Ref:  MG/AF/GG23064
13 October 2023
Energy Queensland
PO Box 1090
Townsville  QLD  4810
To Whom It May Concern

Re:        Consultation in to the Regulatory Proposals for the Ergon Energy Network and Energex 2025-2030 Draft Plans

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 6,000 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.

AgForce welcomes the opportunity to present this submission to Energy Queensland following the publication of the Ergon & Energex 2025-30 Draft Plans.

AgForce stands by its Board-endorsed Land Use Protection Principles (see Appendix 1); and in line with these principles, AgForce supports Energy Queensland in proactively engaging with impacted agricultural stakeholders.

AgForce recognises that the use of tariffs is necessary for Ergon to maintain economic viability and to maintain and increase supply of power distribution.  However, we are concerned that an increase in tariffs will cause significant disadvantage to our members who are often unable to better utilise renewable energies, or change their energy usage patterns compared to other customers.  

Many of our members rely on electricity for sheds, bores and irrigation purposes and for private residences and accommodation dwellings.
Furthermore, for most primary producers there is no option to change their energy usage patterns, to better optimise off-peak tariff times, due to their operating structure and business needs.  For example, the below activities still rely on an electricity supply:
  • Broadacre cropping members irrigate and/or harvest water flows 24 hours/7 days a week, several times per year; and
  • Some livestock producers have on-site abattoirs that require large cold rooms to be running 24 hours/7 days a week.
The Single Wire Earth Return (SWER) system also prohibits our members from better utilising solar energy because there is a restricted 5kw system limit to the Ergon network; and where energy generated by solar, that could be fed back into the grid, is restricted to 1.5kw to 2.0kw.  This limits relief to primary producers in counteracting the increased costs for energy usage.

Whilst AgForce recognises the importance that renewables play in our energy supply, it must be recognised that our members face barriers with the change to the reliance on renewable energies and the push to ‘electrification of everything’.  The push to electric vehicles is unsuitable to rural and regional residents as not all electric vehicles are able to be charged with SWER systems, with many on-farm transformers being of insufficient capacity to support vehicle charging, in addition to existing use.  Furthermore, our members face frequent power outages, making any reliance on electric vehicles impractical. 

However, our members are aware that the change to electric vehicles is a reality of the future, with electric buggies and motorbikes already prevalent in the market.  This necessarily means that there will need to be transformer upgrades in rural and regional areas so that our members are able to make the shift to electric vehicles and machinery, without interfering with the power supply to residential dwellings.

AgForce endorses Ergon’s investment priorities, especially to replace power poles, as AgForce members have commented that often infrastructure is not maintained in rural areas.  For example, members have reported that overhead powerlines have sagged in areas where machinery was once able to pass underneath without obstruction, but where they are now hanging too low for the same machine to pass under.  This creates huge safety concerns for machine operators and logistical issues for business operations.

AgForce endorses Ergon’s priority to reinforce the distribution network, as often primary producers will incur lengthy unplanned power outages due to pole and wire failures.  

However, with an increase in maintenance on poles and wires, there will necessarily be an increase in access to properties.  A key policy priority of AgForce, is to ensure that anyone with legal access to rural properties, must abide by farm gate signage and property biosecurity plans, which should either be developed by, or in consultation with, the landowner.

Ergon employees/contractors should be trained to ensure compliance with Queensland's Biosecurity Act 2014, including a comprehensive understanding of the general biosecurity obligation (GBO); and when Ergon advises the landholder that they intend to enter a property, it would be desirable for Ergon to also record what weeds are already present on site.
Under the Queensland government’s GBO, everyone is responsible for managing biosecurity risks that are under their control; and to the best of their ability, recognise and minimise biosecurity risks within their industry, places of work, or places they visit.

In conclusion, AgForce endorses and advocates for a ‘no worse off’ policy for its rural members and their energy supply.  
AgForce thanks Energy Queensland for the opportunity to provide feedback and looks forward to continued engagement to better practices for all stakeholders involved.

Should you require further information, please do not hesitate to contact Anna Fiskbek, AgForce Policy Advisor, by email: or 0407 813 470.
Yours faithfully
Michael Guerin
Chief Executive Officer