FTA /APSA SUBMISSION - PORT BOTANY LANDSIDE IMPROVEMENT STRATEGY (PBLIS)

Monday, March 7, 2022

FTA_Submission_PORTS AND MARITIME ADMINISTRATION ACT & PORT BOTANY LANDSIDE IMPROVEMENT STRATEGY.pdf

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) see merit in the NSW Government commissioned review of the Ports and Maritime Administration Act (PAMA) 1995 and the Port Botany Landside Improvement Strategy (PBLIS).

New South Wales has world class manufacturers and producers who are supported by skilled customs brokers and freight forwarders and are ready to take advantage of the opportunities created by trade liberalisation measures and those economies recovering from COVID-19.
The PAMA and PBLIS have served the international trade sector well, however opportunities clearly exist for further reform to meet needs of the State's framework for ports and maritime management, tackle existing inefficiencies and support NSW industry and jobs growth. 

FTA / APSA look forward to ongoing engagement to support positive outcomes from the review making the below six (6) recommendations with supporting explanatory notes in the following submission.

FORMAL SUBMISSION

SUMMARY OF RECOMMENDATIONS


RECOMMENDATION 1 – (retention of road discipline regulations) retain Port Botany Landside Improvement Strategy regulations that enforce two-way penalties between stevedores and road transport operators in the use of vehicle booking systems.

RECOMMENDATION 2 – (establish a formal rail consultative forum) a structured industry, port and government consultative forum is required to establish rail user requirements, operational needs, strategic goals and the establishment of regulation and standards on a need basis.

RECOMMENDATION 3 – (extend free time of border and biosecurity held containers) revise Section 17 (c) of the Port Botany Landside Improvement Strategy Mandatory Standards to ensure stevedores offer a minimum of 3 working days free storage after the container is free from border or biosecurity intervention.

RECOMMENDATION 4 – (regulate the mandatory use of electronic messaging for container dehire processes) regulate shipping lines to provide Electronic Delivery Order information to empty container park vehicle booking system providers for all import containers to facilitate improvements to transport logistics.

RECOMMENDATION 5 – (regulation of container detention practices) the need for regulation, similar to US Federal Maritime Commission (FMC), to ensure reasonable container detention policies are administered for the dehire of empty containers..

RECOMMENDATION 6 - (regulation of Terminal Access Charges) introduce regulation to force stevedores and empty container parks to cost recover directly against their commercial client (shipping line) rather than through vehicle booking systems used by third party transport operators.