As a general principle, and consistent with the recommendations of Professor Graeme Samuel AC, specificity in legislation is critical, and Standards need to be granular, detailed, explicit, and supported by relevant guidelines and rulings. NFF notes the following remark by Prof. Samuel during the 14 November 2025 Senate Inquiry hearing: “Anything that might look a bit vague in legislation is intended to be completely overcome by the instruments which are Standards which will be part of regulations”.
It is against this benchmark that NFF has assessed the draft Standards for MNES and Environmental Offsets. While we support the intent underpinning the Standards, further refinement is required to ensure they deliver the clarity and safeguards necessary for effective decision-making and the agricultural sector. The proposed MNES Standard should also be aligned with the recommendations of the Samuel Review to ensure there is a stronger and more explicit embedding of the principle of Ecologically Sustainable Development (ESD) throughout the entirety of the Standard.
The NFF’s full submission can be found here.
Rebecca Wilde
Chrissy Kerin