A new Australian Government drought plan

20th September 2024

Australian Government Drought Plan Consultation draft

To whom it may concern,

Thank you for the opportunity to provide feedback on the on the consultation draft of the Australian Government Drought Plan (draft plan).
NRM Regions Queensland (NRMRQ) operates as the peak body for Natural Resource
Management (NRM) in Queensland.
Queensland’s 12 regional NRM organisations are community-based, with a very strong record in delivering significant outcomes for land and water management through a range of programs, including those delivered by the Queensland and
Australian Governments. We work in partnership with Traditional Owners, Local
Governments, farming groups, the Landcare movement, water utilities and the community, to deliver innovative and science-based solutions to challenges affecting the environment and primary industries. We have deep connections within
Queensland’s regional communities and work closely with the people who live and work in these towns to ensure their livelihoods are protected for generations to come.
Our diverse State-wide team of over 340 staff located in 27 rural and remote offices across Queensland includes scientists, ecologists, GIS practitioners, engineers, community engagement specialists, and support staff.
These 12 Queensland organisations support regional economies and livelihoods through employment, wages, procurement and encouraging growth in other sectors, while also supporting agriculture, construction, manufacturing, conservation, education, research and tourism sectors, and their local communities. The direct and indirect economic contribution from these regional NRM organisations is approximately $183 Million per annum with over $90 Million value add, and we support over 635 jobs in total across rural and regional communities (with a multiplier effect of 2.4).
Regional NRM organisations in Queensland recognise the wide-ranging impacts of drought and have a particular interest in drought programs available to farming
businesses and communities across the drought cycle, including in the Future
Drought Fund Drought Resilience Funding Plan 2024 to 2028.
Regional NRM organisations have a focus on integrated land management through community engagement and support, and a whole of systems approach. As a result, we have been closely involved in delivery of the Future Drought Fund through contributing to the development of the two Drought Hubs based within Queensland, establishing and delivering nodes throughout the state, participating in strategic planning activities, and the development and delivery of activities across the programs, at both the local and regional level.
There is a significant opportunity in the Drought Plan to increase recognition of pre- existing strategic planning activities and approaches across the community including, regional NRM plans, Working on Country plans, Regional Disaster Recovery
Plans (RDRPs) and industry development plans. While development of regional drought plans is a good intent, there is often no inherent relationship with existing priorities. Formal recognition of the existing approaches is needed to ensure they are incorporated, and recognition of their relevance is not left to individual planning approaches.
A highly relevant planning approach recently funded by the Australian Government has been the Emergency Preparedness and Response Plans undertaken by all regional NRM organisations across Australia. In Queensland, the development of these Plans were shared with all relevant natural disaster agencies in the State to explore logical synergies and opportunities for funding the implementation of these plans.
NRM Regions Queensland looks forward to the completion of the final Australian
Government Drought Plan later this year once the consultation phase has been completed and continues to be supportive of the intent of the Future Drought Fund.
Specific comments on the key consultation questions are provided below.

Response to the Key Questions posed in consultation phase

Question 1: Is the Australian Government’s approach to drought across the drought cycle clear in the draft plan?
GENERALLY SUPPORTIVE
The approach to drought described in the consultation draft of the Drought Plan uses the three phases of the drought cycle – ‘Preparing for drought’; ‘In drought’ and
‘Recovering from drought’, which we agree is robust, clear and aligns well with other planning processes. In Queensland, the three-phase cycle used in the Drought Plan
aligns well with the model (‘Prevention/Preparedness’, ’Response’, Recovery’) used in the Queensland Disaster Management Arrangements (QDMA) and is therefore familiar to those dealing with climate-related risks and responses in this state.
Similarly, the four thematic pillars described in the Drought Plan – ‘Evidence -based decision-making’; ’Strategic drought support’; ‘Working together’; and ‘Learning and improving’ is logical and robust. The Queensland Regional Drought Resilience Plans
(RDRPs) have used a similar approach.
However, the Drought Plan lacks a clear governance framework linking local, regional, state/territory and national decision-making related to drought that also responds to regional differences (especially enterprise types and landscapes). In
Australia, there is much more work needed to improve coordination across Agencies and between national, state and local government programs related to drought.
Without such a hierarchical framework in the Drought Plan, achieving the plan’s purpose of “show how governments and stakeholders can work together on drought- related issues” will be difficult to achieve and even more difficult to measure.
Question 2: Is the draft plan clear as to why the Australian Government’s drought policy and response is different to that for natural disasters?
NOT SUPPORTED
Based on advice from the Productivity Commission, the Australian Government chose, in 1979, to remove drought from the national Disaster Recovery Funding
Arrangements (DRFA). The reasons given at the time, and that persist in the draft
Drought Plan, include that funding drought recovery alongside disaster recovery was… “poorly targeted, distorted farm input prices, and worked as a disincentive for farmers to prepare for drought”. From a regional perspective, and from our experience working with key stakeholders and ‘people on the ground’ in regional
Australia, this explanation is unclear.
i.e. “Drought and natural disasters require different responses. Natural disasters, like floods or fires, are caused by fast-onset, short-duration events that are hard to predict with certainty….Droughts are severe weather events but are slower in their onset, easier to predict and their effects are generally more gradual. These differences provide rationale for our drought policy approach being focused on building resilience and enabling farmers to be prepared.”
In supporting the need to build resilience, if we are to achieve a holistic, ‘place-based’ approach to drought resilience – one that is ‘people-centred’, ‘multi-hazard’ and
‘multi-sectoral’ then this policy issue requires re-visiting. Whilst funding may come from multiple sources, the ‘planning’ and ‘management’ of drought would benefit from being understood (as it is locally and regionally) as an integral part of the
context of ‘climate-based’ risks that includes a wide variety of natural risks, hazards and disasters.
From an ‘environmental’ and landscape management perspective, there needs to be recognition that drought can amplify the impacts of natural disasters, and natural disasters can amplify the impact of droughts. For example, drought-affected landscapes with little or no ground cover will be far more susceptible to flood- generated erosion, resulting in greater sedimentation of streams and wetlands; and, bushfire-affected landscapes will fall into drought quicker than landscapes that have not been burnt should a dry season follow the bushfire season. The principle that a drought is not a natural disaster due to the “slow onset” of droughts does not acknowledge the occurrence and impacts of flash droughts. These are rapidly- occurring events that can create the same (if not more savage) impact as a prolonged drought. Eastern and northern Australia is particularly susceptible to flash droughts and there is a high correlation between the likelihood of flash droughts and bushfires. The Plan needs to acknowledge these climatic events.
Whilst the response and recovery for natural disasters may be different to that of drought, the planning and preparedness activities are very similar if not the same.
This was recognised by the recent guidance provided by DCCEEW (2024) to the regional NRM organisations for the development of the Biodiversity and Agricultural
Natural Capital Emergency Preparedness and Response Plans (EPRPs) - in many of these EPRPs, drought was included along with other natural disasters. The purpose of the Emergency Preparedness and Response Plans was to firstly identify the regional Biodiversity and Agricultural Natural Capital (BANC) assets, as well as the risks and mitigation measures. In addition, this initiative provided an opportunity to address significant gaps in the emergency management arrangements in each of the State’s NRM regions pertaining to natural asset operations. The Emergency
Preparedness and Response Plans sought to leverage existing governance frameworks and regional emergency management plans to collaboratively develop a framework for prioritising, preparing, and responding to BANC assets within local emergency management jurisdictions. The scope of the project contributed to a range of Australian Government priorities and included:
• Identifying and mapping BANC assets (drawing on existing information
holdings at Commonwealth, State or regional level investigation) at an
appropriate scale for emergency response. This includes but is not limited to
Matters of National Environmental Significance (MNES) under the
Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) with
biodiversity values (for example, locations of key listed threatened species
and ecological communities, world heritage properties, national heritage
places and Ramsar wetlands) and overlaying this with extreme weather
vulnerability/susceptibility information (for example, the risk of bushfires,
drought, floods, cyclones, diseases, pests, etc.);
• Developing an emergency preparedness and response plan for the NRM
Management Unit with the explicit aim of reducing the impact of catastrophic
events on species, ecosystems and agricultural natural capital assets by
identifying mitigation measures in advance of emergency, expediting and
targeting management activity during events, and expediting and targeting
recovery post events; and
• Undertaking community/stakeholder engagement activities (including
information sharing with the community, landholders First Nations people,
emergency services, and governments) to share and integrate the information
generated to enable consistency within a jurisdiction.
Of particular relevance to this submission is that these Emergency Preparedness and Response Plans described “broadscale changes in atmospheric circulation resulting in short-term (years) drought becoming long term (decadal and longer) increases in aridity. This may include flash drought associated with high evapotranspiration”.
The Drought Plan (and government drought programs) needs to address these issues and the current explanation in the Plan needs bolstering.
Question 3: Does Pillar 1 – Evidence based decision-making provide greater clarity about when, why, how and what the government will consider when determining its response to drought?
GENERALLY SUPPORTIVE
The draft Drought Plan details that; “The Australian Government is implementing a drought response framework to support its own preparedness, planning and response”, and provides a clear explanation of the Drought Response Framework. However, it makes no mention as to whether any of the state or territory governments will also utilise this Framework or how decisions made by the Australian government will integrate with those in other jurisdictions.
In Queensland, for instance, the Department of Agriculture and Fisheries have conducted a review of its own drought policy and there is currently no mention of the
Queensland government utilising the (national) Drought Response Framework. In fact, whilst the Australian government clearly asserts “we do not make drought declarations”, the Queensland government has made these declarations until recently and has been through a review process which at this point has not made any public recommendations.
NRM Regions Queensland would like to see the Australian Government drive a more consistent approach to drought management across jurisdictions. As with many
other issues/events that impact on the nation’s regional communities, drought impacts don’t recognise state/territory borders. There needs to be a nationally agreed approach/framework regarding drought declarations.
Similarly, there is no description of linkages or how decisions made by the Australian government (through the Framework) would integrate, inform and/or take into account the decisions made locally by farming businesses and communities and their respective local governments. It is appreciated that this may be provided in more detailed documents which are yet to be produced, but a recognition of this linkage in the Drought Plan would be useful.
Feedback gained through the development of the Queensland RDRPs was that there are many tools out there to provide evidence and inform better decision-making, what is lacking is the effective extension of these tools and building people’s capacity to use them. NRM Regions Queensland would like to see more emphasis for strengthening local capacity for evidence-based decisions identified by local communities e.g. access to free tools; training; and increasing the number of
Climate Mate type roles through a proposed joint approach by NRM Regions
Australia and BOM. The complexity of farming systems and the advent of environmental markets (eg. carbon and biodiversity certificates) is driving the return and increased need for one on one extension to deal with individual situations and personal aspirations, if we really want to see growing resilience and transformation of farming businesses occur across Australia.
Question 4: Does Pillar 2 – Strategic drought support provide greater clarity about how the Australian Government will respond across the drought cycle, including what support it will not provide?
SUPPORTED
NRM Regions Queensland strongly supports the Drought Plan’s principles for strategic drought support. This section of the Plan, clearly defines the programs of support available during the three phases of the Drought Cycle, as well as a clear explanation of what support will not be provided. It is to be expected, at times, that the clear understanding of these declared principles will need informed and effective discussion before policy decisions are made
For example, the draft Drought Plan states that the government will not provide support that “…is unable to demonstrate sufficient public benefits”. However, ‘public benefit’ is often very hard to define and quantify, and in fact is quite variable in its definition across Government departments. A more detailed explanation of what the government understands to be ‘public benefit’ and how it will be assessed could be added into the Drought Plan itself.
The draft Drought Plan promotes support that “…complements and leverages other support offered by the Australian Government, states and territories, and non- government services” but states that it does not support ‘duplication’. This does and will continue to be a complex and grey issue. The boundaries between ‘duplication’ and ‘complementarity and leverage’ are blurred. NRM Regions Queensland most strongly supports the effective and efficient use of public funds. However, this topic is one for thoughtful discussion rather than arbitrary boundaries. For instance, It has been our experience that drought-resilient communities are ‘resilient’ in a holistic and multi-faceted manner, but a wide variety of programs to build ‘resilience’ to many factors still deserves strong support from the Future Drought Fund. In most if not all of the RDRPs’ consultation forums, stakeholders expressed gratitude to the role of their local Rural Financial Counsellors. At a local/regional level Rural Financial
Counsellors have been actively involved in Future Drought Fund initiatives and this should be supported and increased.
Question 5: Have you identified any gaps in how we have responded to any of the review recommendations in the draft plan?
NO

Question 6: Do you have any comments on the work underway for us to consider as we progress it?
YES
NRM Regions Queensland have identified the following as areas where this Drought
Plan could be enhanced:
• Provides an agreed definition of drought that can be used by all jurisdictions,
community groups, as well as the business and the Not-for-profit sectors, for
planning purposes.
• Provides a clear and understandable explanation of how the Drought Plan
integrates with other key plans and policies (eg. the Australian Disaster
Preparedness Framework, National Drought Agreement, Future Drought Fund,
Emergency Preparedness & Response Plans) and emerging government
climate change plans and strategies including the National Climate Risk
Assessment work. This would require some clearer explanation of why
drought is not considered a ‘natural disaster’ in Australia.
• Articulate, as simply and clearly as possible, specific actions (both policy and
program) that will be taken by various levels of government (including local
government) and recommended actions that should be taken by community
groups, as well as the business and the Not-for-profit sectors. The Drought
Plan must recognise and promote regional differences around both the
impacts of drought and solutions to mitigate these impacts and avoid a ‘one-
size-fits-all’ approach at all costs.
• Recognise the regional NRM organisational infrastructure that exists across
the country. These critical organisations operate to deliver integrated NRM
outcomes, working across all sectors of the community and this approach is
essential to deliver true landscape (socio-economic) resilience. Many
strategies designed to enhance natural capital and increase farming
productivity will also enhance resilience to other impacts of climate change
such as climate variability, biosecurity challenges and increased pest plants
and animals. There is a high degree of overlap between the knowledge and
tools needed and the actions required to ensure sustainable agricultural
operations, regardless of whether the climatic driver is a period of sustained
dry or other climate change driven impacts. From a land manager
perspective, management actions have become increased in complexity and
many of the actions applied by land managers will increase resilience,
regardless of the cause of the shock. Actions to prepare for everyday climate
variability and conditions, aren’t specifically dictated by drought alone and
don’t recognise the formal declaration of a drought. The impacts of ‘drought’
declaration is mostly due to the trigger for varying policy application, not on
ground changes.
• Provide cross-referencing to the development of the Emergency
Preparedness and Response Plans (EPRPs) for the nation’s natural resource
management (NRM) regions - in many of these EPRPs, drought was included
along with other natural disasters. The purpose of the Emergency
Preparedness and Response Plans was to firstly identify the regional
Biodiversity and Agricultural Natural Capital (BANC) assets, as well as the
risks and mitigation measures. The Emergency Preparedness and Response
Plans sought to leverage existing governance frameworks and regional
emergency management plans to collaboratively develop a framework for
prioritising, preparing, and responding to BANC assets within local emergency
management jurisdictions. .
• Recognise and invest appropriately in eco-anxiety as a real condition and
growing phenomenon affecting an increasing number of rural individuals and
communities.

Thank you once again or the opportunity to contribute to this consultation phase and we look forward to the completion of the Australian Government’s Drought Plan.
Yours Sincerely,

Chris Norman
CEO, NRM Regions Queensland