Ref:  MG/AF/GG23073

13 November 2023
Department of Industry, Science and Resources  
Online & by Email:
Dear Sir/Madam

Re:  Future Gas Strategy

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 make this submission to the Department of Industry, Science & Resources in response to the Future Gas Strategy Consultation Paper.  AgForce would like to draw attention to AgForce’s Board-endorsed Land Use Protection Principles (see Appendix 1), which relate to land uses that compete with agriculture, such as renewable energy projects and small-holder mining.  In line with these principles, AgForce supports the Federal Government in proactively engaging with impacted agricultural stakeholders.
AgForce believes that a proactive approach is required when engaging with rural landholders and draws the Department’s attention to the Queensland government’s upcoming review into co-existence institutions and CSG-induced subsidence management framework, which has close links to developing the Future Gas Strategy.

Biosecurity Concerns of Landholders
Gas exploration, extraction and processing have inherent biosecurity risks.  With gas projects advancing ever more into agriculturally productive areas, government has a role to ensure that resource companies liaise with agricultural landholders; who are often the most directly impacted by biosecurity incursions.  While it is the responsibility of corporations and individuals to operate in accordance with the general biosecurity obligation (GBO) under Queensland's Biosecurity Act 2014, government at all levels can play an important role in ensuring biosecurity risks are comprehensibly assessed and mitigated for as part of the project approval conditions.  Conditions must include development of biosecurity prevention and response preparedness plans, created in consultation with agricultural landholders.  There is also an ongoing role for monitoring compliance with these plans.   
How can the Australian Government better communicate and provide more transparency to local communities regarding gas projects?
AgForce recommends that the Australian Government should provide a layer on a National Mapping tool which provides timely details of every gas well, including the Environment Protection & Biodiversity Conservation Act 1999 (‘EPBC Act’) project, which authorises each well.  AgForce also advocates for a system to be developed which can generate a report that lists wells in order of production commencement date.  This transparency is essential for landholders to have assurance that wells are being lawfully operated by tenure holders.  Some AgForce members who are host landholders have been waiting for 18 months for the Department of Climate Change, Energy, the Environment & Water (DCCEEW) to inform them which wells operating on their land are authorised by Arrow Energy Project EPBC2010/5344 and which are authorised by Arrow Energy Project EPBC2010/5343, as these projects are co-located.  Failure of DCCEEW to provide such basic information is unacceptable and hinders relationships with host landholders and deteriorates community sentiment.

Additionally, AgForce would also like to see that the economic impacts to agricultural natural capital and the social impacts to agriculture and agricultural communities are quantified amongst other economic issues so that there can be a clear and quantitative assessment of the impacts.

What opportunities exist to improve engagement and consultation processes with industry?
Many AgForce members are users of Matters of National Environmental Significant (MNES) water as they use groundwater, surface water and overland water for their operations.  Currently the Australian Government provides no education or factsheets on how the EPBC Act may protect users of MNES water.  Such education could be provided through face to face and online materials and through the use of webinars which should, address the risks related to the application and dispersal of chemicals into soils, surface water, ground water and the organisms therein.
AgForce advocates for water monitoring and management plans (WMMP) and the amendment of those plans should be available for public consultation prior to approval.  We see that it should be mandatory for proponents preparing WMMP to engage agricultural experts with experience in the locality of the proposed project development to advise on relevant MNES water implications to agricultural users of water.
Topographical (LiDAR[1]) data captured by contractors engaged by gas miners together with metadata and associated data, should be required as part of the project conditions to be provided directly to landholders without further processing by the gas miner within 3 months of data capture, as MNES water is impacted by topographical changes from subsidence caused by conventional and unconventional gas mining and landholders are best positioned to detect adverse changes to landform.

How can all levels of government better support the industry to engage with First Nations people and community groups.
AgForce takes issue with the fact that there was a complete failure to consult with the agricultural industry.  AgForce finds it bewildering that environmental advocacy groups and unions are considered stakeholders, yet the agricultural industry is not.  Host landholders should not be grouped in with community and the general public, as the host landholder has interests at stake that are far beyond those of the community and general public.  In order to better engage with First Nations people and community groups, the Australian Government should operate a robust, transparent and active oversight and compliance framework which it complies with.  The resulting increase in compliance would improve engagement with stakeholders.                                                                        
AgForce has taken the first step in preparing this submission and expects there will be further engagement and further consultation, of which AgForce expects to be a part of.  It is through effective consultation with landholders that more informed decisions are made.  Furthermore, AgForce would advocate for better communication between landholders and the coal seam gas industry moving forward.
How can the Australian Government better communicate and provide more transparency to local communities regarding Carbon Capture and Storage (CCS) projects?
AgForce has major concerns with the proposed CCS projects.  Landholders and the risk such projects pose to agricultural production have been completely excluded from the discussion paper.  The fact that landholders have not been given a say regarding projects which have the ability to completely stop agricultural production is bewildering.  There appears to be a complete omission to recognise the Commonwealth Government’s priority to increase agricultural production to $100 million by 2030.[2]

AgForce see that CCS projects must have strict controls with visible oversight and regulation.  It requires rigorous baseline information, relevant and timely monitoring and measurement and controls to protect existing food and fibre production and agricultural and community access to MNES water.  The Future Gas Consultation Paper omits a cost benefit analysis and risk assessment of adverse impacts to agricultural land use.  AgForce sees that CCS is discussed in a misleading way as it fails to acknowledge that none of the commercial CCS projects operating in Australia have yet been proven to be commercially viable and CCS is still an experimental technology in commercial terms.
AgForce would also like to see independent reports as to the suitability of such aquifers for CCS projects as it would be extremely disappointing to see water suitable for livestock and cropping destroyed due to biased ‘expert reports’.

Gas Transportation and Infrastructure
AgForce again takes issue with the fact that landholders have been omitted from consultation on gas transport infrastructure.  In Queensland the extensive network of gas gathering and transport pipelines will generally remain in situ at end of project life with ownership retained by responsible tenure holders.  In practical terms landholders will be left to manage operations around this decaying network, including consequential changes to overland water flows.  The FGS must include a plan for rehabilitation of abandoned and disused pipeline networks and preservation of MNES water flows.

In conclusion, the consultation paper focuses on the benefit of international supply of gas whilst omitting all reference to the cost of the environmental impact of gas extraction and cost of impact upon current and future agricultural land use eg, draining of aquifers and release of toxic wastes, such as salt, into the environment.  There is no consideration of the risk of decline and permanent decline in agricultural production due to draining of water and subsidence of the land from unconventional gas mining.  This must be considered in the NGS. 
The paper admits that the overall contribution of gas to the energy supply is going to decrease over the coming decades and that our identified gas reserves will be depleted in about 18 years.  Hence, it must be recognised in the NGS that the underlying land use must be preserved and that the long-term ability of food and fibre production is protected to ensure intergenerational equity.  The consultation paper itself reiterates that gas is short-term, so it is critical that agricultural use of land is preserved.
AgForce thanks the Department of Industry, Science & Resources for the opportunity to provide feedback and looks forward to being part of the targeted stakeholder consultation.
If you have any questions or require further information please contact Anna Fiskbek, Policy Advisor by email: or mobile:  0407 813 470.

Yours faithfully
Michael Guerin
Chief Executive Officer
[1] Light detection and ranging (LiDAR) is a remote sensing method used to examine the surface of the earth.