Submission cover sheet
- Name of organisation or individual making this submission
Jotar Pty Ltd
- Authorised delegate/contact person
Jotar Pty Ltd
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?
Yes. These offences seem to be proportionate with the penalty of automatic revocation if convicted, however I believe sex offenders and or pedophiles need to be added to this list, also assault is a very broad term and offenders with minor assault convictions should be assessed on a case by case basis given we have had applicants apply for drivers certificates with very minor convictions from years ago refused due to not being able to provide the information or defend themselves for what may have been a minor situation. In trying to improve our industry, we require a better review process in place.
- Do you think any other information should be included in the towing authorisation form?
No. However, I think the pricing of the authorisation form should be reviewed and decreased. Given the fact that almost identical stationary can be purchased through a printer at approximately a 10th of the price.
- Is there anything else that should be included in the holding yard provisions to ensure the safety of vehicles?
No. However towing operators should be able to retain a vehicle and its contents until the towing invoice has been paid in full.
- 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. Why should we only get 60% of industry rate? I think there needs to be more consultation with heavy towing operators in regards to the cost involved in doing this kind of work.
- 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?
No, I think all facets of towing should require a drivers certificate to promote an even opportunity for towing operators in the market
- Do you think any of the penalties in the Regulation need to be changed? If so why?
Yes, I think the entire penalty structure needs to be reviewed and discussed with a panel from the industry for a more realistic penalty structure. Some of the penalties seem disproportionate to the offences and I feel that the monetary sum of some of the offences are pushing drivers and operators out of the industry. We have lost many drivers, ourselves, out of the industry due to the current fine structure. We struggle as it is to retain and obtain staff in the current climate without being over regulated and over penalised.
- Do you think it is appropriate to change the CPI fee to be consistent with other Regulation fee calculations in the Customer Service portfolio?