On 13 June 2018 the Queensland Parliament requested the Transport and Public Works Committee to inquire into and report by 13 September 2018 on the operations of toll roads in Queensland. Considering:
a) the operation of existing toll roads in South-East Queensland;
b) toll pricing and incentive options to deliver better outcomes for Queenslanders;
c) the operation of the existing complaint process and current statistics;
d) possible measures to continue to improve customer service standards; and
e) existing relationship between the Tolling Customer Ombudsman and the Queensland Ombudsman.
QCOSS undertakes advocacy and develops policy on how to support people out of poverty and disadvantage. Our aim is that everyone can function in society without financial stress and that access to essential services is achieved regardless of income. QCOSS is making a submission to this tolling inquiry to ensure that the voice of low-income and vulnerable road-users is heard and taken into consideration.
This submission is based on the following principles:
- QCOSS believes that transport is an essential service and should be accessible for all to use.
- Roads are community assets underpinning many aspects of community and personal wellbeing.
- There are not always viable alternatives to toll roads.
- Reform is needed to make this essential service fair, reasonable and simple, including consideration of concessions and exemptions for people on low incomes, (as with other essential services).
- Escalating debt from tolling charges and fees trap vulnerable people, with devastating consequences for wellbeing.
- Effective hardship programs are mutually beneficial. Wellbeing should come before super-normal profits.
QCOSS believes that the road tolling system in Queensland is unfair and needs to be reformed. Our recommendations aim to improve outcomes for all road users, but particularly those on low incomes and those experiencing financial hardship.
- Integrate transport planning and limit toll roads
1.1 Transport planning must take a long-term, integrated network view (not driven by market-led proposals). This should incorporate the benefits to community and the environment of public and active transport.
1.2. Queensland government prioritisation of transport infrastructure projects should be separated from their mode of financing.
1.3. Any Queensland public-private partnerships must be transparent and subject to review by the Australian Competition and Consumer Commission (ACCC).
1.4. The Queensland government should place a moratorium on all new private toll roads until, and only if, all issues raised in this inquiry have been adequately addressed.
1.5. Review concession agreements with a view to improving KPIs to address concerns raised in this inquiry.
1.6. The Department of Transport and Main Roads should publish the annual toll road performance report.
2. Make the system fair, reasonable, simple and clear
2.1. Prevent small toll debts escalating into large fines. Make all fees and fines proportionate to the non-compliance. Automatically waive all administrative fees and fines associated with inaccurate contact information.
2.2. Provide incentives for people to update contact information.
2.3. Extend the time to pay, introduce monthly billing, and limit debts to unpaid tolls only for at least 30 days after an amount becomes due (like other service billing).
2.4. The government could fund road usage concessions through vehicle registration discounts or exemptions to those on low incomes who already qualify for other concessions.
2.5. Transurban could fund concessions by modelling the impact on toll road traffic flows of off-peak discounts and renegotiating concession agreements to include these discounts if modelling indicates it is revenue neutral.
2.6. Reduce the complexity of the system particularly for infrequent users. Number plate recognition allows the system to recognise who is a regional or interstate driver and could provide alternative, longer terms of payment.
2.7. Clearly communicate the tolling process, including the timing of fees and charges, and escalation to SPER. Clearly communicate and resource both hardship programs and the role of the community sector in supporting people in financial hardship.
3. Support those in financial hardship
3.1. Transurban should build on their Hardship Pilot, designing products for people on low incomes to help them manage the cost of using toll roads. This could include a combination of a toll only account, longer time to pay without incurring fees, a cap on total fees or a cap on the toll amount.
3.2. Change the language of Transurban and Queensland government material to remove the language of “if you do not pay” to “if the toll is not paid” prior to confirmation of the address and driver identity.
3.3. The tolling ombudsmen should be entirely separate from Transurban. The Queensland ombudsman should deal with all tolling and SPER complaints. Otherwise the Queensland government should appoint an independent Queensland tolling ombudsman that operates under the Attorney-General’s Department guidelines for industry compliant schemes.