Views:
Ref: MG/DC

05 January 2023

Climate Policy Branch,
Department of Agriculture, Fisheries & Forestry (DAFF)


By Email: climate.consultation@aff.gov.au

Re: Agriculture, land and emissions Discussion Paper

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 6,500 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 welcomes the opportunity to participate in the consultation process regarding the development of the Land and Agricultural Sector Plan.  We commend the team on its exploratory and consultative initiation to the beginning of this process.  This collaborative approach will be essential throughout all steps on the development of this sector’s net-zero 2050 plan to ensure an effective, equitable result is obtained. 
In this submission we have provided comments regarding common themes identified amongst the 11 response questions that we find are of note and/or concern to our members. 

Introduction
AgForce recognises that environmental change and variability pose significant challenges to Australian producers, and also creates opportunity for innovation in farming practices.[1]   We acknowledge that the Queensland and broader Australian Agricultural sector is at the beginning of a monumental undertaking requiring a solid plan to navigate the complex and multifaceted challenges of the journey to net-zero 2050. Embracing this transition holds tremendous potential for environmental stewardship, sustainable resource management, and long-term prosperity for the sector. However, achieving these ambitious goals necessitates forging a path that balances environmental responsibility with the critical need for uninterrupted food and fibre production.

A significant initial concern regarding widespread adoption of climate-smart practices within the rural community stems from a perceived sentiment of "fait accompli." Supra-national groups and NGOs are sometimes viewed as seeking to impose restrictions and legislation as a means of controlling or curtailing agricultural activity. This perception poses a serious obstacle to collaboration and progress.  It results in a nagging concern from producers that every new commitment to meet may have an element, not of good environmental stewardship, but incremental slow progress to agricultural restrictions.  To successfully navigate this sentiment and drive genuine buy-in, the government must actively engage with the agricultural industry, fostering a spirit of partnership and shared responsibility.

To achieve this vital partnership, the sector plan must address two key concerns head-on:
  1. Prioritising Food Security: While pursuing ambitious climate targets is paramount, any potential conflict with food security must be swiftly addressed. The sector plan must explicitly acknowledge the inherent tension that may arise between these objectives and provide a clear assurance that, if necessary, food production will not be compromised on the altar of net-zero emission/climate goals.  The UN lists Zero Hunger (Food Security) as #2 of its 17 Sustainable Development Goals[2]. Industry is committed to trying to achieve this balance between food security and climate sustainability but needs the sector plan, the department and government to stand with industry, not against it.  This commitment will alleviate anxieties within the rural community and incentivise participation and uptake in sustainable practices.  In addition, environmental offsets are likely to be among the mechanisms for achieving Government ambitions and the national 2050 net-zero target. AgForce asserts that offsets must not come at the detriment of prime agricultural land. Government has a clear responsibility to support the primary role of agriculture: the provision of high quality, ethically produced food and fibre. Locking away productive land from farmers must not be up for consideration as part of the solution to meeting economy-wide emissions targets.
  2. Collaboration, Not Dictation: Building a successful transition requires genuine partnership, not unilateral impositions. The sector plan must be developed with, not for, the agricultural industry.  AgForce welcomes and commends the approach being taken in the initialisation of the sector plan as a collaborative step in the right direction.  As Queensland’s State Farming Organisation (SFO) representing the interests of Queensland’s broadacre primary producers, we look forward to working with the department to assist with development of robust, sound policy and acting as a conduit between government and producers to maintain clear, honest communications.
AgForce would urge Government to work closely with industry leaders to promote critical improvements in emissions accounting, particularly around carbon sequestration and the ability to reconcile carbon sinks against the emissions profile of farms. Corporate agriculture in Australia is providing world-class thought leadership and pioneering approaches that recognise both emissions and sinks. Fine-tuning accounting pathways for emissions is critical to accurately representing and reporting on the agricultural sector.
It is a reality, that based on the recent DCCEEW ‘Emissions Projection 2023 Report’[3], the agricultural sector will not reach net-zero by 2050.  Under this frame, AgForce stands by the National Farmers Federation position: ‘we support an economy-wide aspiration of net-zero emissions by 2050 provided that no sector specific targets are imposed. “

The truth is that agriculture is a uniquely hard-to-abate sector. We advocate for an approach based on continuing the declining trajectory of agricultural emissions, in-line with R&D exploration and the development of innovative technologies (i.e., feed additives, slow-release fertilisers). The design of the Agriculture and Land Plan must be centred around this reality.

Producer Concerns, Industry Sentiment and Barriers to Adoption
A lot of the issues that create participation barriers stem from several friction points.

One central grievance is the perceived lack of genuine engagement with industry when it comes to goal setting, ambitious or not.  The agricultural community and integrated supply chains recognise the responsibility they have in managing and reducing their contributions to Australia’s overall Greenhouse gas (GHG) emissions.

This has seen numerous initiatives toward climate and carbon neutral commitments by 2030 and 2050 from producer groups and other stakeholder bodies across our commodity groups.  Such examples include the Red Meat[4], and Grains[5] industries making commitments to carbon neutrality and 15% emissions intensity by 2030 respectively.  In addition to this our adjacent industries and supply chain companies also are developing internal commitments when it comes to environmental and GHG requirements. 

However, there is some consternation regarding a feeling of under-consulting when nationally we are signed to a growing number of international commitments and targets.  Industry is then expected to potentially work miracles to meet these targets which leaves landholders to bear the burden of implementation without a sense of shared ownership. This disconnect fosters resentment and hinders effective action, jeopardising the very goals the sector plan seeks to achieve.

Further fuelling anxiety around being handed mandates is the underutilisation of local knowledge. Landholders, with many having decades of ownership and custodianship, possess intimate understanding of their ecosystems. Additionally, they have already observed climate shifts regarding temperature increase and seasonal variability and are the group most incentivised to continually adapt their practices to maintain a holistic land management. 

Yet, decision-making, data interpretation, and policy formulation often seem confined to distant urban centres, where ground truthing of observational data can be lacking.  This creates a harmful dichotomy, with rural communities and landholders seen as passive recipients of policy rather than active participants in positive custodianship of their landscapes.

The sector plan is beginning from a good base in looking to formulate a base understanding before moving forward, this includes the view to understand current initiatives being undertaken.  A federal overarching plan that sits ahead of state and more importantly regional based initiatives would be less desirable.  A rigid, overarching plan risks restricting the adaptability of local circumstances, leading to policies ill-suited to the varying challenges and abatement capacities of different bioregions.
Furthermore, trust in decision-making processes has been drawn into question by questionable data foundations. Reports like the QLD SLATS[6], which whilst adequate for a snapshot view of vegetation change in QLD, are sometimes maligned for failing to differentiate vital vegetation from problematic regrowth. Due to the reliance on spectral signals and colour analysis to analyse this change with minimal ground-truthing, the nuance of high value managed regrowth gets confounded alongside pest and invasive regrowth and low value monoculture afforestation such as brigalow and mulga. While a valuable and science-based tool is critical for measuring change in vegetated landscapes, SLATS has historically reported on, and indeed vilified landowners who have contributed to clearing statistics, without a more balanced view of land stability, groundcover, tree-grass balance and environmental health. When landholders bear the brunt of unintended consequences arising from such shortcomings, sustainable management efforts are further jeopardised.  This leads to the frustrations of landholders when they can see the issue compounding, but policy and legislation prevents timely correction or management.
Beyond these anxieties lies a recognition of the detrimental impact of polarising rhetoric employed by some environmental groups. Inflammatory language and sensationalised narratives, while aiming to galvanise action, can drown out the voices of genuine collaboration and impede the search for pragmatic solutions. Open dialogue, built on mutual respect and a shared commitment to the land, is essential in navigating the complexities of environmental challenges.  The government and sector plan needs to act as the mediator on discussions as all groups have sustainable land management as a cornerstone of desirable outcomes.  Landholders seek the tools and support to engage in active management, including coordinated fire, pest and vegetation management, to ensure positive outcomes for the landscape.

Ultimately, Australia's landscapes thrive not under passive observation, but under ACTIVE management.  This is self-evident from the knowledge wells of both First Nations and Landholders.  Restrictive bureaucratic ‘red’ and ‘green’ tape hampering effective management needs review so that these knowledge banks can be properly utilised.
 
Building on Existing Efforts
AgCarE[7]
AgForce has long advocated for a holistic approach to agricultural sustainability, one that moves beyond a singular focus on greenhouse gas emissions and recognises the intricate web of natural capital and its critical role in sustainable production systems.

Many Landholders can also find themselves unable to capitalise on previous good stewardship, as current Carbon Abatement and Credit schemes cannot be applied retroactively beyond a year or two.  As noted in Minister Bowen’s speech to the Carbon Market institute on the 15 Sep 2023 “ACCUs and carbon markets are not an end in themselves, they are a climate policy tool to contribute to the emissions reductions we must deliver to urgently address climate change, alongside onsite abatement.”[8]

In recognition of the significant investment of landholders and their continued good stewardship, AgForce has developed a tool that allows landholders to value the natural capital inherent on their properties that they have cultivated.  AgCarE began development in 2019 and serves as an accounting program designed to empower our members in their transition towards a natural capital approach. AgCarE operates on a case-by-case basis, meticulously identifying, acknowledging, and rating the performance of individual rural properties and enabling recognition of the interdependent relationship between natural, agricultural production, economic and social systems.
 
This comprehensive auditing tool delves deep into the multifaceted aspects of sustainable agricultural production, offering producers a wealth of valuable insights. AgCarE:
  • Maps a property's complete natural capital asset portfolio, providing a clear understanding of its environmental riches.
  • Identifies potential biodiversity offset opportunities, empowering producers to contribute to ecosystem restoration and conservation.
  • Pinpoints options for carbon abatement, enabling proactive participation in emissions reduction efforts.
  • Provides a comprehensive assessment of farm sustainability, highlighting areas for improvement and celebrating existing strengths.
  • Enhances drought resilience and business continuity through its focus on the water cycle, vegetation health, and soil integrity.
The key drivers of this development were a frustration at the blinkered focus on carbon emissions that sidelined the value of broader sustainability considerations.  The other driver being disappointment with the limited accessibility of existing carbon markets, such as the Emissions Reduction Fund, for many producers. These markets often favour projects involving cleared land, which is often impractical and cost-prohibitive for family farming operations in Queensland. 

AgCarE, whilst initially designed for Queensland graziers, has evolved to encompass a wider range of agricultural commodities.  The tool incorporates commodity-specific modules that recognise and assess individual business practices against established national and international standards.

Furthermore, AgCarE aligns seamlessly with the Australian Agricultural Sustainability Framework (AASF). As a founding member and pilot participant in the AASF, AgCarE contributes to the development of a common ground for sustainability programs, paving the way for their recognition in domestic and international markets.
Beyond the AASF, AgCarE is being actively explored by financial institutions as a potential tool to support their reporting requirements under the Task Force on Climate-Related Financial Disclosures (TCFD) and the Taskforce for Nature Related Financial Disclosures (TNFD). AgCarE has been meticulously mapped against the key reporting principles of both frameworks and is currently under evaluation for official recognition by the TNFD program.

AgCare as a tool allows landholders to generate an all-encompassing view of their properties and then leverage this information to access funding for further development and market access.  The funding component is key, as mentioned further below, economic considerations will be either a key driver or hinderer on the speed of implementation and timeline of goal achievement for the Sector.  By embracing AgCarE, investors can gain confidence in the sustainability credentials of these enterprises recognising the risk profile of the business and mitigation options aligned with their own sustainability commitments.

We firmly believe that AgCarE represents a powerful force for positive change within the agricultural sector, enabling producers to not only achieve individual sustainability goals but also contribute meaningfully to broader national and global commitments whilst ensuring they see the fruit of their efforts.
 
Economic Considerations to Adoption
AgForce would like to note while environmental sustainability is undoubtedly paramount, market realities and economic considerations remain critical for the success and viability of agricultural businesses. Understanding and addressing these challenges head-on is crucial for crafting effective government policies and support mechanisms that facilitate a smooth and prosperous transition to net-zero in the Sector Plan.
One major hurdle, is the current disconnect between consumer preferences and farmer incentives. As evidenced by Meat and Livestock Australia Market Snapshot for Australia[9] consumers at the purchase point do not factor environmental or sustainability concerns amongst the top 10 factors influencing decision making. This creates a significant disincentive for farmers to invest in costly new management strategies and technologies aimed at lowering emissions, as the market offers no immediate economic reward for such efforts. This gap between environmental aspirations and commercial realities needs to be bridged if farmer buy-in is to be accelerated.

Long-term capital investments in energy-efficient machinery further illustrate the economic complexities involved. While these technologies hold immense potential for emissions reduction, their high upfront costs can deter widespread adoption unless their value proposition is adequately demonstrated. Government incentives, such as grants or tax breaks, can play a vital role in accelerating the adoption of these advanced technologies, enabling faster diffusion of emissions-reducing practices throughout the sector.

The rigidity of current carbon programs presents another challenge. The 25-year lockup period mandated by the Clean Energy Regulator, while providing long-term certainty for project investors, raises concerns about adaptability and future flexibility. Locking up significant productive land for a generation may hinder the exploration and implementation of potentially more efficient mitigation strategies that emerge in the years to come. This rigidity contradicts the government's stated goal of supporting an adaptable and resilient agricultural sector, and alternative program structures that offer greater flexibility while maintaining environmental integrity should be explored.

The Australian Government has an opportunity for world-leading best practice in management of environmental offsets through development of appropriate biosecurity plans and emergency response strategies in consultation with local farmers and the wider community. Before declaring environmental offset areas, the principle of free, prior and informed consent must be enshrined in operational procedures, as well as a Good Neighbour Policy to provide a framework for consistent application and interpretation of legislation. In Queensland, this would include observance of the general biosecurity obligation (GBO) under Queensland's Biosecurity Act 2014.  Pest plants and animals, as well as disease, fire, and floodwater, move between different parts of the landscape without regard to boundaries. Land management practices are more effective if they are developed in consultation with neighbours and local communities and implemented cooperatively across the landscape. For example, without consultation with local council and their neighbours, managers of emissions-offset reserves could unwittingly introduce a new species, i.e. planted for carbon capture, that may increase bushfire or biosecurity risks. Aside from the benefits of information sharing, this cooperative approach to managing emission-offset reserves will assist Government to make progress towards wider environmental, social and governance outcomes for a truly sustainable future.

Limited access to key resources, such as seed for reseeding or effective weed and pest control tools, can further impede farmers' ability to undertake essential land management activities aimed at enhancing soil health and carbon sequestration. These limitations are particularly concerning in light of potential government restrictions on fertilisers and other crucial agricultural inputs. Striking a balance between environmental goals and ensuring farmers have the tools they need to maintain and boost productivity is crucial for achieving sustainable and resilient agricultural systems.

Uncertainty and volatility, both in terms of the political landscape and international market dynamics, add another layer of complexity to the transition. AgForce producer members require a stable and predictable environment to make significant investments in new technologies and practices. Policy frameworks that are susceptible to abrupt changes due to shifts in political winds can deter long-term planning and investment, hindering the overall progress of the transition. Furthermore, Australia's high production costs relative to other international players, place an added burden on our farmers. In an increasingly competitive global market, ensuring that sustainability efforts do not inadvertently price Australian agricultural products out of reach of key export markets is critical.
 
Government Involvement
The success of Australian agriculture's transition to net-zero hinges not only on the Agricultural sector's own efforts but also on the active and strategic support of the government. In this critical journey, the government can play a multifaceted role, acting as a facilitator, knowledge disseminator, and co-investor in innovation and infrastructure.
One essential first step is achieving clarity and consistency in the measurement of GHG emissions. As highlighted by the report undertaken into carbon accounting tools by R.Brake for the Western Australian Department of Primary Industries and Regional Development[10], an approximate 6,000 t CO2e discrepancy between existing calculators for the same farming operation creates significant challenges in accurately assessing progress and identifying effective mitigation strategies. This further exacerbates the uncertainty of landowners, the marketplace, and consumers in Australia’s role in meeting international climate and nature related agreements and treaty obligations. The government can foster greater confidence and accuracy by facilitating a national dialogue and agreement on methodologies and standards for GHG calculations. This includes engaging with industry stakeholders, research institutions, and relevant government agencies to establish a robust and transparent framework that inspires trust and facilitates meaningful progress.

Furthermore, a comprehensive review of existing programs, incentives, and knowledge resources is crucial to identify and address potential gaps in support across all levels: federal, state, and private industry.

The findings should be disseminated through a centralised clearinghouse or online portal, easily accessible to farmers and readily updated with new information and opportunities. This portal can then significantly reduce the burden on producers, who are rightly focused on the complexities of their core business and shouldn't have to navigate a labyrinth of disparate resources to access vital information and support.

In addition, as new research and methodologies become available, they need to be condensed from the research paper level to actionable and relevant fact sheets.  This will help producers select and implement relevant improvements without having to spend valuable time deciphering conclusions from research studies and how applicable they may be to their localised production system.

Beyond existing programs, the government can further invest in research and development of transformative technologies and practices that hold promise for emissions reduction and resource efficiency. Collaborative partnerships with universities, research institutions, and the private sector can accelerate the development and commercialisation of these innovations. Additionally, strategic investments in infrastructure that allows for wider adoption of renewable energy sources on farms, improved water management systems, and efficient logistics networks can significantly contribute to decarbonisation and long-term sustainability.

The recent introduction of the Nature Repair Bill represents a step towards recognising the multifaceted nature of the climate challenge and moving beyond a singular focus on carbon abatement. This broader framework, encompassing biodiversity conservation, ecosystem restoration, and land management practices, aligns with the holistic approach advocated by AgCarE and resonates with the concerns of many farmers who recognise the interconnectedness of environmental health and agricultural productivity. The government can continue to build on this momentum by developing and implementing policies that incentivise and reward farmers for their contributions to a broader agenda of climate resilience and ecosystem stewardship.

Conclusion
The government's role in supporting Australian agriculture's transition to net-zero is multifaceted and vital. Fostering consistency in emission measurement, actively identifying, and addressing support gaps, promoting innovation and infrastructure development, and embracing a holistic approach to sustainability.  AgForce recognises the importance and is willing to assist the department in identification of these gaps and dissemination of the deliverables.
 
AgForce appreciates the collaborative process the Land and Agricultural Sector Plan development has begun from and looks forward to working with the department as the plan develops.  As has been noted, strong collaboration between producers, government and industry groups will result in the development of an effective, implementable, and achievable sector plan.
 
Further correspondence and information can be obtained by contacting Daniel Counsell, AgForce Cattle Policy Director by email: counselld@agforceqld.org.au or mobile: 0429 649 881.

Yours sincerely

Michael Guerin 
Chief Executive Officer
 
[6] QLD SLATS - Statewide Landcover and Trees Study (SLATS) | Environment, land and water | Queensland Government (www.qld.gov.au)
[8] Minister Chris Bowen’s Speech transcript - Carbon Market Institute Speech | Ministers (dcceew.gov.au)
[9] MLA Industry Insights Market Snapshot, Australia, 2022 - australia_2022-mla-industry-insights-market-snapshot_010223.pdf
[10] Evaluation of Carbon Calculators DPIRD FINAL 20210519 - Evaluation of Carbon Calculators DPIRD FINAL 20210519.pdf (agric.wa.gov.au)