The Victorian Farmers Federation (VFF) welcomes the opportunity to submit in response to the Macedon Ranges Rural Land Use Strategy. The farming community routinely expresses concern that agricultural issues are not being properly considered by the Victorian planning system. Macedon Ranges Shire includes a unique mix of attractive and pleasing landscapes, that includes farm business and family-owned farms.
The VFF represents many farmers in the Macedon Ranges. These farmers run commercial-scale livestock, grains or mixed farming enterprises or are associate members of the VFF, running smaller farming operations. The ratio between commercial and smaller farms is consistent with other peri-urban and coastal regions of Victoria.
It is critical changes are made to the planning system to support the retention and growth of agriculture in Victoria. Repeated failures to address or consider these matters, in response to consultation or preparation of documents such as this, reinforces industry belief and farming community experience that there is an urban bias in the planning system that sees farming land as vacant or awaiting an urban use, or providing amenity and ecosystem services for towns.
Whilst the VFF accepts that farming operates in a regulated space, it is vital that planning and environmental regulations, which are generally designed for urban scenarios, do not have a perverse or adverse outcome to facilitating the ongoing and productive use of land for agriculture.
VFF also recognises that the planning system is a land use and development system – not a land management system. Land management outcomes must have a nexus to a land-use change or a clear development change. Where existing beneficial land use is expected to change to achieve a management outcome, other legislation that must compensate for the change is appropriate. For too long, ministerial intervention has been used to alter the planning system to avoid regulatory impact statements and compensation.
The VFF is concerned that the draft Macedon Rural Land Use Strategy will have negative consequences on farm businesses in the Macedon Ranges municipal area and set a precedent for other councils within the state to undermine agriculture.
The draft Rural Land Use Strategy includes several maps that identify agricultural land and productive agricultural land, members of the VFF have expressed concern that these maps are not accurate and show properties classified incorrectly on the maps. This is concerning if the maps are being used to inform where the council wants agriculture located.
This discrepancy in the mapping may be caused by the council only considering farming zone lots 40ha and over the only productive agricultural land. This view is incorrect. Smaller lot sizes do not degrade the agricultural value of the land, this only occurs when dwellings and non-farming uses occur on the land.
Farmers often need to buy, lease or run stock on more land, or amalgamate smaller titles. These often relatively small lots give them the critical mass they need to maintain a viable farming operation. These lots may be distant from their main holding, and the distance can also help protect their business from total loss from local climatic events or natural disasters and to spread their climatic risk. Once development occurs on this land its ability to be purchased for farming is removed and the expectations of quasi rural residential potentially increases values in the wider area, with the flow-on impacts for viability given that agriculture is a price-taking industry.
The VFF is concerned that the change of the Farming Zone to Conservation Zone will have a negative impact on farmers and farming businesses located within the affected areas. The purpose of the Rural Conservation Zone is greatly different to the Farming Zone, as are the uses that require a permit. Farming practices evolve and change over time. This is due to a range of reasons such as climate, weather and prices of stock. The concern is that farms will have to stop because they will have to apply for a planning permit every time they want to change to a different practice/method of farming, whereas if they were still in a farming zone, they would not need to apply for a planning permit each time.
This is especially pertinent in the face of climate change. The unnecessary restriction of change in farming practices and methods does not support the intention of the Victorian Government’s Primary Industries Adaption Action Plan that aims to facilitate continual adaption and industry resilience.
The planning permit process is long and complicated. To have to apply for one each time would come at a great cost of money and time to the applicant and would disproportionately impact farmers with legitimate agricultural business in the municipal area.
Farming is part of the history and social fabric of the Macedon Ranges area and will continue to be an important part of the local economy and environment. The VFF has made our concerns with the draft Rural Land Use Strategy known to ensure farming in the Macedon Ranges area is not impeded by unnecessary or unintended impacts on the local agricultural industry.
Thank you for the opportunity to provide this submission. The VFF remains committed to assisting all levels of government in developing the Planning Policy that has good agricultural outcomes and welcomes and encourages industry engagement.