Ref: MG/SF/GG1002
03 April 2023
Department of Energy and Public Works
C/- Hydrogen Queensland
By email: haveyoursayhydrogenqld@epw.qld.gov.au haveyoursayhydrogenqld@epw.qld.gov.au
AgForce is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool and goat producers. The cane, beef, broadacre cropping and sheep, wool and goat industries in Queensland generated around $10.4 billion in on-farm value of production in 2021-22. AgForce’s purpose is to advance sustainable agribusiness and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,500 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
AgForce appreciated the briefing provided by Departmental officials on 17 March 2023 and welcomes the opportunity to provide comment to proposed amendments of the following Acts:
The Gas Supply Act 2003 (GS Act) and the Petroleum and Gas (Production and Safety) Act 2004 (P&G Act), Geothermal Energy Act 2010 (the Geothermal Act) and Greenhouse Gas Storage Act 2009 (GHG storage Act) and other legislation (Hydrogen Industry Development) Amendment Bill 2023 (the Bill).
From the Departmental briefing AgForce understands that the amendments are part of the government’s commitment to the development of a new hydrogen industry within the state, and to facilitate it through expanding the remit of these Acts to accommodate the new gas production.
AgForce’s interests in the amendments relate to potential implications for our members, other primary producers and for the continuation and growth of agriculture in the state. This includes not infringing on land holder rights, delivering real protection for prime agricultural land, and maintaining land and water access for farmers to maintain viable businesses.
Firstly, AgForce supports the highest protections being applied for the safety of primary producers and that the requirements imposed are proportionate to any risk, or increase in risk, that the production and distribution of hydrogen and other gases represents. Any amendments must ensure this outcome is secured.
03 April 2023
Department of Energy and Public Works
C/- Hydrogen Queensland
By email: haveyoursayhydrogenqld@epw.qld.gov.au haveyoursayhydrogenqld@epw.qld.gov.au
To whom it may concern,
AgForce is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool and goat producers. The cane, beef, broadacre cropping and sheep, wool and goat industries in Queensland generated around $10.4 billion in on-farm value of production in 2021-22. AgForce’s purpose is to advance sustainable agribusiness and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,500 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
AgForce appreciated the briefing provided by Departmental officials on 17 March 2023 and welcomes the opportunity to provide comment to proposed amendments of the following Acts:
The Gas Supply Act 2003 (GS Act) and the Petroleum and Gas (Production and Safety) Act 2004 (P&G Act), Geothermal Energy Act 2010 (the Geothermal Act) and Greenhouse Gas Storage Act 2009 (GHG storage Act) and other legislation (Hydrogen Industry Development) Amendment Bill 2023 (the Bill).
From the Departmental briefing AgForce understands that the amendments are part of the government’s commitment to the development of a new hydrogen industry within the state, and to facilitate it through expanding the remit of these Acts to accommodate the new gas production.
AgForce’s interests in the amendments relate to potential implications for our members, other primary producers and for the continuation and growth of agriculture in the state. This includes not infringing on land holder rights, delivering real protection for prime agricultural land, and maintaining land and water access for farmers to maintain viable businesses.
Firstly, AgForce supports the highest protections being applied for the safety of primary producers and that the requirements imposed are proportionate to any risk, or increase in risk, that the production and distribution of hydrogen and other gases represents. Any amendments must ensure this outcome is secured.
Further, we understand from the Departmental briefing that environmental approval, regional interest development approval (RIDA) and native title processes will apply, as will existing land access and easement requirements. AgForce has recently raised several concerns with the existing land access system, including the RIDA process, within a submission to the Resource Industry Development Plan Coexistence discussion paper1. That submission is attached to this letter and should be reviewed, and the issues raised within it addressed as a matter of urgency and incorporated within the policies that apply to any new alternate use of agricultural land and water assets, including hydrogen.
We support the avoidance firstly, and then the minimisation of any unavoidable impacts, on primary producers, including in relation to development footprints, such as easements and alternate tenures. Included in this impact avoidance should be the use of existing infrastructure or pipeline corridors and of state-owned land wherever possible, in preference to resumptions or impacts on privately owned or held land. This should be included in the policies applying to an new H industry expansion.
Covered Gas, Fuel Gas, Hydrogen Gas Blends and forms of transported regulated hydrogen.
AgForce seeks further engagement as it relates to future changes to Regulated Hydrogen and type of Covered Gas for the distribution authority; Access, exporting, licensing, liquification transmission and emergency powers and perform works, or changes to the person’s installation for a covered gas, necessary to allow connection of the distributor’s meter to measure consumption of the covered gas.
AgForce is cautious in regard to legislation changes to distribution, distribution officers (monitoring/observer of works rules), WHS, water access/allocation rules that favour hydrogen over farmer’s productivity.
We recognize hydrogen is an invisible flame over blue flame, we favour an amendment to the code of practice that enhanced support for new operating environment, suitably trained distribution officers or asset protection officers for public works, and land holders adequately informed should they be affected by transmission lines and distribution systems, beyond safe zones.
AgForce welcomes the opportunity to further collaborate with stakeholders, before any legislative changes occur that may affect environmental authority, native title, water entitlement pricing or water planning, land access codes or Acts that may inhibit farm production over hydrogen production and distribution.
If you have any questions or require further information regarding this matter, please contact Sam Forzisi, AgForce Policy Director, by email (forzisi@agforceqld.org.au) or mobile (0499 960 006).
Yours faithfully
Michael Guerin
Chief Executive Officer
Enc. GG23006_QRIDP_Coexistence Discussion Paper
1 Foster coexistence and sustainable communities | Queensland Resources Industry Development Plan