Review of COMPASS - C4ESc4es.com.au/Documents/Sugar Vol 3 Final.pdf · Independent Environmental Audit of the Sugar Industry in ... The energy and commitment from these individuals

Independent Environmental Audit of the Sugar Industry in Queensland, New South Wales and Western Australia

Report Volume 3

Review of COMPASS

Prepared by

C4ES Pty Ltd ABN 97 097 654 872

June 2004

Acknowledgements

The complexity, size and scope of the Australian sugar industry cannot be underestimated, and with this in mind, and given the time constraints of the project, C4ES has made every effort to ensure a professional assessment and present the report without favour. Given the scope of the study and the industry’s strong and divergent views C4ES acknowledge there may inevitably be some gaps in the findings and differing opinions to those expressed in this report.

While many people deserve thanks for their assistance and input, and there are far too many to name, the following require special mention - Australian Cane Farmers Association (ACFA), Australian Sugar Milling Council (ASMC), Bureau of Sugar Experiment Stations (BSES), CANEGROWERS, CANEHARVESTERS, farmers, harvesters, Sugar Industry Guidance Group (IGG), New South Wales Sugar Milling Council (NSWSMC) the CJ Ord Mill and State Agricultural, Natural Resource and regulatory agencies.

Special acknowledgement is also deserved for the cane farmers, harvesters and mill staff who participated in the study and donated their valuable time during the busy harvest season. The vast majority were keen to discuss environmental issues and welcomed the opportunity to drive Audit staff around their properties to discuss and demonstrate the many environmental and productivity initiatives being undertaken.

The energy and commitment from these individuals and organisations has been invaluable, and we thank them for their contribution

Independent Environmental Audit of the Sugar Industry – TOR 3

C4ES Pty Ltd (June 2004) Page 1

Table of Contents

1 Executive Summary ................................................................................................................ 3

2 Introduction ............................................................................................................................. 5 2.1 What is COMPASS?............................................................................................................................................. 5

3 Uptake of COMPASS............................................................................................................... 8 3.1 Workshop Attendance and BMP Adoption............................................................................................................ 8 3.2 Workshop Evaluation .......................................................................................................................................... 10 3.3 Assessment by Harvesters ................................................................................................................................. 13

4 COMPASS and BMP.............................................................................................................. 15 4.1 Addressing Uptake of COMPASS....................................................................................................................... 16 4.2 Improving and Enhancing COMPASS ................................................................................................................ 17

4.2.1 Information Sharing and Peer Interaction.................................................................................................. 18 4.2.2 Independent Verification and Auditing....................................................................................................... 18 4.2.3 Industry Sector Differences ....................................................................................................................... 18 4.2.4 COMPASS within the Industry Framework................................................................................................ 19

4.3 Case Study: Douglas Shire/Mossman Mill .......................................................................................................... 23

5 Acronyms............................................................................................................................... 24

6 References............................................................................................................................. 25





1 Executive Summary

This report addresses Terms of Reference (TOR) 3 of the Independent Environmental Audit of the Sugar Industry in Queensland (Qld), New South Wales (NSW) and Western Australia (WA) (“Environmental Audit”) based on an assessment of the uptake of the COMPASS (“COMbining Profitability And Sustainability in Sugar”) self-assessment program by sugarcane farmers and recommending program improvements as needed.

COMPASS Implementation

Queensland’s Environmental Protection Act 1994 (EP Act 1994) provided the impetus for the farming sector of the Queensland sugar industry to develop a Code of Practice (CoP) in 1998 (CANEGROWERS 1998). The CoP was followed by the funding and development of the COMPASS program launched in November 2001 for sugarcane farmers in both Qld and NSW. The COMPASS Self Assessment Workbook (Azzopardi 2001) builds on the role of the CoP in helping farmers understand what changes, if any, they may need to make to current farming practices to meet their obligations under the EP Act 1994, and is delivered through a series of one-day or two half-day workshops. Farmers are given the opportunity to rank their environmental management performance in ten key management areas to assess their present management operations and list any changes or improvements.

COMPASS Evaluation

The Environmental Audit found that COMPASS workshops are effective in raising environmental awareness and introducing Best Management Practice (BMP) as a concept, but do not necessarily motivate farmers to adopt them.

While COMPASS is not a CoP or a means of regulating action by farmers, it has become an indicator for BMP demonstration in documents such as CANEGROWERS’ eco-efficiency agreement with the Commonwealth (DEH 2003) and the Great Barrier Reef’s (GBR’s) Reef Water Quality Action Plan (RWQAP). Attendance at workshops is used by the farming sector of the industry as an indicator of adoption of BMP, but the Audit survey results do not support this.

In addition, and importantly, farmers in most regions are adopting a range of sustainable practices and implementing BMPs not linked with participation in the COMPASS program and therefore may not be recognised by their peers, the community and/or the industry or accountable under the eco-efficiency agreement.

The limitations of using COMPASS as an indicator for adoption of BMP are:

• the principle of self assessment is unreliable and does not imply compliance; • there are poor feedback mechanisms for monitoring and reporting; • the focus is more general and generic rather than site specific and there is a lack of any

weighting to the different management practices; and • attendees view the experience as an achievement rather than understanding where

COMPASS fits in context with other environmental performance tools. In addition, given the pressures facing the Australian sugar industry in terms of the financial and legal risks of on-site and off-site impacts from sugarcane production, the projected rollout of COMPASS will take too long, and will not have the appropriate impact or effect.



Future Options

The findings of the audit are that the content of COMPASS could provide support for the longer term sustainability of the industry and that in recognition of the value of the current program, recommends maintaining COMPASS (upgraded) as an awareness-raising and self-assessment tool. However, it is also recommended that COMPASS be used in conjunction with other programs for addressing risk and improving natural resource management. At the same time it is important to build and enhance other programs that better reflect actual BMP adoption and improved environmental outcomes through a frame work with farmer and farm accreditation. Such efforts will require:

• improved monitoring and reporting mechanisms;

• stakeholder engagement; and

• accountability and linkage with other current and/or pending programs.

For example, strategic linkage of COMPASS with the Rural Water Use Efficiency (RWUE) program, Land and Water Management Plans (LWMP) and proposed farm management systems (FMS) could allow the sugar industry to demonstrate significant environmental improvement and be better understood in context with other land uses.

The proposed framework (see Volume 4) will provide a foundation for unifying industry action by acknowledging environmental impacts of previous actions. It sets out industry (farmers, harvesters and mills) responsibilities, commitment to environmental protection and approaches to be taken to ensure that the industry has taken all reasonable and practicable measures to protect the environment, compliant with the Environment Protection Act 1994 and other relevant legislation.

Summary

Under increasing concern and expanding knowledge about the environmental impacts of poor farming practices, farmers may be forced to comply with more restrictive environmental controls if they are not able to demonstrate improved performance to their communities. To be sustainable the sugar industry must adopt and implement best management practices (BMPs) that will reduce the risk of on-site and off-site environmental impacts especially where the farming is conducted in environmentally sensitive areas.

Most BMPs make economic sense, ensure minimal environmental impact and are concepts which are understood by the broader community, especially from a consumer awareness perspective. At the moment, the future of real and demonstrated change in environmental management practices and systems, including the adoption of BMP, is too dependent on an increased rollout of COMPASS workshops. However, as detailed in this report, the program’s current format requires reviewing and re-structuring if it is to be used as a tool for change within the sugar industry.

Based on farmer surveys, stakeholder consultations and additional analysis, participation in COMPASS workshops, in their current form, should not be used as a primary indicator of outreach on, or implementation at a farm level, of BMP. Furthermore, using this correlation with the current COMPASS program fails to acknowledge the efforts by many farmers who may not have attended a COMPASS workshop but have adopted BMP and it also sends an inaccurate and incomplete message to both governments and the community.

COMPASS provides a platform on which to develop a more comprehensive program for engaging farmers in more sustainable on-farm practices as one component within a suite of tools and strategies which can be used to develop and implement BPM.



2 Introduction

This report addresses the Environmental Audit’s Terms of Reference (TOR) 3, which requires C4ES to:

Examine the uptake of the COMPASS program by growers and assess its capacity to act as a platform for the adoption of Best Management Practice. In addition, recommend any additional management tools or improvements to COMPASS required to encourage adoption of Best Management Practice with a key focus on enhanced environmental, social and economic performance.

This document is Volume 3 of the Environmental Audit Report. For more detailed information the reader should refer to Volumes 1, 2 and 4.

Methodology

From October 2003 to January 2004, detailed on-site interviews/surveys were conducted across cane growing regions in Qld, NSW and WA with 255 farmers, 10 mills, 27 harvesters and two refineries. The results of 30 key stakeholders that provided written submissions on a pro-forma survey document were also complemented with extensive personal consultations with over 100 stakeholders. For more details on the methodology refer to Volume 1.

2.1 What is COMPASS? Following the development of the Code of Practice (CoP) by CANEGROWERS in 1998 to help farmers meet their obligations of duty of care under Qld’s Environmental Protection Act 1994, it became clear that a process was needed to stimulate farmer involvement and hence greater compliance with the CoP.

The farming sector of the Qld and NSW sugar industries developed a self-assessment tool for sugarcane farmers to identify financial, social and environmental improvements to their farming practices. The Bureau of Sugar Experiment Stations (BSES) led development of the program, with the support of the sugar industry and the Qld Government. The resultant program was launched in November 2001 and workshops commenced in February 2002.

While COMPASS was originally developed mainly as a tool to create awareness of BMP amongst cane farmers, and help them benchmark their performance against the CoP, it has evolved into a document which is much more comprehensive than the current CoP. COMPASS is not in itself a code of practice or a means of regulating action by farmers, but it has become a key indicator for demonstrating improved environmental performance through CANEGROWERS’ eco-efficiency agreement with the Commonwealth and the (Great Barrier Reef’s (GBR’s) Reef Water Quality Action Plan (RWQAP).

COMPASS Program Outline

COMPASS workshops focus on farmers ranking their own on-farm environmental management performance. The COMPASS workbook (Azzopardi 2001) identifies ten key management areas which landholders are required to work through so that they can assess their present management operations against practices that are considered both profitable and sustainable.

Landholders subjectively assign a value ranking against farm management actions from 1 to 4, with 1 as the top ranking and representing a high level of adoption of desirable management practices. A sample worksheet is provided in Figure 1.



Figure 1: Sample COMPASS worksheet Source: BSES Ltd

Farmers calculate rankings for each section and assign a cumulative overall ranking (Figure 2).

Figure 2: Section and cumulative rankings Source: BSES Ltd



COMPASS also provides a section for farmers to plan any changes or improvements to their current practices (Figure 3), and while it does not identify the changes, it does provide access to the appropriate information.

Figure 3: Sample COMPASS action plans Source: BSES Ltd

Program Delivery

The program is delivered through a series of one-day or two half-day workshops. Delivery of the program is based on an arrangement between CANEGROWERS who provide administrative support such as venues and FARMBIS applications and maintain a database and BSES who provide trained facilitators with technical expertise. CANEGROWERS and BSES now take joint responsibility for the promotion of the workshops to farmers.

The cost of the one-day workshop is reported as:

BSES technical facilitation $800

CANEGROWERS administration support $600

Venue $250

Catering $15/head

Workbook $30 each

The current charge to attend the workshops is $33 per enterprise.



3 Uptake of COMPASS

To-date the uptake of COMPASS BMPs by the industry has been measured by attendance at workshops and is broadly regarded as being low. However, to put poor attendance into perspective, the program is relatively new, with only a limited number of workshops held. In addition low sugar prices have depressed the industry and influenced farmer attitudes.

3.1 Workshop Attendance and BMP Adoption The Environmental Audit Farmer Survey was designed to capture information and data relating to COMPASS by including a number of the management practice questions which are reflected in the COMPASS workbook (Azzopardi 2001), and specific questions relating to the actual COMPASS process.

Awareness and Attendance

Although there was a very high awareness of the COMPASS program (83%) reported by farmers, actual attendance at workshops was much lower across all regions with 31% of farmers surveyed having attended a workshop (Figure 4).

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Figure 4: Proportion of farmers surveyed who are aware of COMPASS and have attended a workshop

BSES/CANEGROWERS data on COMPASS workshop attendance differs from results reported by farmers during the Environmental Audit, as shown in Figure 5. Official COMPASS program figures show over 860 farmers, or an overall rate of approximately 14% of CANEGROWERS(Qld)/ BSES(NSW) members have attended a workshop (as of January 2004), as opposed to the 31% participation rate reported by farmers during this study.



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Figure 5: Farmers surveyed attendance at workshops compared to CANEGROWERS records (as of Jan 04)

As stated above attendance is higher among farmers surveyed than the attendance data provided by BSES/CANEGROWERS. A reason for this result may be that in Qld a significant proportion of the farmers in the original survey random selection chose not to, or could not participate in the survey. This necessitated the selection of “extra farmers” sourced through the assistance of the regional CANEGROWERS office and/or mills staff to ensure that a representative number of farmers were surveyed in each region. Of those surveyed the proportion of the “extra farmers” who attended COMPASS workshops was higher than the originally “randomly selected” farmers but this is not considered to have had a significant impact on the outcome of survey when compared with the responses of the remaining randomly selected farmers. For more detail refer to the methodology in Volume 1 of the study.

COMPASS and Adoption of BMP

To determine whether BMP are more likely to be adopted by farmers who attend COMPASS workshops, thirty of the survey questions that reflect BMP were selected, and then a comparative analysis of the responses was made. The results in Figure 6 show that BMP adoption does not vary significantly between growers who have and haven’t attended COMPASS workshops.

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Figure 6: BMP implementation relative to COMPASS workshop attendance



3.2 Workshop Evaluation

Farmer Evaluation

The COMPASS program is designed to be evaluated by participants at the conclusion of the workshop and a follow-up survey of participants four to six months after a workshop. The follow-up survey is intended to gather information on how farmers are progressing on their action plans and how they view the process after a time. There was no published data available on the follow up survey at the time of the Environmental Audit.

The Workshops

Farmers surveyed who had attended a workshop generally believed there is value in attending the workshops, with 38% finding them very helpful, 55% somewhat helpful, and only 6% indicating that COMPASS is not helpful. Figure 7 shows how farmers surveyed evaluated COMPASS.

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Figure 7: Farmers view of the benefits of the COMPASS program.

Figure 8 shows self assessment ranking from COMPASS tabulated from a total of 200 COMPASS participants’ worksheets. These results show that a clear majority of farmers attending COMPASS workshops report a ranking of 2, indicating adoption of most recommended BMPs across the board, but with some room for improvement.

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Figure 8: Tabulated COMPASS participant self-assessments Source: BSES Ltd and CANEGROWERS



This finding (Figure 8) is not supported by the Environmental Audit’s harvester survey (Figures 11 & 12) and stakeholder consultations, which indicate that while there may be a marked improvement in harvester BMP adoption by farmers, there needs to be considerably more improvement. In turn this may have implications for the efficacy of the role of COMPASS in the CANEGROWERS eco-efficiency agreement and the GBR RWQAP.

The discrepancy between farmer self assessment reporting in workshops to date and reporting by harvesters and stakeholders during the survey may be a result of a higher attendance of farmers at COMPASS workshops who are interested in improvement and best practice. The response by harvesters and stakeholders is more likely to be based on a broader industry representation.

Alternatively the higher than expected self assessment results may be part of a normal psyche of wanting to believe our own behaviour is above average and a propensity to mark ourselves on the high side rather than an admission that we are failing. This could also help to account for the high reporting of 2’s in the self assessment.

Making Changes

Overall, of the farmers who had attended the workshop, the majority (60%) indicated COMPASS helped them implement changes to their management practices (Figure 9), and this was reasonably consistent for all regions except for the Burdekin (38%).

The most common areas of change were related to chemicals and record keeping.

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Figure 9: Farmers who have attended a workshop reporting that the COMPASS program helped them implement any changes



Plans to Increase Uptake

Since February 2002, more than 860 farmers have attended a COMPASS workshop (as of January 2004). This represents 15% of CANEGROWERS members throughout Queensland and 10% of BSES members in NSW. This is equivalent to approximately 13% of all Australian sugarcane farmers and needs to be expanded to cover all sugarcane farmers in Qld, NSW and WA.

Under its eco-efficiency agreement with the Commonwealth, CANEGROWERS has agreed to a target of 33% of CANEGROWER members through the program by June 2005 (DEC 2003). COMPASS workshops undertaken historically and proposed are indicated in Figure 10.

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Figure 10: COMPASS workshop progression. Source: BSES Ltd and CANEGROWERS

Improving the Program

Few of the COMPASS workshop participants interviewed had comments for improvements, but some suggestions included:

• keeping the program up-to-date; • including more innovation; • making the course more practical/hands-on; • improving delivery; • improving marketing; and • providing incentives to do the course.

The COMPASS program in its present form may not be the appropriate basis for recording, or improving, the adoption of BMP:

1. As with many programs which focus on best management and environmental issues, they initially attract farmers who are interested in and implementing BMP. This may influence the slightly higher self-reported BMP uptake rankings to-date among workshop participants (Figure 7), and both participation and positive reporting may decrease as the program continues to roll-out.



2. Many of the management strategies in COMPASS may be considered normal farming practices that are already being implemented on some farms as part of responsible and viable land management. This is an important point to consider in the future when ‘selling’ the benefits and value of participating in COMPASS.

3. The perception that COMPASS workshops merely reinforce current practices may affect farmers’ willingness to attend.

4. Participation figures reflect the number of farmers and the number of ‘business units’ or farm enterprises attending workshops, but do not relate to the area of cane being farmed. For example, within the Douglas Shire Council a total of thirty eight Mossman mill area farmers representing 26 farm enterprises have completed a COMPASS workshop. These participants managed 46% of land under production in 2002, whereas attendance records show only 24% (CANEGROWERS figure December’03) of the cane farmers in the region attended.

5. While the proposed rollout of COMPASS represents a significant increase in activity, efforts should be more pronounced in high risk zones in catchment areas in order to raise awareness of BMP. This would include areas at greatest environmental risk, and areas with the poorest BMP adoption for their risk area.

3.3 Assessment by Harvesters A review of the self assessment results of 200 farmers who have undertaken the COMPASS program shows that 33% of farmers ranked themselves as doing all of the practices nominated and 64% doing most of the practices (Figure 8) COMPASS recommends to prepare their crops for harvesting (COMPASSS Workbook Section 10, Azzopardi 2001). This equates to an average 97% of farmers assessing that they either do all or most of the practices.

A series of questions based on the COMPASS’ Farming for Harvesting section and relating to the issues considered important to harvesters were incorporated into the Environmental Audit’s Harvester survey. These were used as a means of comparing the results of the farmer’s self-assessment with the harvester’s assessment of farmers’ performance relating to:

• farm layout criteria (Figure 11); and • farmers’ crop presentation (Figure 12).

The outcome of the summation of practices (always + mostly) demonstrated some difference between farmers average self assessment and harvesters views notwithstanding over 90% of the harvesters interviewed were also cane farmers. The average ranking by harvesters for those farmers who “always do it” is reasonably consistent with the self assessment but the second ranking (mostly) by the harvesters has a considerably more conservative response than that of the farmers (Figure 8).



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Figure 11: Harvester views on farmer awareness of Farm Layout Criteria

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Figure 12: Harvester views on farmers Crop Presentation



4 COMPASS and BMP

COMPASS is an example of a traditional extension and adoption program, based on productivity increases and emphasising information provision and technology transfer. However there is currently a shift away from focusing just on productivity, and more towards the development of a sustainable production system, which encompass social, economic and environmental principles of the Triple Bottom Line (TBL).

COMPASS and Environmental Education

In environmental education terms and in support of BMP, TBL and eco-efficiency, changing behaviour and effecting positive environmental outcomes requires an integrated approach and cannot be achieved through education alone – as per Figure 13 below.

Figure 13: An integrated approach to eco-efficiency.

Adapted from “Focusing On Our Future”, A Guide for Waste Educators (2001).

As indicated in the survey/audit results, participation in an education or extension program, such as COMPASS is appropriate and effective in raising awareness, but is only the very first step and does not translate into immediate action. This is especially significant when those attending the initial COMPASS workshops may have a relatively high degree of confidence in their farming practices, and it becomes a case of “preaching to the converted” and/or reinforcing current behaviour.

In addition, the format of the program has tended to rely heavily on classroom-based and self-assessment activities, an approach which is not generally recognised as being of great practical use, especially given the current demographic of the target group. Generally, environmental education programs focus on practical hands-on learning, and incorporate field trips, the “nature’s classroom” approach, real-life working case studies and peer education.



COMPASS Limitations

The role of COMPASS as a `lead program’ for environmental improvements, detracts from ownership and admission of the severity of environmental impacts, and at the same time fails to recognise the recent significant improvements within the industry not related to COMPASS attendance particularly in the farming sector.

Current COMPASS limitations include:

• lack of real rather than perceived indicators for adoption of BMP across the farming sector; • lack of follow up to identify actual uptake rather than a perceived outcome; • lack of clarity as to where the program fits as a tool in overall strategic planning; • some statements and questions which are leading; • no evident mechanism for two-way data flow; • inability to attract the poorer performing farmers and address associated industry risks; • unable to reflect the increased up-take of BMP by better performing farmers who may not

have attended a COMPASS workshop; • lack of site-specific or localised practices, and therefore less ownership; • no attempt to targeting high risk areas or practices, nor weighting of any practices; • lack of integration of COMPASS as part of a “whole of system” approach to the sugar value

chain; and • limited perspective on balancing social, commercial, business and environmental practices.

To use COMPASS in its current form as a basis for other initiatives would be a risk because it is not able to provide the most appropriate framework for assessing, measuring and reporting the adoption of BMP. The answer then lies in reassessing what is required to deliver the desired BMP outcomes in an acceptable time frame.

4.1 Addressing Uptake of COMPASS Increasing the attendance at COMPASS workshops is a key component of CANEGROWERS’ eco-efficiency agreement with the Commonwealth (DEH 2003). The three-year agreement details specific steps that CANEGROWERS will undertake to promote eco-efficiency to its members. The agreements are intended to improve on-farm environmental and economic sustainability and reduce water quality impacts to the GBR (Kemp 2003).

Increasing the uptake of COMPASS under the eco-efficiency agreement includes:

• participation in the COMPASS program increasing to at least 33% of CANEGROWERS’ members across all regions by June 2005;

• 200 COMPASS workshops will be held during Years 1 and 2; and • developing promotional activities which continue to raise the profile of the program to

CANEGROWERS’ members. Given the urgency of the pressures facing the Australian sugar industry, in terms of the financial, legal and social risks of on and off-site impacts, the planned rollout of COMPASS over two years to raise awareness to 33% of farmers may be too little too late. As a first step, priority must be given to rolling-out COMPASS in higher-risk areas, while at the same time the program should be strengthened and supported with other measures elsewhere with a faster rollout.



4.2 Improving and Enhancing COMPASS As addressed elsewhere in the Environmental Audit, the Australian sugar industry has not taken full advantage of the significant investment in research and development and improved management practices over the past few years. The industry as a whole needs to not only acknowledge environmental impacts and the problems associated with past and in some cases, present practices, but it must also increase public awareness generally of the current rate of improvement in BMP.

Given the environmental and social imperatives, the accelerating need for accountability, and in recognition of the value of the current program, there are two primary options for COMPASS:

1. Continue COMPASS as an awareness-raising and self-assessment tool, in conjunction with other programs such as the eco-efficiency agreement and proposed Farm management System (FMS), but increasing the rate of program rollout and improving program delivery, especially in higher risk areas. Address limitations as appropriate for this use;

2. Extend COMPASS to increase farmer awareness of off-site environmental impacts and the financial and legal risks to individuals and the industry as a whole. In addition, adapt the program to provide for greater monitoring, independent auditing and reporting of BMP adoption, an example being that proposed for the Douglas Shire/Mossman Mill area (see: Section 4.3). This extended and integrated use will still require increasing the rate of program rollout and improving program delivery, especially in higher risk areas, but this would be undertaken within an Environmental Assurance Framework (EAF - see Volume 4) and local or regional plan and in conjunction with the additional programs.

The recommended approach is to extend COMPASS (2 above) beyond an awareness-raising and self-assessment tool to be used in conjunction with other programs for addressing risk and improving natural resource management. At the same time it is necessary to integrate with other programs which better reflect actual BMP adoption and environmental outcome through a framework that allows property and farmer accreditation. Such efforts will require:

• assessment, auditing and accreditation systems to be built in;

• formal follow up to facilitate improved monitoring and reporting based on regular auditing;

• developing a risk register, with risk identification and management strategies;

• an Environmental Policy;

• stakeholder engagement; and

• accountability and linkage with other current or pending programs.

To ensure greater implementation, COMPASS Action Plans should be examined in conjunction with the proposed framework, farm planning and business planning of individual farmers to identify input costs and the cost-effectiveness of alternative approaches. In addition, proposed farm management systems (FMS) could allow the sugar industry to demonstrate significant environmental improvement and be better understood in context with other land uses.

COMPASS would benefit from the inclusion of sections on greater awareness of regional natural resource management (NRM) needs, land use interactions, and an enhanced understanding of off-site environmental impacts of a range of current and alternative farm practices.



4.2.1 Information Sharing and Peer Interaction There are sufficient examples to suggest that information transfer of technical models is inadequate as a comprehensive strategy to deal with the complexities of NRM, and has led to the community-based approaches of extension. Farmers are more likely to understand and adopt improved practices through peer learning than they are through a passive classroom situation.

In recognition of the need for a substantial peer education and experiential learning program within all sectors of the industry, the delivery of COMPASS program should be delivered in conjunction with:

• farm walks and discussions with regional BMP “champions” so that farmers can see and hear for themselves what can reasonably be accomplished within their area/region (in undertaking the Environmental Audit many farmers were willing to discuss both strengths and weaknesses of their management practices);

• planning within local cells/productivity groups or mill areas to rank response strategies in accordance with specific regional and catchment needs;

• sharing self-assessment action results; and • exploring opportunities for cost/research sharing and enhanced ownership.

Given the significant expertise already available, it is recommended that efforts for increased uptake and expansion of COMPASS within the proposed framework (see Volume 4) would involve sugarcane farming “champions” more effectively, and focus more strongly on experiential and networking strategies.

4.2.2 Independent Verification and Auditing For many years community perceptions and reporting impacts of sugarcane farming on the environment were challenged by sugarcane farmer organisations which have resulted in current communication efforts with the community being met with a healthy level of scepticism. Consequently stakeholders and the broader community do not understand the impact or extent of recent improved management practices and environmental efforts.

To restore some kind of positive communication, and flag a willingness by the industry to be open to criticism, farmers could effectively develop and implement their own Action Plans, which would be independently verified and audited (similar to that for NSW acid sulfate soil management). This would be part of a continuous improvement process to ensure consistent application, awareness of improved practices over time and to assist in two-way information transfer. This verification and auditing would feed actual performance and improvements into regional NRM planning processes, link into farmer and property accreditation and could be communicated more effectively to stakeholders.

4.2.3 Industry Sector Differences In Section 3.3 of this report and elsewhere in the Environmental Audit, it has been shown that different sugar industry sectors have different interpretations and adoptions of BMPs. Given the maturity of the sugarcane industry in Australia and significant community and financial pressures on the industry, all industry sectors need to show greater co-operation and unity to address sugar industry environmental risks and impacts.



In stakeholder surveys, criticisms of the perceived sugar industry’s environmental performance came not just from the community and environmental groups, but also from within the industry itself. Common responses included that the industry needs to wind back on political attacks, engage other stakeholders and do a better job in promoting the current and demonstrable efforts of many farmers devoted to environmental improvements.

If industry sectors are not unified on current industry performance, how can improved practices be effectively communicated to others? As a result of the Environmental Audit findings it is recommended that COMPASS become one component of an Environmental Assurance Framework (EAF) to provide a credible, independently verifiable approach to integrate industry activities and effectively inform stakeholders of industry environmental performance. This will allow greater self-management by the industry for restructuring and increased productivity within defined environmental and social boundaries to meet catchment and regional NRM targets and respond to the RWQAP requirements.

4.2.4 COMPASS within the Industry Framework To ensure continued access to natural resources and environmental compliance, a regional plan should be developed, owned jointly by each of the farming, milling and harvesting sectors, which is part of the framework detailed in Volume 4. Given the significant expertise and experience already available within each region, it is appropriate that such an approach be built from the ground up, rather than top down.

Key components of such an approach would include TBL thinking and identifying higher risk areas and practices including links as part of the RWQAP process.

It is recommended that all sectors of the Australian sugar industry undertake a comprehensive assessment of all environmental policies and recommended practices, and adopt an integrated approach to environmental management in conjunction with other stakeholders. This assessment would form the basis for the proposed environmental framework whose development, objectives and outcomes would be detailed in an industry plan and associated Industry Environmental Policy.

The Industry Environmental Policy and proposed framework could be used as a catalyst to provide a foundation and future plan for unifying industry action by:

• acknowledging environmental impacts of previous actions as report cards; • setting out industry (farmers, harvesters, mills and refineries) responsibilities; • committing to environmental protection; and • complying with the Environment Protection Act 1994 and other relevant legislation.

To help ensure stakeholder engagement and ownership, development and implementation of the framework should include a series of heavily promoted regional workshops in sugarcane growing regions and broadly circulated draft materials with sufficient opportunity for input and ownership. Development would be undertaken in conjunction with key stakeholders including growers, mills, refineries, governments, Regional Guidance Groups, NRM Boards and research, environmental and community organisations. This development would also coincide with the regional industry structural change and data management as proposed in Volume 4.



COMPASS development should include facilitated and summarised discussions with stakeholders to address specific components such as:

• acknowledgement and identification of high risk areas and practices, historically and under current conditions and assembled within group, mill and catchment parameters;

• increased rollout of reviewed COMPASS to increase awareness in high risk areas; • recognition of improved BMP adoption by cane farmers compared to historical activity

based on education and training packages that can provide farmer and property accreditation;

• industry development of integrated environmental policy frameworks and risk reduction strategies to be incorporated into the CoP (or its successor) and COMPASS, and made accessible and promoted to farmers and the broader community;

• development of agreed objectives for particular areas of farm management and agreed BMPs which will achieve these objectives in specific areas (such as irrigation and chemical usage) to be incorporated into a BMP manual with ability to regularly update and access online; and

• a self-assessment program (effectively an improved COMPASS) which is directly related to the BMPs in the Best Practice Manual (for farmers and harvesters).

The upgrading of COMPASS and its activities should be overseen and led by a Steering Committee, such as the Rural Water Use Efficiency 2 (RWUE2) or a Regional Industry Board (RIB) committee. The committee must include independent representation and linkages to the proposed EAF process to ensure that the outcome is a step into the future, rather than an extension of the past.

Proposed Industry Environmental Management Tools

The following diagram summarises the proposed industry environmental management tools that are the basis for the industry EAF. There are many similarities between the industry sectors which will provide for a better monitoring and reporting program.

From the diagram it is also possible to appreciate where the COMPASS program and associated tools fit and how they interact with the other industry sector management tools at a local level.

The Industry Environmental Policy is the primary document (and agreement) that ties the industry together and provides the framework with the links from the different levels of responsibility. However, it is the risk register and management strategies that will demonstrate the most obvious need for cooperation and collaboration, recognising that there is potential for `transferred risks’ from any industry sector that can either bond or break an industry.



Refinery Mill & Cane Transport Harvesters Farms

Environmental & WH&S Policy

Environmental & WH&S Policy

Environmental & WH&S Policy FMS

EPA Licence EPA Licence Environmental Risk

Register Environmental & WH&S

Policy

EMS/CoP & Quality Management System

(QMS) EMS/CoP BMP Manual/CoP BMPs/COMPASS/CoP

BMP implementation BMP implementation BMP implementation BMP implementation

Standard Operating Procedures (SOPs)

Standard Operating Procedures (SOPs)

Environmental Risk Register

Environmental Risk Register

Cane Supply Management System Monitoring & Recording Monitoring & Recording

SRI Codes Audit & Accreditation Audit & Accreditation

Implementation of the COMPASS upgrades could be undertaken in a multi-step process, but should not be implemented in isolation from other industry sectors:

Step 1

Upgrade COMPASS as detailed previously through an established regional committee or as agreed:

• develop parameters for regionalisation of COMPASS; • develop monitoring and reporting provisions to establish two-way data flow through

COMPASS review programs; • upgrade the self assessment section to better reflect regional and catchment nuances; • plan increased rollout of COMPASS in high risk areas, including a stronger focus on

experiential learning, case studies and peer education; and • seek greater strategic linkage of COMPASS with the RWUE program and Land and Water

Management Plans (LWMP).

Step 2

Develop or refine additional environmental risk management options:

• develop a risk register and risk management strategy linked to the BMP’s to be included in the EAF;

• establish an integrated auditing and accreditation system, based on BMP and similar to the Mossman example (see Section 4.3) but again included as part of the EAF;

• develop a strategic linkage of COMPASS with the proposed FMS approach being led by the Queensland Farmers’ Federation (QFF) and trialled in the Burdekin; and

• establish a broader committee including industry, government and community representatives to meet once a year to review changes to BMP and self-assessment monitoring provisions and recommended policies relating to BMP adoption and promotion.



Step 3

Integrate COMPASS into the EAF and link with other environmental management systems across the industry:

• integrate the COMPASS tools with other industry sector environmental management tools so that the industry can adopt a unified reporting system;

• conduct ‘rolling audits’ of industry sectors particularly targeting the high risk areas to monitor the industry changes and provide feedback so that the farm accreditation system and future independent audits capture data to maintain industry perspective;

• conduct independent industry sector audits every 2 years – based on independently verifiable data (including remote sensing, % of growers accredited, participation in DrumMuster, chemical accreditation and water usage) as well as representative cane farmer and stakeholder consultation and surveying (mainly on uptake of self assessment/policy etc). Such auditing should be timed to have audit results available prior to policy/BMP reviews so that the audit can be used to review the program’s success.

Regularly Once Established

Review the COMPASS program within the EAF and consider expanding options:

• annual review of BMP and self-assessment monitoring provisions and recommended policies;

• annual regional strategic planning and stakeholder engagement workshops; • provide regular opportunities for farmer and property accreditation; • develop education and training packages and increase industry certification courses; • independent environmental auditing as specified above; and • prepare for issues such as licensing, water rights and usage.



4.3 Case Study: Douglas Shire/Mossman Mill

A proposal has been developed for the independent auditing of BMP and Action Plans in the Douglas Shire/Mossman Mill area which could serve as a model for EAF development and cane farmer accreditation. It consists of a three stage process comprising self-assessment, peer group assessment and assessment by external auditors. A key component of the proposal is the incorporation of auditable Action Plans for continuous improvement in the system. This builds on the initiative taken with the development of the COMPASS program where Action Plans, while included, were not able to receive the emphasis they deserved.

BMP for 21 different activities have been developed so far, based on COMPASS. These BMPs have been reviewed specifically in relation to the Douglas situation and quantified to ensure similar interpretations by farmers of each level of adoption and facilitate easier auditing.

The 21 BMPs have been placed into four groups, with Group 1 incorporating those practices regarded as having the most impact on sediment and agrichemicals and Group 4 having the least impact. This recognises that not all practices have the same impact and establishes the structure for meeting a required level of environmental performance. From this a draft level of environmental performance will be developed for the region as a whole but not for individual farmers.

A training course for external and peer auditors, auditing protocols, a BMP manual, and a database for registration of both auditors and farmers will be developed by Mossman Agricultural Services (MAS) in conjunction with recognised auditing bodies. The whole proposal is intended to be dynamic with significant consultation with farmers. As part of this process, a capacity building program will be undertaken to help farmers become more aware of the environmental aspects of their farming practices.



5 Acronyms

ACFA Australian Cane Farmers Association BMP Best Management Practice BSES Bureau of Sugar Experiment Stations C4ES C4ES Pty Ltd COMPASS COMbining Profitability And Sustainability in Sugar CoP Code of Practice DAFF Department of Agriculture, Fisheries and Forestry DEH Australian Government Department of Environment and Heritage EAF Environmental Assurance Framework EPA Environment Protection Agency EP Act 1994 Environmental Protection Act 1994 EMS Environmental Management System FIFA Fertilizer Industry Federation of Australia FMS Farm Management System GBR Great Barrier Reef IGG Sugar Industry Guidance Group LWMP Land and Water Management Plans MAS Mossman Agricultural Services MPLE Management Plan for the Local Environment NRM Natural Resource Management NSW New South Wales NSWSMC New South Wales Sugar Milling Council QFF Queensland Farmers’ Federation Qld Queensland QMS Quality Management System RIB Regional Industry Board RWQAP Reef Water Quality Action Plan RWUE Rural Water Use Efficiency SOP Standard Operating Procedure SRI Sugar Research Institute TBL Triple Bottom Line TOR Terms of Reference WA Western Australia



6 References

Australian Government Department of Environment and Heritage (DEH) 2003, Eco-Efficiency Agreement with Queensland Cane Growers Organisation Ltd, Australian Government.

Azzopardi, M 2001, COMPASS: A self-assessment workbook, Bureau of Sugar Experiment Stations, Brisbane. CANEGROWERS 1998, Code of Practice for sustainable cane growing in Queensland, CANEGROWERS, Brisbane. DEH – See Australian Government Department of Environment and Heritage.

Kemp, D (Federal Minister for the Environment and Heritage) 2003, Government and industry in partnership for eco-efficiency, media release, 30 October, Department of the Environment and Heritage, Canberra, viewed 4 November 2003, <http://www.deh.gov.au/minister/env/2003/mr30oct03.html>.