28th November 2025
Office of Ground Water Impact Assessment
GPA Box 2247
BRISBANE QLD 4001
By email: ogia@dlgwv.qld.gov.au
To Whom It May Concern,
RE: Consultation Draft Underground Water Impact Report for Surat Cumulative Management Area
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.
Primary producers operate heavily within the Surat Cumulative Management Area (CMA), where coal seam gas (CSG) development and coal mining interact with regional groundwater systems. Due to the interconnected nature of our water resources and the impacts felt by the AgForce membership, we have a vested interest in The Underground Water Impact Report (UWIR) 2025, its statutory assessment of cumulative groundwater impacts and its proposed management strategies intended to balance resource development with the protection of water users and environmental values.
AgForce welcomes the steps taken by OGIA and its UWIR to provide greater certainty and transparency about groundwater trends, extensive groundwater monitoring and modelling across formations used by primary producers, such as the Condamine Alluvium, Gubberamunda Sandstone, Hutton Sandstone and GAB aquifers. It provides region-wide predictions of depressurisation from CSG and mining, helping landholders understand how their long-term water security may be influenced.
By isolating causes of change, the UWIR allows farmers, irrigators, graziers and agricultural communities to better plan future water management strategies.
One of the strongest benefits for primary producers is the clear framework for identifying and remediating impacts to water bores used for stock, domestic and irrigation purposes.
As of this UWIR, 747 bores are predicted to be impacted in the long term, an increase of 7% from 2021, and 76 bores require short-term assessment for make good action between 2026–2028. Because most of these bores are used for stock and domestic purposes, the make-good process represents a substantial protection for rural businesses but poses the much larger problem that many of the “make good” deals struck by CSG companies is solely financial compensation, not water security which does not protect the long term viability and profitability of prime agricultural land.
AgForce welcomes the report’s expanded groundwater monitoring network, including:
- 705+ monitoring points already established
- Monitoring of groundwater levels, chemistry and extraction volumes
- Increased density of monitoring near agricultural regions such as the Condamine Alluvium
This increases transparency and provides data farmers can rely on when making investment decisions (e.g., irrigation systems, crop selection, feedlot expansion).
Primary producers also welcome the enhanced understanding of subsidence risk and potential management. Subsidence can alter slope and drainage patterns on farms. The UWIR predicts that most regional CSG-induced subsidence remains less than 100–150 mm, though some small zones may exceed 250 mm by 2060.
CSG-induced subsidence can change slopes and drainage, potentially affecting cultivation, irrigation layout, erosion patterns and flood behaviour.
Key findings include:
- Most regional slope changes are <0.001% (10 mm/km), but some zones may reach 0.004% (40 mm/km) near structural features such as the Horrane Fault within the Condamine Alluvium.
- Some areas show ground motion of 10–15 mm/year, occasionally up to 20 mm/year around the western Condamine Alluvium margins
Even small slope changes can influence surface water flows on laser-levelled or precision-graded cropping fields. Because the UWIR explicitly states that farm-scale impacts are not assessed and are subject to a separate government process, landholders may feel uncertainty about how to address or prove subsidence impacts on their properties.
Potential impacts on springs, watercourses and ecosystem health are going to negatively affect grazing land.
Water-dependent ecosystems contribute to property values and grazing productivity. The UWIR identifies impacts greater than 0.2 m in underlying aquifers at:
- 51 spring groups
- 84 watercourse locations
Changes in groundwater-fed baseflow may reduce natural watering points, impact pastures reliant on shallow water tables, or alter wetland function. In areas with high-risk TGDEs, long-term vegetation changes may reduce biodiversity or carrying capacity.
With the updated predictions of subsidence across the effected regions, AgForce implores OGIA to consider next steps and overlay our Land use Protections Principles1 to consider relevant compensation for decreased productivity of land and loss of natural capital.
Following on from the AgForce submission in 20212 we continue to seek:
1. Strong Emphasis on Objective, Independent Science
- Objective, rigorous, independent scientific information to guide water and land-use decisions.
- Improved modelling, monitoring, and reporting, including groundwater, subsidence, surface flows, and water chemistry.
- Transparency and continuous improvement of datasets, methods and monitoring programs.
2. Protection of Agricultural Land and Natural Capital
- A precautionary approach to avoid permanent negative impacts on soil, water, biodiversity and agricultural productivity
- Recognition that agricultural land and natural capital have inherent value and must be prioritised in policy and land-use decisions.
- Rehabilitation requirements and adequate financial assurance to guarantee post-project outcomes.
3. Water Resources as the Key Concern for AgForce Members
- Water resource impacts were the single largest concern for members (8 in 10 “very concerned”)
- Concerns also include rehabilitation, regulatory compliance, and cumulative impacts.
- A strong expectation that groundwater resources must not be permanently diminished.
4. Concerns About Cumulative Impacts from Growing CSG Development
- Continued growth of the CSG footprint (toward ~22,000 wells) and associated long-term impacts on groundwater and landholders
- Need for government to proactively use OGIA findings to address escalating cumulative landholder impacts.
- Multiple requests for “stop-work” triggers when impacts exceed thresholds.
5. Deficiencies and Delays in the Make-Good System
- Slow progress on make-good for IAA bores (only 134 of 233 finalised at the time)
- Calls for an independent review of the make-good system.
- Concern that too many agreements result only in financial compensation rather than water supply replacement.
- Questions around the certainty and reliability of alternative water sources (e.g., Hutton Sandstone).
6. Significant Concerns About Land Subsidence
- Recognition that the report finally confirmed CSG-induced subsidence.
- Concern that subsidence could affect cropping, irrigation layouts, surface-water flows, and farm operations
- Calls for assessment at the farm scale, not just regional scale and inclusion of subsidence risk in CCAs, make-good, and impact avoidance frameworks
- Uneven subsidence
- Unclear reasons for limited InSAR datasets presented
- Need for clear definitions of “initial development stages” with higher subsidence rates
7. Need for Improved Monitoring, Transparency and Compliance for CSG companies
- Comprehensive, property-scale monitoring (groundwater, slopes, subsidence, flows).
- Transparent reporting of Subsidence trends and make-good outcomes
- Stronger, visible government compliance enforcement.
Landholders must have the right to trigger compliance, and confidence in the regulatory system.
8. Calls for Better Landholder Rights and Fairer Negotiation Frameworks
- Strengthened CCAs and access to the Land Access Ombudsman.
- Equal bargaining power for landholders during negotiations.
- Protections for landholders near directional drilling, even if wells are not physically located on their property.
9. Support for Multi-Channel Communication and Public Engagement
A recurrent theme is the need for OGIA and government to use:
- Clear summaries
- Accessible multimedia (videos, podcasts)
- Public updates to ensure landholders and the public understand the issues and scientific findings.
In conclusion, the 2025 Surat UWIR delivers benefits to primary producers by providing clarity and oversight pertaining to groundwater impacts from resource extraction. It establishes a transparent process for make-good arrangements, enhances the monitoring of groundwater systems, and offers improved predictions of long-term impacts.
However, primary producers also face risks, including potential groundwater drawdown affecting water supplies, localised subsidence influencing land management, environmental changes to groundwater-dependent ecosystems, and uncertainties tied to future cumulative impacts and model limitations.
Overall, the UWIR functions both as a risk-mitigation instrument and an information tool, supporting better planning and preparedness while also identifying issues that require ongoing management and policy development.
Should you have any questions, or would like to discuss this submission further please contract Ruth Thompson, Policy Director on 0427 472 467 or thompsonr@agforceqld.org.au.
Sincerely,
Niki Ford
CEO
AgForce Queensland
2 gia_draft-underground-water-impact-report_submission.pdf