From: [Anonymous submission]

Sent: Tuesday, 17 November 2015 3:33 PM To: Kelly, Theo

Subject: Np8487 Port of Townsville Submission

Attention Theo Kelly Australian Competition and Consumer Commission GPO Box 3131 Canberra ACT 2601 Dear Theo Re : Reference to the Port of Townsville Limited (PoTL) dated 2nd November 2015 We refer to the submission presented to the ACCC from the PoTL dated 2nd November 2015 and wish to provide comments in relation to the PoTL submission. Each point correlated with a response. Background Point 4. Agree that the PoTL is a Cargo Terminal Operator (CTO). But also there are other nominated CTOs that operate within the Port operations. These are Northern Stevedoring Services and BHP. Disagree that they are responsible for ALL security arrangements in relation to common user areas at the Port of Townsville . Clarification needs to be sort when PoTL have the responsibility in relation to common berths. Under the Customs Act 1901 Sect 102D States “ Section 102CC and 102CF to 102CI apply to cargo handler in the same way as they apply to a cargo terminal operator.” PoTL as the CTO of the Townsville Port facility are charged with hiring common used berth to Cargo Handlers. Upon the hiring of the common used berth Under the Custom Act the Cargo handler is charged with the responsibility with compliance. For : Custom Act 1901 , : Maritime Transport and offshore Facilities Security Act 2003 : Work Health and safety Act 2011 ( QLD) The arrangements for security services is now under the obligation of the Cargo Handler as the Hirer of the common berth . Email Communication that confirms from Border force stating that the Cargo terminal operator can engage whom so ever. In terms of what is required under our legislation, as far as I am aware we just place responsibility for the security of cargo that is subject to customs control on the facility that is holding the cargo (CTO/s.77G/s.79). Provided that the entity that is charged with the security of the cargo complies with our legislative requirements they can use whomsoever they choose within the restrictions of ‘fit and proper’.

XXXXXXXX

Point 5.

Agree true statement.

Point 6

Although referring to point 4 Cargo Handlers and other CTOs would be charged with the same obligation under the Maritime Transport and Offshore Facilities Security Act 2003 ( MTOFSA).

All Cargo Handlers and Port operators are charge with maintaining a Maritime Security Plan whether their own or that of the POTL modified to each particular operational need.

All Individual Operators would conduct their own risk assessment in relation to their own operation. As they are best qualified to understand the risk associated with their cargo and operation.

“Amongst other things” only indicates they have no further points to raise?

“In PoTLs view the Customs Act will the requirement of access control required under MTOFSA.”

The PoTLs view can be considered although their view is not a view based on consultation with other authorities regulating Australian Ports or consultation with those operating within the Townsville Port facility.

The lack of consultation was evident during the meeting for Port Handlers and other CTOs.

Point 7

Agree

Point 8

Disagree with this statement.

Reference to Custom Act 1901 – SECT 102BA meaning of Fit and Proper person

XXXXXXXX and their employees are considered Fit and Proper under the classification outlined under the Customs Act 1901 SECT 102BA.

Ref to point 4 statement from Border Force

Point 9

Disagree with part of this statement. “The current arrangements where security services do not contemplate 24/7 access control.

XXXXXXXX have been and still are supplying 24/7 supply of security services to a number of Port facility operators for the purpose of access control.

The requirement for securing cargo terminals 24/7 is on the premise that the cargo terminal while not operational will be under lock and key and under surveillance by CCTV requiring a single operator.

If physical security were allocated to each cargo terminal the cost of operations would increase substantially. This would apply to S15 Custom controlled storage areas The current operation of CCTV surveillance is a current and existing.

Point 10

The statement made by the PoTL still constitutes a miss use of power placing competitors at a disadvantage. Attempting to use a form of blackmail as long as they as they engage the services of Maritime Security Guards (MSG) employed by the PoTL. They will allow them access to the common berth!.

This is an indication that could cause additional expense and safety issues on many levels.

- Holding back facilities available hindering cargo movement causing longer periods for loading and unloading incurring further operational cost.

- The additional cost of Security that would have to be engaged.

- Safety issues withholding vital areas that would be needed to carry out operations in a safe manner.

Point 11

It will certainly increase the level of security only for the reason stated in point 10.

24/7 access control is currently available provided by the PoTL. Here again physical security will not be required 24/7 at every Cargo terminal or S15 Custom Controlled facility.

If the operation requires custom goods or cargo to be moved and the operation is a lengthy operation each Cargo Operator should be able to employee a service of their choose.

Not be forced into using the only provider of security .

Point 12 No Comment

Point 13

Port Of Bonython ACCC 2014

In brief the Port Authority of Bonython placed a requirement on the condition that the new port users would have to use the port security provider.

This would have constituted a breach under the act of free competition.

My understanding that the ACCC/ Court in 2014 had no objection for exclusive dealing in relation to provision of security services by a single security provider.

The Minister having made arrangements with the existing provider

The reason being:

The existing security firm were the sole provider of security at the time.

Engaging another security firm would be less likely due to the remote location.

That the existing security were well versed in the operation of the port.

And the introduction of new security firms would be a detriment to operations and the Public.

The PoTL Statement point 10 still constitutes a breach under the Act of freedom of choose and competitive competition .

The major difference here are as follows:

The PoTL have not provided the security service to the existing Port Users, Cargo terminal Operators or Cargo Handlers to their operations.

The PoTL aren’t the sole provider of security within the Port of Townsville..

The existing Cargo Handlers are comfortable with the existing security arrangements .

The introduction of a new (PoTL) security provider will be detriment to their business.

The provision of security services was awarded to a private contractor Santos Limited and not the Port authority of Bonython.

Point 14 and 15

In relation to the points raised by the PoTL.

We feel that we are not in a position to advise the ACCC what they should or should not do.

This discussion we feel needs to be determined by the ACCC after reviewing all avenues of information provided to them.

Point 16

Ref (b)

The statement made by the PoTL seems to contradicts their presentation made to all Port Users during the meeting held with Border Force recently.

Where PoTL representatives commented:

“There will be in place an agreement of collaboration with the PoTL given to contractors with Custom controlled areas”

Allowing non security personnel access to Custom controlled areas.

“ If the trust was broken then that position of trust would be withdrawn”

This comment made by the PoTL contradicts the statement that they cannot delegate or discharged the responsibility by the PoTL?

Ref (c)

(i) Having no competition or a single provider lessens the standards that need to be maintained. Security providers become complacent.

1. Having open competition ; benefits to the public are

- Helps maintain standards and even improves the standard and quality of services

- Helps control cost. knowing that prices for services can be inflated if only one provider is available.

- Maintained lower operational cost which doesn’t reflect on the end user

(ii) Efficiency in service providers knowing that competition will lift the efficiency of services.

(iii) It has already been shown that the cost proposal for services by PoTL are already higher.

2. The existing pricing structure on their web being an indication of future prices if nominated as sole security provider.

(iv) Over the period of eight years there hasn’t been a duplication of services as the PoTL haven’t been the provider of security services to Cargo Handlers.

3. The areas of responsibility have been clearly defined when Cargo Operators take control/Hire of a Cargo Terminal.

(v) The public will benefit in the increased security presence with operators providing additional coverage.

Ref (d) Having a sole provider would have a determent on the public.

- Three security firms businesses would be affected with up to two being placed completely out of business.

- There are number of employees that would be out of work made redundant.

- Impacts on unemployment Townsville having the 3rd

highest unemployment rate in Queensland.

- Impacts on social welfare departments placing a further strain on a already Public taxed reliant agency.

- The cost of services proposed by PoTL will only be passed onto the consumer.

Ref (f) As a sole provider of services pricing can be set to whatever level they feel fit to set.

As per point 10 raised above the PoTL has the potential to withhold facilities common areas if the demanding price for services are not meet.

If they can offer common areas if they use the port security they can certainly withhold the same if they don’t agree.

Like any other business you can set whatever price that you think but in reality without competition it can’t be controlled by the client.

Ref (g) The PoTL conduct in their attempts to become sole provider of security services has been less than fair, reasonable and appropriate.

In their approach.

Conduct :

Ever since their intentions to be a security provider of MSG at the Port of Townsville they have conducted themselves.

[ACCC paraphrase: Company A considers that the Port of Townsville engaged in conduct to entice Company A security officers to apply for advertised positions with TPA. Company A considers that this conduct was anticompetitive and disruptive. Company A provided details of a particular employee.]

Communication : The lack of consultation on the matters relating not only to the security arrangements but also on the requirements on the implementation of the

Customs Act was evident during the meeting held in conjunction with Boarder force 9

th October 2015. The overwhelming voicing that the port users

haven’t been communicated or consulted with and the lack of transparency was obvious.

Initial meeting with the PoTL with XXXXXXXX was one that seemed to be more open suggesting that they would require the assistance of

XXXXXXXX because of their vast experience. But since the intensions of the Port of Townsville was to monopolise the security for the Port of

Townsville the communication has been nonexistent for all security contractors currently operational within the Port of Townsville. To point that all

Communication would exclude any security contractor. Which would be considered a breach under the custom ACT SECT 102GG

Legislative Compliance Point 17. I am Sure that the ACCC are aware and have access to the Customs Act and will not need to state the same. Agree that the PoTL have a obligation to provide security service to the Port of Townsville as they have always in the past. And that is the access control in and out of the port facility and perimeter fence lines. The Customs Act does place the obligation on the Cargo Terminal Operators as well at Cargo Handlers as stated under the Custom Act SECT 102D Point 18. This applies to all CTOs other than PoTL and also applies to Cargo Handlers who would have the right to choose and provide the required security arrangements under fit and proper. Procedures put in place under individuals plans that would comply with the Customs ACT. Point 19. Agree their current performance would certainly attract attention of fines. Although the fines would apply to all those who would breach their obligation under the Custom Act. Point 20. Incorrect statement by the POTL. Not only are berth operators engaging Maritime Security Guards for the access control when a vessel is alongside to enact a Landside Zone Under the Maritime Transport and Offshore Facilities Act 2003. But are also engaged in the following.

- Patrol of facilities inside and outside of the Port Operations. - Used as escorts for personnel without MSIC on the Landside Zone . - Utilised for access control in and out of the Townsville Port Facility - Contracted as escort for contractors working within the Townsville Port - Contracted security to Cruise Ships ( Contracted to the PoTL) Non regulated ship - Contracted security to Navel Ships. - Official contractor for berth 10 function centre which was subject to tender ( which the PoTL

are not) Point 21 This statement is true to a point. The requirement under the Custom Act requires the facility to be secured 24 hours per day. As The CTO of the Townsville Port Facility That would require to ensure access into and out of the facility is maintained with the proper checks and patrolling the perimeter fence line. Currently being done by the PoTL Procedures for the implantation of how this is to be done Internally has not been finalised. As there is yet to be consultation with Boarder Force and other CTOs and Cargo Handlers of the Cargo Terminals . Yes while the facility isn’t being used the facility will be ; Under lock and Key, under CCTV surveillance and if access is required PoTL to dispatch its security to attend nothing different from what it is currently in place. S15 Areas assigned as Custom controlled areas are also under surveillance. While Cargo Handlers have taken on the hire of any berth then the operational area would require access control this will dependant on the type of operation.

Still under the Customs Act requiring regulated control. This is where the Cargo Handler has the same responsibility as the CTO. And have the choose to engage which security provider to enforce the requirement under the Customs Act under fit and proper. Not be dictated to. Point 22. The Onus is on the Cargo Handler and Other CTO”s operating under the provision of the Custom Act Ref back to SECT 102D of the Custom Act. So to say that if a Cargo Handler is exempt from being charged with any breach . This would mean a Cargo Handler could continually break the Customs Act and there would be no consequences ? Point 23. The responsibility is taken on by the berth Operator( Cargo Handler) and responsibility then is that of the Cargo handler and also includes the Security firm they wish to contract. Point 24 and 25 The PoTL are yet to implement the Customs Act which was implement in 2013 Legislative obligation that has almost taken 3 years to implement? It is the Cargo Handlers that will be better positioned that understand their operations and apply the legislative requirements under the Custom ACT. Point 26

(a) Will apply to all (b) These are off the record. So they don’t exist .Off the record check the number of breaches

the PoTL incurred from Customs? (c) The PoTL need to understand that the standards required of the Security Providers are not

the standards required by PoTL but that of our direct Client. That the POTL have little or no understanding what the set requirement is for their contracted security. The PoTL haven’t not got in place a Operational standard that has been made available .

Point no 27 and 28 The legislation under the customs act hasn’t been implemented by the PoTL so how can they justify that the current port security providers are not to a standard? They have no standard in place to measure against. No Policy or procedure. And how is anyone expected to meet the standard if they can’t provide the information.? Its only the PoTL view what they perceive. PoTLs understanding of services isn’t controlled by PoTL but buy the CTOs and Cargo Operators that engage their security services it’s their operational requirement that is followed and that is access control. Point 31 This also has the reverse affect where finical gain can be sort by the PoTL by hindering cargo movement. As the majority are cleared by customs prior to unloading As for Custom controlled good within S15 areas . Each operator will be charged with the proper release of Custom controlled goods. The security service who is engaged can be anyone as long as they are fit and proper according to Boarder Force. Point 32 States the existing security providers are not able to provide the services to a very high standard and not at the level required by the PoTL

- So why do PoTL continually badgered and harassed XXXXXXXX Officers to apply for the positions at the PoTL, our team have been there for many of years and do know the requirement for port access.

- So why PoTL engage XXXXXXXX to manage their shortfalls when required . - The standard of PoTL security when unchecked will decline below the standard required

without competition - I would question the statement made about PoTLs claims of providing a very high standard

and that the contracted security services are of a low standard

4. Clients ; Cement Australia, Queensland Sugar Limited, Puma, Northern Stevedoring Services, Magnetic Shipping Services theses clients among more a more than pleased with the level of service afforded to them.

5. PS It would be naive to say that we are perfect but we are all human and we learn from what little mistakes we have made.

Point 33 The PoTL states that there will be no requirement for Landside Restricted Zones required under MTOFSA. But there is still a requirement to have access control under The Customs Act. Movement of Crew Movement of Cargo on and off Cargo Terminal once cleared by Customs. Safety aspects of operations Public Benefit Point 34 . This is only the opinion of the PoTL . The opinion of our Clients is that the security provider engaged they would be a better indication of the level of services provided. Point 35. How will they improve quality of service measured against what? What benefits will be gained? Already the cost provided by the PoTL is causing concern by all Port Cargo handlers and the possibility of being the sole provider will see future increases that they will be unable to avoid? This will be detriment to the general public having a increase in operational cost. Theses operational cost have the full potential to be passed on to the general public. Townsville is a distribution centre for fuel and increased cost will only be passed onto the consumer. Townsville already is one of the highest priced regions for fuel along the eastern of Australia. Other commodities like tyres, copper will feel the impact of the increase cost of operations. The increased cost for security services if supplied by the PoTL will have the effect on job decrease increasing the already high unemployment rate in Townsville. Point 36. Who will regulate the PoTL security services? A self regulating body have rarely been successful in self regulation. Inconsistent security provider? XXXXXXXX have been a consistent provider of security and have lifted the level of service to The Port of Townsville. Point 37. PoTL like security contractors have in place a system of support. Each Cargo Handler is responsible for the management of the security contractor under their Port Plan. Each security Officer has direct contact with the Cargo Handler Supervisor or shift Manager. The Maritime Security guards have 24/7 contact with Management or system support if the need arises. And this includes calling upon PoTL security or Border Force .

Point 38. This service is already in place as part of their obligation to the Port of Townsville access control in and out of the port facility. Point 39. This has been covered previously. But to make a point of contradiction made by the PoTL Point 20 states only required to engaged as maritime security Guards for the purpose of access control. Point 39 states security providers perform a varity of unrelated security functions. Do the PoTL really understand what the requirement of the Security role that they are attempting to take over? Point 40. Over the eight years of providing security services at the Port of Townsville there always has been some minor miscommunication. And the miscommunication has resulted in the poor administration of policies provided by PoTL and the clarification of those policies. As contracted Security Provider to the Cargo Handler we have defined procedures and responsibilities which have resulted in an understanding that continues to improve efficiencies in operations. Better efficiencies relating to controlled cost. Point 41. The issue of standards has been already raised. Point 42. This is the presumption of the PoTL. If they have consulted the Port handlers and if the ACCC were to contract every Port user they would soon see that the statement would not be supported . Point 43. The quality of MSG that existed with the Security Contractors must have been of a high standard already. Because why would the PoTL poach theses Security Officers if they were not of a high standard.? Efficiency and Supervision. Point 45 As a Security Provider there has been little difficulties co coordinating security requirements. As the security requirements has been left to individual Cargo Operators to arrange. If the PoTL were to attempt to control all the requirement I would see then that they would have difficulties. The claim that there would be miscommunication between security providers hasn’t taken place to my knowledge. In fact recently the communication between Security contractors worked smoothly without issue . Point 46. There has been no requirement for the PoTL to exercise control of contracted Security. The only requirement for PoTL security were required to do is ensure that security were in place in respect to legislations. Being fit and proper complying with all certification MSIC , MSG, Port Induction, compliant with Safety securing the berth and access control These were conducted in their normal duties. Hours worked are regulated closely by both the Cargo Handler and Management of the Security Contractors. Rostering is based on information provided by agents and Cargo Handlers.

Contracted Security MSGs are charged the responsibility to ensure all legislation requirements are meet and efficiencies in operation are reviewed. Rostering needs to be flexible due to the unpredictable circumstances that may arise with Port operations. Procedures are in place for fatigue management and are in line with the security providers Act 2010. Level of MSG’s are constantly reviewed. Only now have we struggled due to the action of PoTL harassing and poaching current security providers employees. Measures are in place now to employ further MSG for the Townsville Port operations. The process of having MSIC approval on average takes up to 4 weeks. The PoTL have used their powers to process their MSIC within two weeks. We are reviewing the time it will take to have a Security contractors employee to process their employees MSIC? Point 47 The PoTL talks about the minimisation of Gaps and or duplication in security services. Under current legislation there is no room for gaps and the duplication of security has never been an issue as Cargo Handlers are in control of coordinating their security requirements. Point 48. This point has been covered Ref Point 16 Point 49 Agree in part if PoTL were to engage a external contractor under their obligation of employment they would be held accountable. Liken to any employee engaged by the PoTL. Point 50 This point has been covered Ref Point 35 Point 51 As Cargo Terminal Handlers are constantly monitoring the service of their contractors and are in the best position to do so. If the security service provided by the PoTL was not acceptable by the Cargo Handlers to what extent without competition would they expect performance standards to be maintained or improved? Point 52 Who would regulate the conduct of PoTL security services? How does the Port Authority determine that the PoTL services will be more reliable than current security services? The performance of the PoTL security service has been less than perfect. Point 53 Current arrangements for engaging security services and for the payment are well coordinated between Client and security contractors. With 24/7 contact point available. Point 54

Once again the cost presented to all port users is already higher than the current model so how can this present itself as cost affective? Without competition the PoTL will still be charging the rate presented on their Web site. Cost – Pricing Mechanism. Point 55, 56,57,58 The market rate which were determined by the PoTL were gathered from the existing Security contractors pricing structure provided to the PoTL security services. Knowing that they would need to be competitive if they were to be a force in providing a security service. And it is already a major issue with all Port Cargo handlers and operators that the current pricing structure provided by PoTL will Increase the operational cost. Point 61 Customers will adjust the hours spent on security as legislation will dictate the requirement. By continuing to engage their current Security Provider Customers will continue to save control the the expenditure both in cost of services and administration cost. Point 62 No duplication has occurred . And the only removal will the removal of free and open competition leaving the PoTL to open pricing structure. Again if the Cargo Handler is engaging the security contractor that is fit and proper then there is no need for PoTL to supervise. Point 63 The PoTL would need to understand that each Cargo Handler would not relinquish the responsibility of supervision of their business to PoTL to Supervise. Or entrust the PoTL to leave them open to compliance with the Custom Act. Point 64 Security Contractors also work under the same Security Service award and same principals for over 12 years. Point 65 So if a port service officer were used to fill in the shortfall what rate will the end user cargo handler be charged at? The rate for Maritime Security Guard or that of the Port service security. Would this then not create a additional cost to port service supplied. Min 1 Hour for Port security services officer in place would incur an min of $400 according to the charges shown on the web site? Point 66 Just another open statement that will pave the door for increase if the PoTL are sole provider of security services. The recovery of cost? What would these recovery cost and how much will this increase the cost of services? Not making enough profit? Not covering administrative cost of additional supervision, recoup hut hire cost, Filled in to many requirements with Port security services?

Future Pricing Point 67 I would question the operational cost of running a Port Facility in comparison to a Security Contractor. The recovery cost of business in a Port facility would be greater than that of the Security Contractors All business will eventually negotiate new rates taking into account current market trend , CPI , Security award increases. Point 68 This makes good business sense to run at a loss? Does this then lessen the quality of services? Point 69 No comment Point 70 Already the model pricing proposed by PoTL is a concern to all Port Cargo handlers which will drive the cost of operations up. This will make importers and exporters certainly look at other avenues . The only way to be competitive is to have open competition . Point 71 In any business model the operational cost is always important. This is why there is a need to have open competition to keep a check on cost. Although with such an important requirement the cost can be overseen based on performance. During our last tender for Security service the client saw fit to reengage us again based on a performance criteria and compliance with legislation over a cheaper supplier. Point 72. Sorry the only meeting other than the initial meeting with Jacob Kalma was the meeting held in conjunction with Border Force and Cargo terminal operators. And the issue of cost was raised as a major concern that the cost are already higher than their current contractors! Point 73. If the POTL are given the go ahead as the controlling body for the supply off MSGs to common areas it will be rigorous indeed. Because how long does an enterprise continue to trade at a loss? At some point share holders will want to see a profit? Which will mean price increase. And without competition they can set what price they see fit. This leaves Cargo terminal operators with no option. Except the increase of cease operations . If the PoTL have based their model for the supply of security services based on current market cost for the supply of security service and working under the Security Services Award . And seeing that their pricing structure is already higher than existing security provider then there should be clear profit in the provision of supplying a MSG! Point 74 Once again the model presented is a profitable venture this is a factor the PoTL are pushing hard to have total control. Recent investments that need to be done to comply with Customs ACT.

Additional Response Point 75 Outside the one lease with the port they are attempting to monopolise the provision of security services. Point 76 No need for comment Point 77 While cargo terminal in common areas and storage areas are not hired by cargo handlers the PoTL under the Custom act have an obligation. While the Cargo Terminal is hired by Cargo Handlers as already defined by Boarder Force the cargo handler has the same obligation as the CTO. This leaves the requirement of engaging a security service of their choosing not one that is thrust upon them and more costly. Point 78 No need for comment Unconscionable Conduct. Point 79 to 88 I believe that we have covered the questionable conduct of the PoTL already in the points above. Point 79 No need for comment Point 80 Except for the initial meeting held back in July 2015 there has been no further consultation or invitation to attend any meeting. Point 81 No need for comment Point 82 No further Comment required Point 83 No further Comment required Point 84 Would ask the ACCC to check with Client at the Port . Cement Australia (Rhett Pruden 0402-227058) QSL for example. To test this statement. Point 85 No further Comment required Point 86 Due to the delays in the implementation of the Custom Act by the PoTL. We have been able to engage some MSG that have been engaged by the PoTL. Comments made by XXXXXXXX when attending the Port of Townsville meeting for PoTL MSG.

Stated that if NSS breach in any way or think it is a breach they are directly to report them to the Port authority. If the Cargo Handler engages the services of MSG their obligation as a MSG is to the Cargo Handler. This creates a conflict of interest. Point 87 No further Comment required Point 88 The PoTL are required to meet their obligation under the Custom Act. But so are all the other Cargo Handlers and operators. Miscellaneous Allegations. As contractors we are answerable to the Cargo Handler the Hirer of the Berth. All incidents are directed back to the Cargo Handler These are then dealt with between the Cargo handler and the PoTL. Summary. We ask that the ACCC review all possible avenues before making a determination. Custom Act Under the Custom Act and verified by the Border Force that the Cargo Handler has the same obligation as that of the CTO. Therefore the statement made by the PoTL stating that they cannot relinquish the responsibility to others on common berths does not fall under the Customs Act guide lines. When the Hirer of the common berths takes responsibility of the berth or storage facility they also take responsibility that convenes them under the custom Act. Therefore the statement made by the PoTL that they can be the only provider of MSG security provider to common berths is not correct. That the obligation is on the Hirer the Cargo Handler which has a choose to engage any security provider as long as they are fit and proper according the Customs Act. Restriction of Competitive Competition The argument that a single provider of security services would be more beneficial and a benefit to the public. It is the Cargo Handlers the port user that are wanting to be able to choose the provider instead of being dictated too. The availability to have different firms bid for the business to obtain the best possible price to keep cost of their operations to a minimum . Without this choose the proposed increase in security cost proposed by the PoTL has already seen a increase . And if allocated as the only provider to common berths only leaves Cargo handlers with no options. Accept what they have been given? Not like they can pick up their business and then relocate. Public Benefit The benefits to the public as proposed by the PoTL seem to be misguided by:- The increased security cost by the PoTL that is in the best interest of the Public? That will only increase the price of commodities in the North Queensland region which will be passed onto the public. Fuel being the biggest commodity and has a major flow on affect.

Will increase the cost of operations which has the possibility of reducing the work force to accommodated the increase. Which will mean a greater strain on the Government unemployment scheme . Townsville recording the third highest Unemployment figures in Queensland . Possible more proposed taxes to support. Increased proficiencies What the PoTL are recommending that the PoTL will be the single provider and with them that there will be increased proficiencies. As a current provider of security we have grown with the Clients we service and understand the requirement of the operation. The Cargo Handlers or operators see no reason for a change in service provider. They are happy with the services that are provided and seeing another provider as more of a hindrance to their operations. Without competition one security provider can become complacent and proficiencies and standards fall.