Submission cover sheet
- Name of organisation or individual making this submission
Questions on possible options
- Do you think it is appropriate to exclude multi car carriers from the definition of a tow truck?
- Do you agree that an applicant must provide proof they have the relevant consent approval for the use of a holding yard?
- Do you agree that a tow truck drivers certificate should only be suspended and not revoked for medical reasons or for failure to renew a drivers licence?
- Are all of the offences listed in clauses 7 and 16 proportionate to the penalty of automatic revocation if convicted? If so, why?
No, because there is no enforcement of these rules and regulations West of the Blue Mountain. Highway Patrol also do not enforce these rules. When we took our concerns to the Local Chief Inspector, they were not even aware of these laws and how they applied. We believe that the pentalties are suffient providing that there is follow up and checking to ensure that these people are not continually re offending ie on Social Media.
- Do you think any other information should be included in the towing authorisation form?
No, we believe that these forms provide the relevent information.
- Is there anything else that should be included in the holding yard provisions to ensure the safety of vehicles?
No, current rules for holding yards are sufficient, again when enforced; as we know of at least two in our area that do not meet the requirements but are still operating.
- Do you think the fee unit (0.6 per hour) appropriate for the clean-up of debris from a heavy vehicle accident or accident in non-metropolitan areas, if not why not?
No, as for the hour that your on the side of the road cleaning it up for $60.00 we could have earned 4 to 5 times that in the same time period driving the trucks. not to mention you need to take into consideration the wages per hour for drivers, which with penalty rates exceeds this amount easily. So if you look at wages of $30.00 per hour, and consider double time and a half for Sundays.
- Do you think the tow truck equipment outlined in clause 83 is appropriate for the clean-up of debris?
- Do you think that scrap metal operators should be required to keep clean-up equipment in their tow truck?
- What is the appropriate amount required for a tow truck operator to begin the process of disposing an unclaimed vehicle?
- Do you agree that those who tow recreational vehicles (including caravans) should be exempt from the requirement to be licensed under the Regulation?
- Do you agree that mechanics should be allowed to drive a tow truck under the circumstances outlined above?
- Do you agree with the proposal to add types of motor vehicles that are allowed to be towed without a licence or driver certificate? What type of equipment should be exempt and why?
None, having Drivers Certificates show that back ground checks have been done, no equipment should be exempt. This protects our industry and the reputation of those within it. It also protects the consumers but being able to easily identify drivers, and that they are accountable.
- Do you think any of the penalties in the Regulation need to be changed? If so why?
Not relevant to this question, however, we feel that we should be able to attend Tribunals through Fair Trading like other business covered by the Fair Trading Banner ie For Non Payment of Tows. Selling of unpaid wrecks to recoup costs is unfeasible in our town as there are no wreckers and scrap value is virtually zero, therefore we do not recoup and costs, especially after having to pay the Police Force for the privilege of disposing of the vehicle
- Do you think it is appropriate to change the CPI fee to be consistent with other Regulation fee calculations in the Customer Service portfolio?