Ref: MA/AF/MA25003
20 May 2025
Queensland Parliament
State Development, Infrastructure and Works Committee
By Email: sdiwc@parliament.qld.gov.au
Dear Sir / Madam
Re: Planning (Social Impact and Community Benefit) and Other Legislation Amendment Regulation 2025
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 $11.2 billion in on-farm value of production in 2022-23. 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.
Thank you for the opportunity to provide comment on the Planning (Social Impact and Community Benefit) and Other Legislation Amendment Regulation 2025.
AgForce has a strong policy position on representing members’ interests in the protection of land use and is supportive of efforts by all authorities, at federal, state and local levels, that enable the effective coexistence of agriculture with other forms of land use. Please see Appendix 1 where the Land Use Protection Principles of AgForce members, as endorsed by the AgForce Queensland Farmers’ Limited Board, are presented as an overall expectation of what broadacre agricultural industry commits to when seeking coexistence with other sectors.
AgForce has not made comment on all sections and solely focuses on the amendments proposed concerning renewable energy projects
1. SOCIAL IMACT ASSESSMENT
AgForce supports the requirement for wind farms and large-scale solar farms to undertake social impact assessment. AgForce would however, like to see more attention provided specifically to neighbouring landholders to the project. We see that neighbouring landholders are more likely to experience direct impact from exposure to hazards and risks from renewable energy projects and by environmental factors such as dust and noise pollution as listed in the Draft Social Impact Assessment Guidelines.1
2. COMMUNITY BENEFIT AGREEMENT (CBA)
AgForce supports the requirement for proponents to enter into a community benefit agreement with the relevant local government.
3. IMPACT ASSESSABLE - MANDATORY PUBLIC NOTIFICATION
AgForce supports the State Assessment and Referral Agency (SARA) assessing wind farms and large-scale solar farms and the requirement for public notification as this allows communities to participate in the development process.
4. THIRD-PARTY APPEAL RIGHTS
AgForce has concerns over whether qualifying criteria should be implemented so that who has third party appeal rights are limited in some regard to individuals/companies who may be directly impacted by the project, e.g. neighbouring landholders. This would reduce the amount of frivolous and vexatious claims before the Planning and Environment court.
STATE CODE 26 - SOLAR FARM DEVELOPMENT
AgForce has similar concerns regarding acoustic amenity and decommissioning as was raised in our submission to State Code 232
AgForce would like some consideration afforded to reducing negative financial impacts on neighbouring landholders to solar farms. Should a solar farm be located in close visual proximity to a neighbouring property’s boundary or homestead, compensation should be afforded to the neighbouring landholder for loss in equity to their land as this could have devastating impacts on borrowing capacity and their ability to run their agricultural operation to its potential. AgForce would also request neighbouring landholders be afforded consideration within Performance Outcomes 13-15 as they will also be subject to negative impacts on their visual amenity and potential experience of glint and
glare should the solar farm be located close to their boundary.
Regarding Performance Outcomes 7-9 AgForce would like to see consideration afforded to how liability can be determined should the solar farm become non-compliant with the Reef Protection Regulations once operational. Even if a landholder has done their due diligence in their Conduct and Compensation Agreement (CCA) there is still a real risk of a scenario where there is a lack of ground cover under the solar farm where sediment run off occurs and is deemed to be in breach of the Reef Protection Regulations.
This would be an unfair liability for the landholder of the project site to bear (if they are different to the solar farm developer/owner - i.e. where a grazier leases a portion of their land to the project developer)
In regard to Performance Outcome 12 AgForce would like to see that noise monitoring continues once the project is operational and that the predicted acoustic levels are not the sole determinant of whether the project is compliant with the Regulation being, Environmental Protection (Noise) Policy 2019.
Whilst we appreciate that Performance Outcome 28 mentions that decommissioning plans should be secured by bonds or financial guarantees, AgForce would like to see some criteria that these bonds or financial guarantees are obtained from reputable financial institutions.
AgForce thanks the State Development, Infrastructure and Works Committee for the opportunity to provide feedback and looks forward to continued engagement to ensure 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 Allpass
General Manager - Policy & Advocacy
2https://www.agforceqld.org.au/knowledgebase/article/AGF-01846/