Victorian Strategic Agricultural Land consultation: Sustain's Response

On 14th March 2019, the Victorian Government announced a public and stakeholder consultation to identify and protect what it termed 'strategic agricultural land', in order to 'protect food production in the peri-urban and green wedge areas'.

Sustain has delivered its response to this consultation, in which we raise a number of substantial concerns about the concept itself and the process by which it is being delivered. We reproduce our response below, which fully endorses the recommendations of the Foodprint Melbourne, 'Roadmap for a resilient and sustainable Melbourne foodbowl' (infographic above).

Sustain response to strategic agricultural land consultation

23^rd April, 2019

To whom it may concern,

Protecting Melbourne’s strategic agricultural land – public consultation response

I am writing on behalf of Sustain: The Australian Food Network in response to the proposed DEWLP approach of protecting strategic agricultural land through the Victorian and Local Planning schemes.

We, as an organisation, are concerned by the premise of this approach to protecting and growing the strong and vibrant agricultural industry on Melbourne’s fringe. Designating areas of the Green Wedge and peri-urban areas as being of higher value than others inadvertently weakens the Urban Growth Boundary and creates a target for developers in lobbying for opening up ‘low value’ farmland for housing and other non-agricultural uses. It also runs the risk of impacting on the land values of what are currently valuable and viable farms in Melbourne’s food bowl and directing investment and support from government away from these areas.

It could be argued that the assessment process proposed for this region is fundamentally flawed on three particular fronts.

The reports commissioned to inform the policy approach are substantially different in their approach and methodology, with one effectively dismissing anything other than Class 1 and 2 soils, while the other embraces the broader range of influences on land suitability for a broad variety of crops and food production options. More weight appears to have been given to the more narrow land capability approach in the proposed criteria. Neither methodology effectively assesses the potential of the range of modern agriculture techniques available to us which could be highly successful in these fringe areas and significantly contribute to both the economic development and food security of Melbourne.
The report does not consider the food requirements of the city itself in any way. If we are to truly secure Melbourne’s food system and supply in a climate constrained future, we should be considering the modelled population growth and what quantity of food will be required to feed this population to the standard it wishes to be fed – including variety, nutritional value, quality etc. In a climate constrained future, even a marginal asset that can produce food is better than no asset at all. When planning for housing for a city, we use exactly this approach – how many people, how many homes, how much land for the style of housing stock the populous wishes to live in – but this approach has been lost in this modelling for the future of Melbourne’s food supply.
The Green Wedge and peri-urban areas of Melbourne have received no State or Federal government support to develop as an agricultural region for nearly four decades. There has been little to no extension services, no funding to support economic development or enhance market access, no investment in associated infrastructure, etc. In fact – agriculture has been discouraged in many ways in these areas, with land fragmentation and subdivision permitted, removal of infrastructure (such as community abattoirs and other processing facilities), diversion of funding, resources and a distinct lack of enthusiasm from AgVic (or its previous iterations) to work with farmers in these areas for many years. How can the potential of these areas be objectively assessed when there has been so little support and investment into their development?

Having made these observations, Melbourne’s food bowl has continued to punch above its weight in terms of food production and making the most of Melbourne’s vibrant food culture. The Foodprint Melbourne project has clearly demonstrated this over the past 3 years of research and their latest report offers clear direction as summarised by the following (taken from the ‘Roadmap for a resilient and sustainable Melbourne foodbowl’ Foodprint Melbourne Report):

Planning for a sustainable and resilient city foodbowl requires an integrated policy approach
Five key pillars of policy action underpin a resilient and sustainable city foodbowl – farmland protection, farm viability, water access, nutrient recycling and sustainable farming
Farmland should be permanently protected on Melbourne’s fringe by maintaining Melbourne’s Urban Growth Boundary, mapping agricultural land and introducing a new agricultural ‘zone’
Promoting the viability of farming in Melbourne’s foodbowl is as important as protecting farmland
Farm viability should be promoted by investing in infrastructure that enables small-medium scale farmers to gain greater control of supply chains, ensuring that peri-urban producers are able to access relevant funding streams and applying local government ‘farm rates’ to all actively farmed land
Water reuse for food production should be increased to address water scarcity in a warming climate
Water reuse should be increased by adopting an integrated water management approach to managing water assets in farming areas, developing integrated assessment frameworks to cost delivery of recycled water and investigating options for greater reuse of storm water
City foodbowls offer opportunities to close the loop by returning valuable nutrients from city organic waste back to the soil
Nutrient recycling on farm should be promoted by preventing contamination of organic waste streams, collaborating with farmers to develop ‘fit for purpose’ compost products and establishing a Melbourne Nutrient Recycling Network
Sustainable farming should be incentivised in Melbourne’s foodbowl
Sustainable farming approaches should be incentivised through local government rate rebates, direct payments and extension services aimed at peri-urban farmers
A diverse range of sustainable farming approaches should be promoted to increase the resilience of the city’s food system, including regenerative and agroecological approaches as well as sustainable intensification and closed-environment agriculture.

In short, the proposed approach does not strengthen farming in Melbourne’s food bowl, but has the potential to undermine the strength of the Urban Growth Boundary, expose the government to lobbying from the development industry, create further uncertainty and reduce investment in the industry and does not consider the economic development support required to ensure the foodbowl not only reaches its potential now, but is secure for Melbourne’s future to underpin the climate resilience of the city.

If you wish to discuss these issues further, please do not hesitate to contact us.

Kind regards,

Annemaree Docking
Secretary

On behalf of Sustain: The Australian Food Network