Ref: MG/AR/GG24070
27 September 2024
Office of the Great Barrier Reef & World Heritage
Queensland Department of Environment, Science & Innovation
GPO Box 2454
BRISBANE QLD 4001
By Email: OfficeoftheGBR@des.qld.gov.au
Dear Sir/Madam
Re: The Reef 2050 Water Quality Improvement Plan (Reef 2050 WQIP)
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 is the leading voice for Queensland producers 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.
EXECUTIVE SUMMARY
AgForce appreciates the opportunity provided by the Department of Environment, Science & Innovation (DESI) to contribute to the Reef 2050 WQIP Review. This submission outlines key concerns and recommendations relevant for broad acre agriculturalists in Great Barrier Reef (GBR) catchment areas.
KEY POINTS:
- Human-induced climate change is the primary threat to the GBR and poor water quality can exacerbate climate-related impact: This is acknowledged in the 2022 Scientific Consensus Statement. It is essential that the WQIP recognises that climate change can itself change water quality outcomes by increasing temperatures and changing rainfall patterns that can affect nutrient runoff and soil erosion, eutrophication and the release of nutrients from sediments into the water column.
- 2022 Scientific Consensus Statement: AgForce is pleased to acknowledge this excellent body of work. Scientific evidence is a fundamental basis on which to build sound policy. The statement identifies that the monitoring, modelling and reporting programs that inform water quality could be strengthened and refined by increasing their spatial and temporal coverage to capture regional and local differences and provide more balanced coverage across land uses and ecosystems. AgForce welcomes this more thorough approach and hopes it will lead to fewer assumptions about the role of agriculture as the driver of poor water quality. Further, AgForce holds firmly to our view that key decisions must be based on empirical evidence rather than modelling. To continue to grow trust in Reef Science, a deeper discussion with industry is needed about emerging Consensus Statement findings and recommendations (prior to the release of this important document).
- Recognition of existing best practices: Many agricultural producers are already implementing best practices that contribute to water quality improvement. Departmental staff liaising with primary producers are encouraged to consider that they are addressing highly capable operators of complex agroecological systems.
- Genuine and balanced stakeholder engagement: Our members have a long history of engagement with DESI and there is a sense of disillusionment based on past failures of the department to genuinely respond to feedback provided.
- Fair and Effective Compliance: Compliance measures need to be fair, non-punitive and only used as a last resort after careful consideration and clear communication. Our experience has, unfortunately, all too often been that heavy handed officers enact stressful and sometimes devastating measures with insufficient understanding of primary production and without compassion for complexities and mitigating circumstances. There is great value in the Department’s compliance teams developing strong industry-based partnership or advisory arrangements within the key GBR catchments, enabling more targeted and effective compliance effort.
- Role of third-party facilitation: Frustration builds in response to mounting communication failures. When done correctly using trusted agents – to be identified through AgForce – utilising third-party facilitation can improve the relationship between government and industry and enable continuous improvement at the GBR-scale.
- Catchment based approaches and impact of other land use types: The preoccupation with agricultural land users is not only unfair but is ultimately unlikely to improve water quality. There are multiple land use types in GBR catchment areas, with poorly understood impacts. We continue to ask that areas not under agricultural land management get equal focus – including national and state government managed areas.
- Legislative conflicts: Conflicts between different pieces of legislation need to be resolved to provide clear and achievable guidelines for producers. This is particularly relevant in the context of vegetation management and biosecurity. It is greatly disappointing that vegetation mapping, despite advances in AI and machine learning, have not translated to better differentiation between vegetation types, especially woody weeds.
- Role of vegetation management for quality groundcover: We call on DESI to take on board the message that controlling regrowth and weeds is key to improving beneficial forage and ground cover, with production, biodiversity and water quality benefits. There is considerable scope for scientific, evidence-based approaches to improving vegetation policy, rather than the simplified ideological stance that creates an unscientific bias towards high density tree cover.
BACKGROUND
Recognising Climate Change
In the 2022 Scientific Consensus Statement, human-induced climate change is identified as the primary threat to the GBR. We welcome this acknowledgement, as for too long the agricultural community has been unfairly targeted as the culprit for GBR deterioration.
It is also essential that the WQIP recognises that climate change can change water quality outcomes and must incorporate strategies to mitigate these impacts.
For example, increasing temperatures and changing rainfall patterns can affect nutrient runoff and soil erosion and warmer temperatures can increase eutrophication. Additionally, warmer weather can enhance the release of nutrients from sediments into the water column1. The plan should include measures to incorporate understanding of these issues.
Reducing greenhouse gas emissions is essential for mitigating the impact of climate change on reef health. This being the case, our producers in reef catchments should be treated as part of the solution and rewarded for activities with both economic and environmental benefits. A striking example is the capacity for diversification of sugar cane for bioethanol production2, biojet fuel and renewable diesel3. While this is clearly not the focus of the WQIP, there is considerable scope for investment at the state and federal level to develop new jobs around these opportunities from an existing land use, reenergising and revitalising the local communities while targeting greenhouse gas emissions and climate change, which is the greatest threat to the GBR.
In Australia, enteric methane (CH4), mostly produced by grazing sheep and cattle, is thought to account for 71% of the agricultural sector’s greenhouse gas emissions4. Potential plant-based mitigation strategies that reduce CH4 include low methanogenic tropical and temperate grass, as well as legume and shrub forage
species5. AgForce has members in GBR catchments who are already adopting this approach and given that it is without major impacts on forage digestibility, it offers a strategy for CH4 abatement that has considerable potential for wider adoption. This is an example of where an advisory extension service for pastoralists in GBR catchments could promote strategies with both productivity and reef benefits.
Emerging crops suited to various GBR catchment areas also promise opportunities for both agricultural diversification and climate, as well as soil health and reduced chemical inputs. For example, Sunn Hemp (Crotalaria juncea) is a leguminous cover crop that enhances soil health by fixing nitrogen, reducing the need for synthetic fertilisers and improving soil structure, which helps in reducing sedimentation6. Moreover, it is a potential biofuel source and an excellent carbon sequestration agent, contributing to climate change mitigation7.
Another example is Pongamia (Pongamia pinnata), a nitrogen-fixing tree that improves soil fertility and structure, making it ideal for restoring degraded lands8.
Its high oil content makes it a viable biofuel source and it sequesters significant amounts of carbon, aiding in climate change mitigation9.
Impact of other Land Use Types
The 2022 scientific consensus statement identifies that the monitoring, modelling and reporting programs that inform water quality could be strengthened and refined by increasing their spatial and temporal coverage to capture regional and local differences, provide more balanced coverage across land uses and ecosystems and improve trend analysis and quantify uncertainties. AgForce welcomes this more thorough approach and the recognition that agriculture is not the only type of land use that needs to be assessed for water quality outcomes. Our members, many from multi-generational families in reef catchments, assert that sediment and nutrients can and do originate from rainforests and protected area estates higher in the catchment. This, together with the expansion of urban centres and coastal developments and the rapid rollout of renewable energy projects, such as solar and wind farms, has significant implications for water quality. These projects often involve large-scale land clearing and can disrupt existing land management practices that reduce water contamination. Renewable energy projects should be subject to rigorous environmental impact assessments to ensure that they do not negatively impact water quality or agricultural productivity. This includes assessing the potential for soil erosion, changes in hydrology and the spread of invasive species.
Mitigation measures should be implemented to minimise any negative impacts. There are opportunities to integrate renewable energy projects with agricultural practices in a way that benefits both, where they provide additional income for producers while maintaining productive land use.
Recognition of Existing Best Practice Management
The majority of agricultural producers in reef catchments are already implementing best practice management that contributes to improved water quality outcomes. In the context of sugar cane growers, the majority are utilising tactics including stubble cover, rotating into legumes (which fix nitrogen and reduce fertiliser inputs), keeping well maintained drainage networks, subsurface placement of fertiliser and other ways to reduce fertiliser inputs through soil testing and variable rate application, so that fertiliser application is limited to what is necessary to achieve production goals. These practices help to minimise nutrient runoff into waterways, improving water quality.
Other tactics also used in grain systems include reducing spray drift from herbicide and crop protection products through drift reduction nozzles, adjusting spray pressure, lowering boom height, monitoring weather conditions, establishing buffer zones, incorporating drift retardants and maintaining equipment to ensure larger droplets and minimise off-target movement.
In grazing systems, ground cover is maintained through conservative stocking rates, often including pasture spelling, rotational grazing and other strategies to maintain perennial pastures and minimise soil disturbance.
All these are commonly used techniques that increase groundcover, reduce runoff into waterways and reduce contamination of water in GBR catchment areas. Yet, unless producers allow themselves to be coerced into DESI endorsed BMP programs, they remain a high priority for regulatory compliance checks and excluded from annual reef report card reporting.
Adaptive management is a key component of a successful agricultural business. This involves continuously monitoring and evaluating the effectiveness of management practices and making adjustments as needed.
Adaptive management allows for flexibility and responsiveness to changing conditions and new information, ensuring that management practices remain effective over time. This is a large part of the reason many agriculturalists choose not to align themselves with a particular BMP program.
A product such as AgCarE10, developed by AgForce, is versatile and can be applied to any production system, whether it is cattle, sheep, wool, goats, cane, or grains. It helps producers achieve their goals while contributing to broader environmental outcomes. This kind of approach avoids high-handed approaches that assume a need for change or a desire to force independent business owners into a pre-determined box where best practice is very narrowly defined.
Genuine and Balanced Stakeholder Engagement
Target Setting
Water quality targets should be realistic and achievable, considering the practical realities of farming, land management, climatic and economic constraints. These targets should be set in consultation with agricultural stakeholders and scientists to ensure they are both scientifically sound and practically feasible.
A Realistic Approach to Ground Cover
The reef protection regulations in Queensland have guidelines related to ground cover. Specifically, for grazing lands, the regulations focus on maintaining and improving ground cover to minimise soil loss and reduce sediment and nutrient runoff to the GBR. Ground cover is a key indicator of land condition. If ground cover falls below 50% by 30 September each year, the land is considered to be in poor condition. However, it is recognized that achieving 50% ground cover may not always be possible for some land types, even with reasonable efforts11,12.
Yet what constitutes a reasonable effort in the eyes of a compliance officer is less easy to determine. Moreover, rainfall does not know about this September deadline and the GreenDate13 (break of season) is known to vary considerably from one location to another.
While the target of 50% ground cover is often exceeded on most agricultural properties, natural causes can temporarily reduce ground cover, which can often be explained by landholders (if they are given a chance to explain). It should also be recognised that not all regional ecosystems in GBR catchment are the same and
certain areas are less capable of supporting vegetation due to harsh climatic conditions and/or poor soil quality.
A holistic approach to ground cover management is necessary to achieve the goals of the Reef 2050 WQIP. This approach should consider all aspects of land management, including natural land conditions, climatic cycles and landholder interventions like weed control and vegetation management. We maintain that well-established and well-managed perennial pastures can be more effective at reducing overland flow than dense wooded vegetation, particularly in sloping areas, due to the amount of bare earth between trees.
Empirical studies using locally collected data, encompassing long-term (multi-year) hydrological dynamics, varying slope gradients, soil types and climatic zones, are necessary to properly understand the impacts of management and vegetation types on overland flow and water quality (nutrification and sedimentation) – at present there is a substantial knowledge gap in this area, leading to assumptions and generalisations that tree cover is superior to grass cover.
Support and Incentivise Management Interventions
Agricultural land is a highly appropriate context for voluntary management interventions to reduce overland flow, sedimentation and nutrification of waterways. Some examples of suggested government and landholder co-investment are:
- Pasture Renovation, improving the quality of pastures by reseeding and strategic grazing.
- Constructing ponding, terraces, contour banks and other earthworks.
- Riparian vegetation restoration, including grassed buffer strips. This is especially important in riparian zones where declared weeds dominate and degrade the ecosystem.
- Gully erosion control by implementing structures such as check dams, rock chutes and revegetation.
These activities, tailored to local conditions and supported by community engagement, with appropriate agronomic, hydrological and engineering input, represent a strong area of investment for water quality and ecosystem health in catchment areas of the GBR. In cases where these activities also support production outcomes, this is likely to produce far more favourable outcomes for departmental and landholder relationships than the short-sighted and unproductive focus on compliance. We also suggest it will produce greater real-world benefits than many other existing areas of investment (eg, research based on modelling only).
Opportunities for Dialogue
There is a widespread feeling among our members in reef catchments that their views are not being adequately heard. Establishing a balanced reference panel with representatives from the agricultural sector, scientists and other relevant stakeholders can ensure all voices are heard and considered. Stakeholder engagement should be ongoing and iterative, with regular opportunities for feedback and input. Creating opportunities for genuine two-way dialogue between government and industry is essential for building trust and cooperation. This includes regular meetings, workshops and regional forums where producers can provide feedback and share their experiences. However, participants will quickly lose faith if these opportunities do not lead to meaningful changes in policy and practice.
Role of Third-Party Facilitation
Third-party facilitation, when done by a trusted group or individual, can improve the relationship between government and industry. An independent facilitator can help ensure accountability and focus on achieving the best outcomes for the reef. This approach can build trust and cooperation and ensure the regulatory process is fair and effective. An independent facilitator can provide a neutral perspective and mediate conflicts between government and industry, ensuring all voices are heard and focusing on solutions that benefit the reef, which might not necessarily support continuing the prevalent pattern of spending in the reef budget and is likely to prioritise place-based mitigation of heavily degraded areas. It is recommended that AgForce is consulted to determine the preferred third party is on a per catchment basis.
Role of Compliance
AgForce hears repeatedly from our members that there is an absence of clear and respectful communication from compliance officers and little opportunity for genuine two-way dialogue.
Compliance officers must be trained to understand the realities of agricultural operations and communicate in a way that builds trust and cooperation rather than creating adversarial relationships. Compliance measures should be fair, non-punitive and exercised only as last resort after all other measures have been exhausted.
They should support producers in demonstrating how they are achieving water quality goals rather than looking for reasons to penalise them.
A supportive approach to compliance includes providing producers with the resources and clear guidance they need to demonstrate compliance with regulations. However, this approach will take trust that will not be easy to build based on past experiences – agricultural landholders that have personally experienced
heavy-handed compliance or have heard of others that have been treated in an unwarranted fashion, will be less likely to willingly engage with compliance officers.
Considering that climate change is the primary driver for the decline of the GBR, it will be counterproductive to the WQIP if the compliance team continue to prosecute local agricultural producers for breaches that, even if true, have a miniscule impact on reef health. According to the 2022 Reef Scientific Consensus Statement, there is no peer-reviewed evidence of regulations effectively improving reef water quality14.
Replace Compliance with an Advisory Extension Service
All this considered, it is reasonable to suggest that compliance activities directed at agricultural enterprises should be discontinued. The compliance-based approach is highly unlikely to facilitate progress towards improved relationships between DESI and primary producers, which is essential for the success of the WQIP. A properly trained advisory extension service, skilled in agricultural land management, has considerable potential to promote adaptations that have both benefits for production and water quality – dual economic and environmental benefits will have far greater desirability for primary producers. Such a service is likely to be welcomed by agricultural stakeholders in reef catchments who are eager for ways to improve the performance of their business, using cost-effective and practical actions.
Catchment-Based Approaches
Emphasising the importance of catchment-based approaches for effective water quality management is crucial for the success of the Reef 2050 WQIP. Catchment-based approaches recognise the interconnectedness of land and water systems and provide a holistic framework for managing water quality.
Integrated catchment management involves coordinating the efforts of all stakeholders within a catchment area to achieve water quality goals. This includes working with producers, other land use groups, local governments, national parks and other stakeholders to develop and implement catchment-specific strategies. Integrated catchment management helps to ensure that all activities within a catchment area are aligned with local water quality objectives.
Scale of Operations
Agricultural operations in Queensland vary widely in scale, from small family farms to large commercial enterprises. The solutions proposed in the Reef 2050 WQIP must be flexible enough to accommodate this diversity.
For example, large properties may require different management practices than smaller ones and the plan should provide guidelines that are appropriate for different scales of operation and types of agricultural enterprises.
Regional Challenges
Different regions of the GBR catchment area face unique challenges in managing water quality. For example, some areas may have more issues with soil erosion, while others may struggle with nutrient runoff or weed infestations or feral pig impacts. The plan should provide region-specific guidelines that address these unique challenges and provide practical solutions that are achievable for producers in each region.
Place-Based Support
Providing place-based support is essential for the success of catchment-based approaches. This includes establishing local support networks, providing technical assistance and facilitating collaboration among stakeholders. Place-based support helps to build local capacity and ensures that water quality initiatives are tailored to the specific needs and conditions of each catchment area as identified by the people that live there. Support is essential to help land managers identify and implement the incremental steps towards improved land condition and management.
Vegetation Management and Legislative Barriers
Woody vegetation in grasslands and savannas has increased worldwide over the past 100–200 years15. This phenomenon of ‘woody plant encroachment’ (WPE) has been documented to occur at different times but at comparable rates in rangelands of the Americas, Australia and southern Africa. WPE threatens the maintenance of grassland ecosystems that support both livestock production and rangeland biodiversity. Moreover, grass stems are effective at capturing surface-water runoff and sediment.
Both reef and vegetation regulations in Queensland are complicating management goals aimed at managing WPE and restoring grasses and other forage species. Added to this, large areas of WPE in reef catchments are declared weeds, such as Rubber Vine, Prickly Aacacia, Bellyache Bush, Lantana and Chinee Apple and form dense thickets in riparian areas that reduce accessibility and value of agricultural land and exacerbate soil erosion and sedimentation.
Mechanical intervention is often necessary to control woody weeds. However, there is widespread confusion over use of mechanical clearing, making it difficult for producers to manage weeds effectively. Allowing mechanical intervention where needed does cause soil disturbance but overtime the capacity of pasture to respond to removal of competition from woody weeds will lead to a more stable riparian environment. As cited in the Scientific Consensus Statement, the combination of woody and grass species is likely to offer the greatest benefit in terms of bank stabilisation16.
Because reef regulations and the Reef WQIP do not make any distinction between weedy vegetation and other more desirable forms of groundcover and state vegetation mapping is unable to distinguish weed species, farm managers are uncertain how to plan and implement important long-term property and business management decisions, exposing them to costly legal action, accompanied by stress that takes its toll on mental health.
From the perspective of water quality, ecological processes work on much longer timeframes and can be severely compromised when mismatching and where constantly changing regulations are enforced that impact the ability to properly manage vegetation.
There are multiple pieces of legislation and regulations for environmental management and planning which are used across agricultural land in Queensland and if not properly aligned, will hamper progress towards water quality targets.
Harmonising regulations across different legislative frameworks is essential. This includes providing detailed information on regulatory requirements, as well as practical advice on how to comply with these requirements. Guidance should be easily accessible and regularly updated to reflect changes in legislation and related compliance activities – even then it can be very hard to find on government websites, which reinforces the need for place-based support.
CONCLUSION
AgForce is committed to collaborating with DESI. By recognising the strong environmental management by agricultural land managers in reef catchments and listening to their experienced insights, greater progress will be realised towards setting realistic targets and a sensible approach to record keeping and compliance checks. Our members in reef catchments, often from multigenerational families living in that landscape, can be powerful partners in achieving better water quality outcomes.
Key recommendations include recognising the value of ground cover provided by well managed pastures through addressing challenges with vegetation thickening and weed control and sincere collaboration with agricultural landholders to devise practical and realistic solutions tailored to the scale and specific challenges of each catchment and type of agricultural operation. Effective communication enabled through trusted third-party facilitators will be crucial for building credibility, confidence and cooperation between government and industry.
In preparing this submission, AgForce has consulted with other organisations who share similar opinions and principles. As an endorsement to AgForce’s Reef 2050 WQIP review submission, three organisations have written letters to support AgForce’s work. These letters can be found as attachments to this submission.
Thank you for considering this submission. AgForce looks forward to continuing to work with DESI to protect the GBR while supporting sustainable agricultural practices.
Should you require further information, please do not hesitate to contact Dr Annie Ruttledge, Senior Policy Advisor for Biosecurity & Sustainability: ruttledgea@agforce.qld.org.au or 0429 062 852.
Thank you for your attention to this critical matter.
Yours faithfully
Michael Guerin
Chief Executive Officer
1Wang, H., Li, Q., & Xu, J. (2023). Climate Warming Does Not Override Eutrophication, but Facilitates Nutrient Release from Sediment and Motivates Eutrophic Process. Microorganisms, 11(4), 910. https://doi.org/10.3390/microorganisms11040910
2 Scientific breakthrough on sugar cane genome maps out green fuel future
4 Badgery, W., Li, G., Simmons, A., Wood, J., Smith, R., Peck, D., ... & Eckard, R. (2023). Reducing enteric methane of ruminants in Australian grazing systems–a review of the role for temperate legumes and herbs. Crop and Pasture Science.
5 Durmic Z., Black J. L., Martin G. B., Vercoe P. E. (2022) Harnessing plant bioactivity for enteric methane mitigation in Australia. Animal Production Science 62, 1160-1172. https://doi.org/10.1071/AN21004">https://doi.org/10.1071/AN21004
6 Fall, T., Freidenreich, A., Swartz, S., Vincent, C., Li, Y., & Brym, Z. (2021). Questions and Answers for Using Sunn Hemp (Crotalaria juncea L.) as a Green Manure Cover Crop. EDIS, University of Florida. https://edis.ifas.ufl.edu/publication/AG443
7 Bhandari, H. R., Shivakumar, K. V., Kar, C. S., Bera, A., & Meena, J. K. (2022). Sunn Hemp: A Climate-Smart Crop. In Developing Climate Resilient Grain and Forage Legumes (pp. 277-296). Springer. https://doi.org/10.1007/978-981-16-9848-4_13
8 Degani, E., Prasad, M. V. R., Paradkar, A., Pena, R., Soltangheisi, A., Ullah, I., Warr, B., & Tibbett, M. (2022). A critical review of Pongamia pinnata multiple applications: From land remediation and carbon sequestration to socioeconomic benefits. Journal of Environmental Management, 324, 116297. https://doi.org/10.1016/j.jenvman.2022.116297
9 Leksono, B., Rahman, S. A., Larjavaara, M., Purbaya, D. A., Arpiwi, N. L., Samsudin, Y. B., Artati, Y., Windyarini, E., Sudrajat, D. J., Aminah, A., Maulana, A. M., Bhatta, K. P., Kwon, J., & Baral, H. (2021). Pongamia: A Possible Option for Degraded Land Restoration and Bioenergy Production in Indonesia. Forests, 12(11), 1468.
https://doi.org/10.3390/f12111468
10AgCarE – audit of sustainable production, carbon and biodiversity assets on property. https://www.agcare.org.au/
11 Queensland Government. “Requirements for graziers.” Queensland Government website
12 Queensland Government. “Reef protection regulations.” Queensland Government website
14 Waterhouse J, Pineda M-C, Sambrook K, Newlands M, McKenzie L, Davis A, Pearson R, Fabricius K, Lewis S, Uthicke S, Bainbridge Z, Collier C, Adame F, Prosser I, Wilkinson S, Bartley R, Brooks A, Robson B, Diaz-Pulido G, Reyes C, Caballes C, Burford M, Thorburn P, Weber T, Waltham N, Star M, Negri A, Warne M St J, Templeman S, Silburn M, Chariton A, Coggan A, Murray-Prior R, Schultz T, Espinoza T, Burns C, Gordon I, Devlin M (2024) 2022 Scientific Consensus Statement: Summary, pages 88, 89. https://reefwqconsensus.com.au/wp-content/uploads/2024/06/2022-Scientific-Consensus-Statement-Summary_FINAL.pdfl
15Archer, S.R., Andersen, E.M., Predick, K.I., Schwinning, S., Steidl, R.J., Woods, S.R. (2017). Woody Plant Encroachment: Causes and Consequences. In: Briske, D. (eds) Rangeland Systems. Springer Series on Environmental Management. Springer, Cham. https://doi.org/10.1007/978-3-319-46709-2_2
16 Simon, A., Collison, A.J.C., 2002. Quantifying the mechanical and hydrologic effects of riparian vegetation on streambank stability. Earth Surface Processes and Landforms, 27, 527-546.
ATTACHMENTS - Letters of Support