Submissions 2020
Revised Planning and Design Code Consultation
Livestock SA has previously made submissions on Phase Two (Rural Areas) and Phase Three (Urban Areas) of the Draft Planning and Design Code Consultation. As part of these submissions, Livestock SA raised the conflict between primary production industries and believes this issue is still not addressed in the revised Planning and Design Code. Livestock SA believes if we are to protect and grow existing broadacre agriculture and avoid conflict with other agricultural pursuits, there needs to be policies in place ensuring that with any change, it becomes the responsibility of the landowner making the change, including to more intensive agriculture, viticulture and horticulture, to provide the appropriate buffers and anything else that may be required. Livestock SA also believes where broadacre land becomes non-viable due to restrictions imposed by approved new activities, particularly in the peri-urban zone, needs to be addressed further and remains concerned that broadacre livestock production has already been virtually squeezed out of this zone, with a resultant loss of economic production for the State.
Limestone Coast Pest Management Strategy Review
The Pest Management Strategy plan will be able to provide a good basis for some effective pest polices for the effective management and control of pest plants and animals.
Livestock SA believes consideration should be given in the review to supplementing pest risk assessments with benefit cost analyses, so that an economic assessment can also be made of the management and control programs for pest animals and plants.
Livestock SA also believes rabbit management should be moved to the ‘destroy infestations’ management category as it is estimated rabbits cause over $200 million a year in losses to Australian agriculture.
Feral cats also need to be mentioned when discussing management of pests as they can threaten lamb production and carry infectious diseases.
Mention of the management of over-abundant native animals has not been discussed in the review.
Of particular concern in the Limestone Coast region are the relatively high numbers of kangaroos, the ease with which kangaroo numbers can quickly increase and the effect this can have on total grazing pressure. Further options need to be considered for effective control of kangaroos in this region.
Building a new Biosecurity Act for South Australia
The State Government is proposing to develop a new, consolidated Biosecurity Act for South Australia. There is no mention of funding requirements for the conditions mentioned in the new Biosecurity Act. If there is any suggestion of a new Biosecurity Act levy, this will need to be discussed within industry. There needs to be increased enforcement to increase compliance. The new act should ensure there is consistency with other livestock biosecurity legislation nationally and in other states. There are also recent changes regarding farm trespass, along with parts of the Animal Welfare Act 1985 and the new Landscape South Australia Act 2019, which need to be considered in the new Act. Livestock SA also suggests Livestock Act 1997 should not be repealed until after the new Act is fully developed. The new act should encompass all the features of the current Livestock Act.
South Australia’s Road Safety Strategy to 2031
Livestock SA fully endorses the aim of the new Road Safety Strategy to reduce lives lost and serious injuries on South Australia’s roads.
The widening of rural roads, secure fences on road corridors and the clearing of bushes and trees which obscure vision are key actions required. There is also a continued need for funding to improve the safety of regional and remote roads. This includes the need to install passing lanes and maintaining road verges. Shoulder sealing is also a cheap and mostly effective safety method which can be further implemented.
Draft Pastoral Lands Bill 2020
Livestock SA was involved with several Draft Pastoral Lands Bill consultation meetings to discuss the proposed new Pastoral Lands Act. The draft Bill is a vast improvement on the existing Act and Livestock SA generally supports the proposed changes. There are still areas of concern which need to be addressed. There is a need for adequate funding to resource the pastoral unit to ensure its capability to effectively manage the proposed changes to the Bill. Pastoralists cannot be expected to be entirely responsible for funding all activities in the pastoral region. There is considerable concern about losing maximum stocking rates as they are used by financially institutions to assess the capacity of a leaseholder to repay loans and used to set water allocations. There is an ongoing need for the management of feral and over-abundant native animals. There also needs to be emphasis on the importance of livestock biosecurity. Goats need to be added to the Bill as they are an income opportunity for pastoralists and the Bill has an economic development focus.
The Electoral Districts Boundaries Commission – draft report
Livestock SA has made a submission to the SA Electoral Boundaries Commission expressing disappointment about the draft boundaries in relation to the pastoral region. Not only has Port Augusta been split into the two electoral districts of Giles and Stuart, but the way the boundaries are now drawn, Giles will be centred on Whyalla and Stuart on Port Pirie. Neither of these towns have any relationship with South Australia’s pastoral community. The Commission is asked to consider how the boundaries can be redrawn.
Essential production and supply chain security in the context of emergency circumstances in SA
Livestock SA would like to relate to the Economic and Finance Committee’s Inquiry in relation to livestock producers and the recent challenges regarding COVID-19. The disruptions to livestock production and its supply chain in South Australia have been minimal as agriculture has been classified as an essential industry. There have been some difficulties regarding border restrictions. Livestock SA worked with PIRSA and other State Government Departments to ensure livestock producers stayed up to date and informed on the situation. Livestock SA is supporting the National Farmers’ Federation’s please to the National Cabinet to develop a clear and consistent national Agricultural Worker Movement Code. Availability of labour is important to ensure agriculture can continue to progress and thrive.
Drafting South Australia’s Mining Regulations
Livestock SA strongly endorses the submission made by Grain Producers SA, particularly regarding the policy principles and the recommendations on the draft regulations. Pastoralists are often impacted by mining exploration and associated activities. While they do not own the land they operate on, they do invest considerable funds and should be treated as landowner. Good livestock biosecurity practices are essential to minimize risk of disease or pest incursion on properties. Livestock SA believes mining companies need to maintain strict ‘come clean, go clean’ policies and stick to dedicated tracks within a property to minimize introduction and spread of pest, weed and disease. Livestock SA now has two Biosecurity Extension Officers who are willing to work with the mining sector on biosecurity practices and procedures. Mining companies access to property owned water infrastructure and natural water courses at the landowner’s expense is also unacceptable and consideration needs to be given to preparing procedures for this access.
Animal Welfare Reforms
Livestock SA is involved with and has representatives on the South Australian Animal Health and Welfare Advisory Committee and has recently established, along with South Australian Dairyfarmers Association, a Biosecurity, Animal Health and Welfare Advisory Committee (BAHWAC). Livestock SA also endorses the new policy making pain relief mandatory for sheep mulesing. In our recent Livestock SA members survey, 96 per cent of respondents were in favour of making pain relief for mulesing mandatory. Livestock SA was also involved in creation of the South Australian Animal Welfare Standards for Sheep and Cattle and has an interest in the outcomes of the current proposed changes to the Animal Welfare Regulations 2020.
Review of agvet chemicals regulatory framework
Livestock SA was recently involved in the stakeholder consultation regarding the review of agvet chemicals regulatory framework.
Key points
- Stakeholders were generally supportive of using overseas data to enable Australia to have increased access to niche chemical products which are not available here
- There was concern over the removal of efficacy as an assessment criterion due to potential impacts on animal welfare and biosecurity
- Stakeholders highlighted the high cost of retaining accreditation and how this may impact willingness to become/stay accredited
- It would be beneficial to have greater clarity relating to emergency permits and the criteria for use
- Upfront feed for registration may act as a deterrent
- Stakeholders agreed on national harmonisation of control of use in relation to registered veterinarians’ ability to supply restricted medicines to other veterinarians
- Residue testing of produce needs to increase
Proposed changes to the Animal Welfare Regulations 2020
Livestock SA welcomes the opportunity to comment of the proposed amendments to the Animal Welfare Regulations 2012. Livestock SA supports the amendment to exclude livestock from the prohibition on the use of electronic confinement devices. Virtual fencing technology relies on the use of electronic tags and collars and has environmental and animal welfare benefits. Livestock SA supports the amendment to discontinue the use of a lethal toxin in wild dog traps if the traps are checked at least every 24 hours and any wild dog or dingo is humanely destroyed. This ensures producers minimise the suffering of wild dog as well as reducing the risk of damage to livestock and native animals. Livestock SA also supports the removal of the requirement for a rubber-jawed leg-hold trap to be only set inside the Dog fence and 100 metres outside the dog fence. Producers outside the fence must be given access to the same wild dog control measures to those inside the fence.
Training and Skills Development Amendment Bill
Livestock SA welcomes the opportunity to comment on the proposed changes to the Training and Skills Development Act 2008. The aim of the Bill is to help develop a more responsive training system for apprenticeships and traineeships. For agriculture, this is necessary to attract more employees to work in the industry. Often agriculture is overlooked when apprenticeships and traineeships are considered however, with an aging workforce, there is now a need to quickly and readily obtain new staff in the industry who can work with agtech. Livestock SA are looking forward to working in partnership with government so there are flexible industry-endorsed approaches to training and skills development.
Valuation of Land Affected by Spray Drift
Where broadacre producers have properties next to more intensive agricultural and horticultural pursuits and residential or industrial areas, there is always the concern regarding spray drift.
The proposed policy document ‘Valuation of Land Affected by Spray Drift’ refers to the need for a ‘buffer zone’ relating to an area to be left fallow between a spraying area and neighbouring areas to mitigate the impact of spray drift. Consideration needs to be given to how to assess this buffer zone and how to assess its lower value for the landowner.
The ‘Valuation of Farming Land Adjoining Sensitive Land Uses Directive’ policy should work in conjunction with the ‘Valuation of Land Affected by Spray Drift’ policy as each document is dealing with different land parcels.
If we are to protect and grow existing broadacre agriculture and to avoid conflict with other agricultural pursuits, there needs to be policies ensuring the landowner is responsible.
Changes to the ABS 2020-21 Agricultural Census
The suggested changes to the Agricultural Census, recommended by the Australian Bureau of Statistics will results in no reporting for the split between the number of pure Merino lambs marked versus all other breeds, the number of ewes mated to produce lambs marked to Merino rams versus all other rams and the split between the number of pure Merino breeding ewes versus all other breeds. From a wool perspective, it is vital to the industry to determine the breeds that are being produced. Knowing the split between breeds helps producers and industry bodies to determine the growth of the industry in each sector. From a livestock perspective, it is extremely important to have information on differing classes of livestock and the differing breeds within a stock class. The changes that are proposed will not provide sufficient differentiation between differing sheep breeds within the broad category of lamb.
Electoral Districts Boundaries Commission Submission
For the best representation of all pastoralists in the SA Parliament, Livestock SA believes that pastoralists should all be in the one electorate with Port Augusta also in the same electorate.
Board Member Gillian Fennell presented at a hearing in Port Augusta on June 24, highlighting that most pastoralists did business in Port Augusta, not Whyalla, and so aligning pastoralists with Whyalla did not make sense.
SA Productivity Commission R&D Inquiry
Livestock SA provided input to the commission’s inquiry into research and development outlining key targets from the Sheep and Beef Industry Blueprints.
It acknowledged that the State Government has an objective to lift the sustainable economic growth rate in South Australia to an average of 3% per year. Livestock SA is participating in further developing these sectors in line with this growth agenda but said the need for dedicated R&D for sheep, cattle and goats is essential.
Review of WoolPoll
Livestock SA supports the WoolPoll as it gives growers the opportunity to have input into the size of the levy, however welcomes the review of WoolPoll as the process needs to be made more robust to ensure maximum participation.
Livestock SA believes WoolProducers Australia should be given oversight responsibility for WoolPoll, as the national industry body in the wool industry that works in the interests of all woolgrowers.
Livestock SA has circulated the discussion paper questions among members to determine Livestock SA’s position.
Streamlining and modernising agricultural levies legislation
Livestock SA supports the Department of Agriculture, Water and the Environment’s proposal to streamline and modernise the agricultural levies legislation, to ensure it is efficient, responsive and flexible enough to meet industry needs.
Livestock SA supports the option to transform the levies legislation, and is directly interested in two Research and Development Corporations (RDCs) – Meat and Livestock Australia (MLA) and Australian Wool Innovation (AWI). Livestock producers in SA as levy payers want to know how their money is spent by these organisations and how they can influence these decisions. It is essential that the bodies that represent producers have an oversight role of their relevant RDCs.
Livestock SA also supports the levy payer register, which will allow all livestock producers who pay levies to be properly consulted ensuring greater transparency and accountability.
Outback Communities Authority business plan and budget 2020-21
Livestock SA has been asked on behalf of pastoral members to comment to the Outback Communities Authority on the annual business plan and budget 2020-21.
Their main concern is to ensure the beef and sheep producers in the Outback Communities area are represented as pastoralists and not just as residents. Most feel the pastoral industry’s identity has been lost, especially when it comes to future policy development and planning. The annual business plan also does not mention support for pastoralists severely affected by the drought. Livestock SA would like to work with the Outback Communities Authority on drought assistance required for the region and also provide information to tourists and others travelling to the Far North to make them aware they are not able to camp on pastoral leases.
Design of Livestock Loading/Unloading Ramps and Forcing Yards
Livestock SA welcomes the opportunity to be able to make comment on the draft ‘Design of Livestock Loading/Unloading Ramps and Forcing Yards’: AS5340, however would be opposed to any moves to make this code mandatory. This must be no more than a guideline that producers can follow when upgrading or building new livestock yards.
Producers are aware of the ‘Fit to load’ guidelines when sending livestock from their properties. Similarly, this draft could be the basis for ‘Safe to load’ guidelines – safe for the animal, safe for the carrier and safe for the farmer.
Livestock SA also endorses Cattle Council of Australia and Sheep Producers Australia’s submission.
Draft Far North Prescribed Wells Water Allocation Plan 2019-2029
Livestock SA recommends that the process of developing the Far North Prescribed Wells Area Water Allocation Plan 2019-2029 be paused until the South Australian Arid Lands Landscape Board is fully operational and the new Pastoral Land Management and Conservation Act is established. Following this a further period of consultation should be undertaken. Livestock SA recommends water licenses must be permanently attached to pastoral leases and expresses its concern about the science that sits behind the calculated water access entitlements along with the unease about the possibility of water meters being required. Livestock SA wishes to express its disappointment in plan consultation, with further consultation required before the plan can be implemented.
Revised Wild Dog Management Policy
Livestock SA supports the revised wild dog management policy as the whole of landscape approach proposed is necessary to control wild dogs in South Australia. Stringent measures are required if there is to be any chance of eradicating wild dogs inside the dog fence. The measures currently in place, along with those proposed, will need to be well-policed and enforced with strict penalties applied to those who do not conform.
Livestock SA is concerned in the lack of measures to control wild dogs outside the dog fence. While there are some changes in the policy that will assist in minimising the impacts of wild dogs on cattle outside the dog fence, stricter measures are required. The treatment for wild dog control also needs to be expanded to include all pastoral lands outside of the fence and consideration should be made to combining the SA Wild Dog Advisory Group and the SA Dog Fence Board to ensure effective management of wild dogs in this state.
Draft SA Water regulatory determination 2020
Livestock SA welcomes ESCOSA’s draft determination which proposes reductions to the total revenue that SA Water may recover during the four-year period commencing 1 July 2020. The revenue outcomes proposed would still provide SA Water with sufficient revenue to fund efficient operations and prudent investments on a long-term basis and meet the health, safety, environmental and customer service standards that will apply to SA Water over the coming four years.
One of the major concerns for livestock producers is the security of water supplies for livestock at reasonable prices, with the increasing cost of water becoming a restraint on investment in livestock production systems throughout SA. Livestock SA is hopeful that the outcomes of both the State Government’s Water Pricing Inquiry and this draft determination will mean a reduction in water prices.
Independent Review into SA’s 2019/20 Bushfire Season
Primary Producers SA has made a submission to the SA Fire and Emergency Services Commission regarding the 2019/20 bushfire season. The submission discusses the need for equipment subsidies for farm fire units, consistency of quality of equipment within CFS brigades, aerial support, access to land or properties following fires, military support, logistics particularly on Kangaroo Island, grant eligibility and administration, national park environmental effects and Federal versus State government responsibilities.
Draft Planning and Design Code Consultation: Phase Three
In November, Livestock SA made a submission of Phase Two (Rural Areas) of the Draft Planning and Design Code Consultation. As Phase Three covers a significant part of rural South Australia, particularly in terms of agricultural production including livestock, several points need to be addressed including clarifications of definitions within the new Planning and Design Code, consistency with other legislation, minimum size for farming, conflict between primary production industries and flexibility in changes of practice. Other concerns include updates to the Peri-Urban zone and the impact on broadacre livestock production.
Review of the draft release National Wool Declaration
Following the release of the Draft National Wool Declaration (NWD) V8 on 18 February 2020, Livestock SA would like to support Wool Producers Australia’s comments once again regarding the AWEX’s Review of the NWD.
We wish to reiterate that the proposal to still include identification of alternative methods to mulesing adds another dimension that was not envisaged when the NWD was first introduced. Livestock SA is concerned that this will add to confusion not only for growers, but along the wool pipeline including buyers, processors, retailers and customers. This alteration could meant that less wool producers will provide this. While Livestock SA does not agree with making the NWD mandatory, its use needs to be encouraged.
Hi-Tech Sector Discussion Paper
The Department for Innovation and Skills discussion paper ‘Hi-Tech Sector’ outlines various industries that have competitive hi-tech advantages whether it be advances within their technology products or services. It is disappointing to see that the agricultural industry has not been recognized or acknowledged within the discussion paper.
The agricultural industry is at the forefront of new technology and has immense potential for growth and development to help increase the South Australian economy. Although new technologies are developing at exponential rates, they are not being well adopted by farmers. The industry needs more support for new technologies to be implemented on farms, while encouraging the continual advancement of the agricultural industry.
There needs to be more recognition to the agricultural industry, particularly as it is one of the main contributors to our economy. With the continual support, technologies will continue to advance in order to meet future demands, challenges and needs. Livestock SA acknowledges the need of technology within the agricultural industry and will offer our on-going support to producers and the industry.
2019 Review of the National Wool Declaration
Livestock SA would like to support Wool Producers Australia’s submission to AWEX’s review of the National Wool Declaration (NWD), which rejects the proposed new mulesing status categories. The NWD was developed specifically to provide details on mulesing status, as well as dark and medullated fibre risk. The addition of the new categories may cause immense confusion amongst growers and the supply chain.
Review of Draft South Australian Commercial Kangaroo Management Plan 2018-2022
Livestock SA is concerned that kangaroo numbers are becoming an increasing issue for landowners across South Australia, in particular for pastoralists. Livestock SA believes the State can not rely on commercial harvesting to ensure kangaroo numbers are lowered to a level where they are not detrimental to the landscape and the community as a whole. We believe that a roundtable of stakeholders needs to be held to tackle the issue of how to manage the current overabundance of kangaroos.
