The Victorian Farmers Federation is the peak body representing Victorian agriculture. VFF has been on the record regarding our concerns in relation to lack of regulatory knowledge and considerations in relation to agriculture and the GED and the appropriateness of the EPA in relation to human health.
Even though some aspects of the 1970 Act applied to agriculture – such as organic matter as industrial waste, agriculture was applying the circular economy approach to what we know is a key material for plant growth and soil health.
Will the guidelines meet the objective?
The purpose of the guideline is to contribute to state of knowledge by a risk management approach to help you better understand how to identify and assess (eg calculate) and manage your direct and indirect CHG emissions. We believe this is duplication of industry standards and national jurisdiction. Many aspects of agriculture and climate change adaptation is federally regulated. VFF is concerned that the state of knowledge guideline is silent on regulatory considerations, and proportionality to risk.
It seems the Guidelines is calling for farmers to look at their emissions (sources, baselines, calculators) and identify options for GHG reductions then as part of a General Environmental Duty. While this may be required in other areas, for agriculture it is best delivered under Australia’s Rural Research and Development Corporations (RRDCs). VFF supports the work of the RRDCs and their contributions to state of knowledge and continual improvement and best practice that is achievable for many.
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