THE Victorian Farmers Federation has called for an overarching strategy to protect agricultural land throughout the entire state, rather than stopping at the edge of Melbourne.
VFF president Emma Germano described the government's Green Wedges and Agricultural Land Action Plan, which covers area for 100 kilometres around Melbourne, as a "disappointing document".
"The problems it is required to solve are complex and require deep thought," Ms Germano said.
"It's really slight on detail on the potential outcomes and there has been very, very little meaningful consultation.
"It's an attempt to kind of simplify, for the purpose of appeasing certain groups of people, what is actually a very complex issue that requires a very meaningful plan."
In some cases, food production might be easier and cheaper outside the 100 kilometre zone - but Ms Germano said that didn't mean agriculture didn't have a place in the area around Melbourne.
The new policy contains 20 action items, including what the government said was strengthening councils to protect agricultural land from inappropriate development.
Ms Germano said the government has set up VicGrid to plan future transmission and Renewable Energy Zones leading to a statewide Victorian Transmission Plan by mid-2025.
"We have now got VicGrid, who are doing this mapping across the state for renewables and transmission lines - but we are actually saying, you need that mapping and strategic land use plan, across all of Victoria."
After two names and rounds of consultation, in February 2019 and December 2020, the actual action plan "has very little correlation to the [written] documents and feedback that was given".
An options paper received 879 public submissions but the process stalled during the COVID-19 pandemic.
Ms Germano said an advisory committee be appointed to consider the submissions but that had not happened.
Significant support needed to be provided to rural councils to help them identify agricultural land, and how to apply the planning provisions, she said.
"There should be meaningful development of guidance, as to how to make those decisions, as to avoid land use conflict."
"It's so vague, some of the actions themselves don't really mean anything," she said.
Agricultural land should also be seen as having an economic development focus, rather than being viewed as a resource, she said.
"Unless you consider agricultural land as economic development, you miss the point in to how you make decisions, in regard to that land."
Taking away the ability for families to sell where they were and going out of the Melbourne areas was "potentially creating handbrakes and barriers to meaningful agricultural production".
She cast doubts on claims that a significant proportion of food, particularly vegetables was grown within 100km of Melbourne, saying it was "nonsense".
"I think there are plenty of farmers in Lindenow and other areas of the state who would say 'where would you have ever got that from?," she said.
"The government has tried to appease a group of people but ultimately what we need is a 50 year plan to say where are they are doing housing development and where they are not, so businesses have some level of certainty in what they are investing in."
The government should not make farming operations "teeter on the edge of viability" by imposing onerous provisions on activities, or locking land up through easements for utilities, roads or waste transfer stations, she said.
"A report had been published just to tick off the activity, rather than created meaningful solutions to something that should be of vital strategic to importance to the state of Victoria," she said.
"We will continue to lobby around the planning provisions - we thing there should be ministerial advisory committees on changes to planning policy and a state and regionally significant agriculture clause into the planning framework."