Submissions 2021

Infrastructure Victoria 30 Year Infrastructure Strategy

February 2021


The Australian Logistics Council (ALC) welcomes the opportunity to make a submission on Infrastructure Victoria’s (IV) draft 30 year infrastructure strategy. (the Strategy)

ALC is the peak national body representing major companies participating in the freight logistics industry. ALC’s policy focus is on delivering enhanced supply chain efficiency and safety.


Why is freight important?

Freight affects every Australian, every day, everywhere. Common goods purchased by Australians such as food, clothing, household appliances and medicine all need to be transported by freight operators. Similarly, the freight supply chain provides the materials to build and operate critical community infrastructure – roads, hospitals and schools – which are fundamental to our society.

An inefficient and unproductive national supply chain can ultimately result in lost export income, reduced employment, higher consumer prices and Australia becoming less competitive in the global market.

That is why ALC agrees with observations made in the Strategy that:

  • ports are crucial international gateways for exporting goods to international markets and to allow Victoria to access goods from around the world; and
  • freight terminals maintain a central position in supply chains.

ALC makes the following observations on the Strategy:


The Port of Melbourne

There appears some tension between draft recommendation 24 (optimise capacity at the Port of Melbourne) and draft recommendation 35 (identify new priority locations in established suburbs for residential intensification).

As the strategy indicates, a Land Use Framework Plan is being developed (as relevant) for Fishermans Bend and Docklands. There is a clear government intent to increase population density in areas close to the CBD.

Yet as indicated on page 81 of the Strategy, community pressure could be a significant barrier to the port’s future growth.

The Commonwealth has recently published Draft National Urban Freight Planning Principles[1] that are intended to be included in the planning documentation generated by States and Territories.

They are one of the important outputs from the National Freight and Supply Chain Strategy – a process championed by ALC.


As the document says:

Australia’s urban areas are growing, and so is our urban freight task. In 2018-19, people living in our capital cities increased by 1.8%, and capital city growth accounted for 79% of total population growth. Australia’s urban freight task is expected to grow by nearly 60% over 20 years to 2040. Freight movements underpin our access to essential goods, such as food and fuel, ensure stores are stocked with products to sell, remove our waste, and deliver the construction materials that keep our cities growing.[2]


Land use planning and development approvals that inadequately consider noise, vibrations and other amenity impacts of freight facilities can see inappropriate zoning of these facilities, with industrial areas and transport corridors near or in residential and commercial use of land. Restrictions to address amenity impacts including limitations of operating hours, areas of operation and vehicle type dampen productivity of the sector, decreasing economic competitiveness and increasing costs. These restrictions and initial amenity impacts can be avoided through adequate protection of industrial zones and appropriate planning in the construction of residential and commercial precincts near industrial activity.[3]


This is because ALC believes they are a step in the right direction, as they recognise the importance that the ability of freight to efficiently move must be facilitated by the rules set out in planning documents. The gist of the Principles should be incorporated in Victorian planning instrumentation.

However, ALC believes they can be improved through requiring the development of planning instruments that permit the continuous movement of freight to and from freight infrastructure.

It will be making this case as the Draft Principles are brought to Australian governments for decision.

Given the importance of the Port of Melbourne to the Victorian economy identified in the Strategy, it is important that its capacity to operate to its maximum capacity, free from the frustrations of urban encroachment is protected.

The final Strategy should recommend that planning instruments relating to urban development in the vicinity should be designed in a manner that permits the continuous movement of freight to and from the Port of Melbourne.


Future Bay West Port option

Given the above discussion, it is clear the Final Strategy must support immediate action to protect the possible West Port option, as discussed in Draft recommendation 26.


Integrated land planning

ALC agrees with the observations made on page 100 of the Draft Strategy in which IV suggests integrated land use and infrastructure planning can better manage change in communities and unlock greater benefits, and reflects on the fact that in the past, governments have been reluctant to publish plans which commit them to infrastructure projects.

In submissions made on the development of Plan Melbourne in both 2013 and 2015, ALC proposed that a positive statutory duty be imposed on those making planning decisions to consider the Victorian Freight Plan (as it is currently named) when making decisions.

ALC again makes this recommendation.


Purchase land for Melbourne’s future freight terminals

As indicated on page 83 of the Draft Strategy:

Intermodal terminals maintain a central position in supply chains, acting as a connecting interface between the network and customer-facing operations. Additional freight terminals are required both to meet the growing freight task, and to avoid operating time restrictions from incompatible land uses. Two terminals in Melbourne’s north and west are critical to the future of the network. The Western Intermodal Freight Terminal at Truganina, in Melbourne’s west, and the Beveridge Intermodal Freight Terminal in Melbourne’s outer north and west to reach existing freight terminals. Furthermore, Melbourne’s current major freight hub at Dynon might not have the capacity to cope with extra trains brought in on Inland Rail. The two new freight terminals could be designed to accommodate each of these considerations.


Inland Rail is a $9.3 billion freight rail project, taking 24 hours to travel the 1,700 kilometres from Acacia Ridge in Queensland to Tottenham in Victoria.47 Construction of Inland Rail began in 2018, with a scheduled completion date of 2025.48 Victoria has no freight terminals which can currently handle the double stacked, 1.8 kilometre trains the project will enable. Accommodating these larger freight trains requires extensive and costly modification of the bridges, overpasses and other infrastructure in Melbourne’s outer north and west to reach existing freight terminals. Furthermore, Melbourne’s current major freight hub at Dynon might not have the capacity to cope with extra trains brought in on Inland Rail. The two new freight terminals could be designed to accommodate each of these considerations.


ALC acknowledges the development of a business case for the proposed Western Interstate Freight Terminal and trusts a successful business case will be determined so that Victorian industry can gain the full benefits of the Inland Rail project.

ALC otherwise agrees with the thrust of draft recommendation 26.

Land must be reserved for the intermodals of the future that will support the growing freight task.


Technology and data analytics

IV has correctly identified the importance of the use of data when making planning and infrastructure development decisions.

ALC has developed a Single Freight Data Standard for National Digital Framework, which is designed to:

  1. assist in the collection of statistics for purposes such as the ABS Transport Satellite Account, through the presentation of information in a uniform format;
  2. provide a uniform data format that can be used for those wishing to enhance the visibility of freight in which they have an interest;
  3. present information to road managers in a way that would facilitate decisions relating to access to routes by heavy vehicles;
  4. assist compliance with legislation; and

5          facilitate planning by both industry and governments.

The document may be found here:

In due course, the Victorian Government may wish to encourage the collection of data using this standard so that investment decisions can be made on the best information available.


Transport network pricing and electric vehicles

As IV says on page 40 of the Draft submission:

Many freight truck movements occur through residential areas, creating noise and pollution. Consequently, hundreds of roads have restrictions, bans and curfews to limit truck movements. Zero emissions freight vehicles are quieter and less polluting. Creating exemptions from some of these restrictions for zero emissions freight vehicles would incentivise faster adoption. In the next five years, the Victorian Government should incentivise zero emissions freight vehicles by reviewing restrictions on zero emissions freight movements on these roads. This particularly applies to roads leading to the Port of Melbourne, where Infrastructure Victoria has found the community impact of freight traffic could be a barrier to increasing the port’s capacity.


ALC is committed to facilitating the introduction of electric powered commercial vehicles into Australia.

It therefore agrees with the content of Draft Recommendation 1, which encourages the Victorian Government to advocate for the Commonwealth to adopt international rules in relation to the importation of vehicles and vehicle emission standards.


Australia is such a small market it cannot expect to develop specific standards or requirements without finding that either manufacturers will not enter into the market or that the additional compliance costs will mean that vehicles will be too costly to purchase.

As noted in draft recommendation 48, the Victorian Government has announced in the budget a new distance-based charge for electric and plug-in hybrid vehicles from July 2021 – although it should be noted the Government has yet to consult on the precise design of the taxing mechanism.

Australia is a national economy.

Whilst acknowledging the announcement, ALC is firmly of the view that taxation mechanisms for road use should be uniform throughout the country.

Victoria and South Australia appear to be moving towards distance-based charging, but not the other jurisdictions.

The next Infrastructure and Transport Ministers’ Meeting (ITMM) to be held in June 2021.


ALC recommends Victoria use that meeting to advocate for a nationally consistent access pricing mechanism for electric vehicles, which could then be possibly used as the basis for road user charging for light and heavy vehicles generally.


ALC thank the Department for the opportunity to respond to ‘the strategy’. ALC is available for continued engagement to enable industry and Government to work collaboratively in ‘the strategy’s’ implementation. 



[2] Page 3

[3] ibid

Read more about our policy below:

Infrastructure Victoria - 30 Year Infrastructure Strategy

Infrastructure Victoria - 30 Year Infrastructure Strategy

ALC Submission - Infrastructure Victoria 30 Year Infrastructure Strategy COVER