Consultation report · 2018-03-19 · Consultation report . Strategic cropping land . ... submissions from the public by 12 March 2010. ... public briefings and presentations held

Consultation report Strategic cropping land draft policy and planning framework Results of the analysis of the submissions received on the draft Strategic cropping land policy and planning framework–discussion paper July 2010

Looking forward. Delivering now. The Department of Infrastructure and Planning leads a coordinated Queensland Government approach to planning, infrastructure and development across the state.

© State of Queensland. Published by the Department of Infrastructure and Planning, July 2010,100 George Street, Brisbane Qld 4000.

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Contents Contents .........................................................................................................3 Introduction....................................................................................................4 Consultation program ...................................................................................4

Briefing sessions..........................................................................................4 Discussion paper .........................................................................................5

Review of submissions received..................................................................5 Review process ...........................................................................................5 Submissions format .....................................................................................5 Classification of submissions.......................................................................5 Analysis of responses to the discussion paper ............................................6

Results of submissions analysis..................................................................6 Question 1: Are the criteria on page 4 of the discussion paper appropriate

for defining strategic cropping land?........................................................7 Question 2: What planning principles should be included in a new state

planning instrument for strategic cropping land? .....................................8 Question 3: What amendments should be made to the Mineral Resources

Act 1989 and the Petroleum and Gas (Production and Safety) Act 2004 to protect strategic cropping land?...........................................................9

Question 4: Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities?.....................................................10

Question 5: Should mining proposals be assessed on all classes of strategic cropping land? ........................................................................12

Question 6: Should all development proposals on strategic cropping land be assessed using common guidelines? ...............................................13

Question 7: How should permanent plantations for carbon sequestration on strategic cropping land be assessed? ...................................................15

Appendix 1: Issues and questions raised by participants at briefing sessions ................................................................................................16

Appendix 2: Summary of responses to questions 1, 4, 5 and 6.................18 Appendix 3: Summary of issues raised by respondents to the SCL

discussion paper....................................................................................19

Consultation Report Strategic cropping land policy and planning framework

3

Introduction The Queensland Government considers that the best cropping land, defined as strategic cropping land (SCL), is a finite resource that must be conserved and managed for the longer term. As a general aim, planning and approval powers should be used to protect such land from those developments that would lead to its permanent alienation or diminished productivity.

On 10 February 2010, the Queensland Government released the Strategic Cropping Land–Policy and Planning Framework discussion paper (www.dip.qld.gov.au/croppingland) and called for submissions from the public by 12 March 2010. During the submission period briefings and presentations were delivered to regional stakeholder groups and public information sessions were held state wide at several regional centres.

This report describes the consultation process and summarises issues raised by stakeholders who attended public meetings held across Queensland, as well as the issues raised in the formal submissions received in response to publication of the discussion paper.

Consultation program The consultation program consisted of:

public briefings and presentations held across Queensland during February and March 2010, including discussions with peak bodies with an interest in the development of SCL

release of a discussion paper on the SCL policy and planning framework on 10 February 2010 for public comment with submissions closing on 12 March 2010.

Briefing sessions Table 1 lists the dates, locations and number of people attending the briefing sessions held across Queensland.

Table 1: SCL briefings and presentations

Date Event No of people

8 February 2010 Queensland Resources Council 3 9 February 2010 Australian Petroleum Production & Exploration

Association 1

11 February 2010 Maranoa-Balonne Regional Planning Committee 20 15 February 2010 Regional Landscape Open Space Advisory Committee

(RLOSAC) 30

15 February 2010 Council of Mayors South East Queensland (CoMSEQ), Local Government Association of Queensland (LGAQ)

2

16 February 2010 Queensland Farmers Federation, Agforce, Future Food Queensland

4

22 February 2010 Public forum, Bundaberg 8 23 February 2010 Public forum, Rockhampton 18 24 February 2010 Public forum, Mackay 26 25 February 2010 Public forum, Townsville 14 26 February 2010 Public forum, Cairns 31 1 March 2010 Public forum, Ipswich 16 2 March 2010 Public forum, Toowoomba 60 3 March 2010 Public forum, Dalby 80 5 March 2010 Public forum, Emerald 100 6 March 2010 Public forum, Nambour 11 10 March 2010 Public forum, Roma 2 Total 426

Appendix 1 contains a summary of questions and issues raised at the public meetings.

http://www.dip.qld.gov.au/croppingland

Discussion paper A total of 389 submissions were received from farmers, farmers’ organisations, resource companies, peak industry bodies, government agencies, local and regional governments, public institutions, non-governmental organisations and others. The issues and concerns raised at the public meetings and in the submissions received are crucial to the development of the SCL policy framework and, to the extent possible, these will be addressed in the preferred policy framework.

Review of submissions received

Review process A submission review process was established to: consider all formal submissions received in an objective, equitable and fair manner provide guidance and advice to the Planning Minister in respect to preparing the final SCL

policy and planning framework. The submissions review process involved five steps: Step 1: Registration and acknowledgement of submissions Step 2: Classification of submissions Step 3: Analysis of submission issues Step 4: Evaluation and response to issues Step 5: Preparation of consultation report

All submissions were treated as confidential by the Department of Infrastructure and Planning (DIP). However, some submitters chose to make the contents of their submissions public.

Submissions format Submissions were received in a number of formats. A submission form was provided as a guide, asking for a response to seven key questions about the draft policy. A significant space was allowed to respond to each question, including provision for additional comments. In addition to the submission form, numerous submissions were received in the form of reports and letters, with some containing supporting documents and photographs.

Classification of submissions A total of 389 submissions were received, of which 273 submissions (70 per cent) were made by private individuals–overwhelmingly farmers and/or their representatives (Table 2). Non-government organisations provided 32 submissions (eight per cent). Farmers’ organisations accounted for 15 submissions, regional councils for 13 submissions and seven submissions were made by state government agencies.


5

Table 2: Classification of submissions

Classification of respondents Submissions

received State government agencies 7 Regional councils 13 Local governments 2 Farmers organisations 15 Individuals (farmers and representatives) 273 Sugar milling industry 3 Cane growers 3 Cane growers organisations 4 Forestry industry 7 Resources industry 9 Extractive industry 1 Non-government organisations 32 Farming businesses 11 Motor Trade Association 1 Religious organisations 1 Consultants (agriculture, planning) 4 Political (parties/members of parliament) 3

TOTAL 389

Analysis of responses to the discussion paper The submission form posed seven questions relating to the development of SCL. Questions 1, 4, 5 and 6 provided for a direct response by requiring the submitter to tick a box indicating their level of agreement with a question. These questions were:

Are the criteria on page 4 of the discussion paper appropriate for defining strategic cropping land?

Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities?

Should mining proposals be assessed on all classes of strategic cropping land? Should all development proposals on strategic cropping land be assessed using common

guidelines? A table classifying the direct responses to questions 1, 4, 5 and 6 is provided in Appendix 2. Space was also provided on the form for submitters to elaborate on their answers. It was noticeable that many submitters did not provide direct responses to the questions and instead chose to provide written comments. In this regard, the majority of respondents supplied extensive written comments on the questions posed.

Results of submissions analysis The 389 submissions were reviewed by departmental officers who recorded all issues raised and grouped the submissions into categories. The results of this analysis are summarised in the tables in Appendix 3. A summary of the issues raised under each question is provided below. The submissions received and the results of the submissions were not amenable to statistical analysis. For example, in some instances identical submissions were received from members of particular organisations or interest groups. This has had the effect of highlighting issues that may have otherwise been raised by a small number of other submitters. Regardless, all submissions were considered.

The main themes to emerge under each of the questions are summarised below. Issues are listed under each question as provided by submitters and do not always relate directly to the actual question posed.

Question 1: Are the criteria on page 4 of the discussion paper appropriate for defining strategic cropping land? Figure 1 shows the breakdown of the responses to Question 1. A table summarising the direct response totals to questions 1, 4, 5 and 6 is included as Appendix 2.

Figure 1: Summary of direct responses to Question 1

Do you agree with the proposed criteria to define strategic cropping land?

36

65

20 21

66

181

0

20

40

60

80

100

120

140

160

180

200

Strongly agree Agree Neither agree nordisagree

Disagree Strongly disagree No response or writtenresponse only

Su

bm

issi

on

s

The split between submitters who supported the criteria and did not support the criteria was roughly equal, with 26 per cent who agreed or strongly agreed and 22 per cent who disagreed or strongly disagreed. However, nearly half of the submitters (46 per cent) did not answer the question, opting instead to provide a written response or provided no response at all. Figure 2 summarises the written responses to Question 1 and the issues about identification of SCL. The definition of SCL was the issue that was of greatest concern. Over a quarter of the submitters stated that SCL should be more broadly defined, particularly to include marginal cropping land and grazing lands. A significant percentage (17.5 per cent) of the submitters felt that soil quality alone was insufficient as a criterion for identifying SCL, and 9.5 per cent believed that slope should not be used as a criterion since modern farming practices can overcome soil and slope limitations. Some submitters pointed out the link between particular crop and soil types, and that slope is actually of benefit for the growing of certain crops. Support was expressed for the inclusion of natural factors (11.6 per cent) and the natural environment (21.1 per cent) in the criteria for the identification of SCL. The inclusion of the economic viability of cropping as a criterion was raised by 13.6 per cent of submitters, while 18.3 per cent felt that land fragmentation should be avoided when cropping land is identified and mapped.


7

The potentially negative impact of development such as mining on water sources (rivers, streams, wetlands, and aquifers) was raised as an important issue in 13.9 per cent of submissions. Concern was also expressed about the accuracy of the mapping of SCL with 15.2 per cent of submitters indicating that improved mapping was essential.

Figure 2: Summary of written responses to Question 1

Criteria for the identification of strategic cropping land

26.0%

0.5%

17.5%

9.5%

1.3%

5.1%

11.6%

21.1%

13.6%

18.3%

6.2%

2.3%

13.9%15.2%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

Broad

en S

CL de

finitio

n

Narro

wer S

CL de

finitio

n

Soil q

uality

insu

fficien

t indic

ator

Slope

shou

ld no

t be

a cr

iterio

n

Use sc

oring

syste

m

Consid

er in

frastr

uctu

re a

vaila

bility

Consid

er n

atur

al fa

ctors

Consid

er n

atur

al en

viron

men

t

Consid

er e

cono

mic

viabil

ity o

f cro

pping

Avoid

land

fragm

enta

tion

Consid

er e

nviro

nmen

tal im

pact/

clim

ate

chan

ge

Recog

nise

regio

nal p

lan

Consid

er w

ater

impa

cts

Impr

oved

SCL

map

ping

Question 2: What planning principles should be included in a new state planning instrument for strategic cropping land? Figure 3 provides a summary of the principles and issues suggested by a considerable number of submitters. A quarter (24.9 per cent) of the submitters felt that SCL should be protected against all forms of development, particularly mining, and 20.1 per cent of submitters expressed concern over the impact of mining on water sources (rivers, streams, wetlands, and aquifers). Twelve per cent of the submitters suggested that buffer zones should be introduced to protect cropping land against mining, 12.9 per cent were completely opposed to mining on cropping land, 5.4 per cent wanted a moratorium on mining introduced, and 17.2 per cent were opposed to any kind of development on SCL. Nearly five per cent of the submitters regarded urban development as incompatible with SCL, 3.6 per cent indicated that alternative (non-cropping) land should be developed first, and the same percentage indicated that cropping land should be developed only if no alternative land was available.


Planning principles to be included in SPP

24.9%

20.1%

24.4%

2.3%0.8% 1.0%

4.9%

1.5%

3.6% 3.9%

12.1%12.9%

5.4%

2.6%

17.2%

3.6%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

Prote

ct S

CL ag

ainst

deve

lopm

ent

Asses

s im

pact

of m

ining

on

water

sour

ces

SCL is

a fin

ite re

sour

ce

SCL is

not a

finite

reso

urce

Allow h

ousin

g an

d infra

struc

ture

on

SCL

Allow d

evel

opm

ent o

f per

i-urb

an la

nd

Urban

dev

elop

men

t inco

mpa

tible

with S

CL

Preve

nt su

bdivi

sion

of cr

oppin

g lan

d

Develo

p alt

erna

tive

sites

first

Consid

er se

cond

ary e

ffects

of d

evelo

pmen

t

Buffe

r zon

es to

pro

tect

SCL fro

m m

ining

No m

ining

on

SCL

Mor

ator

ium o

n m

ining

Allow m

ining

subje

ct to

stric

t con

ditio

ns

No de

velop

men

t on

SCL (e

spec

ially

mini

ng)

Develo

p SCL

when

no a

ltern

ative

exis

t

Question 3: What amendments should be made to the Mineral Resources Act 1989 and the Petroleum and Gas (Production and Safety) Act 2004 to protect strategic cropping land? Figure 4 provides a summary of legislative amendments and issues raised. A range of opinions were expressed about amendments to legislation and policy with approximately 16 per cent of the submissions suggesting that SCL should be protected by law against development. A similar percentage indicated that current legislation is sufficient to protect SCL, 14.7 per cent believed that the current State Planning Policy 1/92- Development and the Conservation of Agricultural Land should be amended to protect SCL from other forms of development and 14.1 per cent indicated that equal rules should apply to all forms of development. Access and compensation arrangements were regarded as inadequate by 5.4 per cent of submitters and 5.1 per cent believed that landholders should be consulted in the development application process. Just over eight per cent of the submitters were of the opinion that SCL could be developed subject to strict rehabilitation requirements, 2.3 per cent thought that rehabilitation to the previous standard was not possible, 3.1 per cent wanted environmental impact statements (EIS) to apply to all development applications and 6.2 per cent supported the protection of water resources. Support (2.3 per cent) was expressed for the assessment of development applications by an independent body. A similar percentage supported buffer zones and the introduction of a moratorium on mining. Slightly more than two per cent of the submitters suggested that farmers should be the decision makers in relation to how their land is used.


9


Amendments to the Mineral resources Act 1989

15.7% 15.9%

14.1%14.7%

5.4%

8.5%

2.3%

6.2%5.1%

3.1%2.3% 2.3% 2.1% 2.3%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

14.0%

16.0%

18.0%

Prote

ct SCL

in Le

gislat

ion

Curre

nt le

gislat

ion

and

polic

y is a

dequ

ate

Apply

equa

l rule

s to

all d

evelo

pmen

t app

licat

ions

Amen

d cu

rrent

SPP 1

/92

Impr

ove

acce

ss a

nd co

mpe

nsat

ion a

rrang

emen

ts

Develo

pmen

t sub

ject t

o re

habil

itatio

n

Rehab

ilitat

ion to

sta

ndar

d is

not p

ossib

le

Prote

ction

of w

ater

sour

ces

Consu

lt lan

downe

rs in

app

licat

ion

proc

ess

EIS m

ust a

pply

to a

ll dev

elopm

ent

Inde

pend

ent a

sses

smen

t (ind

epen

dent

requ

ired)

Inclu

de b

uffe

r zon

es a

roun

d SCL

Mor

ator

ium

on

mini

ng le

ases

Let f

arm

ers

decid

e ab

out u

se o

f the

ir lan

d

Question 4: Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities? Figure 5 provides a summary of the breakdown of direct responses to Question 4. Considering the direct responses only, 57 (15 per cent) out of the 389 submissions strongly agreed or agreed that petroleum and mining activities should be treated differently to other mining activities. Seventy submitters (17.9 per cent) disagreed or strongly disagreed with the statement, 77 (19.7 per cent) neither agreed nor disagreed, while 183 (47 per cent) did not answer the question directly, opting instead to provide a written response. The written responses to Question 4 are summarised in Figure 6. Analysis of the written submissions reveals that 12.9 per cent of submitters thought that petroleum and gas activities should be treated differently to mining, while 19.8 per cent were of the opinion that petroleum and gas should be treated the same as other mining activities. Just under 12 per cent regarded petroleum and gas extraction as having a lesser impact that other mining activities, while about three per cent believed that their impact was similar. A significant percentage of submitters (22.9 per cent) submitted that the impact of petroleum and gas activities on water resources must be considered when such development was assessed, with 16.7 per cent indicating that in their opinion petroleum and gas activities had a negative impact on water resources. About 10 per cent of the submitters were of the opinion that petroleum and gas activities should not be permitted on SCL and 4.9 per cent indicated that the impact of petroleum and gas activities on SCL should be minimised. Other issues identified included the need to deal with waste water (2.6 per cent), prohibiting the storage of salt water on cropping land (3.6 per cent) and the need for full rehabilitation of cropping land (1.8 per cent).


Should petroleum and gas activities be treated differently to other mining activities?

22

37

77

30

40

183

0

20

40

60

80

100

120

140

160

180

200



Su

bm

issi

on

s


Assessment of petroleum and gas activities compared to other mining activities

12.9%

19.8%

11.8%

3.1%

22.9%

16.7%

2.6%3.6%

10.3%

4.9%

1.8% 2.3%1.3% 1.0% 1.0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

P&G: tre

at d

iffere

nt to

mining

P&G: tre

at th

e sa

me

as m

ining

P&G hav

e les

s im

pact

than

mini

ng

P&G and

mining

hav

e im

pact

Consid

er P

&G im

pact

on w

ater

reso

urce

s

P&G det

rimen

tally

affe

cts w

ater

sour

ces

Deal w

ith w

aste

wat

er e

ffecti

vely

No sa

lt/salt

wat

er st

orag

e on

crop

ping

land

Prohibit

P&G e

xtrac

tion

on S

CL

Mini

mise

impa

ct o

f P&G e

xtrac

tion

Requir

e fu

ll reh

abilit

ation

of S

CL

P&G com

patib

le with

SCL

Consid

er cu

mula

tive

impa

cts o

f P&G

Consid

er im

pact

of P

&G infra

stru

ctur

e

Perm

it P&G p

rovid

ed n

o sa

lt wat

er st

orag

e


11

Question 5: Should mining proposals be assessed on all classes of strategic cropping land? Figure 7 provides a summary of the breakdown of the direct responses to Question 5. Support for the assessment of mining proposals on all classes of cropping land was strong with 163 submitters (42 per cent) agreeing or strongly agreeing. In comparison, 32 submitters (10 per cent) disagreed or strongly disagreed. However, 182 submitters (47 per cent) did not directly answer the question, opting instead to provide a written response. Analysis of the written submissions (Figure 8) reveals that 31.1 per cent of submitters were of the opinion that mining proposals should be assessed on all classes of SCL. Other issues raised under this question include broadening the definition of SCL (21.3 per cent), prohibiting mining on specific classes of SCL (14.1 per cent), and prohibiting development on all classes of SCL (12.6 per cent). Mining rehabilitation was identified as an issue with 14.1 per cent of submitters stating that mining rehabilitation was possible and acceptable and 13.4 per cent stating that the standard of rehabilitation had to be specified. By contrast, 10.5 per cent of the submitters were of the opinion that proper rehabilitation of mined land is not possible. Regarding rehabilitation standards, 5.1 per cent of submitters believed post-mining productivity of the land should be restored to the level that existed before mining took place. Further issues included imposing penalties in cases where land is not properly rehabilitated and the need to restore the topography of the land to the same standard that existed prior to mining.


Should mining proposals be assessed on all classes of strategic cropping land?

91

72

6 6

32

182

0

20

40

60

80

100

120

140

160

180

200



Su

bm

issi

on

s


Question 6: Should all development proposals on strategic cropping land be assessed using common guidelines? Figure 9 provides a summary of the direct responses to Question 6 and Figure 10 shows the results of the analysis of the written submissions on Question 6.


Seventy-three submissions (19 per cent) strongly agreed or agreed that development proposals should be assessed using common guidelines, while 68 submitters (17 per cent) disagreed or

Should all development proposals on strategic cropping land be assessed using common guidelines?

45

28

16

3731

232

0

50

100

150

200

250



Su

bm

issi

on

sShould mining proposals be assessed on all classes of cropping land

31.1%

21.3%

14.1%

12.6%

14.1%

10.5%

13.4%

5.1%

1.8% 1.3%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

Assessmining on all

classes ofSCL

Broadendefinition of

SCL

No mining onspecific

classes ofSCL

Nodevelopmenton all classes

on SCL

Miningrehabilitation

possible(conditional)

Miningrehabilitationnot possible

Specifystandards forrehabilitation

Equalproductivity,

post-rehabilitation

Penalties forineffective

rehabilitation

Return land tooriginal

topography


13

strongly disagreed. More than half of the submitters did not respond to Question 5 directly, opting instead to provide written comments.


Assessment of development proposals using common guidelines

20.8%

11.3%

8.0%

2.1%

10.3%

1.8%

4.6%

18.5%

22.9%

2.1%

15.2%

8.7%

22.4%

11.1%9.5%

8.2%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

Use co

mm

on a

sses

smen

t guid

eline

s

Use sp

ecific

ass

essm

ent g

uideli

nes

Prohibit

mini

ng &

dev

elopm

ent o

n SCL

Allow m

ining

and

dev

elopm

ent o

n SCL

Allow o

ffset

s

Offset

s sho

uld n

ot b

e all

owed

Rehab

ilitat

ion

to p

re-m

ining

stan

dard

Clarify

crite

ria a

nd d

efini

tions

Clarif

y "Pub

lic b

enef

it, ne

ed a

nd in

tere

st"

Exclude

"Pub

lic b

enef

it" a

s crit

erion

Consid

er e

cono

mic

trade

-offs

Econ/

envir

onm

enta

l impa

ct of

dev

elopm

ent

Consid

er so

cio-e

cono

mic

impa

ct of

mini

ng

Long

term

pub

lic in

tere

st in

guide

lines

Consid

er d

evelo

pmen

t of a

ltern

ative

site

s

Consid

er vi

abilit

y of u

sing

land

for a

gricu

lture

Assessment of development proposals using common guidelines was supported by 20.8 per cent of the submitters, while 11.3 per cent were of the opinion that development-specific guidelines should be applied. Eight per cent of the submitters supported a prohibition on mining and development of SCL, while 2.1 per cent believed that mining and development should be permitted on SCL. About 10 per cent of the submitters felt that offsets, for example, providing infrastructure in a specified area as a condition of development on SCL, should be allowed, while 1.8 per cent were of the opinion that offsets should not be allowed as a mechanism to obtain approval for the development of SCL. Slightly fewer than five per cent of the submitters suggested that once mining operations had ceased, SCL had to be returned to the same condition that existed before mining took place. Concern was expressed about definitions and terminology with 18.5 per cent indicating that definitions required further clarification, and 22.9 per cent requesting clarification of the term ‘public benefit.’ Regarding the potential impact of mining and development on SCL, 15.2 per cent stated that economic trade-offs between mining and cropping had to be considered, 9.7 per cent mentioned the environmental impact of development as a concern, over 22 per cent were concerned about the socio-economic impacts of development, particularly mining, on the farming community, 8.2 per cent suggested that the viability of using land for agriculture had to be considered before permitting development on SCL, and 9.5 per cent believed that alternative sites had to be considered before permission was granted for development on SCL.

Question 7: How should permanent plantations for carbon sequestration on strategic cropping land be assessed? Figure 11 provides a summary of the results of the written submissions on Question 7. A significant percentage of submitters (36 per cent) were of the opinion that plantations for carbon sequestration should not be permitted on SCL, while about eight per cent thought that forestry plantations (excluding carbon sequestration plantations) should be permitted on SCL. Nearly twelve per cent submitted that the development of plantations should be assessed in the same way to any other development. A small percentage (1.3 per cent) of submitters were of the opinion that plantations could be permitted on SCL subject to conditions and one per cent stated that forestry plantations should be regarded as cropping.

Figure 11: Assessment of permanent plantations for carbon sequestration

Assessment of permanent plantations for carbon sequestration

36.2%

7.7%

11.8%

1.3% 1.0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

No carbon plantations onSCL

Allow plantations on croppingland

Assess same as otherdevelopment

Permit plantations underconditions

Treat timber plantations ascropping


15

Appendix 1: Issues and questions raised by participants at briefing sessions

Overriding need in the public interest

What will be the criteria for defining whether development is in the overriding public interest?

How will the local economic benefit of mining be compared with that from agriculture? Concern that much of mining value heads overseas.

Criteria for Strategic Cropping Land

What is the difference between SCL and good quality agricultural land and land used for cropping?

Concern that only the high quality cropping land will be preserved and other good quality agricultural land will only be protected if local councils choose; potential for good quality agricultural land to be opened up for development and urban expansion.

Risk that future cropping lands may not be given protection under the policy because currently not supplied with infrastructure e.g. irrigation.

If a property is not included on the SCL map, is there a process to amend the map? Will there be a review of the good quality agricultural land maps to consider new

technologies that have enabled farmers to improve previously poor country into good cropping land.

Mining approvals

Will mining companies still be allowed to explore on SCL? Mining activity should be prohibited on SCL. There should be a moratorium on approvals until the framework is finalised. If the policy is not retrospective, how will it be applied to existing projects?

EIS process and rehabilitation

Will amendments be made to the EP Act as well as mining legislation? Who determines whether mining can achieve 100% rehabilitation of land productivity? Concern that some mining companies can operate without doing an EIS. Concern about enforcement of mining conditions. How will impacts of mining off-site e.g. salinity, water quality, subsidence, aquifers be

considered? Need to consider damage from underground mining as well as open cut. Subsidence has

occurred on land above underground mines.

Water

CSG has major impact and should be treated the same as mining. How will cumulative impacts be considered as part of a mining application such as impact

on groundwater aquifers and the Great Artesian Basin? Extraction of CSG water does not require an authority under the Water Act, but irrigators

require authorisation under WA to take groundwater. How is the issue of groundwater impacts being dealt with?


17

Planning and assessment processes

What is meant by permanent alienation of cropping land? Mining and urban development assessment should be kept separate as they are very

different land-uses. Will the new policy be applied to the statutory regional planning exercises about to

commence in CQ? What are the transition arrangements until the policy details are finalised? How will plantations for carbon sequestration on strategic cropping land be dealt with?

Other issues

Acknowledge that the new policy is a good start as the government has put agriculture in front of mining.

Local governments’ concurrence role in mining approvals. Could easements for infrastructure under various Acts be co-ordinated? Is compensation available to owners of GQAL adjacent to urban areas? Land access and exploration issues and impacts. Landholders need to view what

development applications are in the system at the moment. Inadequate consultation process: too short and inadequate notice. How will submissions be dealt with? What happens next?

Appendix 2: Summary of responses to questions 1, 4, 5 and 6

Received 389 submissions

Question no.

Question Strongly

agree Agree

Neither agree nor

disagree

Disagree Strongly disagree

No response

or written

response only

1 Are the criteria on Page 4 of the discussion paper appropriate for defining strategic cropping land?

36 65 20 21 66 181

4 Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities?

22 37 77 30 40 183

5 Should mining proposals be assessed on all classes of strategic cropping land?

91 72 6 6 32 182

6 Should all development proposals on strategic cropping land be assessed using common guidelines?

45 28 16 37 31 232

Note: Questions 2, 3 and 7 required written responses only.

Appendix 3: Summary of issues raised by respondents to the SCL discussion paper Question 1: Are the criteria on Page 4 of the discussion paper appropriate for defining strategic cropping land?

Issue Submissions

Broader definition of SCL required 101 26%

Include all three classes of agricultural land in SCL. Include all food producing land (grazing, beef and cattle feedlots). Include all land that would be SCL if irrigation was available. One encompassing class of SCL only—simplify to avoid confusion. Farmers must have right to have land included as SCL. Include marginal lands as SCL (technology can overcome limitations).

Narrower definition of SCL preferred 2 0.5%

Exclude GQAL from SCL. SCL must be the best of the best.

Soil quality insufficient indicator of good quality agricultural land 68 17.5%

Land productivity and yield must be taken into account. Some intensive crops grow well on low quality soils (melons).

Slope should not be a criterion 37 9.5%

Good cropping management can overcome slope. Slope a benefit for some crops.

Apply a scoring system for identification of SCL 5 1.3%

Apply a scoring and points/weighting system to identify SCL.

Infrastructure availability 20 5.1%

Identification of SCL must take account of existing infrastructure (roads and irrigation).

Include cropping land in proximity to agricultural related industry (e.g. sugar mills required by cane growers).

Natural factors to be considered in identification of SCL 45 11.6%

Climate, temperature, evapo-transpiration, rain days, days above 35 degrees, hours of sunlight, rainfall variability.

Consider natural environment 82 21.1%

Include areas to increase biodiversity. Include native refuges. Consider ecology.

Economic viability of cropping 53 13.6%

Economic return must be included as a criterion. All cropping that is economically viable must be classified as SCL. Land productivity determined by land quality, labour and capital

investment. Land values change over time.


19

Question 1: Are the criteria on Page 4 of the discussion paper appropriate for defining strategic cropping land?

Issue Submissions

Land fragmentation and land parcel size 71 18.3%

Fragmentation of SCL must be avoided. Protect mixed country (slopes and hills) against mining.

Environmental impact and climate change 24 6.2%

Take environmental impact into account when identifying SCL.

Regional planning 9 2.3%

Regional plan must be recognised. Ensure planning is at catchment or regional scale.

Water availability, water infrastructure and security 54 13.9%

Impacts on long term sustainability of SCL—water trading may result in land excluded from SCL.

SCL mapping 59 15.2%

Accurate and detailed mapping required. Must be open for evaluation. All criteria must be mapped. Property scale maps preferred. Distinguish between cropping and mining land. Maps must create certainty Trigger map—trigger step and process must be clear and accurate.

Question 2: What planning principles should be included in a new state planning instrument for strategic cropping land?

Issue Submissions

Protect cropping land against development 97 24.9%

Protect cropping land. No development on SCL. Prevent permanent impacts on cropping land. Maintain diversity of crops. Protect fertile soil as a non-renewable resource. Prevent diminished productivity or permanent alienation.

Assess off-site impact of mining on water sources 78 20.1%

Minimise or prevent off-site impact of mining on rivers, streams, wetlands, aquifers and underground water.

Water sources must be monitored. Assess impact of water pumped out of and seeping into mines. Undertake water impact monitoring to ensure compliance by mining

companies. Include protecting underground aquifers. Protect creeks and riparian areas.

Food security (finite vs non-finite resources)

SCL is a finite resource 95 24.4%

Food security and future food needs a critical consideration. Protect SCL for future generations. SCL irreplaceable—protect by law. Qld cannot afford to lose cropping land from production. Protect global food security. Protect domestic food supply. Keep a register of SCL.

SCL is not a finite resource 9 2.3%

Extent of SCL changes over time as result of new and improved technology and innovation.

Extent of SCL affected by infrastructure, rainfall, water availability, new crop types and new food technology.

Crops for fuel 4 1.0%

Do not allow crops for fuel on SCL as it removes it from food production.

Urban development and SCL

Allow housing and infrastructure on SCL 3 0.8%

Infrastructure and housing improve the quality of life of the population.

Allow development of peri-urban land 4 1.0%

Has potential for development. Strict application of SCL favours cropping over other land uses thus

excluding potential entrants and sunrise industries from an area. SCL will restrict urban development (Mackay/Whitsunday)—SCL land

already included in future urban growth area.


21

Question 2: What planning principles should be included in a new state planning instrument for strategic cropping land?

Issue Submissions

Urban development incompatible with SCL 19 4.9%

Protect SCL against urban development and other uses that may affect its sustainability.

Owners of SCL must be indemnified against legal action from urban neighbours.

Subdivision of SCL

Prevent subdivision of cropping land. 6 1.5%

Allow subdivision of cropping land. 1 0.3%

Consider alternative sites before developing SCL 14 3.6%

Consider alternative site for development before allowing development on SCL.

Take into account secondary effects of development 15 3.9%

Consider flow on effects. Consider conflicts of adjoining land uses.

Mining vs SCL

Apply buffer zones 47 12.1%

Buffers zones required to protect cropping from mining.

No mining on SCL/no mining on Classes one, two and three 50 12.9%

Exclude all types of mining from SCL. Sufficient coal resources available—no need to mine SCL. Alternative energy sources can be used. SCL must be exempt from mining. Mining destroys SCL. No need to dig up cropping land.

Introduce moratorium on mining 21 5.4%

Introduce moratorium on mining exploration and leases on SCL. Terminate mines that contravene EIS.

Allow mining subject to strict conditions

Permit mining on Class 3 subject to complete rehabilitation. 7 1.8%

Permit on Classes 2 and 3 subject to conditions. 2 0.5%

SCL Classes 2 and 3 permit gas and water only. 1 0.3%

Exploration on SCL Allow exploration on SCL. 5 1.3% No exploration on SCL. 3 0.8%

Compatibility/incompatibility between mining and SCL Balance can be achieved where mining and agriculture co-exist. 6 1.5%

Mining and agriculture cannot co-exist. 5 1.3%

Development on SCL

No development on SCL (especially mining). 67 17.2%

SCL Class 3—allow rural residential development. 1 0.3%

Only develop on SCL when no alternative sites are available. 14 3.6%

Land developed for irrigation–no urban/mining development. 1 0.3%

Question 3: What amendments should be made to Mineral Resources Act 1989 and Petroleum and Gas (Production and Safety) Act 2004 to protect strategic cropping land?

Issue Submissions

Legislation

Protect SCL in Legislation 61 15.7%

Prohibit all exploration, mining and extraction on SCL. SCL must include all classes of cropping land (SCL Class 1,

Class 2, and Class 3). Developers must demonstrate they can avoid permanent

alienation.

Current legislation and policy is adequate 62 15.9%

EIS is sufficient. Include SCL under EIS legislation. SPP 1/92 is sufficient (use SPP criteria and/or enhance criteria to

improve control over mining). Address environmental issues through environmental

management plan. Mining must not be assessed under the Sustainable Planning Act

2009.

Amend current SPP 1/92 57 14.7%

Amend current SPP 1/92 to protect SCL from mining.

Apply equal rules to all development applications 55 14.1%

Include all sectors (urban development, agriculture and resource).

Treat resources equally under all legislation. Bring resource industries under SPA. Subject mining, oil and gas to same rules and legislation. The MRA and P&GA should be amended to follow SPP1/92. Don't prioritise the resource sector over other land uses. Balanced approach to EP assessment required. Mining industry must be subject to same rules as rural industry

with respect to sediment/chemical runoff to Great Barrier Reef. Include ancillary activities such as pipelines under SCL policy

and legislation.

Land access and compensation arrangements 21 5.4%

Notify landholders when development applications are made on their land.

Compensate farmers to enable rehabilitation to minimum standards and payment on an annual basis—compensation must be agreed to before exploration commences and exploration should have a time limit.

Conditions of entry must be negotiated up front. Compensation procedures and compensation to farmers are

inadequate. Improve land access requirements.

Extractive resources 1 0.3%

Extractive resources (SPP 2/07)—extractive resources must be exempt from proposed SPP for SCL.


23


Issue Submissions

Environmental Impact Statement (EIS) 12 3.1%

Require EIS for all development on cropping land. EIS must be done periodically. Stringent assessment of oil and gas development required.

Rehabilitation

Development must be subject to rehabilitation 33 8.5%

Rehabilitation on development that alienates land. Rehabilitation must be completed progressively. Rehabilitation completed to a high standard. Developers must demonstrate that rehabilitation can be

achieved. Development of SCL if there is proof it can be fully reinstated. Developers must bear the cost of rehabilitation.

Rehabilitation to standard of mined land is not possible 9 2.3%

Satisfactory post-mining rehabilitation is not possible.

Protection of water sources 24 6.2%

Protect waterways, groundwater and aquifers. Reduce impact of development on water sources and flows. P&G Act should limit the use of water. Address impact of evaporation ponds and salt.

State government vs farmers 9 2.3%

Government must stop interfering. Farmers must decide use of their land. Land owners must have greater say about mining. Farmers know their land and what can be produced, including

the yield and productivity of land. Land should be allowed to be used for what it has always been

used for. Farmers should have ownership of ground below the surface

they own.

General comments on legislation and policy

Consult landowners in policy formulation and in the development application process.

20 5.1%

Objective independent assessment required. 9 2.3%

Include buffer zones around SCL. 9 2.3%

Introduce moratorium on mining leases and mining development leases.

8 2.1%

Developers should fund assessments for SCL. 6 1.5%

Acts should be clear, consistent and complimentary. 5 1.3%

Strengthen legislation to enable refusal of mining development in some situations—include local community in decision-making—give power of refusal to local government.

5 1.3%

Strengthen legislation or planning policy to prevent mining. 4

Local council to make the decision. 4 1.0%

Landholders must be consulted in SCL identification process. 4 1.0%


Issue Submissions

Reduce red tape (streamline oil and gas application processes; give minister power to make decisions).

4 1.0%

Legislation and policy must provide certainty for both landholders and the resource industry.

4 1.0%

Mining must fall under the Sustainable Planning Act. 3 0.8%

Support SCL by means of a statutory instrument. 3 0.8%

Independent EIS on all energy projects (including gas). 3 0.8%

Notify landholder when development proposals occur. 3 0.8%

Agricultural land should have its own legislation. 2 0.5%

Assess all development equally. 2 0.5%

New policy should not apply retrospectively. 1 0.3%

Incorporate SCL policy should in all laws that affect agricultural land.

1 0.3%

Public funding should be available to enable farmers to fight for the exclusion of their land from exploration and mining.

1 0.3%

Apply planning principles as law. 1 0.3%

Development assessment

Consider alternative sites first (mine poorer quality, low-productivity agricultural land, and low population areas first).

9 2.3%

Assessment should be triggered early in the application process. 7 1.8%

Food supply and food production is in the overwhelming public interest.

7 1.8%

Independent body must conduct impact assessment and monitor rehabilitation.

6 1.5%

Overwhelming public benefit must not be used as a loophole to permit mining.

5 1.3%

Mining applications subject to higher levels of assessment on SCL.

5 1.3%

Assessments on all stages of resource exploitation including exploration must include public benefit test.

4 1.0%

Treat gas differently to mining due to smaller footprint. 4 1.0%

Impact on water sources (above and below ground) must be assessed at time of application for exploration.

3 0.8%

Development applications must be subject to public consultation. 3 0.8%

Developing companies should establish what Class the land is prior to the granting of exploration rights.

3 0.8%

P&G may be permitted on Class 3 if no lasting impact—permit if can be returned to agricultural production within five years of first mineral sales.

2 0.5%

Assess cropping land per region rather than for whole state/take into productivity of land in account for assessment/consider the regional plan.

2 0.5%

Restricted lands must be reinforced under the MR Act and added to P&G Act to protect water pipelines (can be damaged by heavy drilling equipment being driven over it—currently not covered in

1 0.3%


25


Issue Submissions

notice of entry).

Government should create a map of areas preferred for mining. 1 0.3%

Consider cumulative effects of multiple extractive developments. 1 0.3%

Question 4: Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities?

Issue Submissions

Petroleum and gas: treat different to mining 50 12.9%

Petroleum and gas: treat different to mining.

Petroleum and gas: treat the same as mining 77 19.8%

Petroleum and gas: treat the same as mining.

Petroleum and gas: impact compared to mining

Petroleum and gas have lesser impact. 46 11.8%

Petroleum and gas have greater impact. 1 0.3%

Both activities impact land with unique risks. 12 3.1%

Petroleum and gas: impact on water resources 891 22.9%

Oil and gas development and saline waste water detrimentally affect the ground and surface water.

65 16.7%

Policy must deal with waste water effectively. 10 2.6%

No salt and salt water storage on cropping land. 14 3.6%

Prohibit petroleum and gas extraction on SCL 40 10.3%

Underground mining and coal seam gas extraction is incompatible with cropping land.

13 3.3%

SCL must be protected from exploration and mining/no mining or petroleum and gas extraction should be permitted on SCL.

12 3.1%

Prohibit ponds on SCL or manage salt from ponds. 9 2.3%

Open-cut and underground mining cannot be rehabilitated. 2 0.5%

No petroleum and gas developments on Classes 1 and 2 SCL. 2 0.5%

Land subsidence due to gas extraction renders land useless for cropping.

1 0.3%

Prohibit exploration on SCL. 1 0.3%

Minimise impact of oil and gas extraction 19 4.9%

Use directional drilling. Locate pipelines on common land. Put pipelines underground. Keep infrastructure off SCL. Minimise economic impact on farms. Must be no impact on food production.

1 The number is the total for the category—figures in lighter font are the totals for each sub-category.


27

Question 4: Should petroleum and gas activities under the Petroleum and Gas (Production and Safety Act) 2004 be treated in a different manner to other mining development activities?

Issue Submissions

Rehabilitation of cropping land 7 1.8%

Strict rehabilitation requirements. Permit oil and gas subject to full rehabilitation. Water must be restored to potable quality.

Underground mining and gas extraction is compatible with SCL 9 2.3%

Underground mining is compatible with cropping. Gas fields are compatible with cropping. Oil and gas extraction have a minimal impact on cropping.

Assessment of petroleum and gas applications

Cumulative impacts of oil and gas extraction must be taken into account as some areas have both mining and petroleum and gas.

5 1.3%

Infrastructure for oil and gas has significant impact on SCL. 4 1.0%

Permit petroleum and gas on Class 3 land provided no salt water storage or draining of aquifers/allow P&G on Class 1 provided no long term negative effect.

4 1.0%

Uniform processes required for assessments. 3 0.8%

Oil and gas extraction can be permitted on SCL only if no other sites are available, subject to strict mitigation conditions.

2 0.5%

Impact of petroleum and gas extraction on land must be tested. 2 0.5%

Exploration for petroleum and gas should undergo same assessment process as mining development.

1 0.3%

EIS must be carried out for oil and gas developments. 1 0.3%

Use common assessment criteria. 1 0.3%

Future technologies will allow energy to be extracted with limited effect on the surface.

1 0.3%

Apply buffer zones. 1 0.3%

Include resource sector services, e.g. pipelines, in the EIS process. 1 0.3%

Comments on petroleum and gas extraction

Insufficient compensation to farmers and families for damage to land/farmers must be compensated for loss and/or damage to infrastructure and/or aquifers resulting from exploration and mining.

4 1.0%

Reduce impacts on land by involving landholders in decisions about placement of wellheads.

3 0.8%

SCL policy must apply to all land uses. 2 0.5%

Exploration reduces confidence of landholders and limits investment in crop farming.

1 0.3%

Involved landholders in EIS. 1 0.3%

Bring petroleum and gas extraction under the SPA. 1 0.3%

Question 5: Should mining proposals be assessed on all Classes of strategic cropping land?

Issue Submissions

Assess mining proposals on all Classes of cropping land 121 31.1%

Broaden definition of SCL 83 21.3%

Have only one class of SCL (it is SCL or it isn't). 53 13.6%

All classes of SCL are required to meet future food demand. 19 4.9%

Broaden definition of SCL to include lower classes of land. 7 1.8%

More classes of SCL required. 3 0.8%

Broaden definition of SCL. 1 0.3%

Prohibit mining on specific classes of SCL 55 14.1%

No mining on Class 1 SCL. 25 6.4%

No mining on SCL Class 2. 16 4.1%

Mining can be allowed on Class 3 land provided rehabilitation to former productivity.

12 3.1%


Prohibit development on all classes on SCL 49 12.6%

Prohibit development—no assessment process. Prohibit exploration on all classes of SCL.

Mining rehabilitation possible (conditional) 55 14.1%

Mining rehabilitation possible (conditional). 22 5.7%

Burden of proof on proponent. 20 5.1%

Significant security bond must be posted. 13 3.3%

Mining rehabilitation not possible 41 10.5%

Rehabilitation fails. Rehabilitation not proven. Rehabilitation is problematic and difficult. Full rehabilitation cannot be achieved.

Rehabilitation standards

Specify standards for restoration. 52 13.4%

Following rehabilitation, productivity to return to equal to before development.

20 5.1%

Apply penalties for not effectively rehabilitating. 7 1.8%

Successful rehabilitation must occur on Class 3 before mining is allowed on Class 1 or 2.

5 1.3%

Land must be returned to original topography. 5 1.3%

Mining is a temporary land use and companies will be able to prove that they can rehabilitate land.

5 1.3%

Do not allow rehabilitation. 4 1.0%

NRM groups must approve rehabilitation. 4 1.0%

Demonstrate that subsidence will not occur. 3 0.8%

Following temporary development, rehabilitations needs to improve land to be better than pre-development condition.

1 0.3%

Use average productivity before and after mining as criterion. 1 0.3%


29

Question 5: Should mining proposals be assessed on all Classes of strategic cropping land?

Issue Submissions

Mining only if proof is provided that SCL can be restored post mining. 1 0.3%

Insurance required for failure to rehabilitate. 1 0.3%

Strict rehabilitation must be required, e.g. six months behind development.

1 0.3%

Cropping land may be made more productive through technological advances.

1 0.3%

Reassess land classes over time. 1 0.3%

Defining SCL Classes

Consider soil types when classifying land. 2 0.5%

Consider land use when classifying land. 1 0.3%

Include riparian flood plains in SCL. 1 0.3%

Use GQAL guidelines to identify SCL. 1 0.3%

Consider land productivity. 1 0.3%

One Class of SCL for each tenure. 1 0.3%

Assessments

Some applications on lower Classes can be assessed subject to conditions.

4 1.0%

Correlate assessments to the SCL Class. 3 0.8%

Open-cut mining should be assessed on all Classes of cropping land. 2 0.5%

Stringent assessment of all proposals. 1 0.3%

Assessment on Class 1 and 2 but not Class 3 1 0.3%

Assessment allows an extensive knowledge of resource 1 0.3%

Assessment should be required on Class 1 SCL only. 1 0.3%

Other Issues

Mining impacts on water resources. 2 0.5%

Allow exploration on SCL. 2 0.5%

Mining should be dealt with under the SPA. 1 0.3%

Introduce a rehabilitation levy. 1 0.3%

Involve landholder in assessment process. 1 0.3%

Recognise roles of Classes 2 and 3 in food production. 1 0.3%

Cannot class SCL due to specific attributes of the land. 1 0.3%

Consult with councils to ensure map accurately reflects local area. 1 0.3%

Buffer zones—major buffer zones required around cropping land to protect against impact of mining.

1 0.3%

SCL should have value to the state as an asset similar to mining. 1 0.3%

Resource extraction will reduce the availability of labour for the agricultural sector.

1 0.3%

Developing on SCL will put increased pressure on SCL Class 1 and 2. 1 0.3%

Viability of land determined by economic factors—if food prices high enough marginal land becomes productive.

1 0.3%

Question 6: Should all development proposals on strategic cropping land be assessed using common guidelines?

Issue Submissions

Use common guidelines for assessment of development on SCL 81 20.8%

Use common assessment guidelines. 80 20.6%

Assess all development on cropping land. 1 0.3%

Use specific guidelines for development assessment 44 11.3%

Apply specific guidelines for each kind of development. 18 4.6%

Individual assessment may need different guidelines—differences in impact, disturbance and timeframe built into guidelines.

18 4.6%

Case by case assessment. 8 2.1%

Prohibit mining and development on SCL 31 8.0%


Cropping land should be protected from exploration and mining. 2 0.5%

All types of development on SCL must be excluded. 20 5.1%

No development of any type on Classes 1 and 2 land. 1 0.3%

Many types of development lead to permanent alienation or diminished productivity.

1 0.3%

Urban development destroys smaller cropping areas. 1 0.3%

Allow mining and development on SCL 8 2.1%

Mining of rare minerals (i.e. no coal) can be considered on Class 3 land.

2 0.5%

Permit development on Class 3 provided no permanent destruction of the land.

1 0.3%

Allow community infrastructure on SCL if no other land available. 1 0.3%

Permit agriculture related infrastructure on cropping land. 2 0.5%

Different approach required where communities and businesses are surrounded by SCL—they need land for expansion.

1 0.3%

Agricultural infrastructure and agri-business (e.g. sheds) should not be subject to assessment and be subject to different guidelines.

1 0.3%

Mining offsets

Allow offsets 40 10.3%

Offsets could ensure that Qld retains its share of SCL. Offsets can be used to benefit rural towns. Allow offsets for upgrading of non-SCL to SCL. Include the possibility to offset impacts.

Offsets should not be allowed 7 1.8%

Economic benefits, revenue and jobs should not be considered as an offset for environmental and social harm.

Do not include ability to offset impacts.

Rehabilitation guidelines 18 4.6%

Guidelines for rehabilitation of cropping land must require the standard that existed before development or mining.


31


Issue Submissions

Terminology—SCL criteria and definitions

Clarity criteria and definitions 72 18.5%

Criteria and definitions must be clear. Wide consultation required. Refine criteria and definitions. Criteria must provide clear guidance. Planning principles must be clear and easy to understand, process

and implement. Criteria must be publicly available. Criteria must be transparent to the farming sector. Cropping, cropping land, diminished productivity and permanent

impact must be clearly defined.

Terminology: public benefit, need and interest 89 22.9%

Overwhelming public benefit, overriding need and public interest must be clearly defined.

Must mean for the greater well being of the public. Should be applied to cropping land only. Must be independently assessed.

Exclude public benefit as criterion 8 2.1%

Remove term overwhelming public interest.

Comments on public interest 24 6.2%

When defining overwhelming public interest consider long timeframe. Food supply is in public interest. Development must be in the overwhelming public interest. Change terminology to overriding public interest.

Strategic cropping land—use of term 1 0.3%

Use the terminology of prime instead of strategic.

Economic considerations

Consider economic trade-offs 59 15.2%

Consider a long time frame: consider that mines operate for about 30 years and cropping can continue for 100 years or more.

27 6.9%

Include a general economic analysis e.g. including revenue from mines or employment provided by agriculture.

26 6.7%

Correct comparison is between 25 years of coal mining and 30 years of farming, not between 25 years of mining and no cropping ever again.

2 0.5%

Do not consider commercial interests when assessing development applications on SCL.

1 0.3%

Undertake cost-benefit analyses of mining vs cropping. 1 0.3%

Resources sector creates jobs. 1 0.3%

One in eight Qld jobs flow directly from resources sector. 1 0.3%

Consider socio-economic and environmental impact of mining 34 8.7%

Consider social, environmental and economic impacts.


Issue Submissions

Consider socio-economic impact of mining 87 22.4%

Mining may have a negative impact on communities. Inter-relatedness of agriculture and agricultural businesses. Land values—farmers cannot compete with mining. Impact of mining on farmers about to retire. Impact on towns post-mining. SCL must be protected to ensure continued viability of agri-industries

(e.g. cane growers supporting a sugar mill).

Comments on guidelines

High level of long-term public interest in the guidelines. 43 11.1%

Consider alternative sites. 37 9.5%

Consider viability of using land for agriculture. 32 8.2%

Guidelines must consider impact on SCL. 9 2.3%

Consider adjacent land use. 3 0.8%

Apply broad guidelines and classifications. 1 0.3%

Include regionally specific codes. 1 0.3%

Approval (guidelines) must be outcomes based. 5 1.3%

Robust guidelines are required. 4 1.0%

Guidelines must have inbuilt flexibility for the assessor. 1 0.3%

Guidelines must give certainty and security. 3 0.8%

Use independent guidelines. 1 0.3%

Use local government guidelines. 1 0.3%

Guidelines for different regions of the state. 2 0.5%

Use guidelines based on class of SCL. 1 0.3%

Guidelines must be tailored for particular use (mining, housing, etc.)—different guidelines required for cropping land, flood plains, revegetation, etc.

2 0.5%

Guidelines must prevent alienation or diminished productivity of cropping land.

1 0.3%

Different guidelines required for different areas for e.g. coastal vs floodplain/different cropping land require different assessment criteria.

2 0.5%

Guidelines must consider time frame. 2 0.5%

Use common sense. 1 0.3%

Protect the productive capacity of cropping land. 1 0.3%

Assessment process must involve landholder. 1 0.3%

In some cases urban development on SCL may be in the overwhelming long-term interest of the community, but non-SCL must be developed first.

3 0.8%

Consider impact on land productivity. 2 0.5%

Consider impact on water supply and quality. 3 0.8%

Create a basin wide strategic plan. 1 0.3%

Guidelines must result in standard outcomes. 1 0.3%


33


Issue Submissions

Comments on legislation and policy

Use EIS process for assessment of mining development. 2 0.5%

Resource (mining) development must not be considered under SPA. 2 0.5%

Do not replace SPP 1/92. 1 0.3%

Use SPA rather than common guidelines. 1 0.3%

Principles contained in SPP 1/92 must form basis for legislative changes.

1 0.3%

Public good—each project must be comprehensively assesses against the loss off food production.

1 0.3%

Treat land uses equally—don't give preference to certain land uses. 1 0.3%

Identify SCL by criteria rather than by mapping. 1 0.3%

Farming development must be treated fairly when compared to mining.

1 0.3%

Overwhelming public interest must not be used as a loophole to allow mining on cropping land.

1 0.3%

Question 7: How should permanent plantations for carbon sequestration on strategic cropping land be assessed?

Issue Submissions

Carbon plantations should not be established on SCL 141 36.2%

Plantations should be prohibited on SCL. 55 14.1%

Plantations can grow on more marginal land—consider alternative sites, preferably not on SCL.

37 9.5%

Carbon sequestration plantations permanently alienate SCL—do not allow carbon plantations on SCL.

29 7.5%

SCL should be reserved for food production/protect global food supply/no carbon plantations on SCL.

9 2.3%

Carbon sequestration plantations do not contribute to food or fibre. 4 1.0%

Permanent plantations do little for carbon sequestration/crops help more with carbon sequestration than carbon forests do.

3 0.8%

Grow plantations on buffer zones. 2 0.5%

Carbon plantations not in the public interest. 1 0.3%

No carbon plantations on Classes 1 and 2. 1 0.3%

Allow plantations on cropping land 30 7.7%

Carbon plantations can be returned to food production should the need arise—plantations not as permanent as mining.

11 2.8%

Allow plantations for carbon sequestration SCL. 8 2.1%

Carbon plantations can be permitted on Class 3 cropping land. 4 1.0%

Allow farmers to have small forestry holdings for wind breaks on SCL. 2 0.5%

Plantations are not always permanent. 1 0.3%

Leave carbon plantations untouched where possible. 1 0.3%

Carbon sequestration plantations do not permanently alienate SCL. 1 0.3%

Retain carbon plantations that have been established on SCL in good faith.

1 0.3%

Retain environmentally sensitive native plantations. 1 0.3%

Carbon plantations should be assessed similar to any other development

46 11.8%

Assess plantations the same as any other development. 40 10.3%

Assess carbon forests similar to resource and mining applications. 6 1.5%


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Question 7: How should permanent plantations for carbon sequestration on strategic cropping land be assessed?

Issue Submissions

Permit carbon sink plantations under conditions 5 1.3%

Permit tree belts where they offer and land management advantages. Economic impact of plantations for carbon sequestration must be

considered (reduces employment, but could be used as buffers). Apply higher assessment levels on par with mining. Identify new areas for plantations.

Productive timber plantations 4 1.0%

Qld Timber Plantations Strategy 2020 treats timber plantations equal to cropping—also included as such in QPP.

Include as compatible with SCL (in accordance with SPA 2009).

Comments on assessment of carbon plantations 15 3.9%

Assess carbon plantations as an agricultural crop. 3 0.8%

Assess plantations under SPA. 2 0.5%

Apply public interest test. 2 0.5%

Introduce specific guidelines for plantations/prepare separate policy for carbon forests.

2 0.5%

Consider that plantations compete for groundwater. 1 0.3%

Consider establishment of a plantation as a change of use. 1 0.3%

Test compatibility of plantations with SCL with community. 1 0.3%

When considering carbon plantations do economic assessment. 1 0.3%

Apply principles similar to SPP 1/92 and provisions of SEQ RP. 1 0.3%

Use the term not for harvest rather than carbon plantations. 1 0.3%


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SIP_0243_04

Consultation report · 2018-03-19 · Consultation report . Strategic cropping land . ... submissions from the public by 12 March 2010. ... public briefings and presentations held

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