ATTN: Andrew Johnson
Assistant Secretary Maritime and Shipping Branch | Surface Transport Policy Division Department of Infrastructure, Transport, Regional Development and Communications
Dear Andrew,
In response to the "Coastal Trading Reform for Cargo Vessels – Discussion Paper" issued by the Department of Infrastructure, Transport, Regional Development and Communications (the department) Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) have circulated same amongst its members for review and comment.
In general APSA do not have any particular issues with the general changes suggested within the document with exception of that noted under 2.5 Removal of Five Voyage Minimum for Temporary Licences.
APSA feel that the removal of the Five Voyage minimum has the potential to create a less dependable service for businesses moving freight around Australia via sea. Whilst we understand the new proposed One Voyage licence would be in place for 12 months it gives no ability to forward plan with a commitment of certain voyages by Shipping lines. Some areas of concern if a shipping line only has to commit to one voyage to obtain the licence would be;
- lack of certainty to voyages that will carry coastal cargo which impacts shippers ability to forward plan and commit to contracts; and
- if a vessel falls behind schedule they could simply drop coastal cargo in order to get back to their Asian load ports and back on schedule.
We would also note that the recent industrial actions combined with weather / infrastructure upgrades have seen vessels simply drop full imports and collect full International export cargoes, evacuating minimal empty containers or coastal cargo. This again throws shipper schedules and supply chain into disarray. One member who moves some 120 40' FCLs Syd / Melb to Frem and some 40 40' FCLs Melb to Bne has seen their costs increase 4 fold when having to ship via rail and a further 3 fold if they have to use road. These types of increases cannot be sustained. We would suggest:
- a clause that ensures that regardless of industrial action coastal cargo on a scheduled voyage must be loaded; and
- Vessels offering coastal services should be prioritised for berthing in the event of industrial action or such delays
APSA would see that berthing priority being given to those vessels offering coastal services in the event of industrial action / other delays would provide an incentive for carriers to continue offering service in tough times rather than viewing coastal as the first service to drop.
For your consideration – kind regards
Paul Zalai
Director and Co-Founder | Freight & Trade Alliance (FTA)
Secretariat | Australian Peak Shippers Association (APSA)
Director | Global Shipper Forum (GSF)