Submission

Federated Farmers Submission for National Environment Standard - Plantation Forestry

Federated Farmers is opposed to the proposal.
Our opposition is based on the following reasons:
• Federated Farmers is concerned that the proposal will have a negative impact on small a farm scale production forestry, which is established for many reasons.
• That the proposal will not achieve the objectives intended around efficiency and effectiveness.
• That the proposal will negate the objectives of the NES-PF by re-introducing unwarranted variation, uncertainty and inefficiencies for the forestry sector. 
• That the proposal will lead to further unwarranted and inequitable variation as to what resource users are charged. 
• That the proposal is unnecessary because councils already have a mechanism if they want to charge for permitted activity monitoring, and this occurs with consultation. 
• That there is uncertainty around what “reasonable” costs are, and who decides what is “reasonable.” 
• Federated Farmers submits that councils must follow principles that charges must be lawful, reasonable, fair, uniformly applied, simple to understand, transparent, predictable and certain when setting and implementing charges for monitoring. 
• Submits that the proposal must not result in forest owners being charged by multiple councils for monitoring of the same activity. 
• Federated Farmers is concerned that the proposal will negate an NES-PF objective to reduce the need for advocacy, and that councils have no oversight when setting charges in Long Term and Annual Plans. 
• Federated Farmers submits that administrative conditions be excluded from the permitted activities that councils could set monitoring charges for.