8 August 2025
Office of the Great Barrier Reef & World Heritage
Queensland Department of the Environment, Tourism, Science and Innovation
GPO Box 2454
BRISBANE QLD 4001
By Email: officeofthegbr@detsi.qld.gov.au
To Whom It May Concern
Dear Sir/Madam
Re: Statutory Review of the Regulated Standards under the Reef Protection Regulations
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 $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.
Executive Summary
AgForce welcome the opportunity to contribute to this statutory review of the Reef Protection Standards. We trust that this mandated periodic review is being undertaken in a spirit that provides a genuine opportunity to re-consider the grounds for imposing this compulsory approach.
AgForce directs our comments specifically to the Sugar Cane and Beef Cattle Grazing Standards – reflecting our member base in Reef catchments. In preparing this submission, we acknowledge the significant contribution of the AgForce community.
AgForce members are committed to sustainable land management and water stewardship. However, the current regulatory approach embodied in the Agricultural Environmentally Relevant Activity (ERA) Standards has proven to be costly, inflexible and ineffective in delivering measurable improvements to Reef water quality. The standards are disproportionate compared with non-agricultural landowners, while failing to account for the diversity of farming communities, systems, climatic variability and the lived realities of agricultural production. We urge the reviewers to recognise that farm businesses are typically small to medium sized family enterprises, representing home, workplace and vital income over generations.
AgForce advocates for a shift to a ‘voluntary, producer-led framework’ that supports the adoption of best management practices with proven agronomic and environmental benefits. This approach should be underpinned by robust extension services, recognised accreditation programs and practical tools that empower producers to improve both productivity and water quality outcomes.
AgForce’s Key Recommendations:
- Repeal or significantly revise the Agricultural ERA Standards.
- Apply the Queensland Government Better Regulation Policy and Regulator Performance Framework1, including a comprehensive Regulatory Impact Analysis (RIA)2.
- Replace prescriptive compliance with voluntary, evidence-based programs co-designed by producers.
- Improve communication and accessibility for diverse producer communities (reflecting computer and general literacy levels, cultural and linguistic diversity).
- We promote the continued collaboration toward fostering trusted relationships that achieves better outcomes for all parties in the future.
AgForce urges The Department of Environment, Tourism, Science & Innovation (DETSI) and their Minister to engage directly with producers, peak body policy advisors and trusted agricultural extension and service providers, to co-design a future framework that is practical, inclusive, and effective.
Introduction
Queensland’s agricultural producers have long played a vital role in managing land and water resources within the Great Barrier Reef catchments. Our advocacy represents a broad cross-section of sugarcane producers and livestock graziers who are deeply invested in the sustainability of their farming enterprises and the health of their communities.
The current Agricultural ERA Standards aim to reduce nutrient and sediment runoff from agricultural land. While well-intentioned, these standards have become a source of frustration and concern for many producers. The prescriptive nature of the Agricultural ERA Standards has not delivered clear environmental benefits. Instead, they have unnecessarily added to the cost and time of record keeping requirements for producers – particularly in relation to fertiliser budgeting and ground cover requirements.
Our goal is to advocate for a regulatory framework that:
- Recognises the expertise and commitment of producers.
- Supports innovation and flexibility in land management conducive to increased productivity.
- Delivers measurable improvements in water quality through collaborative, evidence-based solutions.
We believe that a voluntary, producer-led approach supported by targeted investment in extension services and practical tools offers the best pathway to achieving both agricultural productivity and Reef protection.
Limitations of the Current Regulatory Approach
The current Reef Protection Standards, as implemented through the Agricultural ERA framework, are not clearly or directly linked to improved environmental outcomes, and thus do not justify the increased legislated expectations on producers.
Neither the 2024 Statutory Review of Reef Protection Regulations3 or the 2022 Reef Scientific Consensus Statement4 found clear evidence that compliance with the Agricultural ERA Standards has led to measurable improvements in water quality, being unable to directly assess or isolate the impact of regulations from programs such as GRASS and Smartcane BMP. This undermines the scientific rationale for maintaining a prescriptive regulatory approach and continued funding of compliance protocols.
From the Compliance dashboard the percentage of properties deemed to be compliant with the standards is below 20% across all three industries (Beef, Banana and Sugar Cane). This kind of data reflects unfairly on primary producers, and is a product of:
- Poorly developed criteria.
- An ill-defined approach to reporting.
- Focus on record-keeping rather than actual land condition or environmental outcomes.
This approach is a source of misinformation, poorly reflective of the genuine advances in sustainable management by primary producers.
Communication & Accessibility Barriers
Producers can face challenges in understanding and complying with the standards due to:
- Legalistic and technical language.
- Low literacy or English as a second language.
- Low computer literacy.
- Lack of culturally appropriate materials.
The standards are currently only available in English, despite the multicultural makeup of the sugar cane industry in North Queensland. This limits equitable access to information and increases the risk of unintentional non-compliance.
In the past, producers have reported considerable stress and confusion upon receiving letters from the department, which they have found to be highly formalised, legalistic and almost accusatory letters, before and after compliance visits. We believe this erodes goodwill and undermines collaborative efforts to improve reef water quality outcomes.
Through our conversations with the Director of Reef Compliance, we are aware of social research conducted by DETSI that reviewed responses to two different styles of compliance letter:
- The traditional compliance-style formal notice that is quasi-enforcement, and
- a less formalised, plain English, explanatory approach.
We commend the Department for exploring these different approaches and encourage the reviewers to consider the related social research.
Mental Health & Social Impacts
The compliance regime has contributed to stress, anxiety and disengagement among producers. Anecdotal evidence suggests that some producers have exited the industry due to the regulatory burden. AgForce regional managers have reported that members view the compliance visits as audits and adversarial encounters with compliance officers have resulted in the moniker ‘Reef Police’.
AgForce has been encouraged by the positive changes we have observed under the leadership of the current Director of Reef Compliance. Nevertheless, issues of agricultural inexperience and inconsistency in the approach of individual compliance officers remains a cause of concern, elevating producers’ confusion, stress and anxiety.
Natural Events & Reef Vulnerability: Implications for Compliance Activities
Recent extreme weather events have starkly demonstrated the Great Barrier Reef’s acute vulnerability to natural disturbances, far exceeding the impact of regulated agricultural activities. In early 2025, a major flood plume extended over 50,000 km² of reef waters from Cairns to Mackay, driven by severe rainfall and river discharge. This event
significantly degraded water quality across inshore, mid-shelf and outer reefs5. In the preceding months, the Northern Reef region endured two tropical cyclones (Jasper and Kirrily), marine heatwaves and mass coral bleaching6,7
The weather events precipitating this are not only ecologically devastating, but also long-lasting, with impacts persisting well beyond the immediate aftermath. Importantly, they also affect landholders as flooding rainfall causal of nutrients and sediment wash into waterways, wetlands and within reef catchments, consequently producer properties and mental health may be severely compromised.
Given this context, we urge the Department to carefully consider the criteria, timing and frequency of compliance visits. It is essential that such activities are not only paused in the immediate aftermath of acute events, but also deferred for extended periods where land condition (including reduced ground cover) and community wellbeing remain impaired. An empathetic, context-sensitive approach is critical to supporting disaster recovery and building trust in Government.
Practical Concerns with Prescriptive Standards
The standard for Sugar Cane has been created in accordance with section 318 and 768 of the Environmental Protection Act 1994 for the purposes of section 81 of the Act. The clear concern is that it is not designed to also support sugar cane on a commercial basis.
Particularly in relation to fertiliser management, the standards are an overly prescriptive and one-size-fits all approach that fails to recognise the complexity and diversity of agricultural systems, including:
- Soil type and fertility.
- Climate and rainfall variability.
- Farm layout and irrigation practices.
Over-regulation of nutrient inputs can reduce crop yields and is a simplistic approach to delivering water quality benefits – which can be achieved by incentivising voluntary practices to reduce nutrient loss. Producers are highly attuned to preventing nutrient loss, which effectively pours money down the sink.
We particularly believe that without strong and direct evidence, there is no justification to require records of phosphorus fertiliser use, or to impose annual farm budgets for phosphorus inputs. This approach risks unnecessary detrimental impacts on sugar cane growth and profitability.
Record-Keeping Requirements
We request that standards for record keeping are reviewed against The Chemical Usage (Agricultural and Veterinary) Control Act 1988. Any expectations that are inconsistent and additional to the requirements of this Act must be justified in terms of their meaningful contribution to water quality outcomes and weighed against the administrative cost to producers who typically lack the support to meet such demands.
Ground Cover & Land Condition Assessments
The Beef Cattle Grazing Standard mandates a minimum of 50% ground cover. Where groundcover falls below this threshold, graziers must give reasons to explain the situation and provide details of how they will improve ground cover or prevent further deterioration. We do not consider it reasonable to mandate that producers must justify areas of low ground cover caused by factors beyond their control, such as:
- Natural variability in land types.
- Seasonal changes and drought conditions.
- Impacts of natural disasters (eg, floods, fires).
Further, management steps to improve the situation may be completely impractical if not impossible.
Additionally, producers report that compliance officers sometimes use satellite imagery or subjective assessments to challenge land condition, even when producers can demonstrate consistent ground cover through tools like Long Paddock reports. This undermines the principle of producer-led monitoring and creates unnecessary tension.
The Case for a Voluntary, Producer-Led Approach
The 2024 Statutory Review of Reef Protection states that the total number of landholders on the Program Recognition and Project Acknowledgement Register varied from 99 in October 2020, to a peak of 391 in June 2022 and was at 242 in December 2023 (reflecting program start and finish times). The change in participant numbers over time did not correlate with regulatory change.
Producers are best placed to assess and manage their land. Many producers already monitor ground cover, soil health and nutrient use as part of their business operations. Supporting these efforts through extension and incentives rather than regulation will deliver better outcomes for both agriculture and the Reef.
A voluntary, producer-led approach also aligns with The Queensland Government’s Better Regulation Policy, which calls for regulation only where necessary and proportionate.
AgForce urges reviewers to confer with the Reef Program, Rural Economic Development, Department of Primary Industries, to better measure and report the meaningful contribution of producers to reef protection and identify the programs and innovations that present the greatest chance of success for agricultural productivity and reef water quality.
AgForce Recommendations
We make the following recommendations to the Department of the Environment, Tourism, Science & Innovation:
1. Repeal or Substantially Revise the Agricultural ERA Standards
They impose costs on producers and government without delivering measurable environmental benefits. A new approach is needed that is practical, evidence-based and producer-led.
2. Conduct a Comprehensive Regulatory Impact Analysis (RIA)
In accordance with the Queensland Government’s Better Regulation Policy, a full RIA should be undertaken to assess the costs, benefits, and alternatives to the current mandatory Agricultural ERA standards.
3. Replace Prescriptive Compliance with Voluntary, Supported Practice Change
Transition to a framework based on:
- Recognised accreditation programs and acknowledged projects.
- Producer-developed nutrient and land management plans.
- Supported extension services and agronomic advice.
- Incentives for continuous improvement through innovation and peer learning.
- Recognising and rewarding good practice.
- Flexibility in response to seasonal and environmental variability.
4. Improve Communication and Accessibility
Ensure that all Reef-related standards, guidance materials and compliance processes are:
- Written in plain English.
- Neutral and non-adversarial.
- Available in multiple languages.
- Delivered through trusted, culturally competent channels.
- Supported by services for those who need additional assistance.
5. We collaborate toward fostering trusted relationships between ‘the parties’:
- Enhanced producer and department relationships.
- Improved agricultural productivity outcomes.
- Department(s) welcomed on-farm, as part of extension program, rather than compliance.
- Producers recognised as positive land-care stewards and not as environmental vandals.
Conclusion
Queensland’s sugar cane producers and livestock graziers are committed to strong land stewardship. However, the current regulatory approach via standards and associated reporting of non-compliance, has not demonstrated meaningful environmental outcomes. Worse, it has imposed an unsupportable sense of blame on producers for the condition of the Great Barrier Reef, with significant outlay of public monies.
This submission has outlined the limitations of the existing standards, the lack of justification for key elements and the success of voluntary, producer-led programs in driving real change.
As stated by an AgForce member and farmer in a Reef catchment:
“We don’t really accept the standards. They’re not needed … It needs to be more an extension-type program going forward rather than the compliance requirement.”
AgForce invites future opportunities to work with DETSI to deliver a Reef protection strategy that benefits water quality and supports strong agricultural communities in Reef catchments.
For further details, please contact Michael Allpass, General Manager of Policy & Advocacy: allpassm@agforceqld.org.au
Yours faithfully
Michael Guerin
Chief Executive Officer
1 Queensland Government Better Regulation Policy and Regulator Performance Framework. 2025. https://www.treasury.qld.gov.au/resource/better-regulation/
2 The State of Queensland (Queensland Treasury). 2025. The Queensland Government Better Regulation Policy. https://s3.treasury.qld.gov.au/files/Queensland-Government-Better-Regulation-Policy-1.pdf
3 Statutory review of the Reef protection regulations. State of Queensland, February 2024. Available at: https://www.parliament.qld.gov.au/Work-of-the-Assembly/Tabled-Papers/docs/5724t340/5724t340-d5b2.pdf
4 Reef Independent Science Panel. 2022 Scientific Consensus Statement: Land use impacts on Great Barrier Reef water quality and ecosystem condition. Reef 2050 Water Quality Improvement Plan, Queensland Government, 2022. Available at: https://www.reefplan.qld.gov.au/science-and-research/the-scientific-consensus-statement
5 James Cook University. (2025, February). Flood plume reaches offshore reefs in Great Barrier Reef. https://www.jcu.edu.au/news/releases/2025/february/flood-plume-reaches-offshore-reefs-in-great- barrier-reef
6 Byrne, M., Vila-Concejo, A., & University of Sydney. (2025, January 21). Cycle of coral bleaching on the Great Barrier Reef now at 'catastrophic' levels. University of Sydney News. Retrieved from https://www.sydney.edu.au/news-opinion/news/2025/01/21/coral-bleaching-2024-great-barrier-reef-one-tree-island.html
7 Kingsford, M., & James Cook University. (2025, January 28). Reef ‘catastrophic’ heat wave. JCU News. Retrieved from https://www.jcu.edu.au/news/releases/2025/january/reef-catastrophic-heat-wave