I strongly object to the proposed diversion of haulier movements to off-peak hours and the imposition of Terminal Access Charge (TAC). The proposal’s own data shows that approximately 70% of container movements occur between 8.00 a.m. and 8.00 p.m., while night movements fall to below 30% and often single-digit hourly volumes. This clearly demonstrates structural and ecosystem constraints, not behavioural choice by industry players. Import and export volumes increased by 9% in 2024 (over 6.7 million TEU combined), indicating congestion is driven by trade growth and infrastructure limitations, not inefficiency by hauliers or agents.

The proposal also explicitly acknowledges that congestion is caused by accidents, vehicle breakdowns, and roadworks, yet TAC penalises peak-hour transactions without addressing these root causes. Forced night operations increase safety risks, labour shortages, and operational failures, while the proposed incentives are economically insignificant relative to real night-shift costs. TAC therefore functions as a punitive charge rather than an effective traffic-management tool. I strongly urge MOT to defer TAC implementation and focus on structural solutions such as incident response, gate appointment enforcement, and fully supported voluntary off-peak operations.

Please refer to the attached file for my full thoughts and feedback.