC taking on this facilitation role as part of the CMC, in line with the 18 July 2012 media release from the Minister for Roads and Ports referring to the creation of a Port Botany Rail Operations and Coordination Centre (ROOC) facilitating port-rail operational planning, addressing operational issues, coordinating train services through Port Botany and maintaining a safety culture throughout the port precinct.
Road reform
Operational reality is that importers commonly demand delivery of import containers within normal business hours yet stevedores provide slots across a 24/7 basis. In order to manage this task, many transport operators 'stage' container movements by taking delivery of containers in off-peak periods, provide short term storage and make a secondary delivery at the requested time of the importer.
The use of staging solutions will most likely increase with the side-loader fee recently introduced by both Port Botany stevedores. It is understood that this policy is aimed minimising the impact on their operations in servicing vehicles deploying these trailers. It is anticipated that this will lead to an increased use of conventional trailers being to be used to take receipt of containers with secondary delivery to the importer with a side-loader.
Similarly, it is becoming an increasingly common practice for transport operators to stage the return of empty containers to empty container parks (ECP) due to the limited operating hours available at the majority of these facilities across that operate on a Monday to Friday basis (excluding public holidays). This causes delays in the end-to-end receipt and delivery process and at times results in detention fees being paid to shipping lines. This issue is being compounded by the recent policy decision of three major shipping lines to reduce the standard detention free periods from 10 to 7 days. Better coordination of operating hours between stevedores and ECPS would maximise potential for two-way running of vehicles, lessen the need for staging solutions and reduce truck movements within the already congested Port Botany / Sydney Airport precinct.
FTA sees merit in increasing transparency around stevedore time slot allocation. While PBLIS has delivered significant benefits in truck turnaround times, it remains difficult at times for transport operators to obtain slots in either the peak or off-peak periods within the three free day storage periods. This issue is exasperated for containers subject to the Australian Customs and Border Protection Service Cargo Examination Facility (CEF) assessment.
In researching the SPC web site and reviewing various PBLIS reports, it is interesting to note that in the current financial year (up to 13 Jan 2013), 28.9% of all slots were 'carrier cancelled'. This is symptomatic of a much larger problem. It appears as though when slots are available, transport operators obtain as many as they can and then later work through the process of allocating work against each. Leftover slots then are later thrown back into the pool or are simply unused. This creates considerable inefficiencies in the management of the transport logistics process.
Medium and longer term operational issues
It is important that consideration be given to the operational impact that will be generated by the introduction of a third stevedore, Hutchison Port Holdings (HPH) during 2013. It is anticipated that HPH will take business from the incumbent stevedores spreading cargo volumes and reducing the demand for off-peak receipt and delivery in the short to medium term. As overall port volumes grow, there may be merit in introducing further incentives to encourage off-peak receipt and delivery.
An efficient road network to service the Port Botany and Sydney Airport precinct
FTA & AFIF appreciate the need for an efficient road network around the Port Botany / Sydney Airport precinct to minimise congestion and make better use of existing infrastructure. Similarly, the freight sector aims to make better use of existing investments. Through ongoing consultation both government and industry have the opportunity to maintain a focus on achieving this mutual benefit.
An immediate issue requiring further consideration is to review arrangements in context of limitations of high-cube sea freight container movements via Qantas Drive, preventing access to the Princess Highway from Port Botany. This limitation forces additional traffic onto Bunnerong Road, Foreshore / General Holmes / Botany Rd / Gardeners Rd and Denison / Wentworth street.
Relieving congestion around Sydney Airport precinct
All air freight is handled by one of four on-airport cargo terminal operators (CTO) being Toll Dnata, Qantas Freight, Australian air Express and Menzies.
While some freight is delivered direct to / from CTO, the majority of both import and export air freight is consolidated via international freight forwarders within aircraft containers or pallets. Import consolidated freight moves under bond (under control of the Australian Customs and Border Protection Service) and is deconsolidated at licensed premises. Upon statutory release at the consignment level, secondary delivery is arranged to the importer.
Due to the increasing volume of import airfreight and limitations of on-airport space, two cargo terminal operators – Qantas Freight and Toll Dnata – have taken initiatives by successfully introducing 'off-airport' CTO. A by-product of this initiative has been to ease traffic choke points at Sydney Airport with freight forwarders taking delivery of consolidated cargo at off-airport locations in a model that is not too dissimilar to the intermodal terminal concept being promoted in the sea cargo environment. It is also worth noting that the existing on-airport CTO facilities managed by Qantas Freight and Toll Dnata are on short-term leases only, as the land occupied by these CTO is earmarked for further passenger terminal expansion. If passenger traffic movements increase quickly, as the global financial situation improves, this topic will most likely be back on the airport planning agenda again. It is essential that the NSW government and Sydney Airport closely engage with federal statutory authorities, CTO and freight forwarders as a part of any long term planning to take into account commercial interests, fundamental operational requirements and to coordinate overall road management issues.
