17 December 2025
Committee Secretariat
Health, Environment and Innovation Committee
Parliament House
George Street
BRISBANE QLD 4000
By Email: HEIC@parliament.qld.gov.au
To Whom It May Concern,
Re: Environmental Protection (Efficiency and Streamlining) and Other Legislation Amendment Bill 2025
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.
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 refer to AgForce’s Land Use Protection Principles (Appendix 1), as endorsed by the AgForce Queensland Farmers’ Limited Board, that are presented as Queensland’s broadacre agriculture industry’s expectations when working to achieve coexistence with other business sectors.
AgForce welcomes the opportunity to provide feedback on the Environmental Protection (Efficiency and Streamlining) and Other Legislation Amendment Bill 2025 (‘the Bill’).
Environmental Protection Act 1994 (Qld)
Currently, environmentally relevant activities (ERAs) are regulated through an environmental authority (EA) assessment and approval process, which provides regulatory visibility, environmental safeguards, and certainty for landholders and regulators, alike.
The Bill proposes to expand the use of self-assessable codes for low-risk ERAs, replacing individual environmental authorities in certain circumstances. While AgForce acknowledges the intent to streamline regulation, there are significant concerns regarding oversight, compliance and enforcement under a code-based model.
In particular, the Bill does not provide for a publicly accessible or departmental register of code-assessable ERAs. Without such a register:
- the Department may have limited visibility of what activities are occurring, where they are occurring, and when they commence;
- effective compliance monitoring and risk-based enforcement will be undermined;
- cumulative environmental impacts may go unidentified; and
- landholders and neighbouring producers may face increased uncertainty and reduced transparency.
This lack of regulatory visibility creates risk not only for environmental outcomes, but also for primary producers whose land, water or operations may be affected by nearby ERA activities.
Recommendation:
AgForce strongly recommends that a mandatory register of code-assessable ERAs be established. Such a register should record the location, nature and commencement of code-based activities. This will:
- support effective environmental oversight and enforcement;
- enable appropriate risk-based compliance responses by the Department; and
- protect the interests of AgForce members and other rural landholders by improving transparency and accountability.
Water Act 2000 (Qld)
The Bill proposes to extend the Underground Water Impact Report (UWIR) cycle from three years to five years.
The UWIR is a critical tool for:
- identifying groundwater impacts from resource activities;
- modelling risks to aquifers and connected water resources;
- enabling adaptive management to minimise harm to environmental values and landholder water supplies; and
- reviewing and updating monitoring and management strategies within cumulative management areas.
Importantly, changes to monitoring and management arrangements for cumulative management areas can only be made through the UWIR process. Extending the cycle to five years significantly reduces the system’s responsiveness to emerging impacts.
AgForce is strongly opposed to extending the UWIR cycle from three to five years because:
- it diminishes adaptive management capability;
- it increases the risk that impacts to groundwater and dependent primary production businesses and regional/rural communities will go unmanaged for longer periods;
- it may delay identification and remediation of impacts affecting landholders’ water supplies; and
- it is likely to result in poorer environmental and landholder outcomes.
There is already provision under the Water Act 2000 for a responsible entity to apply for an extension of time to prepare a UWIR in special circumstances. This existing flexibility makes a blanket extension to five years unnecessary.
Recommendation:
AgForce considers the proposed five-year UWIR cycle to be unjustified and potentially detrimental to both environmental values and landholder interests, and strongly recommends the retention of the current three-year cycle.
Nature Conservation Act 1992 (Qld)
AgForce has the following concerns regarding the proposed and associated amendments to the Nature Conservation Act 1992 (‘NCA’):
- Reclassifications of fauna and flora species must be clearly communicated and easily accessible to landholders. AgForce recommends that all relevant reclassifications be reflected in the vegetation management report available through the Department of Natural Resources and Mines, Manufacturing and Regional and Rural Development website so landholders can readily understand their obligations.
- Routine and sustainable land management practices associated with broadacre agriculture must not be adversely impacted by flora and fauna reclassifications. Normal grazing, cropping, infrastructure maintenance and land stewardship activities should not be unintentionally captured by conservation regulation.
- Primary producers already operate under overlapping environmental and vegetation management frameworks. AgForce strongly advocates for streamlining and alignment of environmental and vegetation management regulation and opposes the duplication or creation of inconsistent regulatory regimes.
Recommendation:
AgForce emphasises that conservation outcomes are best achieved when regulation is coherent, practical and proportionate, and when landholders are supported as conservationists rather than over-regulated through layers of red-tape.
Conclusion
AgForce urges the Queensland Government to adopt the recommendations outlined above to ensure that the amendments proposed in the Bill:
- protect environmental values through effective oversight and adaptive management;
- maintain transparency and accountability in regulatory systems; and
- support the ongoing viability, resilience and stewardship role of broadacre agriculture in Queensland.
AgForce thanks the Health, Environment and Innovation Parliamentary Committee for the opportunity to provide feedback and looks forward to continued engagement to positively improve practices for all stakeholders involved.
If you have any questions or require further information, please contact AgForce Policy Advisor Anna Fiskbek by email fiskbeka@agforceqld.org.au or mobile: 0407 813 470.
Sincerely,
Niki Ford
Chief Executive Officer