Ref: MG/AF/GG23078

7 December 2023
Department of Resources

By Email:

Dear Sir/Madam

Re: Improved Regulatory Efficiency
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 Resources in response to the Improved Regulatory Efficiency Consultation Paper. As communicated to the Queensland Government previously in relation to land uses that compete with agriculture, such as renewable energy projects and small-holder mining, AgForce stands by Board-endorsed Land Use Protection Principles (see Appendix 1). In line with these principles, AgForce supports Queensland Government in proactively engaging with impacted agricultural stakeholders.

AgForce does not take issue with most of the recommendations within the consultation paper, although would like to make the below comments:

Tidy Surfaces of Mining Leases
AgForce supports the amendments proposed however, would like to see that fire management becomes a condition of a fossicking permit and that a minimum 10 metre firebreak be maintained around camps and infrastructure at all times. This is to ensure landholders are not left to deal with unmanaged camping areas from fossicking activities.
Streamlined Aerial Surveying Requirements
AgForce has concerns with the proposal to provide Exemption from Entry notices to landholders for aerial surveying over 1,000 feet. Awareness around seasons and operations is critical to the understanding of why this is such a concern to livestock producers. At the end of year, conditions are generally drier throughout Queensland and most producers run their organisation for cows to calve from say July – December (depending on location). This therefore means that cows and calves, as well as store cattle, are in a weaker condition at this time of year as cows in particular are lactating and supporting a calf. AgForce does not intend for this example to insinuate that any other time of year would be more appropriate, or if the surveying was done in an area with different livestock, such as sheep or goats.

Furthermore, allowing aircraft to fly slowly at 1,000 feet over livestock for any other reason than for mustering done by experienced pilots who are trained to work cattle from the air, unlike surveying pilots, will mean that livestock will be spooked and run, which could potentially lead to them overheating and dying. In the summertime the death rate would be catastrophic and be in conflict with the Animal Welfare Act.1 AgForce recommends that the requirement for resource authority holders conducting aerial surveys, to submit entry notices, periodic entry reports and Conduct and Compensation Agreements where necessary, remain for all flights.

AgForce thanks the Department of Resources for the opportunity to provide feedback and looks forward to continued engagement to better practices for all stakeholders involved.

If you have any questions or require further information please contact Anna Fiskbek, Policy Advisor by email or mobile: 0407 813 470.

Yours sincerely

Michael Guerin
Chief Executive Officer Enc


Appendix 1: AgForce Land Use Protection Principles
As the body for agriculture, AgForce requires that alternative and potentially impacting land uses ensure:
  1. There is recognition that natural capital has an inherent value
  2. Human health and well-being must not be sacrificed
  3. A precautionary approach that avoids negative legacy effects on natural resources including air, soil, water and biodiversity
  4. There are no negative impacts on existing or future sustainable agricultural opportunities


    • Recognize that resources are finite
    • All projects are assessed on environmental, social and economic criteria
    • There is a formal mechanism for agriculture to be involved in assessment
    • Projects should not be assessed in isolation and cumulative impacts assessed
    • Potential impacts need to be objectively and accurately quantified, rigorously and independently reviewed
    • Agricultural landholders to have equal representation, available resources and bargaining power


    • All projects must have comprehensive monitoring and transparent reporting
    • Non-compliance will trigger cease work
    • Enforcement is primarily the responsibility of government, but landholders must have a right to compel action
    • Industry and Government must proactively identify and manage cumulative impacts, both individual project cumulative impacts and multiple projects cumulative impacts


  • Land needs to be rehabilitated to be the pre-existing natural conditions
  • Financial assurance needs to be adequate for rehabilitation