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AUSTRALASIAN FLEET MANAGEMENT ASSOCIATION Submission to the Department of Infrastructure & Regional Development 2014 Review of the Motor Vehicle Standards Act 1989 October 2014 Suite 30- Commercial Centre 431 St Kilda Road Melbourne Victoria 3 004 Australia P I 61 9866 6056 f I +61 98661304 e I info@afma.net.au w I afma.net.au ABN 171 365 485 449 CONTENTS Page No. A. INTRODUCTION 4-5 B. EXECUTIVE SUMMARY 6-7 C. DETAILED SUBMISSION 1. ADR'S 11. SAFER VEHICLES 111. (A)NCAP IV. EMISSION CONTROL AND AIR QUALITY v. IMPORTATION OF USED VEHICLES v1. IMPORTATION OF NEW VEHICLES v11. IMPORT TARIFFS vm. LUXURY CAR TAX
8 9 9 10 11 11 11 11 11 D. RESPONSE TO SPECIFIC QUESTIONS 13-21
ATTACHMENTS • ADR Examples • ANCAP examples • Emissions • Inquiry into ADR's: Chair's Summary • Inquiry into ADR's: Executive Summary • Inquiry into ADR's: Recommendations • Inquiry into Vehicle Safety: Executive Summary • Inquiry into Vehicle Safety: Recommendations • OECD Cost of Air Pollution Highlights • Safety Equipment Inclusions • Vehicle Pricing A. INTRODUCTION The Australasian Fleet Management Association (AFMA) thanks the Commonwealth Department of Infrastructure and Regional Development for the opportunity to supplement our previous submission, dated 21st June 2013, on the currency and operation of the 'Motor Vehicle Standards Act 1989 (the Act) and its Associated Regulations'. AFMA is a not for profit organisation which has in excess of 600 members across Australia and New Zealand. Collectively these members are responsible for the management of approximately 800,000 vehicles. Purchasing actions of Fleet Managers have a major impact on our economic and social structure as fleet sales account for over 50% of all new vehicle registrations annually. In addition the Fleet sector is the major source of vehicles into the used (retail) vehicle market. Purchasing decisions as to the level of vehicle safety, safety features and emission standards made via fleet acquisitions continues to influence the market for up to a decade after being initially acquired. AFMA has previously responded to requests from Government to share the Association's views on many of the issues related to the effective and efficient operation of Australia's automotive and fleet industry. For over a decade now the Australian automotive industry has been in a state of constant flux. Local manufacturers, traditionally the main supplier of the large passenger vehicle, have seen their market share in both real numbers and percentage fall dramatically. AFMA sees this outcome as being predictable as Australian vehicle manufacturers have consistently failed to compete with importing competitors. In the main the balance of vehicle pricing, fitrnent of safety features as standard equipment and emission performance placed importers at an advantage over locally made vehicles. For many years attempts were made to redress this disadvantage through industry subsidies, targeted taxes and regulations (luxury car tax, import tax, used vehicle import tax, Australian Design Rules (ADR's) which included different/additional requirements to vehicles that are wholly certified in their horne, and internationally, developed markets). All of these measures have by their nature created a market structure in Australia that is by any measure out of step with comparable overseas markets and has led to the detriment of the Australian consumer. In this review the Department has the opportunity to remove these many impediments although the Association concedes that it is not an easy task due to the complexity, interconnectedness and many interest groups that wish to retain the status quo. Besides the Productivity Commission Inquiry Report, No 70 31st March 2014, into the automotive market and the recent OECD study (The Cost of Air Pollution Health Impacts of Road Transport OECD Publication Date: 21 May 2014 80 Pages: ISBN: 9789264210448) AFMA is only aware of two recent detailed studies into the structure and function of the industry. These are the: . / Parliament of Victoria, Road Safety Committee, ‘Inquiry into Vehicle Safety’, August 2008, (IBSN 978-0-9751534-4-4) . / Parliament of Victoria Road Safety Committee Inquiry into the process of development, adoption and implementation of Australian Design Rules (IBSN 978-0-9751534-8-2) November 2009 Both studies provided a bleak assessment of the health of the Australian vehicle market. For the Department’s information we have included the Chairman’s report, the Executive Summaries, and the recommendations from both inquiries (see Attachment). We have also included the highlights of the OECD Publication "Cost of Air Pollution Health Impacts of Road Transport (May 2014)" which shows in Australia that the cost of air pollution has risen significantly as opposed to most developed economies which had small rises or significant reductions (see Attachment). As you are aware AFMA attended the Melbourne workshop on October 3rd where we raised several issues based on our own observations, analysis, interpretation and opinion formed of events. We were challenged on almost all the points we raised by other workshop participants; namely that our views were opinion based. To support our analysis of the market we have included interviews and comment from industry sources on the issues we raised; vehicle pricing, ANCAP, emissions, vehicle safety, ADR's etc. (see Attachment) As AFMA also has members in New Zealand we were able to seek a view on how the lifting of restrictions on the importation of used vehicles affected the New Zealand market. We have included that report in the Attachments. While we will address the specific questions in the discussion paper the Association would like to share its views on how we perceive the status of the Australian automotive market and the issues we feel require urgent attention. B. EXECUTIVE SUMMARY For several years now AFMA has been responding to various Federal and State Governments on the topics of vehicle safety, emissions/air quality issues and ADR's. Although few meaningful changes have been made we are willing to again share our views on these important issues. Unfortunately the reality is that in general the Australian market experiences a lower level of vehicle safety equipment as standard fitment and a higher, and growing, environmental impact. While successive Federal Governments have had opportunities to lead through an active role in vehicle safety and emission reduction such opportunities were, in AFMA’s view, not taken. To date intervention by Government would appear to have been one of maintaining the status quo rather than advancing a more positive outcome. The result has in the Association's view left the Australian market with inferior products and always trailing one step behind what is standard practice in comparable overseas markets. As the industry is a complex interrelated set of issues, rules and regulations there is a need to take a holistic approach that includes everything that impact on the function of the industry. Leaving anything out will most often lead to an incomplete solution to the identified issues. With this review the Association sees a once in a decade opportunity to fix the many distortions in the current market structure. AFMA concedes that it not an easy task due to the complexity, interconnectedness and many interest groups that wish to retain the status quo. Firstly we would like to clearly state that the Association is not advocating a "no rules" approach; we suggest the opposite. The desired outcome is a regulated industry that as a minimum keeps pace with recognised best practice in comparable economies and markets. Product consumers should not bear the consequence of a supplier’s inability to meet what is elsewhere simply standard practice. AFMA would like to see the following issues addressed with the subsequent outcomes: i. Australian Design Rules (ADR's) On ADR harmonisation we would contend that it is those unique additions (not required by any other advanced automotive market) imposed by ADR's that is problematic. AFMA would suggest that replacement of ADR’s with the UNECE regulations would create a better outcome for the industry and consumers as a whole. Design rules whether ADR’s or UNECE are intended to provide a minimum requirement not a state of art outcome. On occasion there is a need for Government to act when research clearly demonstrates that a particular equipment inclusion provides a greater positive outcome than its exclusion. ii. Import Tariffs Although Import tariffs are not in the terms of reference they do play a role in pricing. With free trade agreements in place, or in discussion, with the majority of advanced manufacturing it would seem prudent to dispense with all tariffs. 111. Luxury Car Tax (LCT) The withdrawal of local manufacturing should render the Luxury Car Tax (LCT) obsolete. We understand that its inception was one of protecting the top models from local manufacturers and so it serves no real purpose in a marketplace. Moreover its presence enables pricing distortions to take place where mid-range vehicle models are elevated to luxury vehicle status in Australia purely on a cost base. iv. Australian Emission Standards Australian emissions standards lag behind comparable markets such as Europe who are currently at Euro 5 emission standard. Currently Australia is only planned to switch to Euro 5 in 2016; by which time Europe would have moved on to Euro 6. v. Clean Fuel Initiative AFMA would also like to see a clean fuel initiative as currently fuel supplied to the Australian marketplace is less refined than that in comparable markets and contains higher levels of contaminates. vi. ANCAP and Minimum Import Requirements Establish a relationship between NCAP and an acceptable minimum crash protection rating before registration in Australia. vii. Lemon Laws AFMA believes it is time to strengthen consumer laws in respect to faulty vehicles and replacement laws. Directory: vehicles -> mv standards act -> files vehicles -> Epa vehicle class vehicles -> 2016 chevrolet tahoe vehicle highlights vehicles -> Insurance companies authorized to do business in the state of new jersey and their code numbers vehicles -> 2015 chevrolet corvette stingray new for 2015 vehicles -> Recall of vehicles in Australia fitted with Takata airbags Report on progress and status of the recalls files -> Review of the vehicles -> Part I the solicitation Download 1.88 Mb. Share with your friends:
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