Shipping Australia was pleased to be invited to make several submissions lately to government bodies on the thorny topic of Australian productivity, which is Canberra’s current policy push.
There were common positions across our submissions, so we’ve summarised them here.
- Ocean shipping is vitally important to the Australian economy – to our imports, our exports, the jobs that are available to Australians and to our standard of living. It therefore follows that minimal disruption to, or cost impositions on, ocean shipping is in the Australian national interest.
- As global shipping is inherently cross-border in nature, it is essential that the industry is governed at the highest levels of global governance, specifically all rules should be aligned with the rules of the International Maritime Organization.
- Australian Federal / State / Territory rules, policies, guidance, laws, interpretations, etc must be harmonised with each other and with the IMO rules.
Creation of all rules and guidance of whatever form ought to follow best practice as laid out below under “Principles for rulemaking” (i.e. rulemaking should include industry consultation, cost-benefit analysis, be evidence-based, have clear policy goals that are capable of being achieved, and should include a range of alternatives including doing nothing). - There are massive productivity gains to be realised from hastening the implementation of the Maritime Single Window which would benefit everyone in the Agricultural Supply Chain and, ultimately, everyone in Australia through lower trade costs.
- Agriculture is completely reliant on Australian ports for the import of their input materials and for the exports of their output i.e. their agri-products. But Australia’s container ports are literally among the world’s worst performing ports as ranked by the World Bank because they are regional monopolies and therefore lack competitive pressure to be more productive.
- Unfortunately, there is enormous bureaucracy in the agricultural-seaport supply chain; landside processes, duplication and bureaucracy, induce productivity inefficiencies at the seaport. While there are many factors contributing to this inefficiency, one simple measure of tracking seaport productivity is total ship turnaround time.
- Australia’s Federal / State jurisdictional split is causing issues. Over-governance is causing over-regulation and practical problems such as ships being unnecessarily turned away. Putting the marine-side (the berths, the approaches etc) of Australia’s seaports under Commonwealth jurisdiction would solve these problems.
- Australian Public Service officials (excluding sector-specific officials such as AMSA officials) appear to have a lack of understanding both of the physical commercial ships and also the commercial environment in which they operate. Officials who come into literal or metaphorical contact with the shipping industry ought to have appropriate training, so they respond appropriately. Any such training needs to emphasise a cultural shift so that ships are not unduly held up i.e. that the agricultural public service system and officials prioritise a solutions-based approach.
- Australian container seaports’ port pricing is completely unconstrained by the market and is largely (barring one notable example) unconstrained by a regulatory regime. Accordingly, port prices are being hiked by a very large percentage every year, which is driving a lack of productivity. Both a transparency and a regulatory regime are needed to tackle this pricing problem.
