There is a combination of measures in place to address the impact of land-based run-off into the Great Barrier Reef (Reef), supported and funded by Commonwealth and Queensland governments, agricultural bodies, research institutions and the non-government sector. Of these measures, the most contentious has been the Queensland Government's introduction of a regulated model for those industries impacting on water quality within the Reef.
Despite these best efforts, and as demonstrated in chapters 2 and 3, water quality targets have not been met. The Reef's long-term outlook and the impact of climate change on the health of the Reef has meant more stringent measures were applied, hence the application of the Queensland Government's Reef regulations package.
This chapter considers key measures implemented by stakeholders, including the overall investment made by the Australian and Queensland governments to improve water quality outcomes. This chapter will focus on a key debate about the rationale for a regulated best management practices (BMP) versus the voluntary model supported largely by the agricultural sector, and the barriers that have hindered the adoption of these practices by farmers.
Rationale for the regulation of farm practices in the Great Barrier Reef
Agricultural practices within the Reef's catchment regions have evolved over time. One of the key drivers for practice change across agriculture has been the adoption of BMP programs, through partnerships involving industry, natural resource management bodies, land managers and governments. BMP programs vary, with specific measures designed for each industry operating within the Reef's catchment regions. However, a shared vision of BMP programs is to 'improve productivity, profitability and sustainability of farm enterprises', whilst at the same time reducing the environmental impact of farming operations on local ecosystems.
One of the drivers for practice change across the farming sector has been addressing water quality issues in the Reef's catchments. For example, the BMP program for graziers, Grazing BMP, ensures economic and environmental outcomes are improved through land management practices, such as maintaining ground cover for 70 per cent of a property through the use of appropriate pasture species and tactical grazing that minimises the loss of rainfall through evaporation and sediment run-off. Grazing BMP is administered by AgForce, which represents the cattle, grain, cane, sheep and wool sectors in Queensland.
The sugarcane industry's BMP, Smartcane BMP, engenders efficient fertiliser use as a means to save money and improve environmental outcomes by preventing soil acidification, nitrate run-off to waterways and nitrous oxide emissions. The BMP programs for the sugarcane industry also improve soil health, nutrient management, and irrigation and drainage practices. Canegrowers administer the Smartcane BMP.
The Queensland Government acknowledged the substantial effort made by the agricultural sector to improve agricultural practices within the Reef's catchment regions through these BMP programs. However, despite these efforts, ongoing reports had found the adoption of BMP programs had slowed and would not result in Australia meeting its water quality target established under the Water Quality Improvement Plan (WQIP) and further deterioration of the Reef's ecosystems.
Across the last reporting period, there was only an overall reduction of 0.3 per cent for dissolved in-organic nutrients, and a 0.5 per cent reduction in sediments. Dr Geoff Garrett explained the average reduction of nutrients over the past nine years has equated to only 2.5 per cent per year. This trajectory meant a reduction of 60 per cent would be achieved in 2035 or 2037. Further, the uptake of best management as a percentage of the total businesses over a five year period was only 'three per cent, six per cent, eight per cent, 11 per cent and 16 per cent'. As described by the Queensland Department of Environment and Science's (DES):
Industry and peak bodies were supportive of these practices when they were the focus of incentive programs and were part of the joint bid for government funding for uptake of these practices. However, despite significant government and industry investment, particularly in agriculture, voluntary approaches have failed to facilitate sufficient uptake of improved practices and, at the present trajectory, the Reef water quality targets will not be met. The recently released 2017 and 2018 Reef Water Quality Report Card confirms that, in spite of efforts to date, poor water quality continues to threaten the Reef.
The Australian National University's (ANU) Dr Jennie Mallela noted that whilst across the sugarcane sector there was 'some really good initial progress on hitting targets'; however, farmers have implemented the 'low-hanging fruit' and the 'easy gains have already been made'. Dr Mallela added that farmers should be not be penalised for making the right environmental, sustainable choices, rather they should be provided with incentives to support them to meet water quality and BMP targets.
According to the DES, the rationale for a regulatory regime is to facilitate a 'rapid uptake of improved agricultural practices by producers who are not accredited under a BMP program or partnering with other programs'. The regulations were specifically designed to support those agriculturalists who have not implemented best practices measures. Further, a regulatory approach was 'considered necessary to achieve the rapid and transformational change at a broad scale advocated by the Taskforce to achieve the Reef water targets and improved Reef outcomes'. Those producers already operating under a BMP program 'will be deemed to have met the minimum practice agricultural standards' under the legislation, and a comprehensive support framework had been established 'to work collaboratively with farmers to improve their practices'.
In addition, the Queensland Government's regulatory impact statement for the Reef regulations stated that the rationale for the enhancement of regulations is to 'ensure minimum practice standards are utilised across key industries and land uses in all reef catchments' in order to 'eliminate high-polluting out-dated approaches which are the main source of pollution to the reef'. The statement also found that the adoption of such practices would have a broader positive impact on the profitability and productivity of agricultural practices.
The Queensland Government's use of regulations to improve environmental outcomes is supported by evidence from abroad. The CSIRO, whilst not commenting on the policy itself, stated that where ecosystems have returned to good health have largely been a product of regulation. Further, other industries are regulated for their activities on the water, or industries and communities operating alongside the Reef. Sewage treatment plants, intensive rural industries, mining, aquaculture, tourism operators and the fishing sector are all regulated, with local councils also required to reduce sediments and other pollutants entering the Reef's waterways. Regarding tourism, the Australian Marine Conservation Society (AMCS) observed that it was very highly regulated and those businesses working on the Reef, on the whole, accept those regulations. WWF-Australia noted that:
Across many sectors in society, there is a consistent pattern of voluntary practices either by industry or individuals needing to be underpinned by adequate regulation to bring about changes in behaviour and to improve management outcomes.
The committee was advised that once the regulations were established, a non-regulatory approach would then be utilised to achieve additional pollutant reductions through the support of innovative solutions and by supporting 'catchment restoration to address legacy issues such as accelerated gully erosion'. The DES added that the regulations do not make any new requirements for the use of pesticides or herbicides besides a requirement to record their use. Accordingly, the regulations primarily focus on nutrients and sediments.
The DES explained other mechanisms were in place to recognise and support farmers working towards accreditation. These include recognition of programs not formally recognised under the regulations, in particular:
…a lot of growers and landholders are voluntarily participating in reef programs funded by the Queensland and Australian governments. If a grower is part of those programs our compliance officers might visit them, but they will not take any action against them because they are demonstrating that they are working to achieve compliance. So through the program we're very much recognising good performers and aspirational performers on the land, and we're really only wanting to target the people who don't want to engage.
The DES summarised that the Reef regulations would 'form part of the comprehensive Queensland Reef Water Quality program, which is designed to improve water quality while supporting productive and profitable industries'. It pointed out that the regulations were not the only mechanisms in place to achieve water quality targets, rather the regulations 'are complemented by extensive voluntary programs and investment', such as the Queensland Government's $261 million program over five years that 'includes a suite of tools such as voluntary programs and incentives, extension and education, on-farm trials, and monitoring'. This investment 'complements funding and programs delivered by other sources, in particular the Australian government's Reef Trust including the Reef Trust—Great Barrier Reef Foundation partnership'.
The Australian Government's Reef Trust, in partnership with the Great Barrier Reef Foundation (the Foundation), contributes $201 million towards water quality improvement. This component of Reef Trust funding goes towards progressing water quality for the Reef and supporting the agricultural sector. As part of a five-year plan to target priority pollutants, the Reef Trust invests approximately $160 million into targeted regional programs on high-priority catchments, and a further $10 million each towards innovation and system change, and conservation and protection. Traditional owners receive 10 per cent of water quality funding, equating to approximately $20 million, and $60 million goes towards controlling crown-of-thorns starfish outbreaks. On the ground, this funding supports practice change in the grazing and cane sectors via the Foundation's delivery providers, natural resource management bodies, productivity services and private providers who work directly with farmers to develop farming management plans.
The Australian Government's contribution to these programs is primarily through funding incentives 'under natural resource management programs'. In total, the Australian Government has committed $417 million to improve water quality between 2014–15 and 2023–24 (primarily through the Reef Trust and the former Reef Programme). Both the Australian and Queensland governments have together invested approximately $600 million toward improving water quality in the Reef. Although substantive, WWF-Australia called for an investment of $830 million per year for ten years, which would align with the Reef's asset value of $21 billion.
BMP programs and adoption of best practice across industries
BMP programs have historically been voluntary and industry-led. Considerable time and effort has been made across these industries, in partnership with governments and other stakeholders, to support their uptake within the Reef's catchment regions. As detailed below, the sugarcane, grazier, horticulture, banana and agro-ecological farming sectors argued the current voluntary BMP framework is driving best practice across the agricultural industry. These BMP programs have either been an entirely industry-driven process (horticulture and banana sectors) or via partnerships between governments and the non-government sector (sugarcane and grazing).
The section below details existing BMP programs across the agricultural sector for sugarcane, grazing, horticulture and the banana industry, and discussions about the adequacy of adoption rates for those programs.
Since its establishment in 2014, the Smartcane BMP has been implemented by 560 accredited enterprises, accounting for 126,141 hectares within the Reef's catchment regions. The industry's peak body, Canegrowers, reported that 32 per cent of the cane area in the Reef's catchment regions operated under the Smartcane BMP, with a further 30 per cent preparing for accreditation audits. At an individual level, 22 per cent of cane farmers were accredited.
The Smartcane BMP is working towards having 138,178 hectares of Reef catchment cane farmland operating under the program by 2022, which was a target agreed to by the Queensland Government. As of July 2020, a further 12,037 hectares was remaining to be accredited to achieve this goal. In total, the 3,777 sugarcane growers account for 400,000 hectares of farmland adjacent to the Reef. Figure 5.1 demonstrates the growth of accredited enterprises since 2015.
Figure 5.1: Smartcane BMP accredited enterprises, 2015 to 2020
Source: Canegrowers, Smartcane BMP accredited enterprise figures (tabled 27 July 2020).
Various regional canegrower groups from across the Reef's catchment areas provided regional information about the uptake of the Smartcane BMP:
in the Burdekin region, 44 growers were accredited, and 298 growers had completed self-assessments or were benchmarked against Smartcane BMP (equating to 17,000 hectares, or 40 per cent of cane area);
in the Herbert River region over 90 per cent of the area farmed for sugarcane is operating under a BMP program and moving towards full accreditation, with 40 per cent fully accredited under Smartcane BMP;
in the Wet Tropics region, 44 per cent of cane area (67,044 hectares) is accredited, and a further 86 per cent (131,842 hectares) is benchmarked;
Canegrowers Mackay has 20 per cent (20,000 hectares, 132 enterprises) of total land operating under the Smartcane BMP, with a further 591 farming enterprises in the self-assessment stage or benchmarked towards full accreditation;
Canegrowers Tully reported 100 enterprises were operating under Smartcane BMP, with over 72 per cent of cane production in the region accredited; and
twenty-one per cent of the Proserpine region is accredited, with a further 43 per cent of growers benchmarked and progressing steadily through the Smartcane BMP program.
The industry's best practice framework is called the SIX EASY STEPS methodology (6ES). This methodology enables growers to calculate the optimal rate of nutrients to be used on their cane production. The 6ES has an A,B,C,D framework that is a 'regionally specific, reporting mechanism used to model the water quality impacts of farm' and land management practices. Classification A is allocated to producers that have implemented cutting edge practices, whereas a D is considered unacceptable.
The creator of the 6ES methodology is Sugar Research Australia (SRA), which in 2014 managed a review of nitrogen use efficiency in the sugarcane industry. The review found significant potential for the industry to refine nitrogen application rates via the 6ES. SRA, in its submission, identified the potential to refine the 6ES further and to undertake more research to validate the methodology 'across a range of soil types, farming systems and climatic conditions'. Research commissioned by SRA found the adoption of the 6ES across soil, fertiliser and pesticide management resulted in an economic benefit of between $25 to $220 per hectare per year.
There was resounding support for the Smartcane BMP across industry, government and scientific representatives. The former head of the Queensland Water Science Task Force, Dr Geoff Garrett, submitted that BMP was 'functional "proof" that a cane farmer is "doing the right thing by the Reef"'. He referenced the significant improvement in best practice adoption as a result of an industry-led 'Canechanger Project' in the Wet Tropics. The project showed a 450 per cent increase in BMP adoption across the region in three years. For this reason:
BMP is a crucial piece of the reef water quality puzzle, and it is also the most powerful platform to engage the entire industry in ongoing practice change. It was designed by the industry for industry, endorsed by government, and delivered by Canegrowers.
Incitec Pivot Fertilisers (IPF) spoke of its ongoing work with farmers and governments to improve fertiliser application through testing, education and training and research. In particular, the Fertcare accreditation program designed to support farmers with the practical application rates, and the application methodology called StoolZippa that ensures fertilisers are covered after application. Regarding training, IPF has held 52 Agronomy in Practice courses and has trained 400 people in fertiliser use, which includes education around its use in the Reef's catchment regions.
All of the canegrowers represented in this inquiry expressed their support for BMP programs and a healthy Reef ecosystem. Many have applied best practice measures for decades, with anecdotal reports about the minimal evidence of the adverse impact their practices have on the water ecosystems adjacent to their farming properties. Various cane representatives expressed concern about the interests of their community being secondary to the interests of governments and populations in urban areas, and the impact on communities if the sugarcane sector's profitability is compromised.
Canegrower Proserpine expressed concern that 'the burden on agriculture to reserve [200 years of coastal development] appears disproportionate'. Canegrowers Burdekin detailed the relationship and hardship experienced by canefarmers working on the land:
I know that farmers have embraced and implemented an enormous amount of change for the betterment of both farming productivity and the environment. We will continue to do so. Farmers get their livelihoods from the soil and nature and the climate, and we also spend a lot of our leisure time in the water on the [Reef]. We do not want to jeopardise either. Farmers are productive. In the world in which we work, we tolerate a great many variables that are beyond our control, but we keep fronting up again and again, because we are optimistic by nature. What we feel is intolerable is the deliberate level of interference in our livelihoods which we feel is unwarranted and not based on sound information.
These cane and other farming representatives spoke of not being heard or being recognised for their ongoing stewardship of the lands they farm. Most importantly, these canefarmers spoke of the inadequate recognition of the adoption of BMP programs by farmers. These representatives expressed bewilderment at the Reef report card stating only 9.8 per cent of the sugarcane land applied best practice principles. Whereas the sugarcane industry understood 32 per cent of the cane area in Reef's catchment regions operate under the Smartcane BMP.
The 2017–18 Reef report card found as of June 2018, only 9.8 per cent of land under sugarcane was managed under a BMP, comprising of 3,777 growers managing 520,000 hectares of land across the Reef's catchment. The land management target for 2025 is 90 per cent.
The difference in these figures has caused significant distress for the many canefarmers who have sought to implement, at considerable expense, best practice measures across their regions. Canegrowers Mackay spoke of the impact the move to regulations have had on the sugarcane farming community:
…regardless of these major and expensive changes on farm, we are told that there has been no improvement in the paddock-to-reef reporting, and, in some cases, it shows an actual decline. As a result, growers are confused. They need to contend with many productivity issues on a daily basis, from pests and disease to weather and prices, and the last thing that growers need is an unnecessary increase in layer upon layer of unhelpful regulation to contend with. The goalposts are continuously moved.
A further explanation about these differences was provided by Canegrowers. Referencing the Tully region, Canegrowers stated that under the industry's BMP, 70 per cent of Tully operates under best practice, but the Reef report card for 2019 found 11 per cent applied best practice. The difference is due to the report card relying upon the Paddock to the Reef model to report on the adoption of best practice, which according to Canegrowers does not account for the industry's BMP program (see Chapter 3 for more information about the Paddock to the Reef program). These two assessment processes result in there being 'two views on what is industry best practice' and 'two sets of data' being used. Canegrowers contended that the impact of these two datasets is the inaccurate assumptions about adoption rates by the agricultural sector, which then provided the unsubstantiated rationale for the Reef regulations. Subsequently, the 'report card doesn't reflect what growers are doing, the growers feel like they'll always be set up for failure'. The Queensland Farmers' Federation also shared the concern about the selective use of data, and the inadequate recognition of best practice adoption across farming industries.
The committee asked the DES for clarification about the differences between assessments on the adoption of best practice. In response, the DES explained the varied figures were a product of differences in how they are assessed:
The report card BMP figures are actually assessed at a higher level than the Smartcane BMP level. So for report card purposes we're talking about what is known as A and B practices, and for BMP practices that align mostly with C practice. That's where that confusion of figures comes from. There are also some gaps in reporting, including through the farmers who participate in Smartcane BMP.
On the basis of these two figures, the DES recognised a need to improve its communication. It stated that the committee's inquiry had demonstrated that the department was:
…still not communicating what we're doing as well as we could, from the lack of understanding of what the regulations do. As a department we will need to have a look at what we need to communicate to farmers so they understand what the requirements are.
However, the DES made clear that 45 per cent of canefarmers were compliant with the industry's 6ES, or participants of Smartcane BMP and other nutrient planning programs. For this reason, those farmers are not impacted by the Reef regulations because 'they are already meeting those standards'. The DES re-iterated that:
…regulations do recognise best management practice programs and the farmers that meet them. For example, the cane growers organisation applied for and received recognition that their program Smartcane BMP, which is funded by the Queensland government, meets the same standards of the regulations, so accredited farmers will be the lowest priority for any kind of compliance visit.
In addition, the Smartcane BMP is recognised under the Environmental Protection Act 1994 (Qld) as having met the minimum practice standards for sugarcane production. The confusion about the application of the industry's best practice standards applicability to the Reef regulations package is due to:
…the best management practice for water quality standards that are in the report card and the Paddock to Reef program, which are slightly higher than industry's own best practice standards. Because they both use best practice, it becomes extremely confusing in communicating and is a communication challenge that we clearly haven't resolved yet.
With regard to its compliance program, the DES had found 55 per cent of sugarcane farmers were non-compliant on the first visit. This non-compliance ruling meant a farmer under review did not comply with the industry's 6ES. Despite this relatively high rate of non-compliance, '[u]pon a return visit, compliance rates significantly improved, by 25 per cent, with a further 23 per cent of growers engaging in practice change programs'. The DES pointed out that this increase in practice change demonstrated 'the efficacy of an active compliance program', whilst the AMCS argued that the improvement in compliance demonstrates the value of further investment into compliance officers.
Concerning the resources available for compliance, the DES noted that it was not extensive, with only 13 officers in the program as of July 2020, with a further $3.7 million allocated to expand compliance support. In addition to compliance officers, the DES will use a range of mechanisms to monitor land condition and water quality. Compliance officers will use the Paddock to the Reef program to record information about improved practice change as a result of return visits.
The DES pointed out that the Reef regulations package, namely the minimum practice agricultural standards, 'align with the best practice science and take into account local and industry knowledge' and were 'based on industry-developed practices that are promoted as practices that improve productivity and/or profits for farming businesses'. For example, the department submitted that the basis of the regulated methodology for nutrient application for sugarcane production in the Reef regulation package was founded by Canegrowers' 6ES methodology. The DES emphasised that research has shown those farmers who apply the industry's 6ES were 100 per cent more profitable when trialled for more than a year, and as previously stated, the industry's research found an increased profit of $25 to $220 per hectare per year.
Despite the similarities between the Reef regulations and the Smartcane BMP/6ES methodology, cane groups made clear of their opposition to the use of regulation to facilitate practice change in the industry, irrespective of the measures in place to support farmers. These groups emphasised the importance of partnerships. For example, Canegrowers noted that regulated protections have been in place since 2009, which at the time was promoted as a means to 'resolve all the problems about the health of the reef and fix up the problems around farming'. However:
…despite that regulation, the quality of water and the uptake of practices by farmers is going backwards. Something in terms of logic is not working here. You can't say Australian farmers or Queensland farmers are going backward. All we're saying, to answer your question, is that we think the model of building a bigger and bigger baseball bat won't get the results, where partnerships between farmers and government have gotten better results.
The committee questioned the sugarcane's opposition to the regulations if such a large proportion of cane farmers were accredited or on the pathway towards accreditation, resulting in their compliance with the regulations. Canegrowers disagreed with this presumption because Smartcane BMP has been 'built on the industry's best practice, and the regulation is built on the government's idea of what best practice is, and they're regulating something completely different'.
Canegrowers and the Australian Cane Farmers' Association (ACFA) disagreed that the regulations would lead to innovation and investment in technology that support farmers because they're being 'dragged along in this regulatory current' and that a 'regulatory system has been heavily based on modelling and expected outcomes by government'. Whereas the Smartcane BMP has been based on decades of research by industry and government, with its success being replicated 'over and over again'.
AgForce's BMP program, Grazier BMP, commenced in 2008 with funding from the Australian Government's Reef rescue program. As of 2019, Grazing BMP had 1,400 grazing businesses registered, and managed over 13 million hectares. One hundred of those businesses had completed the accreditation process. The committee heard that '[t]here were over 2,100 grazing businesses right across [Queensland] that had done BMP, managing about 30 million hectares', which accounted for 60 per cent compliance over 45 per cent of land.
The 2017–18 Reef report card found as of June 2018, 35.8 per cent of the grazing sector's land was managed under a BMP (with a target of 90 per cent by 2025). The increase between the 2016 benchmark and the 2017–18 report card were minimal (by 1.3 per cent) across pasture BMP (31.1 per cent), streambanks BMP (51.7 per cent) and gullies BMP (24.7 per cent). For the grain sector, the report card found 38 per cent operated under a BMP, with nutrient use recording good progress (72.2 per cent), followed by soil (34.6 per cent) and pesticides (7.3 per cent).
According to AgForce, uptake of the BMP program was slowed due to farmers feeling the program was not about a true partnership, rather it had become a compliance tool to be used against farmers. These concerns were driven by a poor understanding of the new modelling used to determine BMP practices, as described below:
…our industry no longer felt like it was a partnership. So what was a growing momentum from early adopters and some incredible opportunity ahead of us fell away, because we lost trust. Fundamentally, the reason we don't have 100 per cent of producers in Queensland running a voluntary industry-led program in partnership with government is the loss of trust that started around 2012.
In response to AgForce's concerns, DES explained the purpose and application of the Reef regulations on the grazier sector and options available to landholders to improve land conditions:
…the minimum standards focus on practices to reduce the likelihood of soil loss and sediment runoff into waterways and consequently to the Great Barrier Reef. They are simple outcomes-based standards. If land is in A or B class condition graziers must continue to use measures to maintain the land in that good or fair condition. If the land is in poor or degraded—C or D—condition graziers must take steps to improve poor land condition or prevent the D condition land from degrading further. It is up to the landholder to work out what actions are best for their own land because, obviously, there are lots of different ways of achieving that. The regulations do not require landholders to maintain ground cover at particular levels. As the representatives from AgForce said yesterday, producers who improve the condition of the land improve the economic viability of the land, so these requirements also align with industry standards.
For the grazing sector, the DES uses remote-sensing data to observe trends and identify areas of 'poor' condition. The DES added that it recognised land conditions vary, especially because of droughts and would not target drought-affected properties.
The industry's BMP program had collected data from 2009 to 2019, but AgForce subsequently deleted this data in response to the Queensland Government's decision to regulate the industry. AgForce said it was 'one of the biggest tragedies in agriculture in Queensland', claiming that it was 'forced and had no choice' to delete producers' BMP program data. Its rationale for this action was due to protecting producers' privacy, which was one of the biggest concerns for the agricultural sector:
The Reef regulations provided a power for government to force third parties to provide private producer data for the purposes of compliance. It was one of the biggest issues industry had with that proposed legislation last year. Some 48 hours before the hammer could have fallen on that legislation providing that power to government industry had only two choices, given we knew what was coming. We could either, firstly, hold the data and subject it to a requirement to go to the Queensland government for compliance purposes, therefore, letting down industry fundamentally—given our role was to use the data for peer learning and only for peer learning—or, secondly, delete the data and protect the privacy of that data in the way that we're asked to do so. We couldn't go to industry to ask for their opinion. We had to make a decision as industry's organisation…we were faced with no option, given what was buried deep in that legislation, which we called out at the time and we were ignored.
When asked whether the deletion of its data hindered industry's calls for ground-truthing of data, AgForce re-iterated its concern that the data found on its BMP database could have been used against producers by government rather than be used to improve environmental outcomes. AgForce added that although it deleted this data, the original source data would be available from producers.
The committee sought clarification from the DES about AgForce's decision to delete this data with a particular concern about AgForce's view that the Queensland Government's legislation would be applied retrospectively. In response, DES explained that AgForce's actions were based on its legal advice, and clarified that it would not have the 'power to request that data and was certainly never the intent of the provision'. The DES explained the provision of concern is a:
…transitional provision that allows for a more rapid process for what were the existing BMP programs to be recognised formally under the regulation, and so it was an extrapolation of how that could be applied if the government was to recognise a program without the permission of the industry association, which was never the intent. That's been evidenced with canegrowers asking to be recognised and the government endorsing that recognition.
The DES confirmed that AgForce had not raised its concerns prior to deleting its data, and was informed of AgForce's action through the media.
In addition to privacy concerns, AgForce argued that the science does not align with bureaucratic attempts to enforce environmental management onto a diverse range of agricultural landscapes across the six different catchment regions—all of which are managed differently. AgForce expressed specific concern about scientists' determination of baseline sediment run-off (or pre-European sediment levels) versus the agricultural sector's contribution to sediment levels. For these reasons, AgForce is not supportive of mandatory legislation, even if direct funding was provided by farmers to support compliance.
AgForce also spoke of the complexity of the Reef regulations package, the absence of a template to support farmers with compliance, and the conflict and confusion between farmers' obligations under the Vegetation Management Act 1999 (Qld) and the Reef regulations. A concern shared by The Green Shirts Movement and Property Rights Australia.
The BMP program for the horticulture industry in Queensland is Hort360, which is owned and operated by Growcom. Unlike the sugarcane and grazing sectors, the horticulture industry has not had the same level of insistence to adopt BMP measures, in part driven by its overall size: less than one per cent of the Reef's catchment region is used for horticulture production, accounting for 60,000 hectares distributed across 120 plant types.
It is estimated that 60 per cent of horticulture operating under this BMP program, which equates to 'approximately 900 growers who are participating, or have participated, in some way with that particular program'. As of May 2020, approximately 38 per cent of individual growers within the catchment regions have participated in Hort360. Growcom pointed out that the successful and growing uptake of Hort360 had been achieved without support from the Queensland Government.
The 2017–18 Reef report card found 28.6 per cent of the land under horticulture operated under BMP practices, with 970 horticulture producers farming approximately 50,000 hectares of land. No changes were recorded between soil and pesticide BMP between 2016 and 2017–18 (25.5 per cent and 42.5 per cent respectively), with a minimal increase from 17.6 per cent to 17.9 per cent for nutrient BMP.
In relation to the Queensland Government's Reef regulations package, Growcom explained that its sector's requirements were not to come into effect until 2022. In this time, the horticulture industry has been advised by the Queensland Government that it 'has an opportunity to demonstrate greater uptake of the BMP program' and if successful, would avoid regulation. The DES advised the committee that it was working with Growcom on its Hort360 program to establish minimum standards for both the horticulture and grains sectors. It affirmed that regulations for these sectors would not commence until 2022, but the 'intention is for as many growers to be accredited' under system once established.
Growcom explained one of the key drivers for its participation in a BMP program is to demonstrate 'not just sustainability but also the improved profitability of growers, and those two things—sustainability and profitability—are inherently intertwined'. To this point, Growcom recognised the role of industry to improve its communication with 'members about the value of participation' in BMP programs.
More broadly, Growcom submitted that the absence of adequate evidence to link its farm management practices with quality and health of the Reef has meant the:
…regulatory approach has had to treat all industries and practices as though they present the same high level risk…that is a blunt instrument, liable to introduce into production systems a range of costs and inefficiencies that ultimately do not translate into improved water quality.
Whilst not rejecting the scientific evidence about the impact of water quality on the Reef, Growcom explained that the risk it represents, due to the sector's size and use of closed or hydroponic systems, meant the 'regulatory intervention that has been imposed on [the horticulture] industry' is not warranted. Further, Growcom argued that a regulatory approach requires a lot of scientific evidence to establish an understanding of nutrient levels applied to a crop. Unlike cane farming that has one commodity, horticulture is made up over 120 different crops throughout the entire Reef catchment regions with a 'wide variety of climates and production systems'. Subsequently Growcom concludes that:
There is very little science to fall back on to determine what the appropriate levels of those different nutrients are to effect good water quality but also to ensure that the production of those crops is still commercially viable. That science doesn't exist. It's an enormous task for the Queensland government to do. We have grave doubts that they will be able to do that science in the remaining two and a bit years they have until the regulatory boom gate drops on our industry. Science costs a lot of money, and we see the costs it would impose on the taxpayer to regulate horticulture in this way as prohibitive. We would be better off going down the voluntary process that we've been on with our best management practice program and incentivising growers. As legislators—federal and state—you should be concerned with achieving the most efficient, least-cost way of effecting change, and we don't believe that regulation in this case is the least-cost, most efficient way of effecting change in horticulture. It's a blunt instrument and is not appropriate for our industry.
Banana BMP Environmental Guidelines
The banana industry, much like the horticulture industry, is comparatively small compared to other agricultural enterprises in the Reef's catchment regions. The industry's production land equates to approximately 11,300 hectares across 260 farms, with 94 per cent of its operations occurring in far north Queensland.
Its peak representative body, the Australian Banana Growers' Council (ABGC), expressed concern about the Queensland Government's Reef regulations and advocated for its industry-led BMP program, Banana BMP Environmental Guidelines. This BMP program has been in place since 2013, and has benchmarked 92 per cent of its producers to its BMP checklist. In addition, 61 north Queensland growers (representing 25 per cent of growers) are accredited to private environmental accreditation program called Freshcare that is driven by commercial interest—retailers seeking food that is not affecting the environment. The Freshcare program is closely aligned with the ABGC's Banana BMP. The ABGC employs extension officers to support practice change, and offers grants and training programs to assist growers with improving farming practices aimed at sediment and nutrient run-off.
Similar to Growcom, the ABGC's primary concern is the lack of evidence that shows the banana industry's impact on water quality. It acknowledged and does not dispute its contribution to water quality issues in the Reef, but argued the industry's contribution is low. It submitted there was little information available about water quality and the banana industry, which makes it difficult for the ABGC to comment on the quality of the science and the conclusions made. Reference was made to the significant investment made by banana growers to implement practice change, and the face that the sector's applied nutrient levels are decreasing and areas of vegetation coverage are increasing, yet these developments are not represented in the modelling or reports cards. This absence of recognition of the banana industry's efforts to improve its practices has fostered resentment and scepticism in the sector.
The ABGC called for further research into the industry, as a means to demystify water quality science for growers. The ABGC emphasised the importance of effective communication and ensuring information is shared in a way growers can understand.
Whilst the ABGC commented that its members would come to terms with the Reef regulations, it raised specific concern for the farm design standards for new croplands (greenfield sites) because it would:
…significantly increase costs to establish new farms, reducing the banana industry's capacity to farm in new areas and to escape Panama tropical race 4. TR4 is a destructive disease that cannot be eradicated and is silently spreading across the Tully Valley. The proposed regulations will impair the industry's ability to expand and satisfy growth in demand for bananas.
The DES spoke of its collaboration with the ABGC with its BMP. It stated that the existing BMP framework does not have an independent third party audit system in place, and that the ABGC had engaged Freshcare to work through those auditing requirements. Once completed, the ABGC's BMP program would be formally recognised under the Reef regulations package.
Agro-ecological farming businesses
The agro-ecological farming sector, represented by the Australian Food Sovereignty Alliance (AFSA), also advocated for its credentials at minimising the sector's impact on water quality and concern for the Reef regulations package. Representing small- to medium-scale food producers that operate under regenerative farm principles, the AFSA expressed its support for 'measures aimed at protecting the water quality of the [Reef]' but maintained 'that all regulation needs to be scientific and scale appropriate so that it does not create a barrier to entry or, indeed, a barrier to continued operation for small- and medium-scale farming interests'.
AFSA questioned the rationale for applying regulations to its industry and questioned whether the science supported this approach. AFSA explained its industry's practices are not covered by a BMP accreditation process, but:
Small regenerative farms like ours address all seven themes of the Reef 2050 Long-Term Sustainability Plan, but none of that is recognised nor rewarded. Small -scale agroecological farmers have largely been tarred with the same brush, as have all farmers within the reef catchment districts, and we're not having our regulatory burdens reduced…Little consideration for scale and risk has been made, with complex, yet-to-be-defined arrangements for offsets and requirements for agricultural ERAs. There's no concession or support for those wanting to transition their farms from being a high synthetic input system to a regenerative agroecological system—a change obviously supported by science but not the regulation.
The adoption of BMP programs across the agricultural sector within the Reef's catchment regions is commendable. Farmers across the sugarcane, grazier, grain, banana and horticulture sectors have all made the gradual transition towards best management systems that improve input retention, soils, yields, profits and water quality in the Reef's catchment regions.
Despite these efforts and gradual uptake of best practice, the committee is concerned by ongoing reports of poor water quality in the Reef, and the slowing down of BMP uptake by the sugarcane and grazier sectors. As exemplified by Dr Geoff Garrett, the current trajectory indicates the WQIP target for nutrients WQIP would not be met until 2035, a decade after the agreed target date.
Despite the committee's general view that the Queensland Government's regulations are necessary to expedite rapid uptake of best practice, it is concerned about the disconnect between the industry's understanding of best management adoption rate of 32 per cent versus the 9.8 per cent figure produced by the Reef Report cards (informed by the Paddock to the Reef program).
The committee believes that further work should be done by the Australian and Queensland governments to ensure consistency in reporting for the agricultural industry best practice.
The committee recommends the Australian and Queensland governments ensure future Reef report cards adequately incorporate and recognise the adoption of best practice across the sugarcane sector.
The committee is also concerned by the inadequate understanding of the Reef regulations by the agricultural sector. The DES recognised this matter, and the committee encourages the department to review its communication strategy to ensure farmers are adequately and accurately informed about the Reef regulations. The committee believes a more targeted and decisive communication strategy on behalf of the Queensland Government would have alleviated some of the distress experienced by Queensland farmers.
More broadly, the committee considers communication to be a more substantive problem for matters relating to the Reef and its catchment regions, highlighted by the high degree of misunderstanding about both the Reef regulations and Reef science. The committee is of the view that a more coordinated and strategic communication strategy is required to inform and educate farmers and other stakeholders about governments' policies and Reef science.
The committee recommends the Australian and Queensland governments conduct a strategic review of the communication strategy used to inform stakeholders about Great Barrier Reef policies and science.
The committee also holds the view the Reef regulations are a relatively blunt instrument, applied across the entire agricultural sector operating within the Reef's catchment regions. For the horticulture and the banana industry (including the small-scale agro-ecological farming businesses), there appears to be inadequate evidence to sufficiently determine the level of impact these agricultural practices have on water quality in the Reef. Further, the horticulture sector's diversity poses a challenge in determining the parameters of best practice. The committee therefore calls for additional research into the impact of horticulture and banana cultivation on water quality in the Reef.
The committee recommends the Australian and Queensland governments' commission additional research into the impact of the horticulture and banana industries (including small-scale agro-ecological farmers) on water quality in the Great Barrier Reef catchment regions.