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Sustainable Animal Industries Proposed Changes - Submission of Sustain

The Victorian Government has been conducting a public consultation on proposed reforms to the State Planning Framework regulating the conduct of livestock farming.

The relevant consultation papers are available here.

The proposed reforms have generated considerable controversy in the community, with a widely shared perception that they favour large-scale, intensive factory-farm operations at the expense of small-to-medium scale, pastured poultry and pig operations.

Sustain shares these concerns and we have made a submission accordingly, which you can read here.

The executive summary is as follows:

Executive summary

The changes to planning controls proposed in these reforms have raised serious concerns across wide sectors of the sustainable livestock industry and beyond. Sustain exists to support the transition to a sustainable, resilient, healthy and fair food system, and this mission is broadly shared and supported across the Victorian community and indeed across Australia. At a time when the world’s leading food systems expert have just released a report which concludes that large-scale, industrialised monocultures have total health impacts from paddock to plate costed at nearly $US13 trillion – or fully one-sixth of the estimated global GDP for 2017 – the need to support truly sustainable and diversified agricultural production systems, and food systems more broadly, could not be more clear.Regrettably, these proposals, which discriminate against such systems in favour of large-scale monocultures, take us in precisely the opposite direction. We urge the government to reconsider these reforms, and extend the consultation period in order to fully engage with the community and with leading food systems experts.

We have several concerns, which are summarised below:

  1. The reforms will produce more ambiguity, not less, in terms of how farming systems will be regulated. The outcome will be an increase in the level of regulation without delivering any benefits for either the agribusiness sector or the broader community.
  2. The reforms “pick winners” across agribusiness sub-sectors and strongly favour large scale, industrial farming systems to the detriment of innovative and small-to-medium scale farming approaches.
  3. The reforms will disproportionately impact green wedge and peri-urban areas as these areas favour smaller scale, niche and boutique enterprises which will incur a high regulatory and planning burden disproportionate to the potential risks they pose.
  4. The impact and potential loss of these farming enterprises will have flow on effects into other industries in Melbourne’s North, including potentially undermining the strong food manufacturing sector and the growing interest in the high quality, boutique food and produce from restaurants, specialist food manufacturers/exporters and discerning consumers and tourists.
  5. Similar impacts will be experienced in Melbourne’s West, South, South-East and East, impacting the peri-urban areas of Werribee, Mornington Peninsula, Casey, Cardinia, Baw Baw, South Gippsland, Bass Coast and Yarra Ranges. These are all places of exceptional agricultural and horticultural production that are under severe development pressure as Melbourne continues to expand.
  6. As regards inner metropolitan regions, while not being directly impacted in terms of existing livestock operations, the viability of the flourishing farmers market sector and the growing demand for ‘paddock to plate’ local and regional food provenance cafes and restaurants will be threatened if significant numbers of niche and artisanal producers go out of business. These flow on effects have not yet been quantified and Sustain urges more research to be conducted, as well as the application of the precautionary principle, before any changes are implemented.
  7. The prohibition of all new agricultural enterprises regardless of scale or risk profile in the Urban Growth Zone is unworkable and will result in derelict open country on the urban fringe with vermin, weed and fuel load issues, creating enhanced fire dangers.
  8. The prohibition of food and fibre production for home use in residential zones is surprising, unjustified and is likely to be met with dismay from the broader community, over half of whom are engaged in some form of urban agriculture at home according to survey research.
  9. The reforms appear to have lost sight of the original objectives of the planning protections in terms of environment and amenity, and have little chance of supporting a truly sustainable animal production industry to Victoria. In fact, the regulation may be directly detrimental to the sustainability of animal production in this state.
  10. The proposed reforms treat different production systems and livestock species inequitably. Rather than trying to capture and regulate all aspects of animal production within the Planning Scheme, It should be acknowledged that some of these risks and impacts can be managed through other protection mechanisms and legislation, such as the Environment Protection Act, the Public Health and Wellbeing Act, the Catchment and Land Protection Act and Animal Welfare legislation, where they can be assessed by State department professionals in with expertise in appropriate fields rather than increasing the burden on Council Planners with possibly little to no agricultural knowledge.