Trailer Magazine


PBS: A Game of Regulation

  • From the January 2016 issue.
PBS: A Game of Regulation

Australia’s openness to the idea of high productivity vehicle design has gained it international attention, but a complex approval process and on-going political quarrel have long held it back. Where are we standing now?

It’s safe to say George R.R. Martin did not have high productivity vehicle design in mind when he penned the first sentence of A Game of Thrones in 1991, starting the best-selling novel with a simple, “we should start back.”

Yet, the ominous opening could be a perfect fit to tell the twisted tale of Australia’s Performance-Based Standards (PBS) scheme – at least if you listen closely to those at the coalface.

“Talking about PBS is a lot like explaining Game of Thrones’ intricate storyline to someone who has never heard anything about it,” says Laszlo ‘Les’ Bruzsa, a long-time PBS advocate who is now serving as Chief Engineer at the National Heavy Vehicle Regulator (NHVR) in Brisbane. “There are a lot of forces at work behind the scenes that all follow a slightly different agenda, and the dynamic between them is constantly changing.”

In the book, the short opening line is meant to foreshadow an unknown threat lingering in the descending darkness, urging the protagonist’s hunting party to pause and reassess where they are headed.

In real life Australia, it may represent the course PBS-inspired heavy vehicle design has taken since it was first conceived more than a decade ago, with many a lesson learned by forging boldly ahead and then taking a step back to re-evaluate the course.

“Even today, the level of understanding and support for this initiative fluctuates across the country,” says Les, who has endured many a debate about PBS since 2007. He argues that the pop culture phenomenon and Australia’s PBS scheme are surprisingly alike – both driven by the same hope for a happy ending and both held back by inscrutable complexity. “When we talk PBS, there is still a lot of misinformation out there as to who is responsible for what and who is pulling which string, so creating more transparency is our most important objective as a governing body.”

Complicated Past
The foundation of the PBS scheme as we know it today was laid in 2006 in response to an alarming future outlook by the National Transport Commission (NTC). The report found that Australia’s land transport task would almost double by 2020, prompting the Council of Australian Governments (COAG) and the Productivity Commission to accelerate the development of a high productivity freight vehicle (HPFV) concept under NTC leadership, known as PBS. The Australian Transport Council approved the reform in October 2007.

The idea behind it was simple: Under the technical guidance of an accredited assessor, OEMs and transport businesses were given the opportunity to develop innovative HPFV designs outside the existing envelope and have them approved on a case-by-case basis for use on routes that were found safe and structurally sound. Administered by the NTC, the concept was rolled out on a state level and gave each entity the freedom to set key parameters independently.

Over time, responsibility for the PBS scheme passed from the NTC to the newly constituted NHVR, which was tasked with the creation of a national rulebook for the trucking industry and streamlining the PBS approval process. But despite brimming with good intention, the NHVR got off to a wrong start in early 2014 and had to rely on the help of the state authorities it was meant to replace until a new CEO, Sal Petroccitto, came into office and started bringing the fragile organisation on course again.

A year and a half on, the Brisbane-based organisation is now in charge of all 3,271 PBS-approved heavy vehicle combinations in Australia, which make for a total of about 5,500 individual trailers. On top of that, it is responsible for the entire PBS approval process – from vehicle design through to road access. Public criticism, however, has not subsided just yet, with Sal admitting that, “there is still more work to do to fully realise the safety and productivity benefits available to such a large and geographically diverse industry.”

The reason for the on-going quarrel is two-fold – firstly, technical teething issues have emerged during the scaling up process that go all the way back to the very origin of the scheme. Secondly, the PBS approval process has never been re-examined from the ground up before it was turned into national law, with legacy issues being carried over from the past. Until today, for example, many of the current rules and standards still refer to the NTC as the governing authority and do not necessarily align with the actual Law – an issue that is currently under review by the NHVR.

Disputed present
The first, more technical set of issues is why Les Brusza has been brought in: As Australia’s foremost PBS authority, he is tackling every technical problem one-by-one with stoic composure – from tyre spec’ing (see breakout box) through to police education. Supported by the NHVR executive team, he is confident that there is a solution for almost any issue, but he is also realistic that pleasing each and every stakeholder in the scheme is a highly unlikely outcome – especially not with the small, four-people strong team at his disposal.

“The PBS scheme is all about pushing technical boundaries and testing what’s possible in modern heavy vehicle design, so there will always be a healthy debate on what’s possible and what isn’t,” he says. “Our goal is to make basics such as tyre selection as transparent as possible so we can focus on the innovation part of the equation, and I am hopeful we will get there in time. People just need to understand that every solution has to be made within the law and with all political and commercial stakeholders in mind.”

The second, administrative set of issues is even more delicate in nature. Because PBS started out as an administrative scheme, some legacy issues have been overlooked when it was made part of the Heavy Vehicle National Law in 2014.

A main discussion point in that context is the role of the PBS Review Panel (PRP). Originally established to represent the States and Territories in the PBS process, it had the right to approve or refuse a PBS design when the scheme was still state-driven. Today, that right lies firmly with the NHVR, but the PRP is still in existence and has to be formally consulted for every PBS application – even though Les and his team make the final call.

Critical observers therefore consider the PRP’s on-going involvement a hold-up in the evolution of PBS, arguing it is adding an unnecessary third hoop to jump through without bringing any new technical expertise to the table. Yet, even though it is statistically evident that the Panel’s involvement can take more than a month, with the actual NHVR part taking only a day or two, experts cannot see the PRP give up political influence any time soon.

In promoting PBS to the transport industry, Les has to get that complexity across to those at the coalface – if need be even with a Game of Thrones analogy to showcase just how intertwined the situation really is. “We understand that people are frustrated about the long waiting time for a PBS approval or the fact that technical issues like tyre spec’ing are still not resolved, but they also need to understand that we are not in a position to enable any quick change. It’s politics, at the end of the day.”

Despite the inherent complexity of the PBS scheme, Les and his team have made notable progress since Sal Petroccitto took the helm at the NHVR. The amount of PBS applications that have been processed has grown 20 per cent year-on-year since 2013, and the waiting time has been cut down as well – most often because of Les’ and Sal’s hands-on leadership style and outcome-focused decision making.

“PBS is really making inroads now,” says Sal, who’s 140-strong staff has attended a record 74 industry-related forums throughout 2014-15. “New applications are up by 115 per cent, while PBS vehicle approvals are up by 82 per cent compared to 2013. Even more importantly, PBS vehicles have an excellent safety record and provide a 60 to 70 per cent reduction of crash rates compared with prescriptive vehicles. In that sense, we are extremely happy with where the journey has taken us.”

Sal says the chequered past of the NHVR won’t allow for the young governing body to pause and reflect, though. “There is still a lot of work to be done to get everything right. The PBS scheme is made up of five separate sets of rules and guidelines, all of which were written in 2007 by the NTC and adopted by the NHVR in 2013. These documents need to be reviewed and updated now that we have become aware of some of the key issues they included.”

Restricted access
One issue Sal and Les will have to resolve as part of the review process is road access. Often referred to as the most disputed legacy issue that survived the migration from state to national law, road access is handled by a standalone department that is operating alongside Les’ Productivity and Safety unit and comes into play every time he has green-lit a design. Until September 2015, that happened exactly 3,951 times, Les says, a 142 per cent increase over 2014.

“Most often, those applying for a PBS permit have had a preliminary discussion with the relevant road authority before launching an application, just to make sure they won’t be facing any major roadblock down the track,” Les explains. “The official access approval, though, is being negotiated between the NHVR and the road owner directly, as road funding and maintenance responsibilities in Australia belong with the relevant state, territory or local government.”

What has changed compared to the NTC model, he says, is that the applicant doesn’t have to collect multiple approvals for different states anymore and risk having to comply with varying GCMs on the one trip. Instead, they are now issued one access approval at one constant GCM via one central authority, with an average processing time of 23.48 days in 2014-15.

“Even though we encourage people to consult all relevant road authorities before going ahead with an application, access is still a minefield,” he explains, adding that the engineering team is trying to work closely with the access group to ensure approvals are issued as hassle-free as possible. “The problem is that we are dealing with third parties here that sometimes don’t have sufficient experience with HPFVs to assess what’s coming at them, so we have to continually educate them one council at a time.”

What Les doesn’t mention is that the often-unavoidable staff and organisational changes in state jurisdictions can directly affect the access approval process. As a consequence – and partly also because of highly constrained road and bridge maintenance budgets – some jurisdictions are rumoured to have placed restrictions on PBS-approved vehicles that effectively negate the Heavy Vehicle National Law.

To avoid a rude awakening and bring more dependability to the process, the Regulator is therefore working on a national database of pre-approved roads for the most common HPFV designs, currently focusing on three, four and five-axle truck and dog combinations, which make for 70 per cent of all PBS vehicles in the country. The so-called ‘truck and dog notice’ is said to be step one to the development of a national, generic notice and include some 100 gazette approvals and pre-approvals from road managers across the nation – removing approximately 1000 existing PBS permits on the spot and a further 1000 permits per year in the time to come.

The idea has already proven successful in Queensland and Victoria. In fact, Queensland’s Department of Transport and Main Roads (TMR) was the first jurisdiction in Australia to assess and classify its PBS network in 2008 by translating the existing general access, “as of right” B-double and road train networks into the four-pronged PBS level access model. VicRoads, too, allows certain HPFVs as-of-right access to the network once they had passed a certain standard.

Bringing such an “access guarantee” into play quickly elevated the two states to the top of the national PBS ranking, but Melbourne-based PBS expert, Rob Di Cristoforo, says more could be done. “While the more restrictive Class A networks have been mostly determined, the Class B networks, which can provide the real productivity benefits, are still largely unmapped,” he says. “Because there’s so much uncertainty around road access, the industry would appreciate more ‘in-principle access support’ before obtaining a design approval so applicants can proceed with confidence.”

While Rob’s plea has gained substantial support in the transport community, it is not without challenge to implement, according to a 2014 report by then-TMR PBS specialist, Kyriakos Tyrologos, who is now serving as Leader of Transport and Principal Transport Planner Veitch Lister Consulting.

The reason is that existing axle group mass limits continue to apply under the PBS Scheme, but that GCM is not explicitly limited above the first of four PBS levels, which is equivalent to a general access pass – effectively causing some sort of access vacuum on a council level. While the PBS scheme allows industry to be creative to achieve the required axle group mass limits, for example by adding more points of articulation or a novel distribution of axles, local road managers want to make sure all bridges on the chosen route are compliant and no level crossing issues will arise down the track. Unrestricted GCMs maybe be somewhat unnerving in that context, regardless of the actual axle load.

Length itself  is also an issue, according to Kyriakos’ report, which pointed out that maximum vehicle lengths for Class B categories are longer than Class A, so the increased vehicle length could potentially affect road classification aspects such as stacking distances at intersections and railway level crossings, signal timing and storage length at intersections as well as overtaking provision. Even enforcement bays and rest areas could be affected.

While Kyriakos added that a number of “high profile” route assessments have already been carried out in Queensland to gain more clarity on Class B access, “funding Class B Route assessment applications and associated works does not meet industry demands and will not be financially sustainable in the long term.”

With Rob Di Cristoforo arguing that only a “fair dinkum” Level 2B network will allow for game-changing PBS vehicles to come through, Kyriakos’ assessment indicates that industry may be stuck in neutral until the funding problem is cleared. Until then, TMR has gone ahead with a hands-on solution that allows PBS applicants to fund the Class B geometric route assessment directly.

While that approach may add to the cost of the individual approval, TMR does have the right to use the information from the route assessment to grant access to similar PBS vehicles down the track – meaning industry is theoretically able to explore local Class B accessibility itself.

Promising future
With the governance, access and technology aspects of the PBS scheme still maturing, Sal Petroccitto is optimistic the concept has much more growth potential than currently evident. “The NHVR has made some great gains in establishing itself as a truly national entity, even though there is still more work to do,” he says. “The industry is on a journey of continuous improvement, and so are we, with the goal being further red-tape reduction, consistency across borders and stronger partnerships with industry and government. That’s an exciting outlook and positive for our industry and Australia.”

Agrees Rob Di Cristoforo, emphasising that PBS is the “most progressive” heavy vehicle design scheme in the world. “The debate around PBS can be misleading if you don’t appreciate how far we have come already,” he says. “PBS was founded on the principle of setting out acceptable on-road performance limits and letting the industry design vehicle configurations to those limits. This is progressive policy. Talk to any international truck size and weight expert – it’s the envy of the developed world. Even though the issues we deal with today are real, they are not system-critical.”

Supporting Rob’s claim, a 2014 Austroads study managed to quantify the scheme’s remarkable success story by measuring the direct and indirect benefits that HPFVs bring to Australia – especially in the safety arena. It found that they are involved in 76 per cent fewer accidents than conventional transport equipment, equating to a 63 per cent reduction in major accident incidents on a weighted fleet basis. This is expected to lead to an estimated saving of 96 lives by 2030.

On top of that, Austroads uncovered that the productivity benefits of HPFVs are “significantly higher” than was first expected. “The current estimates for productivity savings will see HPFVs performing the articulated freight task with 37 per cent fewer trucks, with 37 per cent less kilometres, and the rigid truck task being undertaken with 26 per cent less vehicles, performing 23 per cent less kilometres,” it found.

The resulting value of adopting PBS-approved equipment is significant, according to Austroads. “Assuming that staged access to the major highways connecting Brisbane, Sydney, Melbourne and Adelaide is realised by 2030 … Australia will gain $6.9 billion in direct real term benefits. If immediate access was granted to these major city corridors, that figure would generate direct benefits of $8.7 billion.”

With such powerful data backing the PBS scheme, it is understandable that Sal and Les won’t give up on the concept – even though the nationwide scuffle for influence isn’t likely to end any time soon. Despite being held back by a host of legacy issues and the odd structural shortcoming, they argue that the benefits of PBS far outweigh the hassle, especially in regard to road safety.

And as opposed to George R.R. Martin’s protagonist, they do have the option to “start back” and make improvements where needed. “If I could go back in time and start over again, of course I would do some stuff differently,” says Les, adding that as opposed to the Game of Thrones series, PBS is actually saving lives, not taking them. “But I also know that we’re onto something special here, and that’s why we have an obligation to make it work.”

The full story has appeared in the December edition of Trailer. To get your copy, click here.

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