IN THIS SECTION:

Submissions to Government

Integral to the NFF's policy and advocacy role - encompassing all eight of its major policy pillars - is the constructive advice, guidance and direction the NFF provides to the Australian Government, including lodging formal submissions.

Submissions to Government 2012

Preview Commonwealth Environmental Water: Trade Arrangements Discussion Paper (PDF 75.6 kb)
The NFF’s 27 April submission to the Commonwealth Environmental Water: Trade Arrangements Discussion Paper highlighted that the focus of the NFF’s feedback is to ensure that there are positive outcomes for irrigators from their engagement with the Commonwealth Environmental Water Holder (CEWH). In particular, the NFF is seeking assurances that individual irrigators, who choose not to participate in trade to or from the CEWH, will remain unaffected
Preview National Wildlife Corridors Plan Advisory Group for the Draft National Wildlife Corridors Plan (PDF 375.7 kb)
The NFF’s 20 April submission to the National Wildlife Corridors Plan Advisory Group for the Draft National Wildlife Corridors Plan identifies a number of principles for wildlife corridors. The NFF supports the need for involvement in the draft Plan and corridor activities to remain voluntary, and seeks clarification of how the Plan will interact with local, regional and state planning and native vegetation regimes, and that weed and pest animal management must be a key priority. However, the NFF and its Members reject the suggestion that overarching legislation is required.
Preview Environment Protection and Biodiversity Conservation Amendment Bill 2012 (PDF 82.5 kb)
The NFF’s 17 April 2012 submission to the Senate Inquiry into the Environment Protection and Biodiversity Conservation Amendment (Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining Development) Bill 2012 outlined the concern by Communities and farmers are regarding potential impacts to land use, water, fracking, well integrity and the fracking or geogenic chemicals, and thus the NFF strongly supports the current endeavours of the Australian Government seeking to improve the situation
Preview Submission to the Murray-Darling Basin Authority for the proposed Basin Plan (PDF 908.2 kb)
The NFF's 16 April 2012 submission to the Murray-Darling Basin Authority for the proposed Basin Plan outlines the key concerns of the NFF and its members.
Preview Submission to Fair Work Australia -First three years of the Fair Work Act 2009 (PDF 557.7 kb)
The NFF’s 12 April 2012 Submission to Fair Work Australia’s for first three years review of IFA and the NES recommends that Fair Work Australia reduce red tape, confusion and complexities within the Fair Work Act
Preview National Water Commission Amendment Bill 2012 (PDF 70.6 kb)
The NFF’s 10 April 2012 submission to the Senate Environment and Communications Legislation Committee Inquiry into the National Water Commission Amendment Bill 2012 highlights that full implementation of the National Water Initiative is incomplete and this Bill provides flexibility to the National Water Commission to determine, in conjunction with jurisdictions and stakeholders, the most appropriate forward work program that will deliver the high-level water reforms that Australia aspires to.
Preview Submission to the Australian Government's Energy White Paper (PDF 584.7 kb)
The NFF's April 2012 Submission to the Australian Government Energy White Paper reinforces the importance of access to relatively low cost energy in order to bolster our international competitiveness, and ensure food security. The NFF urges Government to continue to focus on the important issue of fuel and energy security, which is so important to the long term competitiveness of the agricultural sector.
Preview Rural Plant Code of Practice 2004 (PDF 220.5 kb)
The NFF’s 30 March 2012 submission to the Rural Plant Code of Practice 2004 – Quad bike and 2 wheel motorbike requirements states that it is appropriate and timely that independent research be undertaken as a matter of utmost priority. With an aim of establishing an acceptable ‘industry standard‘ focused upon mortality and injury reduction.
Preview Annual Wage Review 2011-12 (PDF 252.6 kb)
The NFF's 16 March 2012 Submission to the Annual Wage Review 2011-12 encourages a close consideration of the argument that minimum wages should be set at a level sufficient to encourage labour force participation. The view of NFF is that the federal minimum wage should be increased.
Preview Taxation of trusts (PDF 149.4 kb)
The National Farmers’ Federation 7 February 2012 submission to the review paper ‘Modernising the Taxation of Trust Income’ outlines important role that trust structures play for the agriculture sector, and suggests the review should focus on fixing known problems and clarifying uncertainties in the existing law
Preview Asian Century White paper (PDF 515.4 kb)
The National Farmers’ Federation 7 March 2012 submission to the Asian Century White paper notes that Australian agricultural sector is well positioned to capitalise on the Asian Century with the assistance of enabling policies. Changing demand and supply dynamics in the region combined with Australian agriculture’s fortunate characteristics, positioning and reputation mean the relationship between Australian agriculture and Asia will grow stronger
Preview Agricultural and Veterinary Chemicals Legislation Amendment Bill 2011 (PDF 165.9 kb)
The NFF is not involved in the registration of agricultural and veterinary chemicals, but represents a significant group of individuals who use agricultural and veterinary chemicals.

It is important that, if amendments to the legislation occur, a comprehensive evaluation of their impact is made after implementation. The evaluation should focus on the impact of the amendments on chemical availability and cost, including a review of changes to the price of chemicals, the diversity of chemicals on the market as well as information on the number and types of chemicals for which registrations have been sought and subsequently completed.
Preview Telstra’s draft Regional and Rural Presence Plan (PDF 182.8 kb)
The NFF has sought to ensure that Australian farmers – including those in the most remote areas of the country – have secure access to telecommunication services and upgrades to these services. Access to communication technologies is a fundamental requirement for modern businesses, including agricultural businesses. It is important that people living in rural Australia are not disadvantaged, and that services are delivered to rural Australians at metro-comparable prices, meaning they are equitable and affordable.
Preview Fair Work Act Review (PDF 2.8 Mb)
The NFF’s 17 February 2012 submission to the Fair Work Act Review Panel makes ten recommendations, based on the understanding that economic prosperity and growth requires fairness and security in the workplace.
Preview Inquiry into Australia’s overseas representation (PDF 154.1 kb)
The National Farmers’ Federation 8 February 2012 submission to the Joint Standing Committee on Foreign Affairs, Defence and Trade inquiry into Australia’s overseas representation highlighted the importance of Australia’s overseas representation, as NFF has had significant engagement with Australia’s diplomatic posts over many years, particularly on trade advocacy matters. The NFF urges the Government to provide additional technical capacity through a greater presence of technical specialists in overseas posts in response to a growing need to resolve technical market access issues
Preview Productivity Commission Inquiry into climate change adaptation (PDF 654.0 kb)
The NFF’s 23 January 2012 submission to the Productivity Commission Inquiry into the barriers to effective climate change adaptation acknowledges that agricultural industries will not experience climate change in a consistent way. This submission highlights the importance of Government in providing an environment that supports industries in responding to climate change and policy that encourages and promotes adaptive behaviour and innovation in agriculture and the associated industries to overcome the impacts of climate change and build resilience.
Federal Budget Submission 2012 (PDF 5.2 Mb)
The NFF's Federal Budget Submission 2012 calls on the Government to continue its investment in agriculture. The Submission outlines the 10 key priority areas for agriculture and the NFF under the Budget.

Submissions to Government 2011

Preview AUSVETPLAN Foot and Mouth Disease Strategy (PDF 120.0 kb)
The National Farmers’ Federation 23 December 2011 submission to the report, A review of Australia’s preparedness for the threat of foot–and–mouth disease (the Matthews Report), completed by Ken Matthews AO and his review team highlights a raft of positive recommendations that, if implemented, would markedly advance Australia's ability to prevent, and if necessary respond to, an incursion. NFF believes that the recommendations in the Matthews Report are prudent and must be carefully considered and expanded within the final FMD disease strategy
Preview Minerals Resource Rent Tax Bill 2011 and related bills (PDF 122.4 kb)
The National Farmers’ Federation 23 December 2011 submission to the Minerals Resource Rent Tax Bill 2011 and related bills acknowledges that the impacts of the Mining Tax on agriculture and the regional communities that the sector relies heavily upon can be seen in both negative and positive lights, and recognises that the Minerals Resource Rent Tax Bill 2011 has been packaged together with a range of unrelated policy objectives that the NFF feels strongly about and will impact our members
Preview Environmental Protection and Biodiversity Conservation Amendment (Protecting Australia’s Water Resources) Bill submission (PDF 106.9 kb)
The NFF’s 14 December submission to the Senate Standing Committees on Rural Affairs and Transport inquiry into Environmental Protection and Biodiversity Conservation Amendment (Protecting Australia’s Water Resources) Bill 2011 outlines the major concerns regarding the Bill and highlights that the proposals for water triggers under the EPBC Act are a poor solution for what should be better regulation at a State/Territory Government level for the mining and onshore petroleum industries.
Preview Environment Protection and Biodiversity Conservation Amendment (Emergency Listings) Bill submission (PDF 36.1 kb)
The NFF’s 12 December submission to the Senate Standing Committees on Environment and Communications inquiry into the Environment Protection and Biodiversity Conservation Amendment (Emergency Listings) Bill 2011 noted that the NFF cannot support this Bill due to its retrospective provisions, which significantly increases uncertainty for the agricultural industry.
Preview Regional Telecommunications Review (PDF 198.7 kb)
The NFF’s 9 December 2011 submission to the Regional Telecommunications Review has sought to ensure that Australian farmers – including those in the most remote areas of the country – have access to reliable, high quality telecommunications at an affordable price. It is essential that people living in rural Australia are not disadvantaged, and that the services delivered to rural Australians are equitable and affordable.
Preview Skilled Occupations List (PDF 260.7 kb)
The NFF’s 9 December 2011 submission to the Skilled Occupations List (SOL) for 2012 considers the SOL to be of critical importance to the future labour supply to the agriculture industry, but believes the SOL should be flexible enough to reflect the changing and elastic short and longer term needs of the industry as skills and labour shortages emerge.
Preview Horticultural Code of Conduct: inquiry into the Competition and Consumer Amendment (PDF 516.4 kb)
The NFF’s 5 December submission to the House of Representatives Standing Committee on Agriculture, Resources, Fisheries and Forestry inquiry into Competition and Consumer Amendment (Horticultural Code of Conduct) Bill 2011 highlights that there is still 'unfinished business' for the Government in bedding down the Horticulture Code of Conduct and responding to a number of recommendations from the Australian Competition and Consumer Commission to enhance the Code’s workability.
Preview Threat abatement plan for five northern grasses (PDF 353.6 kb)
The NFF’s 21 November 2011 submission to the ‘Draft threat abatement plan to reduce the impacts on northern Australia by the five listed grasses’ highlights the concerns of our members in the seemingly inconsistent listing of the five northern grasses. Of the five listed grasses, three have high production and economic values (gamba, olive hymenachne and para grass) while the remaining two (mission grass and annual mission grass) have no production values and are considered to have a negative impact on production and environmental values.
Preview Higher education and skills training in agriculture (PDF 1.4 Mb)
The NFF’s 15 November submission to the Senate Inquiry into higher education and skills training in agriculture has sought to demonstrate that there are no easy solutions in attracting more people to the industry and increasing the level of skills. Industry and Governments need to work collaboratively to develop workable solutions.
Preview Role of Local Government (PDF 126.7 kb)
The NFF’s 8 November submission to the Productivity Commission’s inquiry into Business Regulation Benchmarking: Role Of Local Government As Regulator outlined key concerns from our membership in this area, including the increasing shift in cost from state to local governments and increasing regulatory responsibilities of local government.
Preview Retail Pricing Bill (Farm Gate to Plate) (PDF 86.6 kb)
The NFF’s 6 November submission to the Senate Standing Committees on Economics Constitutional Corporations (Farm Gate To Plate) Bill, highlighted that although NFF is supportive of a transparent value chain and obtaining appropriate prices for primary producers, the NFF does not believe that the Bill will improve farm gate prices and will instead create a confusing layer of information for consumers.
Preview Environmental Reforms: the EPBC Act offsets policy, EPBC Act cost recovery, Biodiversity policy and the proposed National Centre for Cooperation on Environment and Development (PDF 398.8 kb)
The NFF’s 24 October 2011 submission to proposals by the Australian Government to finalise an EPBC Act offsets policy, introduce EPBC Act cost recovery, a new Biodiversity policy and the proposed National Centre for Cooperation on Environment and Development.

The NFF supports reform of the Government’s environmental legislation and policies. Such reform must serve to deliver a better business case for farmers and other industries undertaking development. Fundamental to this is the reduction in red tape as well as mechanisms that streamline environmental legislation and regulation (particularly across jurisdictions) to reduce duplication and confusion.
Preview Review of the Permanent Employer Sponsored Visa Categories (PDF 388.2 kb)
The NFF’s 16 September 2011 submission into the review of the Permanent Employer Sponsored Visa Categories seeks to highlight the key challenges and opportunities for resolution for the benefit of rural and remote employers.
Preview Food Labelling Review (PDF 407.1 kb)
The NFF’s 7 September 2011 submission into the Food Labelling Review provides in-principle support for the right of industries to implement voluntary measures that provide information about non-health related attributes to assist consumers in making informed purchasing decisions. The NFF acknowledges that specific factors can require variations and caveats on this principle, however significant pitfalls must be avoided when considering alternatives for food labelling.
Preview Issues Paper to Inform the Development of a National Food Plan (PDF 553.0 kb)
The NFF’s 2 September 2011 submission into the Issues Paper to Inform the Development of a National Food Plan recommends that the key outcome from the National Food Plan should be a shared view across government on the operation and priorities of the food production sector in Australia.
Preview Bankruptcy Amendment (Exceptional Circumstances Exit Package) Bill 2011 submission (PDF 43.1 kb)
The NFF’s 22 August 2011 submission to the Bankruptcy Amendment (Exceptional Circumstances Exit Package) Bill 2011 calls for a shift in the policy focus from ‘drought relief’ to ‘drought management and preparedness’, ensuring farmers are supported and have the tools to manage their businesses.
Preview Road Funding Reforms submission (PDF 138.1 kb)
The NFF’s 22 August 2011 submission into Road Funding Reforms supports the principles behind the reforms but raises signficant questions as to howroad charging will occur and how the benefits from supply side reform will be realised.
Preview Submission on the Clean Energy Legislative Package (PDF 492.9 kb)
The NFF’s 22 August 2011 submission on the Clean Energy Legislative Package reinforced concerns raised previously about the impact that the carbon tax will have on Australian farmers and the agricultural sector with the Government.
Preview Foreign Investment Review Board Interest Test (PDF 423.1 kb)
The NFF recognises that the issue of foreign investment in the agriculture sector is a topical area facing new and emerging dynamics that warrant discussion and policy deliberation. The NFF’s 16 August 2011 submission to the Senate Standing Committees on Rural Affairs and Transport’s examination of the Foreign Investment Review Board National (FIRB) Interest Test, reiterated that the findings of this review will be beneficial in providing additional clarity relating to the operation of the FIRB national interest test.
Preview Review of the Migration Amendment Act (PDF 69.7 kb)
The NFF's 16 August 2011 submission to the Rview of the Migration Amendment (Employer Sanctions) Act supports a comprehensive national education campaign for employers to help them to learn about and understand the requirements and process for checking the visa status of their employees.
Preview Legislative Reform for transition to the National Broadband Network (PDF 91.1 kb)
The NFF's 8 August 2011 submission on the Universal Service Obligation Legislative Reform for the transition to the National Broadband Network seeks to ensure that rural Australians – including those in the most remote areas of the country – have secure access to telecommunication service as well as upgrades to these services.
Preview Japan and Korea Trade Relations (PDF 422.4 kb)
The NFF’s 2 August 2011 Submission to the Trade Sub-Committee of the Joint Standing Committee on Foreign Affairs, Defence and Trade into the Inquiry into Australia's trade and investment relationship with Japan and the Republic of Korea. The NFF acknowledges that agriculture is complex and is seen as a hurdle in negotiations that has resulted in Australia’s FTA’s with Japan and Korea being difficult to conclude. Yet in the context of increasing global demand for food, it is in the interests of the Japanese and Korean economies and the wider population to increase domestic food choice and security by allowing Australian export markets to function without impediment.
Preview Australia’s Biodiversity in a Changing Climate (PDF 746.5 kb)
The NFF’s 29 July 2011 submission to the House of Representatives Standing Committee on Climate Change, Environment and the Arts Inquiry into Australia’s Biodiversity in a Changing Climate highlights agriculture's importance in delivering environmental outcomes on a national level.
Preview Supplementary Submission to the Senate Inquiry into the Murray-Darling Basin: Mining Coal Seam Gas (PDF 392.0 kb)
The NFF’s 30 June Supplementary Submission to the Senate Inquiry into the Murray-Darling Basin: Mining Coal Seam Gas summarises the NFF's key issues regarding the impacts of mining and coal seam gas on the Murray-Darling Basin. This Submission also makes a number of suggestions to resolve some of the key issues relating to communication, land access, mining best practice, rehabilitation, water management, and environmental approvals.
Preview Heavy Vehicle Funding and Implementation (PDF 329.3 kb)
The NFF’s 3 June 2011 Heavy Vehicle Funding and Implementation submission supports transparency in road pricing, but notes that the economic benefits from pricing signals will be limited in many areas of remote and rural Australia where there is no route choice or no flexibility to optimise vehicle type or configuration.
Preview Caring for Our Country Review (PDF 669.3 kb)
The NFF's 20 May 2011 submission to the Caring for Our Country Review has called for a more comprehensive review of the Government’s initiative, as a number of specific issues have been raised by NFF members. The NFF remains highly concerned that the Government's focus on regulation and acquiring large areas of land for biodiversity and ecological outcomes and for public land, has not yet managed to secure improved environmental outcomes.
Preview Heavy Vehicle National Law Draft Regulatory Impact Statement (PDF 85.6 kb)
The NFF's 10 May 2011 Heavy Vehicle National Law Draft Regulatory Impact Statement submission supports the establishment of a single national system of laws for heavy vehicles to improve efficiency in the operation of heavy vehicles and reduce the administrative and regulatory burden for heavy vehicle operators.
Preview National Land Freight Strategy (PDF 93.1 kb)
The NFF's 6 May 2011 National Land Freight Strategy submission has continued to call for a structured approach to defining the current and future freight infrastructure needs.
Preview Drought Pilot Review (PDF 263.4 kb)
The NFF's 21 April 2011 submission to the Drought Pilot Review Panel has called for a shift in the policy focus from ‘drought relief’ to ‘drought management and preparedness’.
Preview Consultation Regulation Impact Statement on A National Scheme for Assessment, Registration and Control of Use of Agricultural and Veterinary Chemicals (PDF 341.2 kb)
The NFF's 11 April 2011 submission to the Department of Agriculture, Fisheries and Forestry, recognising the range of processes exploring registration and regulation of agricultural and veterinary Chemicals. A National Regulatory Framework will have substantial implications for farmers.
Preview Senate Standing Committees on Environment and Communications into Carbon Credits (Carbon Farming Initiative) Bill 2011; Carbon Credits (Consequential Amendments) Bill 2011 and Australian National Registry of Emissions Units Bill 2011 (PDF 395.2 kb)
The NFF has welcomed the introduction of the Carbon Farming Initiative (CFI) legislation into Federal Parliament and is pleased that it has addressed a number of the NFF's key concerns raised through the draft consultation process.
Preview Draft model Work Health and Safety Regulations submission (PDF 354.9 kb)
The NFF's 4 April 2011 Submission in resepct to the draft model Work Health and Safety Regulations relates specifically to issues the NFF have identified in respect to farming implications.
Preview Submission to the Sustainable Population Strategy (PDF 381.0 kb)
The NFF's 28 March 2011 submission to the Sustainable Population Strategy asserts that regional employers need greater assistance in becoming employers of choice.
Preview Submission on the Inquiry into the Provisions of the Water Act 2007 (PDF 643.6 kb)
The NFF’s 18 March 2011 submission to the Senate Legal and Constitutional Affairs Committee Inquiry into the Provisions of the Water Act 2007 focuses on how to achieve a balanced approach to deliver on social, economic and environmental aspirations of the Basin’s communities.
Preview Submission to the Inquiry into Foreign Acquisitions Amendment (Agricultural land) Bill 2010 (PDF 257.4 kb)
The NFF’s February 2011 submission to the Inquiry into Foreign Acquisitions Amendment (Agricultural Land) Bill 2010 highlights the complexity of the issue and outlines the NFF position on foreign investment and what areas the inquiry should examine.
Preview Submission to the Annual Wage Review 2010-11 (PDF 205.3 kb)
The NFF's 18 March 2011 Submission to the Annual Wage Review 2010-11 highlights that the east coast is no longer drought declared, but the "catch up" effect on farm profits arising from 9 continual years of drought is ongoing.
Preview National Broadband Network (PDF 194.9 kb)
The NFF's National Broadband Network Submission, released on 7 March 2011, highlights the role that telecommunications including Broadband play in modern farming practices....
Preview Federal Budget Submission 2011 (PDF 949.2 kb)
The NFF's Federal Budget Submission 2011, released on 22 February 2011, draws together the threads necessary for a national response to flood and cyclone ravaged communities, but also addresses the perennial problems that plague the nation...
Preview National Codes of Practice for the Humane Control of Invasive Animals (PDF 519.9 kb)
The NFF’s 11 February 2011 submission into the Regulatory Impact Assessment for National Codes of Practice for the Humane Control of Invasive Animals, supports mechanisms that reduce the pain and suffering of invasive animals or non-target species. However, the NFF recognises that in some cases, gaps remain in the replacement options for discontinued practices.
Preview Draft National Strategic Rural Research and Development Investment Plan (PDF 307.7 kb)
The NFF's 10 February 2011 submission on the Draft National Strategic Rural Research and Development Investment Plan reiterating the NFF's call for the Australian Government to reverse the decline in agricultural research and development funding and supports the Councils’ recommendation for a Government boost to investment in rural...
Preview Inquiry into the Food Standards Amendment (Truth in Labelling - Genetically Modified Material) Bill 2010 (PDF 98.3 kb)
The NFF's 10 February 2011 submission to the Inquiry into the Food Standards Amendment (Truth in Labelling - Genetically Modified Material) Bill 2010 advocates Australian farmers should have the opportunity to adopt production methods best suited to their business and production system needs...
Preview Carbon Farming Initiative (PDF 459.1 kb)
The NFF's 24 January 2011 submission on the Federal Government's Carbon Farming Initiative, outlining the need for greater flexibility to realise farming's full offset potential and the need for costs and processes to be streamlined for uptake to be meaningful...
Preview National Water Initiative 2011 Biennial Assessment Progress in Implementation Discussion Paper (PDF 683.9 kb)
The NFF's 20 January 2011 submission to the National Water Initiative 2011 Biennial Assessment Progress in Implementation Discussion Paper focuses on national water reform (including the Murray-Darling Basin), as well as addressing discussion paper questions. The NFF contends that major changes to the Water Act 2007 and the shift in responsibilities afforded by the Commonwealth, warrant the Federal Government re-submitting a new NWI implementation plan for accreditation...

Submissions to Government 2010

Preview Inquiry into the Management of the Murray-Darling Basin (PDF 899.2 kb)
The NFF’s 22 December 2010 submission to the Senate Rural Affairs and Transport Standing Committee Inquiry into the Management of the Murray-Darling Basin, calling for a more holistic view of water reform and the need to back this up with major infrastructure – on-farm, through irrigation systems and environmental infrastructure – as well as bolstering research and development...
Preview Submission to the Inquiry into The Impact of the Murray-Darling Basin in Regional Australia (PDF 578.6 kb)
The NFF’s 20 December 2010 submission to the House of Representatives Standing Committee on Regional Australia Inquiry into The Impact of the Murray-Darling Basin in Regional Australia agrues environmental assets in the Basin can be maintained using less water through improvements to infrastructure and wetland management...
Preview NFF Response to the Guide to the Basin Plan (PDF 1.5 Mb)
The NFF’s 17 December 2010 response to the Guide to the Basin Plan, exposing detailed faults in the assumptions, methodologies and proposals underpinning it's development...
Preview National Regulatory Framework on Agricultural and Veterinary Chemicals (PDF 299.8 kb)
The NFF's 16 December 2010 submission to the Department of Agriculture, Fisheries and Forestry, recognising the range of processes exploring registration and regulation of agricultural and veterinary Chemicals. A National Regulatory Framework will have substantial implications for farmers...
Preview The Role of Government in Rail Frieght Investment (PDF 123.8 kb)
The NFF's 15 December 2010 submission to the National Transport Commission raises vital efficiencies that have been generated within farm production to maintain international competitiveness, which are currently constrained by inefficiencies in related sectors, such as transport..
Preview Universal Service Policy for the Transition to the National Broadband Network (PDF 71.9 kb)
The NFF’s 5 November 2010 response to the Department of Broadband, Communications and the Digital Economy’s discussion paper on the Implementation of Universal Service Policy for the transition to the National Broadband Network...
Preview Heavy Vehicle Pricing Review (PDF 190.6 kb)
The NFF's 10 September 2010 submission maintains that the pricing of transport, including road and rail, should be transparent to ensure that farmers are able to make informed decisions about how to transport their produce in the most efficient and cost effective manner...
Preview Productivity Commission Inquiry into The Australian Government Research and Development Corporations Model (PDF 2.0 Mb)
The NFF’s 25 June 2010 submission to the Productivity Commission Inquiry into The Australian Government Research and Development Corporations Model identifies a series of key issues relating to research and development for the agricultural industries and the role of the Rural Research and Development Corporations...
Preview National Ports Strategy (PDF 157.4 kb)
The NFF’s 28 May 2010 submission on the Proposed National Ports Strategy highlights the need for the Strategy to link with other freight infrastructure and that it should be informed by an understanding of current and future freight flows...
Preview Submission to the Review of Food Labelling Law and Policy (PDF 468.5 kb)
The NFF’s 26 May 2010 submission to the Review of Food Labelling Law and Policy insists that labelling laws must not impose unreasonable costs or lead to adverse trade implications, and should be practical to implement...
Preview Population Policy: Regional Labour Pains (DOC 910.0 kb)
The NFF's 23 April 2010 submission to the House Standing Committee on Employment and Workplace Relations Inquiry into Regional Skills Relocation recommending a series of measures - including domestic relocation and tying immigration to regional locations - as part of the solution to Australia's projected population explosion...
Preview Submission to the Senate Economics Committee Inquiry into Access of Small Business to Finance (PDF 341.1 kb)
The NFF’s 16 April 2010 submission to the Senate Economics Committee Inquiry into Access of Small Business to Finance asserts the need to build competition and transparency in the banking sector, improve the understanding by the Reserve Bank of Australia of regional economic conditions, revisit tax-based investment mechanisms for regional Australia and build the education and awareness of risk management tools for farmers...
Preview Submission to Australia's Native Vegetation Framework Consultation Draft (PDF 533.1 kb)
The NFF’s 31 March 2010 submission to Australia's Native Vegetation Framework Consultation Draft callin for a 10-year working relationship between private land managers and acknowledge of the environmental contribution farmers make. The NFF also asserts land clearing bans impact on property rights and must replaced by market-based approaches, and all levels of government should look at stewardship arrangements to recognise on-farm environmental management...
Preview Property Rights: Submission on Native Vegetation Laws, Greenhouse Gas Abatement and Climate Change Measures (PDF 962.1 kb)
The NFF's 19 March 2010 submission to the Senate Finance and Public Administration Committee Inquiry into Native Vegetation Laws, Greenhouse Gas Abatement and Climate Change Measures, calling for legislative changes, market-based drivers for compensation, a Public Benefit Test on government regulations, analysis of international agreements and their impact, and securing tenure over water property rights...
Preview Productivity Commission Inquiry into Bilateral and Regional Trade Agreements (PDF 489.9 kb)
The NFF's 1 March 2010 submission to the Productivity Commission, highlighting multilateral trade reform as the priority trade policy for the NFF. The NFF will continue to drive these agreements on both offensive and defensive grounds.

In the meantime, bilateral agreements must be comprehensive, lead to genuine commercial opportunities, avoid ‘new protectionism’, be transparent, must not undermine the WTO negotiations, must not undermine the process of unilateral reform and they must not compromise public policy...
Preview Submission on Minister Burke’s Rural R&D Council on perspectives of Australia’s Rural Research and Development System (PDF 1.1 Mb)
The NFF’s 17 February 2010 submission to the Minister’s Rural R&D Council highlights the strengths of Australia’s Rural R&D System, but also the need for a whole-of-government approach when responding to the R&D challenges faced by the agricultural sector. This approach needs to consider the role of private investment in R&D, Australia’s support for international agricultural R&D as well as the need for the various Government departments and agencies to align their efforts on agricultural R&D...
Preview COAG Consultation Draft NWI Policy Guidelines for Water Planning & Management (PDF 516.2 kb)
The NFF's 12 February 2010 NFF Submission to the COAG Consultation Draft National Water Initiative Policy guidelines for water planning and management, calling for a consistent approach across all jurisdictions...
Preview Submission to the Productivity Commission’s Draft Research Report on Market Mechanisms for Recovering Water in the Murray-Darling Basin (PDF 516.2 kb)
The NFf'S 12 February 2010 submission reinforces the Commission’s recommendation that a strict scientific basis be required for setting the Sustainable Diversion Limit (SDL) and supports a balanced approach to determining the SDL...
Preview National Scheme for Assessment, Registration and Control of Use of Agricultural and Veterinary Chemicals (PDF 374.2 kb)
The NFF’s 8 February 2010 submission to the Product Safety and Integrity Committee on the proposal for a single, national framework to improve the efficiency and effectiveness of the regulation of agricultural and veterinary chemicals, highlights the need for greater consistency in chemical regulation and control of use. The submission also highlights the need to recognize and preserve the strengths of the current system, including its capacity to recognize and respond to local differences...
Preview Submission to the ACCC Water Trading Rules Draft Advice (PDF 346.0 kb)
The NFF's 1 February 2010 submission to the Australian Competition and Consumer Commission (ACCC) raises shortcomings from the implementation of the Water Act - specifically, water planning and management - and seeks development of advice to the Federal Government to resolve these legislative inadequacies. Key points of concern include: application of rules, over allocation, foreign investment, urban water supply, stock and domestic water, conversion between priority classes...

Submissions to Government 2009

Preview Submission to the Development of Sustainable Diversion Limits Issues Paper for the Murray-Darling Basin Plan (PDF 671.1 kb)
The NFF's 18 December 2009 submission to the Development of Sustainable Diversion Limits Issues Paper for the Murray-Darling Basin Basin Plan, highlighting sustainable diversion limits are a key component for an effective Murray-Darling Basin Water Plan - covering the crucial need for a balance between the agricultural sector and the environment, given socioeconomic considerations have not been accounted for...
Preview Submission on the National Water Initiative (PDF 433.4 kb)
The NFF's 4 December 2009 submission on the National Water Initiative, outlining the need for a consistent approach to capex, water planning and management, across all jurisdictions, to ensure competitive neutrality and minimise the potential for negative impacts to water trade and markets. The NFF also calls for the appointment of independent state-based regulators...
Preview Submission on the ACCC Water Trading Rules Position Paper (PDF 387.1 kb)
The NFF's 23 October 2009 submission to the Australian Competition and Consumer Commission (ACCC) Water Trading Rules Position Paper, outlining concerns...
Preview Senate Inquiry into Water licenses and Rights (PDF 639.5 kb)
The NFF’s 9 October 2009 submission to the Senate Inquiry into Water licenses and Rights details the critical need to educate both State and Commonwealth Governments on water management and planning, particularly for the understanding of the management of water entitlements...
Preview Inquiry into the Impacts of Mining in the Murray-Darling Basin (DOC 98.0 kb)
The NFF's 21 September 2009 submission to the Senate Environment Communications and the Arts References Committee: Inquiry into the Impacts of Mining in the Murray-Darling Basin acknowledges that while agriculture and mining can co-exist, better rules of engagement and research are needed to assess the economic, social and environmental impacts of mining in regional Australia.

The NFF asserts the need to establish fair and equitable processes for managing the mining and agricultural interface, which ensures property rights of farmers and broader social and environmental issues are given due consideration by governments. Concerns also relate to the adequacy of government procedures for making sound and transparent long-term decisions on mining development that safeguard the natural resources on which agriculture and broader society rely. Ultimately, without a clear understanding of the risks from exploration and mining operations, these operations should either be delayed until the research is done, or postponed indefinitely...
Preview Market Mechanisms for Recovering Water in the Murray Darling Basin Productivity Commission (PDF 782.9 kb)
The NFF’s 18 September 2009 submission to the Productivity Commission inquiry into Market Mechanisms for Recovering Water in the Murray Darling Basin, highlighting the need to balance the roll out of infrastructure with water recovery...
Preview Supplementary discussion paper - Carbon accounting for agriculture post-Kyoto (PDF 443.6 kb)
The NFF's 1 September 2009 subsmission puts a broader context around the carbon accounting issues faced by agriculture, particularly in light of the international community's recognition that Kyoto rules ability to underpin domestic mitigation policies for agriculture is limited. World governments are reluctant to impose financial penalties on emissions from their farm sectors, instead opting to permanently exclude direct emissions from agriculture...
Preview Submission to the Review of the WA Genetically Modified Crops Free Areas Act 2003 (DOC 35.0 kb)
The NFF's 13 August 2009 submission to the Western Australian Government's review of the Genetically Modified Free Areas Act 2003, expressing concerns about the impact the Act has on the profitability and competitiveness of farmers in Western Australia...
Preview Submission to the Independent Review of the Federal Environment Protection & Biodiversity Conservation Act (Hawke Review) (PDF 841.7 kb)
The NFF's 10 August 2009 submission to the Interim Report of the Independent Review of the Federal Environment Protection & Biodiversity Conservation Act (Hawke Review) seeks a streamlining of Australia’s environmental law across all jurisdictions. Any changes to the EPBC Act must be based on credible and substantial justification for change and not arise from broader community perceptions of an inability to influence outcomes. Furthermore, market based solutions, such as the Environmental Stewardship Program, have a proven track record for delivering real biodiversity outcomes on the ground...
Preview Framework for Determining Commonwealth Environmental Watering Actions (PDF 143.1 kb)
The NFF's 31 July 2009 submission to the Australian Government Department of the Environment, Water, Heritage and the Arts on the interim framework being established as a short-term strategy pending the implementation of the Environmental Watering Plan under the Murray-Darlin Basin Plan coming into effect...
Preview Non-Commercial Losses (PDF 432.7 kb)
The NFF's 31 July 2009 submission on the Australian Government's Exposure Draft regarding Non-Commerical Losses. The proposed changes could lead to significant unintended consequences including the potential to provide a disincentive for farmers to maximise off-farm income, negatively impact environmental outcomes, negatively impact regional communities, lead to repercussions on existing loans, negatively impact farm values, and provide a disincentive to start up ventures...
Preview Impact of Managed Investment Schemes - Agribusiness (PDF 385.0 kb)
The NFF's 23 July 2009 submission to the Senate Inquiry into Food Production in Australia, following the collapse of two of the largest Managed Investment Scheme (MIS) operators, Timbercorp and Great Southern Plantations. The NFF is concerned about the exponential growth in MIS forestry projects and believes that in many instances, the MIS mechanism does not promote sound investment decisions in rural and regional Australia. The NFF believes that many MIS projects have created negative distortions of resource allocation in regional areas...
Preview Inquiry Into Agribusiness Managed Investment Schemes (PDF 588.8 kb)
The NFF's 26 June 2009 submission to the Parliamentary Joint Committee on Corporations and Financial Services, Department of the Senate, examining the collapse of two of the largest Managed Investment Scheme (MIS) operators, Timbercorp and Great Southern Plantations. This has intensified the focus on the MIS mechanism and how appropriate it is (or is not) for rural and regional Australia. The NFF is concerned about the exponential growth in MIS forestry projects and believes that in many instances, the MIS mechanism does not promote sound investment decisions in rural and regional Australia. The NFF believes that many MIS projects have created negative distortions of resource allocation in regional areas...
Preview Australia’s Anti-Dumping And Countervailing System (PDF 284.3 kb)
The NFF's June 2009 submission to the Productivity Commission Issue Paper outlining the major challenge for anti-dumping policy in identifying options to improve the accessibility of Australia’s anti-dumping system for industries with legitimate claims against dumped products, while insuring that any changes to policy or administration do not result in an increase in the number of unsubstantiated applications from industry sectors seeking to use the anti-dumping system as a means of reinstating industry protection...
Preview Tightening The Non-commercial Loan Rules: Public Consultation (PDF 359.2 kb)
The NFF's 16 June 2009 submission relates to the Australian Government’s rationale for tightening the non-commercial loan provisions under Division 7A. However, the NFF encourages the Government to ensure that farmers are not unintentionally affected by the new legislation through their legitimate use of company assets owned exclusively for business use - in particular farm land. Should the Government fail to allow for this anomaly, the financial implications and resulting red tape would be an extremely significant impost to many farm businesses who currently hold their farm land within a private company structure...
Preview Submission to the ACCC on Water Planning & Management Charges Draft Rules (PDF 264.9 kb)
The NFF's 5 June 2009 submission is the latest response to a series of rules being developed by the Australian Competition and Consumer Commission (ACCC) to enhance water charge regimes, and to ensure consistent pricing principles apply across the Murray-Darling Basin...
Preview Submission on Biodiversity Conservation Strategy (PDF 771.9 kb)
The NFF’s 29 May 2009 submission highlights the unique knowledge and contribution landholders make to effective management of and outcome for biodiversity. It is time to acknowledge past and current efforts, in particular the voluntary efforts of farmers to retain and re-establish native vegetation on their properties, whilst also planning the next decade of biodiversity management...
Preview Submission to the ACCC on Water Trade Rules Issues Paper (PDF 637.8 kb)
The NFF's 1 May 2009 submission is the latest response to a series of rules being developed by the Australian Competition and Consumer Commission (ACCC) to enhance water market and trading regimes. This submission was requested by the Murray-Darling Basin Authority, with the final rules to be included in the Basin Plan...
Preview Submission into Climate Policy (PDF 395.2 kb)
The NFF's 8 April 2009 submission the Senate Select Committee on Climate Policy, noting that it is widely recognised that an emissions trading scheme is an inappropriate policy mechanism for the Australian agricultural sector. In addition to the potential for perverse economic and social impacts from the CPRS, the NFF is concerned about the potential for the CPRS to lead to significant perverse environmental outcomes in areas such as water runoff, biodiversity, and Australia’s ability to continue to make a contribution to global food and fibre supplies. This submission outlines the policy principles for appropriate climate change mitigation policy for the agriculture sector...
Preview Impact of the global financial crisis on regional Australia (PDF 438.8 kb)
The global financial crisis heralds numerous short- and long-term challenges for agriculture, which, in turn, will impact on regional communities. To reduce the impact of the GFC on regional Australia, the NFF's 27 March 2009 submission recommends action to increase transparency on banks passing on interest rate cuts, correcting the inequities with bank deposit guarantee, investment in economic and social infrastructure, aggressively pursuing the trade reform agenda, building labour flexibility and facilitating regional tourism...
Preview Inquiry into the Exposure Drafts of the Legislation to Implement the CPRS (PDF 445.8 kb)
Despite agriculture not being covered by the proposal Carbon Pollution reduction Scheme (CPRS), the sector will be unaffected, therefore, the exposure draft legislation is of enormous interest to farmers. The NFF's 25 March 2009 submission highlights issues regarding the international competitiveness impacts on the agricultural sector, concerns around the opt-in forestry provisions and the need for the legislation to have flexibility in recognising non-Kyoto compliant emissions units...
Preview Submission to the 2009 Wage Review (PDF 1.5 Mb)
The NFF’s 20 March 2009 submission to the Australian Fair Pay Commission (AFPC) Wage Review, outlining the static and intensifying impact of drought on rural employers, coupled with the global economic crisis and recent domestic disasters. Referencing the net growth in employment in agriculture in the last five consecutive quarters, the submission strongly demonstrates the way wage constraint has assisted the sector to retain staff, poising it for post-drought recovery. A key facet of the submission highlights the parallels between wage restrain and preserving economy-wide employment levels...
Preview Inquiry into the Role of Government in Assisting Australian Farmers to Adapt to the Impacts of Climate Change (PDF 514.4 kb)
Climate change, its effect on agricultural productivity and the policy responses to combat its effects, are of vital importance to the NFF and its members. Indeed, as they relate to farmers they are of significant importance to the Australian economy. In this debate we must not forget about the challenge that also arises from adapting to climate change policy. The NFF's 6 March 2009 submission highlights the immediate challenge of adapting to climate change mitigation policies may be greater for farmers than adapting to climate change itself. To help the farm sector adapt to climate change, the NFF recommends actions to facilitate a new model for drought support, arresting the decline in agricultural R&D, national coordination of R&D and extension services, development of appropriate climate change policies for agriculture and investment in Australia’s climatic forecasting capability...
Preview Submission on the Regulatory Impact Statement for the National Framework for Regulation, Registration and Licensing of Heavy Vehicles (DOC 138.0 kb)
The NFF's 18 February 2009 submission highlighting the over-regulation, or unpredictable regulation, can adversely impact on the cost of transport and the incentives for new investment, and calling for a coherent, transparent and stable regulatory environment to encourage investment in appropriate modes of transport...
Preview Submission to the consultation draft of Australia’s Strategy for The National Reserve System 2008-2030 (PDF 352.4 kb)
The NFF’s 22 January 2009 submission to the consultation draft of Australia’s Strategy for The National Reserve System 2008-2030 concentrates on cooperative arrangements for protection of Australia’s biodiversity while, at the same time, protecting and enhancing Australia’s agricultural production. The Government must recognise the contribution of private land conservation through non-legal title...
Preview Federal Budget Submission 2009 (PDF 1.8 Mb)
The NFF’s Federal Budget Submission 2009, released on 19 January 2009, has been devised as a plan for tackling the dual international issues of the global financial crisis and the world food shortage - covering Drought Reform,
Research and Development, Data and Information Services, Water, The Environment, Taxation, Social Security, Education, Infrastructure, and Quarantine...

Submissions to Government 2008

The following are submissions the NFF has made on various subjects to the Australian Government in 2008 - including parliamentary committees and government departments and agencies...

Preview Submission to the Productivity Commission Draft Inquiry Report into Government Drought Support (PDF 719.4 kb)
The NFF's 22 December 2008 response to the Productivity Commission looks to farming’s future and the importance of providing farmers with a suite of effective tools to manage risk, continual innovation incentives and disaster support is crucial to not just the viability of farmers, but to the ability for farming to continue to feed and clothe the world as populations boom and agricultural resources shrink while responding to climate variability.

The NFF argues that a new drought policy should be introduced to run alongside existing support programs, consistent with a commensurate level of funding towards management and preparedness, risk management tools, sustainability and recovery from drought. Within guidelines, these measures should be available to all farmers, not just those within the current EC-declared area...
Preview Fair Work Bill 2008 - Submission to the Senate Standing Committee on Education, Employment and Workplace Relations (PDF 466.7 kb)
The NFF's 23 December 2008 submission addresses three core concerns within the Fair Work Bill 2008, focusing on application of the Bill, technical details and finally, policy concerns.

While Bill reflects a generally balanced approach to reforming the national workplace relations system, and the Australian Government has carried out extensive consultation, nevertheless many concerns of the agricultural sector have simply not been addressed. Similarly, some provisions in the Bill will not achieve their intended policy objectives...
Preview Natural Resource Management Ministerial Council Soils & Terrain Discussion Paper (PDF 357.9 kb)
The NFF's 11 December 2008 submission urges the Australian Government adopt a strategic national approach to soil management, highlighting the lack of knowledge around these ecosystems is impinging on Australian farmers' ability to make informed soil management decisions and, therebym hampering sustainably goals...
Preview Submission to the Senate Inquiry into the Coorong and Lower Lakes: Part 2. Implications for Long-Term Sustainable Management of the Murray-Darling Basin (PDF 358.2 kb)
The NFF's 19 November 2008 submission to the Senate Inquiry contends that the current arrangements being finalised for the Basin be allowed to be implemented prior to further reviews of arrangements are undertaken. Furthermore, there are a number of mechanisms contained in the Water Act 2007 and Water Amendment Bill 2008 that provide for reviews...
Preview Submission to the ACCC on Water Market Draft Rules (PDF 289.2 kb)
The NFF's 10 November 2008 submission is the latest response to a series of rules being developed by the Australian Competition and Consumer Commission (ACCC) to enhance water market and trading regimes, and to ensure consistent pricing principles apply across the Murray-Darling Basin...
Preview Submission to the Senate Inquiry into the Water Amendement Bill (PDF 309.7 kb)
The NFF's 7 November 2008 submission supports the Water Amendment Bill but advocates an amendment to protect water entitlements in relation to critical human needs and reserves. The submission calls for review of impacts on water entitlements...
Preview Submission on the Review of Australia's Future Tax System (PDF 422.3 kb)
The NFF's 17 October 2008 submission highlights key areas where taxation can play a major role in influencing the behaviour of Australia’s farming community and, if used effectively, induce positives for the economy, the environment and society, and outlines the potential for taxation to play an important role in achieving desired policy outcomes in the areas of climate change, environmental stewardship, drought and regional development while highlighting important core principles in developing taxation measures...
Preview Submission on Infrastructure Australia (PDF 397.6 kb)
The NFF's 15 October 2008 submission outlines key infrastructure needs in the areas of water, energy, transport and telecommunications. Specific focus has been placed on the need to factor in the community service obligation within the Infrastructure Australia planning process, while highlighting specific needs including a new model for determining the future transport infrastructure needs of agriculture, the grain branch lines, the North-South Railway, increased road access to high productivity vehicles, water infrastructure to cover urban, on-farm, environmental and irrigation needs, quality affordable telecommunications services, and utility level renewal energy creation...
Preview Submission to the Skills Australia Future Governance of the National VET System (DOC 208.0 kb)
The NFF's 15 October 2008 submission asserting that the National Training System is dominated by bureaucracy, despite claims that it is industry-led, and that reform is essential in the training system to ensure that skills based training reflects the relevant, practical needs of employers through a central role for industry...
Preview Deegan Review - Discussion Paper 2 (PDF 373.0 kb)
The second of three NFF submissions, lodged on 7 October 2008, to the Subclass 457 Integrity Review, conducted by Ms Barbara Deegan, into the skilled migration program, canvassing responses in relation to English language requirements and occupational health and safety...
Preview Deegan Review - Discussion Paper 3 (PDF 401.1 kb)
The final of three NFF submissions, lodged on 7 October 2008, to the Subclass 457 Integrity Review, conducted by Ms Barbara Deegan, into the skilled migration program, canvassing responses in relation to the regulatory frameworks for skilled migration, employer obligations and Labour Agreements...
Preview EPBC Act Senate Inquiry (PDF 455.8 kb)
The NFF's 26 September 2008 submission strongly supports incentives-based approaches, rather than regulation, to ensure a culture of active management of private land environmental assets leading to optimal outcomes.

The NFF submits that improvements required include streamlining multi-jurisdictional NRM assessment processes, a more transparent linkage between the Caring for our Country program and the EPBC Act, and adequate resourcing of a communications strategy to ensure that farmers are aware of the EPBC Act and their obligations under it...
Preview The Pension Review (PDF 379.1 kb)
The NFF's 26 September 2008 submission to the Australian Government's Review of the Age Pension, Carer Payment and the Disability Support Pension, as part of the Government's broader inquiry into Australia's Future Tax System.

The NFF recommends that the five-year time limit be removed on the ability of farmers to gift the farm to their children upon retirement and access the age pension. This opportunity should be provided for retiring farmers to gift their farm to a member of the younger generation of their family without being disadvantaged by the disposal of assets rule...
Preview ACCC Access Termination Fees Position Paper Submission (PDF 251.0 kb)
The NFF's 15 September 2008 submission responding to a series of rules being developed by the Australian Competition and Consumer Commission (ACCC) to enhance water market and trading regimes, and to ensure consistent pricing principles apply across the Murray-Darling Basin...
Preview Submission to the Review of Non-forestry Managed Investment Schemes (PDF 382.5 kb)
The NFF's 12 September 2008 submission reiterates the view that the Managed Investment Scheme mechanism is not appropriate for agriculture, in many instances leading to distored resource allocation in rural and regional Australia...
Preview Senate Coorong Inquiry Submission (PDF 755.5 kb)
The NFF's 11 September 2008 submission to the Senate Inquiry contends that there is little that can be done to provide freshwater for the Lower Lakes in the short-term and, to do so, will significantly impact upon the social, economic and environmental fabric of the Basin.

The NFF also submits that the proposed Emergency Water Bill is poor policy as it seeks to fast-track development of an Interim Basin Plan, having a significant impact on agriculture across the Basin. The NFF cannot support this Bill...
Preview Submission to the Australian Government's Carbon Pollution Reduction Scheme (CPRS) Green Paper (PDF 1.2 Mb)
The NFF's 10 September 2008 submission in response to the Australian Government's Carbon Pollution Reduction Scheme (CPRS) Green Paper, outlining key issues and concerns, including the areas of Emissions Intensive Trade Exposed sector assistance, points of obligation for the agriculture sector, land use change, international carbon accounting rule inadequacies, research and development needs and complementary measures.

The submission also proposes an outline of the process required between now and 2013 when a decision is required about if or when agriculture will be able to be equitably covered by the CPRS...
Preview Deegan Review – Discussion Paper 1 (PDF 410.7 kb)
The first of three NFF submissions, lodged in August 2008, to the Subclass 457 Integrity Review, conducted by Ms Barbara Deegan, into the skilled migration program, canvassing responses in relation to the Minimum Salary Level, spouse entitlements and Labour Agreements...
Preview Submission to the National Review into Model Occupational Health and Safety Laws (PDF 298.5 kb)
The NFF’s August 2008 submission to the Australian Government's national review of workplace safety legislation, the national safety body and the adoption of uniform safety legislation...
Preview Senate Inquiry into Natural Resource Management and other Conservation Challenges (PDF 387.0 kb)
The NFF's 29 August 2008 submission to the Senate Inquiry into Natural Resource Management (NRM) and other Conservation Challenges supported regional NRM delivery but welcomed the opportunity for contestable open grants that allows for a range of applicants to delivery NRM outcomes under the six national priorities of the Commonwealth’s Caring for our Country program...
Preview Submission to the Senate Committee on Fuel and Energy (PDF 504.7 kb)
The NFF's 28 August 2008 submission outlining the impact that fuel and energy prices are having on Australian farmers and identifying a range of initiatives that the NFF believes can help to alleviate the situation into the future.

These include: Alternative transport fuel development, Associated R&D, On-farm biodiesel regulations, Competition issues, Bioenergy research and development, and Renewable energy research and development...
Preview ACCC: Water Bulk Water Charge Rules Issues Paper (PDF 478.2 kb)
The NFF's 18 August 2008 submission - responding to a series of rules being developed by the Australian Competition and Consumer Commission...
Preview Submission to the ACCC Water Market Rules Position Paper (PDF 453.1 kb)
The NFF's August 2008 submission commenting on issues arising from the Australian Competition and Consumer Commission's position paper for water market rules...
Preview Submission to the Productivity Commission Inquiry into Government Drought Support (PDF 869.5 kb)
The NFF’s August 2008 Submission to the Productivity Commission Inquiry into Government Drought Support calls for a new approach to agriculture policy where drought policy is one aspect within a national framework, and focuses on partnerships between government and primary producers. Under this framework, climate change adjustment tools must be maintained in non-drought years to achieve optimum results.

The NFF also recommends that an Exceptional Circumstances policy trigger is no longer appropriate under a changing climate. The National Drought Policy (NDP) principles of self-reliance and risk management remain relevant but policy measures better aligned to these principles are needed. The key platforms of this policy must include farmers' ability to access the most appropriate policy options for them, a meaningful transition period, and tangible on-farm preparedness improvements...
Preview Innovation Review (PDF 337.8 kb)
The NFF's 31 July 2008 submsiion to the Australian Government's Innovation Review notes that agriculture boasts one of the highest productivity rates of any industry in Australia through a strong commitment to research and development, which must continue in order to compete in the global marketplace.

A major challenge will be attracting people into an agriculture-related career to replace the present number of baby-boomer scientists nearing retirement. Further, a focus on innovation adoption and commercialisation is imperative to any research and development effort with industry engagement and strategic direction alignment being seen as crucial components of any innovation system...
Preview Inquiry into Legislation Underpinning Carbon Sink Forests (PDF 381.9 kb)
The NFF's 31 July 2008 submission to the Senate Standing Committee on Rural and Regional Affairs and Transport, regarding implementation, operation and administration of carbon sink forests, calling for legislative amendements to provide a genuine incentive for farmers to engage in an appropriate level of on-farm forestry.

It also calls for Government to examine the impacts of the broader suite of current and proposed policies that are designed to drive forestry - including MIS and the forestry component of the proposed CPRS - which collectively have significant potential to influence land use in regional Australia.

The submission also highlights the need to change the international greenhouse gas accounting rules in order to enable agriculture to participate effectively in the global response to climate change...
Preview Submission to the Inquiry into Legislation Underpinning Carbon Sink Forests (PDF 381.9 kb)
The NFF's 31 July 2008 submission to the Senate Standing Committee on Rural and Regional Affairs and Transport regarding the implementation, operation and administration of the legislation underpinning carbon sink forests, and any related matter. The NFF calls for the legislation to be amended to provide a genuine incentive for farmers to establish trees for carbon sink forests and for them to engage in an appropriate level of on-farm forestry.

It also calls for Government to examine the impacts of the broader suite of exisitng and proposed policies that are designed to drive forestry, including Managed Investment Schemes, and the forestry component of the proposed Carbon Pollution Reduction Scheme, which collectively have significant potential to influence land use in regional Australia. The submission highlights the need to change the international greenhouse gas accounting rules to enable agriculture to participate effectively in the global response to climate change...
Preview Submission on DEEWR Language, Literacy and Numeracy Program (PDF 252.7 kb)
The NFF's 21 July 2008 submission to the Department of Employment and Workplace Relations highlighting that studies show rural and regional school students have lower literacy and numeracy outcomes than city students. There are also smaller numbers who go on to commence University.

As modern farming involves high-tech equipment, science, and skill proficiency, the basis for these higher level skills is founded with an aptitude in language, literacy and numeracy. These programs are best directed during the school years with specific intervention required to ameliorate long-term social exclusion...
Preview Submission to Ban the Importation of Savannah Cats (PDF 36.2 kb)
The NFF's 17 July 2008 submission to the Department of Environment, Water, Heritage and The Arts sought the import ban of Savannah Cats and other hybrid animals due to the significant risk to the environment and livestock...
Preview ACCC: Water Charge Rules Issues paper (PDF 478.2 kb)
The NFF's 15 July 2008 submission - responding to a series of rules being developed by the Australian Competition and Consumer Commission...
Preview Higher Education Review (PDF 451.6 kb)
The NFF's 15 June 2008 submission to the Australian Government's Higher Education Review, noting a major challenge in attracting and retaining people in agriculture-related careers and academic disciplines to replace the present number of baby-boomers nearing retirement.

To do this it is imperative that training delivery and education opportunities are available and provided equitably for farmers and rural Australians so that it can benefit from high-level skills.

Higher education is important to farming as it continues to lead research, development and innovation and grow the productivity of agriculture thus sustaining food and fibre security for Australia and the world...
Preview Submission to the Australian Government Review of Export Policies and Programs (PDF 878.2 kb)
The NFF's June 2008 submission to the Government's trade review renews the call for global trade reform as agriculture, globally, remains the most distorted area of international goods trade with average tariffs more than three times higher than in non-agricultural goods...
Preview Murray-Darling Basin Inter-Governmental Agreement submission (PDF 366.8 kb)
The NFF's 4 June 2008 submission to the Council of Australian Government Murray-Darling Basin Water Reform Intergovernmental Agreement put the views of farmers and irrigators to the various areas covered by the Inter-Governmental Agreement, such as proposed concurrent legislation, consultation, Basin Community Committee, inclusion of on-farm projects and purchase of water from 'willing sellers'...
Preview Senate Inquiry into the Coastal Impacts of Climate Change (PDF 89.8 kb)
The NFF's 4 June 2008 submission to the House of Representatives Inquiry into the impacts on coastal communities of climate change sought to raise awareness of the tension between population pressures and land use change...
Preview Submission to the Quarantine and Biosecurity Review (PDF 67.1 kb)
The NFF's May 2008 submission to the Quarantine and Biosecurity Review highlights failures in proactively protecting Australia's shores from pests and diseases. It asserts that transparent, science-based quarantine and biosecurity that protect Australia's environment, biodiversity and agricultural systems assume even greater importance in this modern era of global movement of people, animals and goods and must ne appropriately resourced...
Preview ACCC: Water Market Rules Issues paper (PDF 220.3 kb)
The NFF's 9 May 2008 submission - responding to a series of rules being developed by the Australian Competition and Consumer Commission...
Preview Skilling Australia for the Future (PDF 286.1 kb)
The NFF's May 2008 submission to the Australian Government Department of Education, Employment, and Workplace Relations underscores farming's increasing needs for skills, training and capacity - with particular emphasis on the difficulties of training provision in rural and regional Australia.

It provides recommendations on how to overcome some of these difficulties and calls on the Productivity Places Program to recognise farming occupations and training under the program. It also calls for: appropriate funding for the new and expanded role of Industry Skills Councils; the need for a ‘rural’ voice to be heard by the new Skills Australia Board; solution to overcome problems with training delivery in regional Australia and some unintended consequences of moving to a ‘demand-driven’ system.
The submission also references the NFF's 2008 Labour Shortage Action Plan and Workforce from Abroad Employment Scheme, which are available at the Workplace Relations page of this website...
Preview Submission on the Garnaut on Emissions Trading Scheme Discussion Paper (PDF 331.7 kb)
The NFF’s April 2008 Submission to the Garnaut Emissions Trading Scheme (ETS) Discussion Paper, highlighting the need for voluntary, incentivised transitional mechanisms. While ‘impractical’ for agriculture to be covered within an ETS, the NFF reinforces the imperative of ensuring perverse outcomes for food production are avoided.

The NFF also raises key issues including timeframes for agriculture’s eventual coverage in an ETS, points of obligation for administering the scheme and the issue of trade exposure and energy dependence...
Preview Submission to the Productivity Commission’s Chemicals and Plastics Regulation Draft Report (PDF 202.5 kb)
The NFF's April 2008 submission offers a realistic way forward for reducing the chronic over-regulation of the chemicals and plastics sector, which has had an unjustifiable cost-impost on agriculture and undermined risk-management principles by creating confusion about compliance and jurisdictional authority...
Preview Submission to the Inquiry into the Pricing and Supply Arrangement in the Australian and Global Chemical and Fertiliser Markets (PDF 484.7 kb)
The NFF’s April 2008 submission to the Senate Select Committee on Agriculture and Related Industries noting a more than doubling of fertiliser and chemical prices over the last 12 months - eating into farmer margins and coming on top of mounting costs - forcing farmers to adjust their production systems, often at the expense of productivity.

While acknowledging research identifying global demand and supply drivers behind fertiliser and chemical price rises, the NFF asserts that it must be demonstrated that rationalisation in the fertiliser supply market, particularly on the east coast of Australia, is not leading to excessive profiteering at the expense of Australian farmers. This submission highlights areas that the Inquiry should examine...
Preview Submission on the Draft Report of Chemicals of Security Concern (PDF 147.2 kb)
The NFF's 3 April 2008 submission to the Council of Australian Governments (COAG) Draft Report of Chemicals of Security Concern recognises that two years of industry consultation by Government has developed a workable framework for managing this important security issue - with the NFF welcoming a transparent and cost-effective management framework that builds in consultation with industry as a permanent feature of mitigating security risks on chemicals...
Preview Operating Principles in Relation to Spray Drift Risk (DOC 305.0 kb)
The NFFs 20 March 2008 submission to the Australian Pesticides and Veterinary Medicines Authority (APVMA) assesses the APVMA’s draft Operating Principles in Relation to Spray Drift Risk. As well as providing feedback and raising concerns with the Australian Government, the NFF outlines its own plan to drive improved management of spray drift through awareness-raising and a whole of industry approach...
Preview ACCC Inquiry into the Competitiveness of Retail Prices for Standard Groceries (PDF 508.1 kb)
The NFF's 17 March 2008 submission to the Australian Competition and Consumer Commission's (ACCC's) Inquiry into the Competitiveness of Retail Prices for Groceries, emphasising the need for transparency throughout the food supply chain...
Preview Submission to the Australian Fair Pay Commission’s 2008 General Wage Review (PDF 489.7 kb)
The NFF’s 17 March 2008 Submission to the Australian Fair Pay Commission’s 2008 General Wage Review highlights the continuing impact of the drought on the sector, as well as flagging key economic concerns surrounding wages growth and its impact on interest rates and inflationary pressures. The submission calls for a wage increase of not more than the Consumer Price Index...
Preview Inquiry Into Climate Change and the Australian Agricultural Sector (PDF 350.9 kb)
The NFF's 14 March 2008 submission to the Senate Inquiry looking at the challenges for farm system adaptation and advocates urgent, nationally coordinated research and development on climate change adaptation. This is very much in line with NFF policy on drought and reinforces the NFF’s push for investment in drought management and preparedness...
Preview Federal Budget Submission 2008 (PDF 504.7 kb)
The NFF's 21 January 2008 submission to the Australian Government pressing the case for responsible capacity building investment in Australia - including climate change adaptation and mitigation strategies (in addition to drought preparendess measures), a wholistic transport infrastructure overhaul, education and training initiatives (including retaining the aims and objectives of the FarmBis program), and focused engagement on international trade opportunities - under the 2008-09 Federal Budget...
Preview Submission to the Garnaut Report on Climate Change: Land Use - Agriculture and Forestry (PDF 489.1 kb)
The NFF's 11 January 2008 submission to the Garnaut Report calling for new investment in climate adaptation and mitigation strategies for Australian agriculture – including drought preparedness measures (investing today to better drought-proof Australia tomorrow through mutual obligation measures), as well as new research, development and implementation of technologies, systems and programs that can fast-track adaption by farmers to the threat of increased climate risk. The submission also highlight the absolute need for any Australian emissions trading scheme to take full account of agriculture's total 'life cycle'...

Submissions to Government 2007

The following are submissions the NFF has made on various subjects to the Australian Government in 2007 - including parliamentary committees and government departments and agencies...

Preview Abatement Incentives Prior to the Commencement of the Australian Emissions Trading Scheme (PDF 342.2 kb)
The NFF's 1 December 2007 submission to the Department of Prime Minister and Cabinet, outlining the issues faced by agriculture that require urgent attention by Government in the lead up to any Australian Emissions Trading Scheme...
Preview Submission to the New South Wales Government's GM Moratorium Review (PDF 203.0 kb)
The NFF's 29 August 2007 submission calling on the New South Wales Government to lift its moratorium on gene technology...
Preview Submission to the National Transport Commission on B-Triple Road Network Access (PDF 223.5 kb)
The NFF's 21 August 2007 submission looking for improved access to the road network for higher productivity vehicles, such as B-triples, to unlock productivity gains, offset additional registration costs and improve Australian farmers’ competitiveness on domestic and global markets. The submission highlights some of the key immediate and strategic needs of the farm sector with regards to broadening the B-triple network...
Preview Submission to the South Australian Government’s GM Moratorium Review (PDF 93.5 kb)
The NFF's 13 August 2007 submission calling on the South Australian Government to lift its moratorium on gene technology...
Preview Submission to the Victorian Government’s GM Moratorium Review (PDF 84.7 kb)
The NFF's 13 August 2007 submission calling on the Victorian Government to lift its moratorium on gene technology...
Preview Submission to the AIRC 2007 Wages and Allowances Review (PDF 1.5 Mb)
The NFF's 9 August 2007 submission to the Australian Industrial Relations Commission 2007 Wages and Allowances Review, calling for a flow-on of the Australian Fair Pay Commission's wage decision, including the deferral of wage increases for eligible drought-affected farmers...
Preview Submission to the 2007 Heavy Vehicle Charges Determination: Draft Regulatory Impact Statement (PDF 314.3 kb)
NFF's 31 July 2007 submission containing key concerns for farmers who own over half the national heavy vehicle fleet and are directly affected by any change in the heavy vehicle pricing structure...
Preview Submission to the Senate Standing Committee on Economics Inquiry into Provisions of the Trade Practices Legislation Amendment Bill (No.1) 2007, and Trade Practices Amendment (Predatory Pricing) Bill 2007 (PDF 205.2 kb)
NFF's 10 July 2007 submission demonstrating farmers' support for the Australian Government's Trade Practices Act amendments to Section 46 (Misuse of Market Power) and Section 51AC (Unconscionable Conduct). It also outlines the NFF’s concerns about including an 'effects test' within the provisions for misuse of market power...
Preview Submission to the Productivity Commission Regulatory Burdens on Business (Primary Industry) Review (PDF 138.1 kb)
The NFF's 15 June 2006 submission to inform the Productivity Commission about the impacts of regulatory burdens on farm businesses with a view to reducing the red tape impost for farmers. The submission identifies key areas where regulation is impinging on farm businesses and makes recommendations for change...
Preview Submission to the Migration Amendment (Sponsorship Obligations) Bill (PDF 82.3 kb)
The NFF’s 14 June 2007 submission to the Migration Amendment (Sponsorship Obligations) Bill reiterated opposition to the current minimum salary level, asserting that foreign and Australian workers should be paid at the same rate in accordance with the relevant industrial instrument. However, the NFF welcomed moves to introduce increased flexibility in setting the minimum salary, should it remain, and did not oppose the English language requirement testing level being set at IELTS 4.5...
Preview Submission to the Workplace Relations (Restoring Family Work Balance) Amendment Bill (PDF 114.6 kb)
The NFF’s 4 June 2007 submission to the Inquiry into the Restoring Family Work Balance Bill did not support the passage of the legislation. The NFF highlighted to the Committee that the existing legislation already contains provision for an adequate balance in the requirements of business, while also noting many agricultural roles inherently demand long and unusual hours, which has long been accepted by employer and employee alike as both common practice and necessary. The NFF reiterated to the Committee its objective of fair and flexible workplaces with employment conditions to be negotiated at the workplace...
Preview Submission to the Prime Ministerial Task Group on Emissions Trading (PDF 71.7 kb)
The NFF's 4 April 2007 submission to the Prime Ministerial Task Group on Emissions Trading, supporting a national trading scheme that recognises agriculture has already reduced Australian greenhouse emissions and proposing that farmers should not be direct participants in a national scheme - rather, Australian farmers can best play a part by marketing eligible 'off-set credits' to enable scheme participants to achieve net reductions in their annual emissions...
Preview Submission to the Australian Fair Pay Commission (PDF 299.4 kb)
The NFF's 23 March 2007 submission to the Australian Fair Pay Commission, arguing a further wage increase is not justified so soon after the Commission's original decision commenced on 1 December 2006, and that any further wage decisions be deferred for one year for agriculture on account of the 2006-07 drought...
Preview Submission to the Australian Industry Review of the National Water Initiative (DOC 203.5 kb)
The NFF's 2 March 2007 submission to the National Water Commission's Review of the 'National Water Initiative', recommitting support for increasing productivity and efficiency of water use and promotion of healthy river and groundwater systems in Australia...
Preview Submission to the Council of Australian Government's Review of Hazardous Materials (PDF 855.2 kb)
The NFF's 1 March 2007 submission advocating a mix of government and self-regualtion as the best way to sensibly manage security sensitive chemcials on-farm...
Preview Submission to the Joint Standing Committee into Eligibility Requirements and Monitoring, Enforcement and Reporting Arrangements for Temporary Business Visas (PDF 60.6 kb)
The NFF’s 2 February 2007 submission advocating uniform working conditions for Australian and foreign 457 visa holders and otherconcerns in relation to 457 visas and labour agreements...

Submissions to Government 2006

The following are submissions the NFF made on various subjects to the Australian Government in 2006 - including parliamentary committees and government departments and agencies...

Preview Submission on Collective Bargaining Thresholds (PDF 50.9 kb)
The NFF's 27 November 2006 submission to Treasury advocating for transaction thresholds for farmers to enable collective bargaining notifications to be raised, taking into account the high turnover/low margin nature of agricultural production...
Preview 2007 Federal Budget Submission (PDF 143.8 kb)
The NFF's 20 November 2006 submission to the Australian Government pressing the case for a 'sustainable' farming commitment across five key pillars - Capacity Building (including Drought Preparedness), The Environment, Supply Chain Efficiency, Labour Force Issues and Biosecurity - under the 2006-07 Federal Budget...
Preview Submission to the Productivity Commission Study into Road and Rail Freight Infrastructure Pricing (PDF 99.9 kb)
The NFF's 6 November 2006 submission to the Productivity Commission on future models of road and rail infrastructure pricing with a view to ensuring a fair and equitable system that takes into account the economic contribution of the farm sector...
Preview Submission on the Draft Corridor Strategies for the Sydney-Melbourne and Perth-Adelaide Corridors (PDF 73.8 kb)
The NFF's 7 September 2006 submission to the Department of Transport and Regional Services' Auslink corridor strategies, seeking to improve planning, decision-making and funding of Australia’s national land transport infrastructure...
Preview Submission to the Australian Fair Pay Commission (PDF 214.2 kb)
The NFF's 28 July 2006 submission in relation to the Australian Fair Pay Commission's inaugural wage setting decision...
Preview Submission to the Senate Committee Inquiry into Provisions of the Independent Contractors Bill 2006 and Workplace Relations Legislation Amendment (Independent Contractors) Bill 2006 (PDF 275.3 kb)
The NFF's 21 July 2006 submission provided support for the Bill introducing greater freedom to enter into genuine independent contracting arrangements, while also raising concerns about the Corporations Power and deeming provisions within State legislation...
Preview Submission to the Consultation on Proposed Taxation Arrangements for Plantation Forestry (PDF 125.0 kb)
The NFF's 14 July 2006 submission to the Dutton Inquiry into Managed Investment Schemes and their detrimental impacts on long-term sustainability and profitablity of agricultural production...
Preview Submission to the Productivity Commission Discussion Draft on Rural Water Use and the Environment: The Role of Market Mechanisms (PDF 65.7 kb)
The NFF's 12 July 2006 submission calling for the balanced implementation of the National Water Initiative, particularly relating to ongoing delivery and maintenance of water infrastructure in regional Australia...
Preview Submission to the Inquiry into the Migration Amendment (Employer Sanctions) Bill 2006 (PDF 65.0 kb)
The NFF's 21 April 2006 submission supporting sanctions against reckless breaches of employment legislation, while seeking reasonable thresholds for proving such offences...
Preview Submission to the Inquiry into Pacific Region Seasonal Contract Labour (PDF 68.6 kb)
The NFF's 27 March 2006 submission advocating the merits of a pilot program to source unskilled labour from selected Pacific Island nations in response Australia's regional labour shortage...
Preview Submission in response to the Award Review Taskforce Discussion Papers (PDF 409.1 kb)
The NFF's 3 February 2006 submission, highlighting issues in relation to the simplification and rationalisation process under WorkChoices...
Preview 2006 Federal Budget Submission (PDF 69.3 kb)
On 31 January 2006, the NFF lodged its submission to the Australian Government for three key budgetary pillars - Capital Gains Tax reform, a major upgrading of regional transport infrastructure and recognition of increasing role farmers play in achieving environmental outcomes on behalf of all Australians...

Submissions to Government 2005

The following are submissions the NFF made on various subjects to the Australian Government in 2005 - including parliamentary committees and government departments and agencies...

Preview Submission to the Australian Government Regulations Taskforce (PDF 84.3 kb)
The NFF's 18 November 2005 submission, outling areas where red-tape or excessive regulation are hindering farm business competitiveness...
Preview Submission in response to the Inquiry into the Workplace Relations Amendment (WorkChoices) Bill 2005 (PDF 201.7 kb)
The NFF's 10 November 2005 submission to support the passing of the WorkChoices Bill and to guide the legislation in line with the NFF's call for deregulation of the workplace...
Preview Submission in response to the Food Standards Australia New Zealand Country of Origin Labelling Discussion Paper (PDF 87.1 kb)
The NFF's 8 September 2005 submission, outlining our position on the contentious issue of food labelling...
Preview Submission on the Horticulture Code of Conduct -in Response to the Regulation Impact Statement (PDF 85.4 kb)
The NFF's 25 August 2005 submission assessing the potential impacts of a Manadatory Code of Conduct for the horticultural sector...
Preview Submission in response to the Treasury Fuel Tax Credit Reform Discussion Paper (PDF 45.7 kb)
The NFF's 3 August 2005 submission, responding to the Australian Government's Energy White Paper, particularly addressing fuel tax excis reforms as they pertain to farm production...
Preview Submission to the Senate Economics Legislation Committee's Inquiry Into The Fuel Tax Bill 2006 (PDF 108.1 kb)
The NFF's 24 May 2005 submission to outline the most effective mechanism for farmers accessing their fuel tax excise rebate in relation to the proposed Fuel Tax Bill 2006...
Preview Submission to the Australian Industrial Relations Commission - Safety Net Review 2005 Case (PDF 1.3 Mb)
The NFF's 11 March 2005 submission, stating its legal arguement in relation the annual wage decision...
Preview Submission to the Board of Taxation - Capital Gains Tax (PDF 241.7 kb)
The NFF's 4 March 2005 submission, outlining proposed changes to Captial Gains Tax small business exemptions...