22 September 2023

Committee Secretary
Transport and Resources Committee
Parliament House
George Street
Brisbane QLD 4000 

By Email:    
Dear Sir/Madam

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 assists its members annually to better understand the State Government unimproved land valuations.  AgForce members have access to rural property valuation advice and support from a rural property valuer.

AgForce welcomes the opportunity to review and provide comment on the Land Valuation Amendment Bill 2023.

AgForce supports the objective of the proposed Bill to improve the administration and operation of the statutory land valuation framework by amending the Land Valuation Act to ensure:
  • it is responsive to changes in the property market and operational environment and transparent in its operation;
  • valuations are consistent and defensible, and the supporting processes such as objections and appeals are effective and efficient;
  • a clear and consistent framework for determining when land is valued separately or combined based on land use and occupation.”
Overall, AgForce is supportive of the proposed amendments and the Government’s intentions to ensure statutory valuations are consistent and defensible and the supporting processes such as objections and appeals are fair, efficient and non-adversarial.
It is noted that the key elements of the Land Valuation Amendment Bill 2023 are primarily administrative and procedural in nature and are unlikely to have a significant impact on the AgForce membership.  
Nevertheless, AgForce would like to offer the following comments:
Clause 5 – Insertion of new s 6A:  Valuer-general may make guidelines
AgForce supports the introduction of stakeholder co-designed statutory guidelines (Clause 5) and welcomes a consistent and transparent process.  This amendment will provide state-wide consistency in valuation practice for complex property types and transparency of operational practices, as well as other procedural matters relevant to determining statutory land valuations.

Clause 22 – Replacement of s 59 (non-adjoining farming lots) – 59:  Applying for combined valuation for non-adjoining farming lots or parcels
AgForce supports the amendment to non-adjoining farming lots (Clause 22) which will allow for rural landowners to make decision about how their land is valued in line with how they use those lands.  An applicant-led process gives the landowner flexibility to decide if they want to apply for their lots or parcels to be combined.  It is more efficient for the landowner to make these decisions rather than the Valuer-General, because in some cases landowners do not want their lands combined – for example, to allow for succession planning or where the diversification of land use is planned and the combining lots do not align with those plans.

Clause 37 – Insertion of new s 121 – 121:  Valuer-general may invite objector to participate in
Clause 38 – Omission of ch 3, pt 3, div 2 (When objection conference may or must be held)
AgForce does not support the insertion of new section 121 (Clause 37) or the omission of ch 3, pt 3, div 2 – When objection conference may or must be held (Clause 38).  Clause 37 removes the requirement on the Valuer-general to offer an independently chaired objection conference when a valuation is greater than $5 million.  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).  AgForce strongly believes the Department should automatically offer an independent chaired conference to valuations over $5M to ensure that these objections have been heard fairly by someone outside of the Department.  The current provisions under the Land Valuation Act 2010, allow for a transparent process, ensuring all valuations over            $5 million are offered an independently chaired objection conference.  To date, independently chaired conferences have proven to be an effective way of resolving objections without requiring an appeal to the Land Court.  This proposed amendment will result in independently chaired conferences not being offered to several valuations over $5 million that previously would have been offered.  AgForce feels that the removal of this provision will result in significant increases in the lodging of appeals to the Land Court.  Furthermore, AgForce is concerned that independently chaired objection conferences will only be offered at the discretion of the Valuer-general.

Clause 47 – Insertion of new s 128A – 128A:  Chairperson may require further information
AgForce supports the insertion of new section 128A (Clause 47) which enables the chairperson to request further information.  The independently chaired objection conference should be an open and transparent process.  This amendment will ensure all parties are engaged in the objection process and share relevant information in good faith to improve the objections process and to realise greater efficiencies for all.  This will be achieved by encouraging the disclosure of all relevant information before an independently chaired objection conference starts.

Clause 49 – Insertion of new s 129A – 129A:  Written conference report
AgForce supports the insertion of new section 129A – written conference report (Clause 49).  This amendment requires the chairperson to prepare a written report about an objection conference.  By providing a copy of the written conference report to both parties, it will assist to inform the objector about matters relevant to their objection and may inform the Valuer-general’s objection decision. 
Clause 51 – Amendment of s 135 (Application of div 2)
AgForce supports the amendment to section 135 (Clause 51) which enables the Valuer-general to request further information.  This amendment ensures relevant information is available for deciding an objection, which will reduce errors in decision-making and ultimately reduce the number of appeals to the Land Court.

Clause 61 – Amendment of s 247A (Electronic service)
AgForce supports the amendment to electronic service (Clause 61) which will provide landowners with the flexibility to receive valuation notices in a manner of their choosing.

In Conclusion
AgForce thanks the Transport & Resources Committee for the opportunity to provide comment on the Land Valuation Amendment Bill 2023 and looks forward to continued engagement to better practices for all stakeholders involved.
If you have any questions or require further information, please contact Policy Officer, Nikki Hoffmann, on 0477 963 694 or via email:

Yours faithfully
Michael Guerin
Chief Executive Officer