Ref: MG/AF/GG25004
6 June 2025
Renewable Energy Planning Group
Department of State Development, Infrastructure & Planning
BRISBANE QLD 4001
By Email: renewablesplanning@dsdilgp.qld.gov.au.
Dear Sir/Madam
Re: Proposed Development Assessment (DA) Rules
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 $11.2 billion in on-farm value of production in 2022-23. 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.
Thank you for the opportunity to provide comment on the proposed development assessment rules, namely the proposed State Code 26 – Solar Farm Development.
AgForce has a strong policy position on representing members’ interests in the protection of land use and is supportive of efforts by all authorities, at federal, state and local levels, that enable the effective coexistence of agriculture with other forms of land use. Please see Appendix 1 where the Land Use Protection Principles of AgForce members, as endorsed by the AgForce Queensland Farmers’ Limited Board, are presented as an overall expectation of what broadacre agricultural industry commits to when seeking coexistence with other sectors.
AgForce has not commented on all topics covered within the Draft State Code 26.
1. Agricultural Land
AgForce agrees and endorses Performance Outcomes 2-3 however, we would like to see Performance Outcome read that there will be no loss of high-quality agricultural land.
2. Protecting Water Quality and Stormwater Management
AgForce would like to see some qualifying criteria that interference with farm drainage and irrigation infrastructure should only occur at the last resort after all other avenues are excluded. We would also like to see the host landholder be the decision-maker as to how and where any interference with farm drainage or irrigation infrastructure will occur.
Regarding Performance Outcomes 7-9, AgForce would like consideration given to how liability can be determined should the solar farm be non-compliant with the Reef Regulations as this would be an unfair liability for the landholder of the project site to bear (if they are different to the solar farm developer/owner).
3. Acoustic Amenity
AgForce has similar concerns regarding acoustic amenity as was raised in our submission to State Code 23.1
In regard to Performance Outcome 12, AgForce would like to see that noise monitoring continues once the project is operational and that the predicted acoustic levels are not the sole determinant of whether the project is complaint with the Environmental Protection (Noise) Policy 2019.
4. Visual Amenity, Glint and Glare
AgForce would also request neighbouring landholders be afforded consideration within Performance Outcomes 13-15 as they will also be subject to negative impacts on their visual amenity and potential experience of glint and glare should the solar farm be located close to their boundary.
5. Electromagnetic Interference
AgForce would like to see a detailed Electromagnetic Interference (EMI) report which outlines mitigation and management measures to ensure the project does not result in unacceptable EMI impacts be a condition of approval for the proponent. UHFs and VHFs are a vital resource to landholders, especially during mustering/harvesting. They are critical in communications between workers on the ground and helicopters in the sky, in some cases they can even be lifesaving. Mobile phone use, as it increases in network, is also critical to operating. AgForce would like to see that within the EMI report submitted by proponents it is mandatory to include interreferences with UHF, VHF and mobile devices used by landholders as well as basic communications such as television and satellite internet to be considered.
6. Decommissioning
AgForce has similar concerns regarding decommissioning as was raised in our submission to State Code 23.2
Whilst we appreciate that Performance Outcome 28 mentions that decommissioning plans should be secured by bonds or financial guarantees, AgForce would like to see some criteria that these bonds or financial guarantees are obtained from reputable financial institutions prior to construction of the project.
7. Other
AgForce would like some consideration afforded to reducing negative financial impacts on neighbouring landholders to solar farms. Should a solar farm be located in close visual proximity to a neighbouring property’s boundary or homestead, compensation should be afforded to the neighbouring landholder for loss in equity to their land as this could have devastating impacts on borrowing capacity and their ability to run their agricultural operation to its potential.
AgForce thanks the Department of State Development, Infrastructure & Planning 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: fiskbeka@agforceqld.org.au or mobile: 0407 813 470.
Yours sincerely
Michael Guerin
Chief Executive Officer
1 https://www.agforceqld.org.au/knowledgebase/article/AGF-01846/
2 https://www.agforceqld.org.au/knowledgebase/article/AGF-01846/