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While one of the NHVR's goals is to support and promote productivity in the heavy vehicle industry, the NHVR must adhere to the legislative consent process. In turn, this This consent process indicates that it is at the road manager's discretion to include their road network in a gazette. There are no means within the HVNL to coerce or force a road manager to participate in a gazette.
While aversion to gazettes may be the case for most road managers may be averse to gazettes, it this does not absolve or remove the access request requirement for heavy vehicles, and this is where the process for Prepre-approval process arises.
A road manager may be happy to provide access to their roads, believing that a permit is the overarching risk mitigation implement. For the NHVR, access permits should be a "one-time" requirement for short to medium-spanned freight or transportation requirements (<3 years). In most instances, most access requests are for a lifetime of movements whereby multiple operators will seek to access the same patch of road managers' road network, which can cause a consent bombardment. A consent-bombarded road manager will instead utilise a prior evaluation and consent process, pre-approval. This pre-approval process removes the road manager's requirement to review each access request, with the NHVR utilising the pre-approval in place of the road manager's role.
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While timeframe impacts may appear within the realms of reasonability for permit holders, it does not capture every impactful scenario, particularly when the NHVR wishes to transition to a PAN and, therefore, a pre-approved network for permit application. Multiple road managers updating and amending the same pre-approved network at different instances in time will have an effect on times will affect existing permit processes where the permit is being renewed or amended.
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TfNSW Heavy Vehicle Network Transition:
Pre-approvals such as PANs and PARs relating to for heavy vehicle access in NSW will be available once the network transition is complete. Pushing this process forward before the transition significantly impacts the industry , relating to in terms of costs and potential delays in processing times.Road Management & Dual Ownership:
An uplift to the Road Management feature and refactoring for multiple infrastructure owners is required. The system needs to define an exact legislative process that meets all party's responsibilities and requirements under the HVNL.Access Policy:
There is no defined policy relating to legacy pre-approvals, let alone the adaptation for PANs and PARs. Further policy investigation is required to limit the available conditions and restrictions and harmonise consent timeframes for heavy vehicle access.Access Operations:
Processing impacts will occur due to pre-approval changes such as inclusions, amendments or removals. For example, an Access Permit Renewal occurs simultaneously with a road manager update to a PAN or PAR. Who goes first? An ideal process with a defined ruling is required to ensure that impactful processes, particularly for permit amendments or renewals, are deployed in a manner that is not impactful to any party while still meeting legislative requirements.
Additionally, as a follow-up, there will be an automation requirement to issue notices of the amendment, suspension, cancellation, and access permit version to the permit holder as defined under the HVNL.Intersection Assessment
Similar to road management and dual ownership, there are underlying factors whereby inconsistent jurisdictional policies advise for specific consultation with an impacted party. An example is a State road intersecting with an LGA road, whereby legacy policy and process requires the state to determine whether the intersection is suitable for use instead of the LGA adding their road to the heavy vehicle network.Third Parties:
Again, like the intersection assessments, the jurisdictional consent process for impacted third parties for entities such as Rail, Water, Communication, and Electrical suppliers. In NSW, TfNSW can only officially decide on an access request once the rail authority has provided its advice. In this instance, the affected road manager may not meet the 28-day consent requirement under the law, with the operator access impacted. The legislative consent and permit process is on hold until the affected road manager provides the third party's response.
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