Renewable energy and Energy Efficiency

 General Principles 

1. The VFF supports a smooth transition for Australia’s energy market towards renewable energy based on commercial consent from landholders and project selection and design that improves reliability of energy distribution and without significant increase to energy consumers. 

2. The VFF believes the generation, transmission and storage of electricity on agricultural land must be based on the principle of commercial consent. Infrastructure proponents should negotiate fair terms with landholders that encourages voluntary land access/acquisition through fair compensatory measures. 

3. The VFF recognises that Australia’s energy generation mix needs to change as existing infrastructure assets reach the end of their useful lives and to meet emissions reduction targets. Government policy must not favour specific technologies, but rather enable the technologies to compete on their merits. 

4. The VFF supports research into development and adoption of new generation technologies including both centralised and decentralised generation, and support and promotion of improvements in on-farm energy efficiency and self-sufficiency in generation and storage capacity. 

5. The VFF supports efficient investment in generation, transmission, distribution, and storage capacity to avoid over investment or ‘gold plating’ of the energy network. This includes support for the transition to appropriate transmission, distribution and storage assets and facilitating investment in targeted and necessary interconnectors. 

6. The VFF believes that the avoidance of impacts to agricultural production and supply chains is central to consideration of efficient investment in generation, transmission, distribution, and storage capacity. 

7. The VFF opposes the early decommissioning of existing power plants where the continued supply of dispatchable power cannot be guaranteed. VFF supports investment in new on-demand generation capacity in Victoria to offset the loss of baseload generation facilities in the Latrobe Valley.

On-farm renewable energy and energy efficiency projects

8. The VFF supports policies that aim to promote improvements in on-farm energy efficiency, self-sufficiency in renewable energy generation and storage capacity. 

9. The VFF supports targeted policies and programs that seek to support farmers’ knowledge and decision making in developing on-farm energy efficiency and renewable energy projects. 

10. The VFF believes government must reduce integration barriers to enable farm businesses to invest in larger on-farm renewable energy developments and take advantage of feed-in tariffs, thereby also helping to decentralise energy distribution networks. 

11. The VFF supports the provision of low-cost finance to farmers for on-farm energy efficiency and renewable energy projects through the Clean Energy Finance Corporation and other sources.

12. The VFF opposes policies such as the Large-scale Renewable Energy Target discriminating against small-scale renewable energy developments. Government should promote small-scale developments that have less impact on agricultural land compared to large-scale developments because farm businesses have control over their scale, location and construction. 

13. The VFF supports the regulation of renewable energy installers and contractors to prevent unscrupulous behaviour that targets and disadvantages farm businesses. 

Renewable energy developments and agricultural land 

14. The VFF encourages the construction of large-scale renewable energy and associated developments on non-agricultural land. Where large-scale renewable energy and associated developments must be located on agricultural land, the VFF believes developers must design and operate the facility on the principles of co-existence and commercial consent. That is the proposal must mitigate the development’s impact on the agricultural use and productive output of the land unless a commercial payment is made to a sum agreeable by all parties as being commensurate to any losses incurred. The VFF will oppose renewable energy and associated developments that risk the ongoing and long-term productive use of agricultural land. 

15. The VFF opposes renewable energy and associated developments being located on irrigable farmland where a water use licence is attached to that land or where agricultural production is displaced on high quality soils. 

16. The VFF encourages the undergrounding of transmission and distribution powerlines to ensure minimal disruption to agricultural land use and regional communities, and to help eliminate fire risks. Where possible transmission and distribution should be within existing linear transport corridors on crown land. 

17. The VFF calls for the establishment of a statewide strategic plan for renewable energy developments that considers all issues concerning impacts to agricultural production and regional communities. Formulation of a strategic plan must include consultation with the VFF and impacted regional communities. 

18. The VFF supports local governments to have the ability and power to identify and protect agricultural land through the planning scheme where it is considered that renewable energy developments pose a threat to the ongoing and long-term agricultural productivity in a region. 

19. The VFF supports local content policies aimed at supporting local industry in the construction of renewable energy developments. Such policies must be targeted towards supporting economic development and job creation within the region where renewable energy developments are taking place, not just at a national or state level. 

20. The VFF believes that when establishing statutory processes governing renewable energy developments, government must consider all issues concerning their eventual impacts on land use and rehabilitation including decommissioning on the site and neighbouring properties. Developers, not landowners should be held responsible for all decommissioning and remedial works. This includes placing requirements on developers to recycle or reuse any materials at the end of the development’s life cycle. Where the developer is unable to meet these obligations, the government must be responsible for costs associated with carrying out all decommissioning and remedial works. 

21. the VFF believes that operation of renewable energy generation, transmission or storage should not restrict land use rights or operations, including through the creation of exclusion zones or buffers on dwellings or creating difficulties farmers’ ability to obtain insurance. 

22. The VFF believes the energy infrastructure developers are responsible for any increased costs for insurance, local government rates, land tax, farm operations and compliance with safety regulations. 

23. The VFF supports the development of safety standards and guidelines for the construction of large-scale battery storage to minimise any risk to soil, water, groundwater, crops or livestock from these facilities. 

Regulatory Improvements 

24. The VFF supports relevant legislative and regulatory reform) to apply a comprehensive and enforceable land access code to licensed parties. This must give rights and protections for landholders who host transmission, distribution, storage, or generation facilities from project design through to decommissioning and rehabilitation.

25. The VFF supports relevant legislative and regulatory reform to require energy facility operators to consult with landholders in the design of operational guidelines and are required to recalculate compensation if changes lead to increased costs of production or restriction to use of machinery and practices. 

26. The VFF supports relevant legislative and regulatory reform to require the opportunity for input from landholders in relation to any requirement, regulation, guideline, inquiry or direction that may impact on their safe occupation and use of land. Direct notification to landholders must be provided of any such proposal. 

27. The VFF supports relevant legislative and regulatory reform to maintain landholder awareness of safety risks and regulations relating to energy infrastructure located on land in their ownership. 

28. The VFF supports relevant legislative and regulatory reform to ensure regulations are clearly written to exempt ordinary operation of farm machinery. 

29. The VFF supports relevant legislative and regulatory reform so that all energy infrastructure operators are responsible for ensuring infrastructure is constructed and maintained to allow the safe operation of farm machinery, irrigation and land and crop management practices such as aerial spraying, GPS enabled agriculture, stubble and fuel reduction burns and use of drones. 

Planning System 

30. The VFF supports rigorous planning policies that restrict large-scale renewable energy developments on agricultural land by requiring a permit. Permit requirements should be less restrictive for large-scale developments where agricultural production continues to be the predominant use of the land (co-existence). More restrictive permit requirements should be in place for proposed developments where agriculture is not the predominant use of the land. A permit should not be required for on-farm small-scale developments where the energy generated is to be predominantly used in the farm business. 

31. The VFF supports amendments to the Victorian Planning Policy Framework and relevant Guidelines to ensure that there is appropriate guidance in requirements to protect against unplanned or permanent loss of land. 

32. The VFF supports amendments to the Victoria Planning Provisions to ensure all irrigation areas are identified and strategic agricultural land is identified. 

Wind energy developments 

33. The VFF supports farmers having the choice to enter into arrangements with companies to locate wind energy generation facilities on their properties where projects have been approved in accordance with government policy and planning guidelines. However, wind energy developments must not result in a loss of agricultural productivity or disruption to affected landowners. 

34. The VFF supports the right of farmers and local communities having their views considered in the planning assessment and approval process for wind energy developments by: 

• Requiring an Environmental Effects Statement (EES) process for wind energy generation projects greater than 30 megawatts.
• Providing neighbouring farmers the opportunity to review and make submissions to the approval or EES process.