9 June 2023

Office of the Executive Director State Valuation Services Department of Resources
1 William Street

By Email:

Dear Ms Stone
Re: Proposed Amendments to the Land Valuation Act 2010 – Stakeholder Consultation 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 would like to commend the State Valuation Service (SVS) on the extensive stakeholder consultation to date and extend our appreciation for the opportunity to provide written feedback on the Stakeholder Consultation Paper for the proposed amendments to the Land Valuation Act 2010.
AgForce has considered the proposed amendments in the Stakeholder Consultation Paper and responded to them in an attachment to this letter.
We trust this feedback will be considered and look forward to engaging further in the process. Should you have any queries, please contact Policy Officer Nikki  Hoffmann  on  0477  963  694  or  via  email:

Approved by
Michael Guerin
Chief Executive Officer

AgForce Queensland Farmers Limited: Feedback to the Proposed Amendments to the Land Valuation Act 2010 – Stakeholder Consultation Paper

Proposed Amendments:
  1. Statutory Guidelines
AgForce supports the introduction of stakeholder co-designed statutory guidelines and welcomes a consistent and transparent process and outlining an objective methodology.
  1. Definition of lot and the Valuer-General’s Duty to Value all Land
AgForce supports the amendments to the definition of lot and the Valuer-General’s duty to value all
land with a statutory purpose.
  1. Non-Adjoining Farming Lots
AgForce supports the proposed amendment to non-adjoining farming lots and an applicant-led process whereby a landowner wanting to combine their non-adjoining farming lots into one valuation makes an application.
  1. Allow Combining of Declared Parcels and Lands Remaining after Declared Parcel is Excised (Balance Lands)
AgForce supports the amendment to allow combining of declared parcels and lands remaining after a declared parcel is excised (balance lands).
  1. Definition of Address for Service
AgForce supports the proposed amendment to the definition of address for service. This amendment will provide landowners with the flexibility to receive valuation notices in a manner of their choosing.
  1. Definition of Encumbered
  2. Exception to Annual Valuation Requirement
AgForce supports the clarification resulting from proposed amendments 6-7. Noting, expected to have limited to no impact to our membership.
  1. Properly made but partially Compliant Objections
AgForce supports the proposed amendments to properly made but partially compliant objections. This amendment will streamline and simplify the objections process for all parties and allow for added flexibility in how missing/incomplete information is requested.
  1. Valuation Sought
AgForce supports the proposed amendments to the valuation sought. This amendment will ensure consistent requirements for all objections.
  1. Objection Conference Threshold
AgForce does not support the proposed removal of the $5M threshold for when the Valuer-General must offer an independently chaired conference. Rural valuations are complex valuations with a range of factors that can influence the valuation. A landowner that has a valuation of $5M is paying a significant amount of rates and rent (if leasehold) and the Department should automatically offer an independent chaired conference to ensure that these objections have been heard fairly by someone outside of the Department. AgForce feels that the removal of this provision will result in significant increases in the lodging of appeals to the Land Court.
  1. Further information
  2. Purpose of an objection conference
  3. Function of a chairperson
  4. Chairperson’s obligation to give a disclosure notice
  5. Clarifying what the Valuer-General may consider when deciding an objection
  6. Application for deduction for site improvement (DSI)
  7. Minor clarifying amendments
AgForce supports the proposed amendments 11-17. Noting, expected to have limited to no impact to our membership.