Submissions

The MTA is committed to taking a proactive approach with the Australian and South Australian government to ensure the automotive industry and our members are best represented and protected.

The MTA is committed to taking a proactive approach with the Australian and South Australian government to ensure the automotive industry and our members are best represented and protected.

Through submissions the MTA is able to:

  • Highlight failures of government regulations and legislation affecting our members.
  • Advocate on behalf of our members and highlight member concerns.
  • Propose changes to regulations and legislations which best serve the public, our members and the automotive industry.
  • Provide options which assist our members to be more productive and achieve greater business efficiencies.
  • Initiate positive change for the automotive industry in South Australia.

Below is a selection of some of the submissions made by the Motor Trade Association:

  • Heavy Vehicle National Law Review (2019)
  • Land Tax (Miscellaneous) Amendment Bill (2019)
  • Review of Australian Apprenticeships National Skills Needs List (2019)
  • Jobs for the Future in Regional Areas (2019)
  • Cross Sector Environmental Skills Project (2019)
  • Inquiry into the Motor Vehicle Insurance and Repair Industry in South Australia (2019)
  • Accident Tow Rate Charge Review 2019
  • Electric Vehicle Strategy (2019)
  • VET in Schools (2019)
  • National Transport Regulatory Reform (2019)
  • Training and Skills Development Act Review (2019)
  • SA Skilled Migration Program (2019)
  • Enforceability of Financial Services Industry Code (2019)
  • Australian Qualifications Framework Review (2019)
  • Creating a Modern Industry Policy for South Australia (2019)
  • Automotive Franchising Code (2019)
  • Vocational Education and Training Review (2019)
  • Supported School Transport and the NDIS (2018)
  • National Transport Commission Fatigue Management (2018)
  • Accident Tow Rate Charge Review 2018
  • Quad Bike Safety (2018)
  • Financial Services Royal Commission (2018)
  • South Australian Skills in Demand (2018)
  • Better Fuel for Cleaner Air (2018)
  • Graduated Licensing System for Motorcyclists in SA (2018)
  • Review of the Return to Work Act 2014 (2018)
  • Small Business Tax Concessions (2018)
  • NHVR Master Industry Code (2018)
  • Light and Heavy Vehicle Standards Review (2018)
  • Road Vehicle Standards Bill Submission 2017 (2018)
  • State Budget Submission (2017)
  • State Nominated Skills Occupation List (2017
  • Accident Towing Charges (2017)
  • Interim Guidelines on Misuse of Market Power Concerted Practices (2017)
  • Quad Bike Safety (2017)
  • Review of CBS Compliance and Enforcement Policy (2017)
  • Vehicle Inspections Position Statement (2017)
  • The Work Health and Safety (Notification of Next of Kin) Amendment Bill 2017 (2017)
  • Road Traffic Act Regulations for NA Category (Two Wheel Drive) Vehicles (2017)
  • Bus and Coach Accreditation and Regional Contract Matters (2017)
  • Competition Policy Review Legislation 2016 (2016)
  • ASIC Actions Relating to Dealer Finance (2016)
  • ACCC Market Study into New Car Retailing (2016)
  • ACL Interim Report Feedback Submission (2016)
  • Review of the Return to Work Act 2014 Submission (2014)

For more information on submissions and the MTA’s commitment to Industry Policy and Advocacy please contact 8291 2000 or email mta@mtasant.com.au


MTA Submissions 2019


Preparing the Northern Territory for Electric Vehicles

The MTA submission highlighted to the Northern Territory Government issues raised my members regarding electric vehicles, including lack of information, infrastructure, skills and training, safety concerns, business costs and geographical considerations. The submission noted that the government will need to give careful consideration to the costs and benefits of implementing an EV policy in the Northern Territory, especially during the transition period.

MTA members can access the full submission here


Land Tax (Miscellaneous) Amendment Bill 2019

This submission highlights the concerns of automotive businesses in South Australia in relation to the controversial five year program of state-wide property revaluations and aggregation of properties in seperate trusts and subsidiary companies over many years.

MTA members can access the full submission here


Heavy Vehicle National Law Review (June – October)

The National Transport Commission (NTC) has gone back to basics to review the Heavy Vehicle National Law (HVNL). The HVNL Review aims to result in a performance-based and outcomes-focused regulation that will: improve safety for all road users; support increased economic productivity and innovation; simplify administration and enforcement of the law; support the use of new technologies and methods of operation; and provide flexible, outcome-focused compliance options.

MTA members can view our submission responses in respect of seven issues papers, across 2019, here:


Review of Australian Apprenticeships National Skills Needs List (September)

The MTA provided input into the review of the methodology by which occupations in skills needs are identified and prioritised for the purpose of targeting apprenticeships incentives and payments.

MTA members can view the full submission here


Jobs for the Future in Regional Areas (September)

The submission outlined the MTA’s belief that vocational education and training (VET) providers are well placed to guide the transition into new industries and employment through their wealth of experience in reskilling and retraining programs, and their ability to develop flexible, industry specific, training options.

MTA members can view the full submission here


Cross Sector Environmental Skills Project (September)

The MTA provided feedback on proposed changes to training package units of competency to reflect current and emerging practices in environmental sustainability across multiple industries. The MTA noted its concern that any move to generic environmental and sustainability training units that can be adopted across multiple training packages will fail to meet industry specific training requirements.

MTA members can view the full submission here


Inquiry into the Motor Vehicle Insurance and Repair Industry in South Australia (September)

The MTA provided a submission to the Economic and Finance Committee and appeared at a public hearing, taking a stand on behalf of Collision Repairers and asking for a fair and functional relationship between all parties. The MTA asked the Committee to protect fairness and business confidence in South Australia by mandating and tightening the Motor Vehicle Insurance and Repair Industry (MVIRI) Code of Conduct, as well as protecting consumers from the possible decline of choice, quality and safety of repairs.

MTA members can view the full submission here


Accident Tow Rate Charge Review 2019 (August)

Every year the Accident Towing Rate is reviewed for concerns raised by operators including higher than inflation increases in insurance premiums and stagnant storage charges.

MTA members can view the full submission here


Electric Vehicle Strategy (August)

The MTA submission recommended that the State Government bring stakeholders from the EV industry and automotive industry together as the first step in developing an industry plan for the adoption and deployment of Next Generation Vehicles. Our consultation sought input from automotive businesses of varying sizes and types, from regional and metropolitan locations, the VET sector, and consumers. This approach sought to produce a balanced policy position for consideration by Government.

MTA members can view the full submission here


VET in Schools (July)

The Minister for Education released a VET Issues Paper: Vocational Pathways to Employment. A review of VET for School Students, seeking stakeholder feedback to contribute to the development of a VET for Schools Policy. The MTA provided feedback on the key challenges identified, and the questions raised, in the issues paper.

MTA members can view the full submission here


National Transport Regulatory Reform (July)

The MTA’s submission considered that: the Heavy Vehicle National Law’s (HVNL) objective, as stipulated by the National Heavy Vehicle Regulator (NHVR), has not been met; this is due to the design of the HVNL, rather than the failing of the regulator; and the legislative review of the HVNL being undertaken by the National Transport Commission (NTC) is likely to respond to many of industry’s concerns.

MTA members can view the full submission here


Training and Skills Development Act Review (June)

The MTA maintains its position that the training and skills systems should focus on employment, and that this is best achieved through enhanced integration and cooperation between schools, industry based RTO’s, employers including GTOs, TAFE and industry.

MTA members can view the full submission here


SA Skilled Migration Program (June)

The MTA has made recommendations which seek to maintain the position of all currently listed automotive trades on the State Nominated Occupations List, and to include automotive parts interpreter, transmission specialist and tyre fitter on the list, understanding ANZSCO recognition is required for this to occur.

MTA members can view the full submission here


Enforceability of Financial Services Industry Code (April)

The MTA believes that Industry Codes of Conduct play an important role in building consumers trust and confidence in the operation of complex markets, particularly where prescribed dispute resolution procedures can demonstrate effective regulation and enforcement of code provisions. The MTA recommended that industry codes should only be voluntary by exception, and that the Motor Vehicle Insurance and Repair Industry Code of Conduct specifically be made mandatory as a matter of urgency.

MTA members can view the full submission here


Australian Qualifications Framework Review (March)

The MTA is supportive of both having a national qualification framework as well as its timely review. The MTA supports the extension of the Australian Qualifications Framework (AQF) to accommodate more qualifications. However, our consultation also identified the need for a greater emphasis on industry collaboration in regards to the development and currency of training packages to ensure they remain relevant to the modern automotive industry.

MTA members can view the full submission here


Creating a Modern Industry Policy for South Australia (March)

The MTA’s submission highlighted that the automotive industry continues to be a major driver of economic activity and employment both in South Australia and nationally, and is also at the forefront of innovative products and processes which are enhancing the consumer experience every day.

MTA members can view the full submission here


Automotive Franchising Code (February)

The MTA supports regulatory intervention in the form of a mandated and prescribed Automotive Code of Conduct, including deterrent financial penalties for non-compliance, to provide a fair and balanced relationship between New Car Franchised dealers and Vehicle Manufacturers.

MTA members can view the full submission here


Vocational Education and Training Review (February)

The MTA submission noted that the effectiveness of the Federal Government’s investment in VET can only be determined if the objectives of the VET system are clear and reporting measures reflect those objectives. The MTA considered that the current purpose of the VET system is unclear, leading to confusion amongst stakeholders as to their place in the system and how to manage their participation within it.

MTA members can view the full submission here


MTA Submissions 2018


Supported School Transport and the NDIS (July)

Ensuring that children with special needs receive the optimum level of supported services is a key concern of the MTA and the wider transport sector in relation to school transport. The MTA’s submission response seeks to address the concerns expressed by our members for the welfare and wellbeing of NDIS participants, their families and caregivers.

MTA members can view the full submission here


National Transport Commission Fatigue Management (July)

In response to the issues raised in the National Transport Commission (NTC) discussion paper, the MTA made 11 recommendations that seek to provide a practical, industry led response to the matters raised. The MTA considers that a single federal approach across all states would simplify and clarify fatigue management requirements for all stakeholders.

MTA members can view the full submission here


Accident Tow Rate Charge Review 2018 (June)

Every year the Accident Towing Rate is reviewed for concerns raised by operators including the impact of insurance costs and the stagnation of storage charges.

MTA members can view the full submission here


Quad Bike Safety (May)

The MTA supports increased efforts at the point of sale to further educate consumers on the correct operation of quad bikes and the critical importance of abiding by the specifications set by the manufacturers to reduce injuries and fatalities. However, the MTA does not believe that the evidence supplied supports a definitive conclusion that Australian specific regulations mandating the fitment of Roll Over Protection Systems (ROPS) and Crush Protection Devices (CPD) would result in a material change in the number of injuries and fatalities associated with the use of all-terrain vehicles (ATV’s).

MTA members can view the full submission here


Financial Services Royal Commission (April)

The MTA has previously made a number of submissions on behalf of its members to the ASIC review of the car finance market to highlight the important benefits consumers can derive from dealer financing arrangements. The MTA recommended that the Royal Commission recognise the lengthy review process undertaken by ASIC, which involved all stakeholders, and defer to the reform package proposed by ASIC.

MTA members can view the full submission here


South Australian Skills in Demand (April)

The MTA recommended 12 occupations which are currently experiencing skills shortages for inclusion in the State Nominated Occupation List (SNOL) to address the current skills shortage in South Australia. It was also recommended that transmission specialists, who are not captured by the current environment scans, be included in the SNOL as well. The MTA also submitted that skilled migrant workers should be assessed through industry bodies with training capacity to ensure they meet Australian Qualifications Framework (AQF) standards of competency in their given fields and do not displace competent skilled Australian labour from the workforce.

MTA members can view the full submission here


Better Fuel for Cleaner Air (March)

The MTA’s submission noted that improving fuel quality standards is broadly accepted in principle as a desirable outcome by the automotive industry. The submission recognised the need to balance the inevitable regulatory and transitional burdens associated with increasing fuel quality standards, while minimising the downstream cost effects on fuel retailers and fuel consumers in a responsible way.

MTA members can view the full submission here


Graduated Licensing System for Motorcyclists in SA (February)

The MTA considers that the Graduated Licensing System (GLS) reform package proposed by the Centre for Automotive Safety Research (CASR) has substantial merit. The reforms proposed will make significant improvements in rider knowledge and confidence, and in the operation and understanding of motorcycles in on-road environments. This will result in better safety outcomes for riders and other road users. However, the MTA does not support the proposal to lift the motorcycle licence age from its current levels, as it is incongruent with the overall package of reforms and there is a lack of evidence as to its efficacy in other jurisdictions.

MTA members can view the full submission here


Review of the Return to Work Act 2014 (January)

The MTA’s submission proposed amendments to the Return to Work Act in response to issues that have emerged during the operation of the new Act, and as a result of findings of the South Australian Employment Tribunal (SAET). The proposed amendments sought to maximise an employee’s ability to return to work safely without imposing unproductive costs on employers.

MTA members can view the full submission here


Small business tax concessions

The submission focussed on automotive businesses views on keeping the instant asset write off, abolishing payroll tax and reducing the burden of collecting and reporting taxation on behalf of the government. The MTA also highlighted the need for extra tax breaks for businesses starting up or going through growth phases.

MTA members can view the full submission here


NHVR Master Industry Code of Conduct

Members have reiterated that more clarity is needed around the NHVR Master Industry Code of Conduct in relation to changes in Chain of Responsibility obligations. In particular, our submission highlights the need to fight to make sure that drivers and mechanics are properly protected from the misconduct of others, as well as the need to ensure that roadside inspectors have the appropriate qualifications and experience to do their job.

MTA members can view the full submission here


Light and Heavy Vehicle Standards Review

We continue to pursue the introduction of a federally administered light vehicle inspection scheme that ensures safety on our roads and consistency with Australian Design Rules. We are also fighting to ensure that tyre ages are included in an inspection scheme.

MTA members can view the full submission here


Clarification , simplification and modernisation of the consumer guarantee framework (2018)

The MTA has surveyed its entire membership to assist in developing an appropriate response to the Regulatory Impact Statement.

MTA members can view the full submission here.


Road Vehicle Standards Bill Submission 2017 (2018)

The MTA’s submission makes eight recommendations and requests clarification on a further eight issues following consultation with our members.

MTA members can view the full submission here.


MTA Submissions 2017

State Budget Submission (2017)

Our submission seeks to achieve progress towards the Premier’s vision by prioritising:

  1. Enhancing business cash flows to increase sustainability and enable enterprise expansion.
  2. Increasing workforce productivity and employment outcomes through improved training structures and greater assistance for training providers.
  3. Reducing business costs such as electricity and overheads.
  4. Increasing access to government funding pools to assist in innovation and transformation.

MTA members can view the full submission here.


State Nominated Skills Occupation List (2017)

The South Australian economy is facing a current and growing skills shortage.

The automotive sector, notwithstanding the end of automotive manufacturing, continues to be a significant employer in South Australia, with over 28,000 people employed in the automotive trades we support.

MTA members can view the full submission here.


Accident Towing Charges (2017)

Every year the Accident Towing Rate is reviewed for concerns raised by operators including the impact of insurance costs and the stagnation of storage charges.

MTA members can view the full submission here.


Interim Guidelines on Misuse of Market Power Concerted Practices (2017)

The MTA supports the introduction of the misuse of market power provisions to the Australian Competition and Consumer Act 2010.

The intent of the ‘effects test’ is to give the ACCC greater scope to successfully investigate and prosecute businesses engaging in the misuse of market power by allowing for the effect of any conduct to be considered as grounds for a breach, rather than only considering the purpose of that conduct.

MTA members can view the full submission here.


Quad Bike Safety (2017)

There have been a number of injuries and deaths associated with the use of Quadbikes.

The MTA has considered the data presented in the issues paper and has undertaken extensive consultation with its dealership members in order to provide the ACCC with an appropriate response to the issues raised in their paper.

The evidence supplied in the paper does not support a definitive conclusion that Australian specific regulations mandating the fitment of Roll Over Protection Systems and Crush Protection Devices would result in a material change in the number of injuries and fatalities associated with the use of all-terrain vehicles.

MTA members can view the full submission here.


Review of CBS Compliance and Enforcement Policy (2017)

The Australian Consumer Law and Second Hand Vehicle Dealers Act seminars, developed jointly by MTA and CBS, have been positively received by industry and have greatly assisted in informing dealers of their rights and obligations in relation to consumers. The MTA recommends that this program of engagement and education continue into the future.

The MTA considers that there is considerable scope to expand enforcement actions to include those businesses, including auto recyclers and mechanics, who do not meet environmental standards as prescribed by law.

The MTA considers enforcement action would be enhanced by increased awareness of the reporting mechanism on the CBS website, with subsequent enforcement action acting as a deterrent to others in the industry.

Non-compliant businesses pose a consumer detriment and substantially harm their respective industries.

MTA members can view the full submission here.


Vehicle Inspections Position Statement

The MTA supports mandatory vehicle inspections to reduce the incidence of vehicle related fatalities on our roads.

The absence of a robust system to identify ‘at risk’ vehicles, encourage regular maintenance and servicing and to reduce the number of aged vehicles on South Australian roads has hidden the risk of un-roadworthy vehicles.

MTA members can view the full submission here.


The Work Health and Safety (Notification of Next of Kin) Amendment Bill 2017 (2017)

While the MTA supports the objective of the Bill to ensure next of kin are notified in the event of an incident, we cannot support the proposed amendments of the Bill. Further, it should be reiterated that the proper responsibility for notifying next of kin should remain with trained emergency personnel.

MTA members can view the full submission here.


Road Traffic Act Regulations for NA Category (Two Wheel Drive) Vehicles (2017)

The MTA recommends amending the regulations to include this provision from the National Code of Practice:

"Off-Road and Goods Vehicle Wheel Track.

The wheel track of off-road four wheel drive vehicles and goods vehicles (MC, NA, NB ADR category) must not be increased by more than 50mm beyond the maximum specified by the vehicle manufacturer for the particular model. If a solid axle from another manufacturer is used, the wheel track may be increased by 50mm beyond the maximum specified by the vehicle manufacturer for that particular axle, provided all other requirements such as clearances and the tyres do not protrude outside of the vehicle bodywork."

MTA members can view the full submission here.


Bus and Coach Accreditation and Regional Contract Matters (2017)

The MTA wishes to reiterate the concerns our members have expressed about being excluded from government procurement processes and the lack of transparent communication to the whole industry.

MTA members can view the full submission here.


MTA Submissions 2016

Competition Policy Review Legislation 2016 (2016)

The MTA considers the introduction of an ‘effects test’ into s46 of the Australian Competition and Consumer Act 2010 (ACC) a step forward in regulating competition practices in Australia.

The drafting of the proposed amendments accords with the MTA’s recommendation to the consultation panel which considered the ‘Options for Strengthening the Misuse of Market Power Provisions’ in the ACC.

MTA members can view the full submission here.


ASIC Actions Relating to Dealer Finance (2016)

The MTA does not support ASIC's contention that the current dealer finance model is inherently unfair, presents a systematic conflict of interest or poses systematic risk to the dealer finance market resulting in consumer harm.

MTA members can view the full submission here.


ACCC Market Study in New Car Retailing (2016)

An ultra-competitive market already exists in new car retailing, as it does across the retail, service and repair sectors, and any moves to further slice margins will affect employment and business viability in the sector, undermining the competition remit afforded to the ACCC and lead to greater consumer detriment.

MTA members can view the full submission here.


ACL Interim Report Feedback Submission (2016)

The MTA’s submission focuses on five key areas discussed in the report that most impact on our membership and the ACCC has sought further advice on.

These are:

  • The Consumer Guarantee Threshold;
  • Small Business Considerations;
  • Lemon Laws;
  • Product Safety; and
  • Manufacturer’s Warranties

MTA members can view the full submission here.


MTA Submissions 2014

Review of the Return to Work Act 2014 Submission (2014)

The MTA believes that this review does provide an opportunity to refine those elements of the scheme that:

  • Are likely to pose significant funding threats to the scheme due to issues of interpretation by the courts.
  • Do not operate in a manner that best supports the scheme’s primary objective of returning injured workers to meaningful and sustainable work as efficiently and safely as possible.
  • May impact the scheme’s ability to return injured workers to meaningful and sustainable work as efficiently and safely as possible.

MTA members can view the full submission here.