Ref: MG/AF/GG24043
10 June 2024
GasFields Commission Queensland
53 Albert Street
BRISBANE CITY QLD 4000
By Email: Marcus.rees@gfcq.org.au
Dear Mr Rees
Gasfields Commission Queensland Expanded Remit to Coexistence Queensland
Thank you for the opportunity to provide comment on the proposed expanded remit of the GasFields Commission into Coexistence Queensland.
AgForce Queensland Farmers Limited (AgForce) is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & 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 6,000 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 has a strong policy position on representing members’ interests in the protection of land use and is supportive of efforts by all authorities, at federal, state and local levels, that enable the effective coexistence of agriculture with other forms of land use. Please see Appendix 1 where the Land Use Protection Principles of AgForce members, as endorsed by the AgForce Board, are presented as an overall expectation of what broadacre agricultural industry commits to when seeking coexistence with other sectors.
Facilitating Better Relationships
AgForce sees that in many regards the social licence of the GasFields Commission (GFCQ) has been eroded and Coexistence Queensland will need to ‘out-perform’ the GFCQ in their expanded role. This will be challenging with the differing legislation and regulations surrounding renewable energy projects compared to
coal seam gas. AgForce sees that sustainable coexistence must be the overriding principle of Coexistence Queensland (CQ) in order for CQ to adequately perform its functions.
Central Point of Contact
In terms of channels used to ensure CQ is an accessible and responsive point of contact, it should be acknowledged that landholders are not always in range of reception during the day.
A chatbox with a call-back system used to describe a situation the landholder wishes to discuss with an option to leave a number and time for a scheduled call back could facilitate easier communication.
AgForce would also like to see CQ implement a triage function within its operation as some enquiries will be of a more urgent nature than others. CQ staff will need to be able to interact with different government departments in order to suitably resolve/refer enquiries. It is vital that CQ is able to advocate/relay
information to government in order to ensure a complaint is also appropriately and adequately dealt with.
Advice
Whilst AgForce agrees there is a need for an advisory role within CQ and with all due respect, the government are not legal specialists trained to offer specific advice. Nonetheless, AgForce sees that broad advice from CQ would benefit landholders in navigating information gaps.
Whilst AgForce appreciates that CQ is to advise all stakeholders, not just landholders, there is a need for landholders to be informed of all impacts of renewable/gas projects, at least in a broad sense.
Some of the issues that AgForce sees that are often overlooked, or ‘swept under the carpet’ are outlined below:
Landholders should be reminded that generally they have the right to ‘say no’ to developers looking to access their properties for electricity generation/storage projects such as wind farms, solar farms and battery storage facilities.
Landholders should be told of the differences between allowing access to renewable developers in comparison to gas project proponents.
Encouragement to developers that compulsory acquisition powers should be used as a last resort, otherwise the social licence of the industry will be lost quickly;
Landholders should be ‘warned’ of areas of law that are lacking in regard to renewable projects, such as decommissioning clauses within contracts for compensation to host landholders of wind farms, allowing them to seek more personalised and specific advice from solicitors.
Neighbours of host landholders to renewable or gas projects should be able to access objective data/analysis and a right for their concerns in relation to any neighbouring projects to be heard.
AgForce sees that to develop a better social licence there needs to be transparent information regarding the impacts during both construction and maintenance phases of CSG and renewables.
Recognition by developers/proponents that coexistence cannot effectively occur everywhere – some areas of intensively used farmland, or of specific agricultural land uses, or of endangered or fragile ecosystems may be impacted to such a degree that the precautionary principle should be applied and so resource or other alternate activities do not proceed on that land.
Information and Education Services
It must be said at the outset that AgForce remains sceptical of government bodies funded to ‘educate’ landholders about the ‘benefits of coexistence’. In saying that, AgForce does hold aspirations that Coexistence Queensland will be able to outperform the GasFields Commission and support the efforts of Coexistence
Queensland to obtain feedback from stakeholders from the outset.
It is essential in the provision of information and education that Coexistence Queensland remain a neutral party in relation to the varying interests of competing land uses and not become involved in the promotion of any one sector.
AgForce believes that the below could be useful tools to deliver effective and digestible information to landholders and communities:
Links on Coexistence Queensland’s website to toolkits, like QFF’s Renewable Energy Landholder Toolkit.
Fact Sheets available to download in PDF form.
Information sessions in areas where CSG/renewable projects are proposed.
Information about high value agricultural land should also be communicated to proponents/developers.
Partnering on Research and Engagement
AgForce sees that the below areas would be valuable for Coexistence Queensland to pursue in collaboration with relevant stakeholders:
Research on human and animal health from the effects of wind turbines.
Research on the effects of sediment run off from lack of ground cover under solar panels.
Continued research into subsidence issues, contamination of groundwater etc, from CSG.
To address health and wellbeing concerns from resource activities, AgForce sees that visitation days from an organisation such as Beyond Blue would be beneficial to landholders. AgForce would suggest that these days occur without the presence of developers/proponents.
Training for developer/proponent staff/contractors should also be a priority as this will ensure landholders are communicated with in a sensitive matter, thus encouraging better relationships.
Lessons Learned from the Development of the Gas Industry
AgForce strongly advocated that it must be at the forefront of CQ’s process to facilitate better coexistence that landholders are the biggest stakeholder in these coexistence arrangements. Landholders have felt that their entitlement to enjoy and use the land which they either own as freehold, or lease, is
worthless in the eyes of the gas industry. Better appreciation that these projects are being built on someone’s land, not just vacant land, is needed. With increased understanding of this the social licence of gas and renewables can be improved.
Key Challenges and Opportunities in Managing Coexistence in a Rapidly Transforming Energy Landscape
AgForce sees that the key challenges in managing coexistence include preserving high-value agricultural land so that Australia’s food supply is not jeopardised by the increasing push to move to renewable energies. It must be remembered that often land cannot be rehabilitated to its original state.
AgForce thanks GFCQ for the opportunity to provide feedback and looks forward to continued engagement to better practices for all stakeholders involved.
If you have any questions or require further information please contact Anna Fiskbek, Policy Advisor, by email: fiskbeka@agforceqld.org.au or mobile: 0407 813 470.
Yours sincerely
Michael Guerin – Chief Executive Officer
APPENDICES
Appendix 1: AgForce Land use Protection Principles
As the body for agriculture, AgForce requires that alternative and potentially impacting land uses ensure:
1. There is recognition that natural capital has an inherent value
2. Human health and well-being must not be sacrificed
3. A precautionary approach that avoids negative legacy effects on natural resources including air, soil, water and biodiversity
4. There are no negative impacts on existing or future sustainable agricultural opportunities
Before:
• Recognize that resources are finite
• All projects are assessed on environmental, social and economic criteria
• There is a formal mechanism for agriculture to be involved in assessment
• Projects should not be assessed in isolation and cumulative impacts assessed
• Potential impacts need to be objectively, and accurately quantified rigorously and independently reviewed
• Agricultural landholders to have equal representation, available resources and bargaining power
During:
• All projects must have comprehensive monitoring and transparent reporting
• Non-compliance will trigger cease work
• Enforcement is primarily the responsibility of government, but landholders must have a right to compel action
• Industry and Government must proactively identify and manage cumulative impacts, both individual project cumulative impacts and multiple projects cumulative impacts
After:
• Land needs to be rehabilitated to be the pre-existing natural conditions
• Financial assurance needs to be adequate for rehabilitation
See: https://www.agforceqld.org.au/knowledgebase/article/AGF-01250/
Neighbours of host landholders to renewable or gas projects
should be able to access objective data/analysis and a right for their concerns
in relation to any neighbouring projects to be heard.
Recognition by developers/proponents that coexistence cannot
effectively occur everywhere – some areas of intensively used farmland, or of
specific agricultural land uses, or of endangered or fragile ecosystems may be
impacted to such a degree that the precautionary principle should be applied
and so resource or other alternate activities do not proceed on that land.