Views:

Ref:  MG/AF/GG25000

5 February 2025

Department of Energy and Climate

By Email: renewablesframework@epw.qld.gov.au

 

Dear Sir/Madam

Re:  Feedback to the Draft Renewables Regulatory Framework

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, AgForce’s Land Use Protection Principles, as endorsed by the AgForce Board. These principles present an overall expectation of what the broadacre agricultural industry expects, when negotiating partnerships with the coexistence sectors.

Thank you for the opportunity to provide comment on the Draft Renewables Regulatory Framework.

AgForce has not made comment on all sections of this consultation paper but has made comment on the below.

1.           ENHANCED ENVIRONMENTAL OUTCOMES

1.1        Improving Environmental Assessments and Compliance

Updating the wind code to strengthen protections for communities and the environment

AgForce supports updates to strengthen State Code 23:  Wind Farm Development and its associated Planning Guidance.  AgForce provided a submission to the Wind Farm Code in September 20231 and would reiterate the points made:

Including:

Noise Policy:

  • Wind farms should be subject to the Environmental ProtectionAct 1994 (EP Act)/Environmental Protection (Noise) Policy 2019.
  • That a maximum of 30 dB(A) indoors (with windows open) be the permissible nighttime noise limit averaged over 10-minute intervals as to obtain an accurate average measurement.
  • Ongoing requirement of noise compliance monitoring, recording and reporting.
  • The low frequency noise and infrasound should be assessed as part of the wind farm assessment.
  • An adequate buffer distance between a ‘sensitive land use’2  (i.e. residential dwellings) that reflects the size of current wind turbines should be included in the guidelines based upon advice from a more appropriate and impartial acoustician. Dr David presented a paper to the 20th International Congress on Sound and Vibration held 7-11 July 2013, titled ‘An Underpinning Methodology To Derive Stand-Off Distances From A Wind Farm’, on this issue.
  • A review by an independent acoustician should be obtained to inform the guidelines.
  • Further research as to the effects on livestock be conducted to allow for adequate and appropriate compensation on impacted businesses.
  • Cumulative noise should be considered when further turbines are built on an existing wind farm.
  • The concept of wind masking should not be used in the Code.
  • AgForce has received information from Les Huson, acoustician, who recommends that the acoustic assessment should be performed on acoustically hard ground, as is the preferred method in South Australia and New South Wales.
  • Ultimately, wind farms should achieve the objectives set out in the Environment Protection (Noise) Policy 2019.

Decommissioning:

  • It is mandatory for the proponent/developer to commence funding a decommissioning trust fund from the project’s commencement, as it would be easier to obtain significant funding earlier on in the project life.
  • Developer to organise for a bank guarantee, sinking fund, trust fund or a security bond deposit to be held by the landowner throughout the life of the project, so that landholders can have confidence that funds are being put aside by the proponent/developer.
  • Clarity that any agreement between the original proponent/developer will be carried over to be an agreement between the landholder and any new company that buys the project.

AgForce notes that analogous requirements exist in Queensland’s mining industry legislation, the EP Act and federally in the offshore mining space, hence we see no reason that the same requirements cannot also be implemented in the renewable energy sector.

Conducting Phase Two of the Planning Framework for Renewables

AgForce supports further review of the planning framework for renewables and urges the government to provide consistency in the assessment pathways for renewable energy projects. AgForce would see that an impact assessable approach is the most suitable as to allow for rigorous assessment against current planning frameworks and allows for public notification and public comment.  Greater transparency will foster better trust and social licence in host communities.

AgForce also urges the government to ensure food production is protected through the planning framework by preserving productive agricultural land.  What is considered productive agricultural land should include both farming and grazing properties in regions which are seasonally reliable.  AgForce would like to see this be a consideration within the planning and approval framework. 

Exploring an Expanded Role of the State Environment Agency

AgForce supports bioregional planning from DETSI; but would like to receive greater detail on the expanded role of the State Environment Agency regarding renewables as part of the regulatory framework.

1.2        Focusing on Outcomes and Strategic Planning

Undertaking proactive planning and investigating strategic advanced offsets in Renewable Energy Zones (REZ)

AgForce has concerns with the proposal to co-locate energy projects with carbon and nature repair market projects. We would like to seek clarification as to whether this proposal is intending to have renewable energy projects located on land that is hosting an existing carbon and nature repair project concurrently, or whether the proposal is to turn the project site into a carbon or nature repair market project after decommissioning as part of the rehabilitation of the land. AgForce has concerns with simply locking up land as part of the project offset. This will cause significant consequences, including biosecurity risks as large amounts of unmanaged land provide habitat for feral animals to breed and weeds to spread as well as creating a significant bushfire risk as the grass will not be managed from grazing or crop production.

Continuing bioregional planning to achieve better overall environmental outcomes and faster decisions for business

AgForce supports the continuation of bioregional planning as to allow for sustainable long-term use of productive agricultural land.

Exploring other pathways for enhancing environmental outcomes

AgForce has concerns with environmental outcomes being informed solely by environmental stakeholders and seeks a commitment that broadacre agriculture will continue to be consulted on environmental outcomes to ensure agricultural production protection in the long term.

1.3 Fostering a Circular Economy

AgForce supports sustainable recycling of renewables such as solar panels and wind turbines. However, given the cost and the energy required to recycle solar panels, and the fact that the composite material that makes up a wind turbine is not usually recyclable, AgForce is concerned about the economics to recycle, and the practicality that suitable recycling options will be developed.

2. EFFECTIVE COMMUNITY PARTICIPATION

Code of Conduct

AgForce supports the creation of a mandatory Code of Conduct for renewable energy developers and hopes to be able to provide input into the development of the Code to ensure mitigation of impacts on host and neighbouring landholders and host communities.

Leaders Council through Coexistence Queensland

AgForce has queries as to the composition of a Community Leaders’ Council.  AgForce strongly encourages the Department to include local landholders, local government and other relevant entities to be involved in the Leaders’ Council to ensure that local perspectives are paramount and allows local government and relevant entities to be involved.

2.2 Ensuring Local Benefits for Host Communities

AgForce agrees with the need to set clear minimum standards for community benefits and developing new models for delivery of a positive community legacy.

Setting clear minimum standards for community benefits

AgForce supports setting an expected minimum contribution for community benefits and the requirement for public reporting of contributions and outcomes under the statutory Code of Conduct.

Developing new models for delivering positive community legacy

AgForce has concerns regarding community investment in renewable energy projects.  Whilst we approve of the aspect of creating profit sharing arrangements for communities, we are concerned with the potential liability issues that may arise from these investments, particularly regarding decommissioning. If a community holds shares in a project but the energy developer falls into insolvency, where would this leave the community regarding liability for either decommissioning or re-commissioning the project?

Expanding regional internet access with Powerlink SuperGrid Telecommunications Program

Whilst AgForce supports better access to the internet in regional areas via the joint initiative between Powerlink and Queensland Capacity Network, we also make the comment that internet and mobile coverage should be something that can be accessed regardless of whether residents are within a REZ. Telstra and the Federal Government should be taking better initiative of this. 

Project planning should consider the adverse impact on landholders and the community when a large influx of construction workers (generally all of whom have a private phone in addition to a work phone) start in areas where mobile networks are already over-capacity.

Continuing to roll out the Local Energy Partnership Program

AgForce agrees that partnerships are important for coexistence so that all stakeholders can provide input for their relevant industry.  AgForce will continue to advocate for the benefit of Queensland’s primary producers and Australian agriculture to ensure food security for a growing global population, ensuring accountability for all groups and organisations that assist the government with the Local Energy Partnerships framework. 

3. EASY ACCESS TO INFORMATION

Improving transparency of renewable energy pipeline

AgForce supports the investment into a notification scheme for renewable energy projects as well as the exploration of a need for a comprehensive online portal with project mapping.

3.2 Empowering Communities and Local Government

What Guidance Community may need to engage with renewable energy developers

Community and landholders (including host and neighbouring) should be aware of possible detrimental issues that could occur as a consequence of hosting renewable energy projects, so they are able to draw their attention to these issues during negotiation processes. Such issues include but are not limited to:

  • Legal;
  • Workplace health and safety;
  • Livestock health;
  • Biosecurity management;
  • Taxation implications;
  • Re-classification of land use from primary production status, thus also causing increase in rates;
  • Potential loss of equity in property; and
  • Issues with LPA accreditation.

Communities should also be able to easily access information regarding the extent of the size of a particular project and which access/freight routes are allowed to be used to get infrastructure to the project site.

AgForce would also urge the government to consider creating roles within government departments for field and compliance officers to monitor the work and progress of developers, as member feedback indicates they are not confident that planning conditions are always followed.

3.3 Supporting Independent Trusted Information

Supporting independent analysis of emerging issues in the energy transformation

AgForce supports independent analysis of emerging issues however, we would caution against repression bias, where information/research is restricted to only that which the development promoters (government/industry) view as promoting the industry. AgForce would like to see a truly independent analysis where the true ‘pitfalls’ of renewables are also explored and reported on as to ensure landholders are making fully informed decisions regarding hosting projects, but also information to the general public as to cost of power and power reliability.

Exploring ways to increase energy literacy and education

AgForce would advocate that the proposed forums should highlight potential negatives and consequences for host and neighbouring landholders.  The forums should not be used as part of a scheme to help ‘sell’ the idea of renewable projects to landholders.  AgForce also has concerns about use of terminology including ‘local champions’ and ‘myth-busting’ which conveys diminishment of genuine stakeholder concerns rather than reliance on outcome of balanced and proper scientific research and investigation.

4. ENDURING LANDHOLDER PROTECTIONS

Supporting landholders with a toolkit, information telephone service and website

AgForce supports the utilisation of a toolkit, information, telephone services and a website however, we fear that there will be a duplication of resources from differing departments and bodies which can lead to conflicting information being provided.

SuperGrid Landholder Payment Framework

AgForce supports the SuperGrid Landholder Payment Framework and endorses the property-specific approach as opposed to the flat rate method.  AgForce strongly encourages Powerlink to engage with landholders as to the extent certain activities/infrastructures can cause impacts/damage to landholder’s land and businesses. AgForce would also expect the framework is regularly reviewed to ensure the framework provides appropriate compensation. 

Investigating a Statutory Land Access Code for Transmission Providers

AgForce supports the need for investigating a land access code for transmission providers.  AgForce reiterates QFF’s position regarding heightened biosecurity risks and issues with the increase in development activity on page 13 of their submission:

“Biosecurity remains a key concern for the agriculture sector and continued food and fibre security. Heightened risks have been forecast due to the increased development activity planned for many regional communities and additional pressures of climate change. Biosecurity requirements must be adhered to by renewable energy developers and transmission businesses at a farm, regional, state and federal level. Those who are contributing to the increased risk should also contribute to managing/mitigating this risk. Other implementation considerations include how to ensure land access protocols are adhered by all farm visitors, including subcontractors and consultants; as well as what happens if parties move on, how is that knowledge transferred. What will be the consequences if developers/utility providers continue to display poor practice?”3

Investigating a requirement for financial support to landholders to access advice

AgForce supports the investigation for a requirement for financial support to landholders (both host and neighbouring landholders) to access advice.  AgForce sees that landholders are often at an un-even playing field from the onset, particularly as the project proponents will have in-house Counsel and also the ability to brief out to top tier firms.  Landholders should also be aware of not just legal services, but also other professional services such as agribusinesses accountants, property valuers, agribusiness insurance, agronomists, etc that may provide other relevant expert advice. Landholders, whilst businesspeople, should not be led to believe that they are capable in negotiating by  themselves with renewable proponents.

Exploring the need to develop model contracts for landholder agreements

AgForce has reservations about developing model contracts as we see that standard contracts could be relied upon and inadvertently take away from the individual landholder to negotiate for what is best for their business.  All landholders’ businesses are unique to their commodity, relevant market, land type and location and they require independent advice from appropriately qualified experts.

AgForce would recommend a list of key issues that arise consistently for them to consider during their negotiations. QFF’s landholder toolkit also expands on this list.

There should also be a focus on informing neighbouring landholders, who may still suffer impacts from projects, but are not hosts to the projects, of their rights to compensation.

4.2 Creating Clear Escalation Pathways

Working with the Commonwealth Government to support greater coordination

AgForce agrees with the Australian Energy Infrastructure Commissioner’s recommendation for a developer rating scheme to provide transparency over developer performance and capability.

Investigating the expansion of the Ombudsman to include complaint pathways for large-scale renewable energy

AgForce members are often disgruntled with the way project proponents respond to complaints, particularly regarding the transparency of information provided.  Many landholders are uncertain as to where they can turn to for complaints. AgForce queries whether the Energy & Water Ombudsman Queensland (EWOQ) has the capacity to expand its remit into renewable energy projects and if not, resources need to be allocated to the EWOQ. AgForce regularly receives feedback that its members are unaware of the jurisdiction of Coexistence Queensland (CQ), particularly, those who have not previously dealt with what was previously the GasFields Commission.  In light of this, AgForce would recommend that there is material published that clearly defines the jurisdiction of CQ and EWOQ. 

AgForce seeks an improved understanding as to whether decisions of the EWOQ would be binding should their remit be expanded?

4.3 ENFORCING COMPREHENSIVE END-OF-LIFE PLANNING AND PROTECTIONS

Exploring New Requirements for Life Cycle Planning for renewable energy developers

AgForce supports and echoes QFF’s submission on pages 14-15 regarding end-of-life cycle planning.4 
 

“QFF recommends that adequate, consultative planning be done to understand the issues and mitigations for each project phase so that sufficient preparation can be done. Additionally, sufficient scope and ability is needed to respond quickly to unforeseen issues that arise during each phase. The risk of unintended end of life risks cannot be left to sit with individual farmers.

  •  Initiation and feasibility: Project location, scale, connectivity and likely impacts need to be well understood and planned for using feedback from all stakeholders, who offer relevant feedback on local issues and concerns. Appropriate planning approvals must be in place before a project proceeds.
  • Construction periods: can cause significant disruptions for landholders and the broader community and must be managed to ensure the liveability and capacity for existing industries to conduct business as usual is maintained or adequately compensated. Consideration should be given to offsetting negative impacts or disruption, and regulation and enforcement of poor practise and or non-compliance.
  • Maintenance stages: need to be incorporated into all future planning from a community and landholder impact perspective. Issues such as long-term weed and pest management around energy infrastructure corridors are critical. The future use of herbicides etc. that may impact on neighbouring farmland as well as corridors becoming illegal land access points increasing the threat of trespassing for neighbouring properties, pathogen transmission, illegal dumping, must also be managed.
  •  Decommissioning: (see section below)”

Investigating models to provide financial assurance for end-of-life activities for renewable energy projects

AgForce reiterates our comments made in our previous submission to the State Code 23: 

‘The Australian Energy Infrastructure Commissioner has referred to the event where the project owner defaults on the agreed conditions which therefore results in the liability for decommissioning the project falling to the landholder.5 Under section 73 of the Planning Act, the development approval binds the original owner of the premises, the owners’ successors in title and any occupier of the premises.  The ramifications of such an occurrence are manifold.  The AEIC has also highlighted that the project operator may sell the project to another company over the course of the life of the project, which could easily result in the arrangement to fund the decommissioning being lost and the
enforceability of the agreement being eroded over time. There is nothing in the Planning Act to provide for the development approval to bind the wind farm proponent/developer once it transfers the wind farm, or the successors in title to the wind farm or the holding company of the proponent. Often the wind farm proponent/developer is a $2 subsidiary of a publicly listed company with no resources to fulfill the conditions – particularly the decommissioning condition.’

‘The AEIC website states that the cost to decommission each wind turbine ranges from $400,000- $600,000, depending on the size of the turbine.6 This cost could increase vastly if there are structural failures or is unstable, where the AEIC states it could cost millions to remove each turbine from the project site. Concerningly, if the cost to decommission the wind farm did fall upon the landholder, there would likely be no avenue for the landholder to recover the costs of decommissioning the project as they would not have ownership over the project’s assets. AgForce sees that if such a cost was put onto the landholder that this would be overly burdensome and almost impossible to undertake in some circumstances.  Plainly, it is completely unacceptable that this is even a possibility with the current guidelines.’

AgForce would recommend a similar scheme to the Queensland resource sector’s Financial Provisioning Scheme be implemented and that bank guarantees that cover the cost of decommissioning be established as a requirement of the approval for the project.

AgForce would also suggest a bank guarantee or bond scheme also be put in place for other types of renewable energy projects. 

4.4 Undertaking Strategic Land Use Planning

Supporting sustainable development through Regional Plans

The Australian definition of ecologically sustainable development is in our National Policy.7 To meet this definition of ecologically sustainable development, Regional Plans need to consider that not all land in Queensland is suitable for farming or efficient grazing.  Planning frameworks need to consider that renewable energy projects compete for land use, they do not perfectly coexist with farming, grazing, horticulture, etc, operations.  It must be considered that more fertile areas of land should not be considered for hosting renewable energy projects, they should be limited to areas of less productivity and areas where seasons are not as reliable.  The ability for Queensland to produce food and fibre needs to be protected through Regional Plans. 

Conducting early cumulative impact analysis in REZ planning

AgForce supports the conduction of early cumulative impact analysis for REZ planning.  AgForce supports and reiterates QFF’s comments in their September 2023 Submission on Queensland Renewable Energy Zone (REZ) Roadmap, which they also summarised within their submission to the Renewables Regulatory Framework below:

  • "Cumulative impacts - There needs to be an understanding and recognition that not all project and offset impacts are the same across different communities and the potentially cumulative effect must be taken into account and forward planned for.  This needs to include not only farmland, but the associated processing facilities such as sugar mills, cotton gins, etc.  Community and industry benefit sharing requires a deep understanding of each community’s priorities and a one size fits all approach will not achieve the best outcomes.
  • Biosecurity – increased risks are forecast largely due to the increased development activity planned for many regional communities. Biosecurity requirements must be adhered to by developers at a farm, regional, state and federal level but it is also reasonable to expect that those who are contributing to the increased risk also contribute to managing/mitigating this risk. Biosecurity is a shared responsibility and costs must also be shared. Developers should be held to account by a national biosecurity code outlining the minimum standards that must be adhered to. QFF has been involved in the working group to develop the Queensland Renewable Energy Council’s (QREC)-led Renewable Energy Industry Biosecurity Guide to ensure these considerations are well understood by the renewable energy sector.
  • Local bushfire risk management – developers must be aware of, participate in and contribute to the bushfire resilience, preparedness, and response capacity of the community in which they operate. Road infrastructure and competition for police escorts - increased demands on road networks and associated services required in transporting energy infrastructure components are likely to impact existing industries and communities more broadly. These impacts must be understood, managed, and mitigated so as to ensure business as usual for the community. Regional road capacity and considerations must be understood and included in proper assessments up front. For example, the cane train network in Queensland is specific to the Queensland canegrower region, an existing and important operational factor for the sugar industry which must be considered in any changes or additions to freight movements that take place in that area. Any increased activity must not impact the operations of the cane train and the sugar industry’s ability to continue business as usual. The culminative impact on road networks and services (eg, wide load escorts) must be considered and included in AEIC Community Engagement Review | Australian Energy Infrastructure Commissioner | Oct 2023 5 pre-development assessments, not post, with the opportunity for those areas with transport  limitations/barriers that are too great or culminative impacts cannot be managed / mitigated, to rule out potential developments.
  • Water – Industry is interested and concerned about the impact of renewable energy projects (particularly pumped hydro schemes) on water supply schemes in the proposed pumped hydro areas. Building new storages for pumped hydro relies on modelling of water storage capacity, rainfall, retention and evaporation. The feedback from our industry members is that the hydrological modelling needs to adequately predict evaporation and other potential losses and conservatively manage for the potential losses from the existing water management systems, to avoid potential impacts on downstream water supply users.”8

4.5 Supporting Sustainable Practices for Coexistence

Exploring Agrivoltaics for Queensland landscape

AgForce is supportive of greater discussion to better understand agrivoltaics however, if there were to be any issues with contamination found in meat products that has resulted from the renewable energy project, the landholder must be compensated for the loss of income not only for the animals found to have contaminants but also for any disruption caused to future sales as a flow on effect.

Investigating tax implications for renewables on farm

AgForce supports the need to investigate and clarify issues relating to taxation consequences to the landholder, from how compensation and/or income and decommissioning costs, are incurred from renewable energy projects and how project infrastructure is assessed by the Australian Taxation Office. 

5 EFFICIENT INDUSTRY FACILITATION

5.1 Streamlining Processes and Facilitation

Investigating the need for greater industry facilitation

AgForce sees that there is a need for greater cohesion within the planning and assessment framework. AgForce supports the Coordinator-General providing advice on the most efficient assessment pathway as this provides certainty to communities regarding whether the project will go ahead and to what extent. AgForce sees that this is often a concern for communities as they do not know the extent of projects which can result in a loss of trust and reduced social licence for development companies. The lack of regulatory oversight has meant that community and landholder consultation has not been carried out to a satisfactory level, which has resulted in communities feeling betrayed and
ignored by developers.

AgForce supports the consideration of strengthening the Coordinator-General’s role to bridge regulatory gaps, emphasising that allowing smaller projects to utilise existing pathways for assessment may continue to lead to unsatisfactory outcomes for communities. AgForce would support a new framework where all projects are assessed at State Government level, rather than having some projects being assessed at local government level and some at State level, creating lack of consistency between approval processes.

However, AgForce does have concerns with the ability for the Coordinator-General to exercise their power under the State Development and Public Works Organisation Act 1971 (SDPWO Act). AgForce sees fit that landholders have the reassurance that the Coordinator-General will not exercise their compulsory acquisition powers for
renewable energy projects, particularly given that most projects are privately owned.  Hosting a renewable energy project should remain completely optional and discretionary to landholders.

5.2 Driving Investment Confidence through Greater Certainty

Proactively considering enabling infrastructure in REZs

AgForce sees that there is a need for greater coordination within REZs.  AgForce also supports and would like to reiterate QFF’s response to the Queensland Renewable Energy Zone Roadmap September 2023, page 10,9  which details the need for greater coordination within REZs.

Update the Infrastructure Blueprint and REZ Roadmap

AgForce supports the biannual review and update of the Supergrid Infrastructure Blueprint.  AgForce would also like to see Queensland Energy System Advisory Board have the ability to provide advice to communities. AgForce would also like to better understand the composition of the QESAB.

5.3 Building Industry Partnerships for the Future

Continuing to deliver on industry partnerships with peak bodies

AgForce supports industry partnership with peak bodies.

AgForce supports the Clean Energy Council (CEC) providing industry training on social licence as we see this as a major pitfall of the renewable energy sector.

AgForce thanks the Department for Energy & Climate 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

 

1https://www.agforceqld.org.au/knowledgebase/article/AGF-01846/#:~:text=However%2C%20under%20Code%2023%20the,noise%20plus%205dB(A)style='font-size:9.0pt;line-height:107%;font-family:"Calibri",sans-serif'>.

2Planning guideline State code 23: Wind farm development

3https://www.qff.org.au/wp-content/uploads/2025/01/20250110-QFF-submission-to-Queensland-Treasury-Draft-Renewables-Regulatory-Framework-WEB.pdf

4https://www.qff.org.au/wp-content/uploads/2025/01/20250110-QFF-submission-to-Queensland-Treasury-Draft-Renewables-Regulatory-Framework-WEB.pdf

5https://www.aeic.gov.au/observations-and-recommendations/chapter-1-host-landowner-negotiations

6https://www.aeic.gov.au/observations-and-recommendations/chapter-1-host-landowner-negotiations

7https://documents.parliament.qld.gov.au/TableOffice/TabledPapers/2016/5516T2036.pdf

8https://www.qff.org.au/wp-content/uploads/2025/01/20250110-QFF-submission-to-Queensland-Treasury-Draft-Renewables-Regulatory-Framework-WEB.pdf

9https://www.qff.org.au/wp-content/uploads/2023/09/20230925-QFF-Submission-to-DEPW-Qld-Renewable-Energy-Zone-Roadmap-WEB.pdf


 

 

Keywords: Submission, Renewables, Regulatory, Framework