26 September 2023.

Ref: MG/SF/GG25054

23 August 2023 Minister Mick de Brenni

Minister for Energy, Renewables & Hydrogen and Minister for Public Works & Procurement

By Email:


Dear Minister de Brenni

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 welcomes the opportunity to provide feedback on the options and opportunities of the Queensland Government’s sustainable liquid fuels strategy (SLFS).

The renewable fuels discussion has been active in Australia for almost 2 decades and renewable fuels’ use, such as ethanol, biofuels and biodiesel has been used around the world since the invention of the diesel engine in 1897 eg, the Model T Ford was designed to run on 100% biodiesel (vegetable oil). The benefit of biodiesel over petrol diesel is well documented for fuel efficiency, better combustion, lower emissions, alternative uses, etc.

AgForce believes because of the government’s net zero emissions objective by 2050 and the role of the agricultural sector in this space, a new chapter in the renewable fuels story has begun.

The AgForce membership represents producers with a strong focus on sustainable agriculture and are conscious of the renewable energy benefits. Producers want to be part of the renewable energy story; to be part of the solution and to assist with the energy source transitions and decarbonization.

AgForce’s Response to the 18 Consultation Questions of the SLFS

1. Are there other objectives that you think should be included?

An opportunity exists to create regional bio-circular economies; manufacturing plants and biodiesel/biofuel refineries, with farmers being the producers, suppliers and the firm market buyers of the renewable fuel produced, now and in the future.

Technology has opened an opportunity to utilize any and all agricultural bi-products or waste products that does not add pressure to the material production or existing supply use consumption, but creates a corresponding market for these products.

2. How should a ‘sustainable’ liquid fuel be defined to contribute to decarbonization objectives?

“Policy definition(s)”: ‘sustainable’ liquid fuel (SLF) – biofuel blends or biofuels; biodiesel, bioethanol ethanol, biomass and aviation biofuel – Sustainable Aviation Fuel (SAF), etc.

SLF; product and policy designed to reduce the reliance on fossil fuel and imported oil. To diversify the supply of energy sources, supply chains, to generate employment in agriculture and to promote investment, innovation and technological development in rural and regional areas through the adaption and reliance on feedstock – building on Australia’s advanced agricultural production system.

3. Do you agree that the sectors identified as ‘hard to abate’ are likely to continue to rely on liquid fuels in the medium to long-term?

The hard to abate sectors will require specific liquid fuel strategy solutions. They are likely to continue to rely on diesel due to geographical constraints, economic factors (farm business input cost, cost to upgrade machinery, etc) and fuel availability and reliability.

A change in the renewable fuels market will require a vision, a long-term investment by government and support for an industry of 50 plus years, until the sector becomes efficient and productive.

Hard to abate sectors also offer opportunity. One solution is to begin with one hard to abate sector (ie, agriculture) and work to improve its dependence on fossil fuel, as the production systems evolve and become more efficient, progress to another – hard to abate sector.

4. Are there any transitional and/or long-term fuels that should be prioritised to leverage timeframes and Queensland’s resources, capabilities and industrial base?

The most likely outcome that will be accepted by agricultural industry due to machinery of original equipment manufacturers (OEM) and infrastructure capacity is biodiesel, bioethanol or ethanol or biofuels. These fuel sources provide transition without compromise of machine parts or expiration of machine warranties, up to a certain level of fuel additive ie, B20.

This fuel source and manufacturing can withstand the ages despite new discoveries or advances, also this fuel type has alternative use and will grow and enhance our agricultural sector.

5. Where and when do you see the opportunities for the following types of sustainable liquid fuels, both as transitional fuels and as long-term fuels? Renewable diesel, Biodiesel blends (B5, B20, etc), Ethanol-blended fuels (E10, E85 etc) and other sustainable fuel types (please describe)

Australian farmers’ natural competitive advantage in agriculture, positioned in regional areas, is ideal to optimise the agricultural production capabilities of an area. For this reason, we believe that purpose-built bio-refineries should be rurally and regionally based and tailored to meet feedstock supply of the area rather than one biproduct type output approach.

An opportunity exists to consider production of second-generation biofuels being produced from biomass, green waste and large-scale algae production.

Biofuel from sugar cane or Sugar Leaf Top (SCT) or soybean should be prioritised, especially in the sugar capital of Australia. The cane crop is one of the highest sequestrators of carbon, also is one of the most resilient crops to grow; with 16 plus varieties and can be produced twice a year or rotated with soybean, which is also used for feedstock.

The Sustainable Aviation Fuel (SAF) market is progressing and the sugar cane industry has the capacity to fill demand of both SAF and biofuel/biodiesel in Australia. It is close to the coast and populous centers, so transportation efficiencies exist.

However, for the sustainable biofuel blend market to grow and compete globally, the cane industry will need to grow 3-5 times current market size, currently being 10th in the world.

6. Will sustainable liquid fuels be an important part of your decarbonisation journey?                                                                                                                               

The benefit of sustainable liquid fuels on emissions is well documented.

Australian agriculture has always adopted new technology and equipment and they will embrace biodiesel/fuels blends if they are affordable to the cost of production and market conditions are supported by government policy that ensures longevity of consumer use and assists toward viable agri-business and regional communities’ development plans.

In the interim, we suggested a focus on the domestic market, due to Australia’s current feedstock production capacity and unsecure market forces.

We also suggest consideration regarding fuel standards and the refineries capable of aligning to the international/European standards when it comes to fuels and engines, which require further development.

Australia’s decarbonisation journey should be weighted between fuel security and food security strategies and offer producers seamless transitions to production, fuel inputs and economic markets.

To reach our carbon neutral targets, supply chains need to be smaller and more localized. We have to start small if we want the biofuel blend industry to evolve, grow and achieve our longer term objectives.

7. Where do you see customer demand for sustainable liquid fuels, with reference to different fuels and industry sectors?

Australia’s agriculture sector has a strong need for an easily adaptable and accessible biodiesel/biofuel blend product, interchangeable to existing diesel engines.

Agriculture consumes large amounts of fuel to produce the food and fibre we require.

If a solution is presented that is of equal performance and cost, it will be quickly taken up.

Australia is an island with an advanced agricultural system. We have an opportunity to build fuel security and food security, by developing policy and business modeling for the commercialisation and operation of bio-circular, biofuel blend market economies in every region.

(Refer answers to question 1&5),

8. What do you/your customers need now, and what will you require in the future?                                                                                                                                  

Agriculture requires the highest protections being applied for the safety and privacy of farmers, agricultural production and protection of prime agricultural land output.

Recognizing that there is only limited arable land in the state. We advocate for government policy that limits or removes opportunity cost of renewable energy development over agriculture development; that grows and protects our prime agriculture land and improves production systems to ensure future fuel and food security into the future.

Short to medium term government policy intervention and overarching business modelling is required to progress the maturity of a renewable fuel market and supplement its entry over a 50-year period, ignoring excises and duties until the market is mature.

Government to initiate and develop the infrastructure required for a liquid fuels market, including ensuring market access, a guaranteed market, consumers and a guarantee of supply and cost competitiveness.

9. What do you consider to be the most fundamental barriers to sustainable liquid fuel uptake? Do you expect these barriers to change over time?

There are no true barriers provided government policy is used in conjunction with government investment to support industry development and market conditions over the long term ie, infrastructure development, rural and regional bio-refineries, etc.

While agriculture has the capacity to grow in size and provide the feedstock required for a biofuel blend market; agricultural restrictions, red and green tape and infringement on prime agricultural land access by other sectors will require repeal consideration for the agricultural sector to support net zero emissions and biofuel blend objectives.

10. How do you think potential feedstock or production trade-offs should be managed to prioritise resources where competition exists between transitional and emerging sustainable fuel types?

It is not a question of trade-offs or a barter system between feedstock suppliers and customers.

The agricultural industry needs to grow considerably to account for the increase in feedstock inputs required to support the domestic market before it can consider being competitive globally.

Both sugar cane production and grain production in Queensland, and much of the country has capacity to provide an increase in the feedstock required to support a domestic market, and perhaps overtime a global market.

(Refer answers to question, 5,8 & 9).

11. Does the lower carbon content of sustainable fuels justify a cost premium relative to traditional fuels? If so, what is the value proposition?

Agriculture is a price taker and has limited capability to transfer the cost of production. This would directly affect the consumers’ cost of living pressures and force agricultural/family businesses and communities into bankruptcy.

The value proposition is – take the producer on the journey and support agricultural growth and development.

Australia’s ideal climate, mature and modern agricultural industry, well established supply chains, highly skilled workforce and innovative research institutions are adaptable and can ensure adequate feedstock supply is produced to meet the state’s biofuel blend market needs while meeting lower carbon objectives.

12. Are there any fuels that should be prioritised on a ‘least regrets’ basis?                                                                                                                                  

Biodiesel, biofuel and bioethanol/ethanol from grain and cane, specifically SCT; with purpose-built bio-refineries production plants located rurally and regionally where feedstock input and transport networks is readily accessible.

(Refer answer to question 5)

13. Are the existing mandates supporting the uptake of sustainable liquid fuels? If so, how can they be improved? If not, what should change?

Adoption by government of a policy only solution, such as the ethanol fuel mandate, does not guarantee supply and only achieves dependance on an alternative fuel market outside of Australia.

In the past, AgForce has been supportive of progressive biofuel/biodiesel mandates that increase over time. However, for an industry in the introduction/growth phase for it to flourish and grow, it must have a guaranteed market/access, supply, consumers and infrastructure support, similar to the USA, EU, Brazil, India models.

(Refer answer to question 8)

14. What other policy or regulatory options should be considered?   

A balance between government policy versus ‘government-initiated business modelling’ of the biofuel sector; investment and infrastructure development. Regulation that establishes a guaranteed biofuel market - supply and demand frameworks.

“Government initiated business modelling”: agriculture needs to know how much feedstock to produce and be allowed to grow and have supply agreements in place before industry can meet the demand of the end product user. The end product must be an affordable input cost if it is to return to the agricultural, transport or other hard to abate sectors.

(Refer answer to question, 8, 9 and 13

15. How should the strategy interact with Australian Government commitments? 

An alignment or compliment of State government policy to the Australian government proposed definitions regarding the nation’s greenhouse gas emissions reporting and also the sets technical fuel standards and the fuel excise and duty rates for petroleum and sustainable liquid fuels and the rules for fuel tax credits, which influence the relative costs of petroleum liquid fuels to sustainable liquid fuels.1

Such policy alignment should seek to ensure the growth and increase of agricultural production and productivity that supports future feedstock demands of fuel security and of food security into the future.

Low emissions objective or a biofuel blend mandate should not supersede a food security/policy position of government or infringe on the rights of land holders, growth of agricultural production or the network of supply chains in Australia.

16. Do any of the following act as an enabler or a barrier to using sustainable liquid fuels in your industry/business? Industry standards, Australian Government standards, International standards or State regulation or policy?

The food versus fuel debate: proven fact – sustainable biofuels do not compete with food crops.

Biofuel blends now have many possible feedstocks inputs and alternatives, including second generation sources. Although an assessment into the profitability of biofuel production, the value of co-products and the amount of stockfeed required to produce the required biproduct output, must also be formulated and made publicly available for industry consideration.

An example of co-products, corn-based fuel ethanol manufacturing produces dried distiller’s grains (DDGs) while biodiesel production from soybeans results in soybean meal, and the biproduct of the biproduct from the starch of second grade wheat (used to produce ethanol) creates high protein pelletised stock feed for the feedlot industry.

(Refer answers to questions, 9 & 10)

1 Sustainable liquid fuels strategy - options and opportunities paper (

17. What is needed for you to produce/ invest/use sustainable liquid fuels in Queensland?    

For Australia to build a biofuel industry it needs to achieve emissions targets, it requires significant investment in the construction of biofuel refinery and production facilities in rural and regional hubs, with access to multiple feedstock inputs and technologies and with government regulation to support the establishment of a long-term guaranteed buyers’ market.

This investment should also ensure training and skills development occurs locally.

Preparing for the multiple factors effect of biofuel production, such as feedstock cost, operational costs, market pricing and profitability of production constraints.

Better collaboration with industry partners in agriculture, better public reporting on return of government investment. Including feedback to industry on projects already initiated into bio future projects or other renewable energy programs, which may help producers and industry better participate in the solution to liquid fuel strategy for the state.

(Refer answers to question, 1,5)

18. What lessons can we learn from other Australian states or internationally about the future fuels transition?

The need for robust government policy that supports and strengthens the economic case for biofuel consumption commercially.

Fuel taxation levels that influence price competitiveness at the pump and hence consumer choices.

In many countries ethanol benefits from preferential federal and state taxation rates being lower, as and when taxation rates on ethanol are raised; these countries protect the market by raising taxation rates on standard petroleum even more.

AgForce thanks the department for the opportunity to contribute to this submission and is committed to collaborate with government, farmers and other industry representatives to be the conduit of information and offer solutions to improve agricultural outcomes and progress commercialisation of renewable fuels strategies in regional areas, in line with the government's net zero emissions objectives, for the benefit of future fuel and food security and for generations to follow.

If you have any questions or require further information regarding this submission, please contact Sam Forzisi, AgForce Policy Director, by email:, or mobile: 0499 960 006.

Yours sincerely

Michael Guerin

Chief Executive Officer