Below is what we have submitted in response to objections to our proposed micro-abattoir at Jonai Farms:

9 March 2023

Re: PLN22/0346 – Development Application for a micro-abattoir at Jonai Farms & Meatsmiths (Dja Dja Wurrung Country, 129 Morgantis Rd Eganstown VIC 3461)

To Hepburn Shire & those who have raised objections:

Farmers globally have seen the closure of local abattoirs over several decades, bringing longer travel times for livestock and farmers, and difficulties finding a facility that meets farmers’ slaughter schedule, let alone values. Many of the large, industrial abattoirs have refused service for small-scale farmers entirely, leaving them with no option except to stop farming.

Here at Jonai Farms, we have experienced the acquisition of both abattoirs we use by multinational corporations in the past couple of years, and decreased access since. JBS, the largest meatpacker in the world, bought the abattoir where we slaughter pigs last year, and almost immediately reduced the days on which we can access slaughter. (This huge global corporation has been involved in a long list of scandals, including serious breaches of animal welfare and work safety. See the Four Corners story we contributed to – The Butchers from Brazil - to learn more about what we are facing.)

In response to diminishing access and increasing risk to our livelihood, we have been actively investigating models for local abattoirs since 2017, and concluded that building a micro-abattoir on our farm to service a small group of local farms is the best solution. Small-scale abattoirs on farms can provide far greater welfare outcomes for animals – shorter or no travel distances/times, less stress, and smaller holding facilities, and positive outcomes are greatest where there is more farmer control and participation in decision making. Unlike their industrial counterparts, small, local abattoirs are embedded in communities – the connection to neighbours and ecosystems are a built-in risk mitigation measure as they are answerable to their communities in a way massive facilities behind locked gates will never be. The viability of a local abattoir is also greatest when there is no lease payable to a landlord, given the very small margins of most abattoirs.

The objective of the Jonai Meatsmith Collective abattoir is to effectively and safely construct and operate a micro-abattoir on our agroecological farm for best practice animal welfare outcomes in a way that addresses climate change and biodiversity loss through avoided greenhouse gas emissions and a circular bioeconomy. The facility will have capacity for no more than 15 farms over the course of a year, who process between one and 14 animals per month. The maximum number of animals on a slaughter day is 30 pigs or 6 cattle. We detail a typical slaughter day below. Slaughter will take place no more than one day per week, as we are primarily a farm, not an abattoir, where slaughter is an ancillary and necessary part of farming livestock. We are fundamentally committed to protecting the environment and amenity of our neighbours, ourselves, and communities downstream – everything we do here has demonstrated that commitment for nearly 12 years.

We understand that for many people the idea of an abattoir – a slaughterhouse – evokes fear and even ‘disgust’ (as one objector wrote). We believe that this is a result of our disconnected food system, where people have grown so accustomed to buying plastic shrink-wrapped meat on polystyrene trays from one of the two supermarkets that control over 70% of retail food sales in Australia that they forget – or prefer not to think about – the fact that animals are raised and killed somewhere so that you can eat meat.

We are most disappointed by the objections advocating for animals to be transported longer distances to industrial zones for slaughter, rather than in the farming zone where they are raised.

Just because the industrial food system is currently the ‘norm’ in Australia doesn’t mean it should be, nor does it have to be. What is normal about raising genetically uniform sheds of pigs and poultry, or feedlots of cattle munching grain, which concentrate effluent and create enormous risks to environment, amenity, and public health?

Industrial intensive livestock systems are creating what evolutionary epidemiologist Rob Wallace calls 'food for flu’ – they are the source of most emergent novel viruses that pass from animals to humans. And those are the animals in the abattoirs we have had no choice but to use since we started farming in 2011 – abattoirs that we are losing access to as outlined above.

Essentially, that industrial system is what objectors are advocating for by objecting to small-scale local facilities. Objecting to small-scale localised food production, processing and distribution supports the current ‘norm’ of intensive industrial livestock production as the ‘standard’, condemning millions of animals to lives of misery and stressful transport on their last day, and undermining the efforts of small-scale livestock farmers embedded in local communities.

Before we address specific objections, let us walk you through what the abattoir here will really look, smell, and sound like. Note firstly that we are in the Farming Zone, in which abattoirs are a Section 2 use as ‘rural industry’; a ‘permitted use’ subject to being granted a permit. Boning rooms, dairy processing, and other forms of rural industry are allowed with no permit. Rural industry and animal sounds are both a normal part of farming, and as farming is an ‘as of right use’ of the Farming Zone, they are protected from lifestyle complaints unless they are deemed excessive by ‘reasonable persons’.

A Typical Day in the Jonai Meatsmith Collective Abattoir

At 7:30am on a Monday, we will walk 10 pigs along our internal farm road from their paddocks to the abattoir yards. One animal at a time is separated from the others using boards, and then slowly walked around a curved chute with solid walls (to prevent animals from seeing unusual light or strange animals, which can cause stress[1]) and a non-slip floor to the knock box (a small crush that holds animals firmly in place, which has a calming effect according to leading animal welfare scientist Temple Grandin).

Once secure, the slaughterperson stuns the pig with a captive bolt gun, which makes a sound that does not carry more than 50 metres (the nearest house is 200 metres away). The pig is rendered unconscious and is rolled to the side into the facility, where it is bled, causing it to die immediately. Dehairing and evisceration are conducted inside the facility before another pig enters the knock box. By 10:30am, all of our pigs are slaughtered and in the chiller.

During the processing of our animals, two farmers have arrived with their pigs, one driving a Mitsubishi Triton and pulling a 10 x 5 foot tandem trailer with eight pigs, and the other a Ford Courier pulling a 6 x 4 single-axle with four pigs. The farmers unload the animals with assistance from the on-site stock manager into separate holding pens with solid walls. They have access to water and are under shelter. Any vocalising is unlikely to be different from that of the normal sound of animals on a farm.

Animals are held for approximately two hours before slaughter so that they settle from the stress of transport. They are then slaughtered one by one in the same manner as our pigs before them.

Processing is finished by 3:30pm, after which we clean the facility. At most, the facility will use 1500L of water in a day. To put this in context, the average household uses 900L per day, and a household of five typically uses about 1500L – the same as the abattoir. The septic system, like thousands of them around here and across Australia, is well equipped to cope with the small volume of wastewater.

The next day, further processing will commence, and a mostly on-farm resident team will break carcasses down into a range of fresh cuts, smallgoods, and charcuterie, just as we have done for nine years. Farmers will collect their packaged meat as they have done for several years to sell through their own CSA memberships and farmers’ markets, supplying around 1000 local and Melbourne households with highest welfare meat from animals raised in healthy agro-ecosystems.

A waste-nothing approach will ensure that there is minimal surplus nutrient, as most by-product will be further processed for human consumption (e.g. blood and offal) or hides or leather. While most bones are delivered to CSA members to make stock at home, any surplus bones, as well as stomachs and their contents, and other surplus yield from processing will be composted in our in-vessel rotating composting drum – affectionately known as Audrey – just as they have been for the past two years. This creates a rich compost for the market gardens of Tumpinyeri Growers farming here with us adjacent to the abattoir, thereby promoting improved water retention, ground cover, carbon sequestration, and biodiversity while supporting young farmers’ access to land. In a time of escalating crises of climate change and biodiversity loss, we are offering a viable and beneficial solution for resilience – a genuine circular economy right here on the farm.

We have made soap from surplus fat for nine years in 15-30L batches, and can assure everyone that there is no offensive smell, such as there might be at a big industrial rendering plant.

The Collective’s energy requirements for electricity and hot water will be managed with renewables to minimise greenhouse gas emissions. Water will be collected from the roof of the facility and stored in a 100,000L tank. A new bore has been drilled to supply water to Tumpinyeri’s acre of commercial garden beds, which provides a backup to rainwater storage in the case of multiple years of drought (we have applied for a licence for up to 4ML per annum).

The Hepburn Shire Community Vision and Council Plan aim for ‘a resilient, sustainable and protected environment,’ ‘a healthy, supported, and empowered community,’ and ‘diverse economy and opportunities.’ The Collective will be a localized, ecologically-sound, and socially-just operation supporting up to 15 local farms, and employing at least five FTE workers across its direct and ancillary activities. It will bring value chain control into the hands of more farmers, providing a more resilient local agricultural sector. It also meets the Shire’s ambitions to be an ecologically-sound and socially-just agri-tourism destination, with flow-on benefits to the other farms with farm gate shops.

Jonai Farms Responses to Objections

Objection: The proposed site is next to waterways feeding Deep Creek Spring

Objection: The safety of our drinking water is at risk from contamination.

We firmly believe that all of us must be good stewards of land and water, and understand how water flows to and from the lands in our care.

Schedule 1 (ESO1) states that: “Hepburn Shire is situated in the Central Highlands at the source of a number of catchments linked to Port Phillip Bay or the Murray River. Protection of the quality of this water has significant local and regional implications, especially where these catchments provide domestic water supply.” Our farm, like all properties in this area, is in a Special Water Supply Catchment, which is why there is an Environmental Significance Overlay (ESO) applied to properties across the central highlands.

As a pastured pig and cattle farm, we already exclude animals from waterways, and have planted vegetated filter strips above dams and on sloped areas where water flows in high rainfall periods. We keep stocking levels in balance with the ecosystem so as not to produce excess nutrient, and have never applied synthetic fertiliser.

As the primary objective of the ESO1 is to protect the quality of local waterways, the relevance to the abattoir is to ensure separation and filtration between the facility and any solid or liquid waste and two seasonal waterways: one that runs directly behind a dam in our pig paddocks and one that commences on Morgantis Road.

We propose to site the abattoir approximately 175m from the seasonal waterway on Morgantis Road (well in excess of the 30m buffer required by Clause 14.02-1S see site plan below). We have started to develop a silvi-agriculture system in the paddocks below the abattoir site already, which will host hundreds of diverse trees and shrubs in rows 25 metres apart (between which Tumpinyeri Growers are setting up their market garden beds). We chose to develop this system as part of our ongoing commitment to revegetating the landscape for health and beauty, increasing the biodiversity richness to improve ecosystem function by welcoming a broader diversity of species from soil fungi to native grasses to small birds, frogs, and micro-bats. The increased vegetation will also serve as an extra layer of filtration between the abattoir and the waterway. There is also an existing shelterbelt of oaks, blackwoods and wattles we planted nearly 10 years ago along Morgantis Road.

The North Central Catchment Management Authority (NCCMA) has reviewed the application and has ‘no objections’.

While we have long demonstrated care for the water catchment area, we note that there are no controls on chemical application in the Special Water Supply Catchment, and it is unknown how much fertiliser, pesticide, herbicide and fungicide runoff enters the water supply. Guidance from the health department simply recommends that farmers ‘prevent stock access’ to waterways, ‘use and manage nutrients wisely’ and ‘optimise agricultural chemical use’ in catchment areas[2]. Our farming practices evidence much higher ambitions than this.

Objection: Effluent from the slaughter process will be pumped to surrounding paddocks.

Effluent from the slaughter process will not be pumped onto surrounding paddocks. The miniscule volume of wastewater (that may contain wash down water, small volumes of blood, stomach contents, manure, or environmentally-sensitive cleaning liquids) will be captured in sub-surface irrigation and a septic tank. According to the land capability assessment by a qualified earth scientist, which scopes the land capability for higher use than planned:

‘The land application areas have been determined for the 9th decile wet year and satisfies the requirements of Environment Protection Regulations 2021 in that the effluent disposal systems cannot have any detrimental impact on the beneficial use of surface waters or groundwater.’

Our Environmental Management Plan (EMP) submitted to Council states:

Lairage [a.k.a. holding yards] has been designed according to Temple Grandin’s world-renowned high animal welfare designs. Effluent is washed into a holding tank, to be collected and spread on paddocks, as per Livestock Disease Control Act 1994, and EPA Publication IWRG641.1 Farm waste management.

Given the small number of animals in the holding pen on a slaughter day, this practice is the equivalent of the manure from animals grazing in a paddock on any given day being spread on a paddock to ensure it doesn’t concentrate in the yards.

Note that many local farms regularly apply fertiliser to their paddocks (in the form of raw chicken manure or synthetic nitrogen) far in excess of the small additional manure the abattoir will create through bringing in 5-20 external animals one day per week to be held for two hours in the yards.

Objection: Animal waste products will be disposed of on the property.

The abattoir will have equipment and space to ensure we can save cattle hides and edible offal for member farms, and to process intestines for sausage casings (as per AS 5011:2001). Blood will also be collected in a hygienic manner for human consumption in accordance with AS 4696:2007. This significantly reduces the volume of liquid and solid surplus nutrient for composting on site. ‘Waste’ management will be in accordance with PrimeSafe standards and relevant environmental regulation and guidance, where all waste is contained, treated and re-used on site.

All surplus nutrient will be combined with locally sourced carbon material (wood chips/sawdust and soiled cardboard). All on-farm composting occurs via in-vessel rotating drum, reaching a minimum of 55C for three days, managed in accordance with EPA guidelines and AS4454-1004. On rare occasions where composting is not suitable, surplus yield (liquid and solid) will be removed, managed, and disposed off-site to an approved rendering plant for further processing. The composted material is stored in IBCs to mature for a minimum of three months before later spreading on pasture and garden beds. Re-use of composted material is subject to soil testing and agronomic advice to ensure nutrient uptake by actively growing plants.

The solid inedible material generated per day of operation for beef is maximum 750kg[3], of which approximately 100 to 200 kg (hides) is removed from the farm for tanning, and approximately 640kg to be managed on farm. All material that is designated for tanning or rendering off-site is stored in covered bins typically until the morning after processing, and for no more than 50 hours; it is then transported directly to the tanning facility in Ballarat or a relevant rendering facility.

The solid inedible material generated per day of operation for pigs is maximum 420kg to be managed on farm.

The material managed on farm can include paunch contents, rumens, condemned tissues, and meat and fat trim. If the capacity of the on-farm surplus yield management system is insufficient to manage the material, the Collective will remove these from the farm to an approved rendering plant.

Objection: Animal transport vehicles will deteriorate an already fragile road and make dust and noise problems worse.

The abattoir is so small it will only operate at its full potential one day per week, and the farm utes who bring between 1 and 10 animals on the single slaughter day per week are small (e.g. the biggest might be a Land Cruiser pulling a 10 x 5 foot tandem trailer). There will be approximately one to three such vehicles on a slaughter day (2-4 times per month depending on the local farmers’ slaughter schedules – many do not slaughter every month).

For comparison, we regularly see much larger trucks travel Morgantis Road to properties north of us, including weekly Woolies delivery trucks and municipal waste collection trucks. Some of the lifestyle blocks on our road have recently had as many as two dozen large dump trucks with tipper trailers driving loaded up and empty down Morgantis Road for landscaping purposes several days in a row.

The facility will in fact eliminate the heavy trucks that have delivered carcasses back from the big abattoirs to our boning room for the past nine years (approximately three per month historically).

Objection: Flies, noise, and offensive odours go hand-in-hand with abattoirs.

First, we remind Council and objectors once again that ‘Abattoir’ is a Section 2 use in the Farming Zone Clause 35.07. That is, abattoirs are considered ‘rural industry’ in the planning provisions, but unlike boning rooms or dairy processing facilities, they require a permit to operate. To address Clause 35.07-6 Decision Guidelines, we have submitted an Environmental Management Plan to demonstrate the ways we will meet our responsibilities.

While abattoirs meet the aims and requirements of the Farming Zone, we know that some abattoirs (and farms) can sometimes produce noise, odours, and flies that may be objectionable or affect the amenity of neighbours. We value an aesthetically and aromatically pleasing farm, and all measures are in place to reduce potential fly breeding grounds (e.g. closed containers for the small amount of waste before it is composted). The tiny number of animals slaughtered with the highest welfare standards mean noise and odour should not be any different to a normal farm with livestock manure and normal life sounds. We want our animals and those of us who live and farm here to have a pleasant place to live.

Objection: The abattoir site is amongst a group of six (6) residential homes.

Sited in the Farming Zone (not a Residential Zone), our own home on the farm is the closest to the proposed site at approximately 50 metres away, and the other closest adjacent homes are 200 and 250m respectively. As we easily meet the separation distances required from dwellings on another property, and are in the Farming Zone, we consider this objection irrelevant.

Objection: Local properties will decrease in value

While we appreciate that property values might be adversely affected by the construction of a large-scale abattoir at the proposed site, this is not what is proposed. Details above clearly demonstrate that the facility will have negligible impact on roads, and none on water quality or neighbours’ amenity. The structure will be attractive and surrounded by market gardens and rows of diverse trees and shrubs. With its biodiversity and economic diversification, our farm is what the UN Food & Agriculture Organisation calls an ‘Agroecology Lighthouse’[4].

Jonai Farms has been featured in a number of beautiful cookbooks, on multiple shows on the ABC (including Landline and Four Corners), on Channel 10’s The Project and Channel 9’s The Living Room, and most recently on Down to Earth with Zac Efron on Netflix. We genuinely believe that we are a farming community showing the way to a liveable and joyful future, who attract more people to the region because they see the greater resilience that systems like ours provide in the face of climate change and more pandemics.

Objection: An abattoir will deter tourists who stay in local short-term accommodation.

While the objectives of the Farming Zone are not to support tourism, Hepburn Shire is a well-known tourist destination. We note that the position of objectors who want more tourists in Eganstown, which means more traffic, is in direct contradiction to concerns about increased traffic.

However, we don’t believe the minimal increased traffic due to the growing number of short-term accommodation options in the area warrants community concern. These tourists have visited our farm gate shop for many years as well, and will continue to do so when we have a new shop next to the abattoir. In fact, our popular range of agri-tourism workshops draw domestic and international tourists to the area, and their need for short-term accommodation is obviously synergistic with those who provide it.

Objection: Expert advice funded by government warns against an abattoir on this type of site.

This is a vexatious objection with no evidence to support it. It was printed on a flyer distributed in our area with an email address provided for residents to make further enquiries. When another local emailed the party, the response was as per the screenshot below:

‘Abattoir’ is a Section 2 use in the Farming Zone Clause 35.07. Not only does the Land Capability Assessment (LCA) cited above clearly demonstrate that the land is suitable for the purpose of a micro-abattoir, which thus also meets the Decision Guidelines, there are many policy frameworks and strategies at all levels of government that support the development as per below:

The Hepburn Planning Policy Framework[5] Clause 14 Natural Resource Management states that ‘Planning should ensure agricultural land is managed sustainably, while acknowledging the economic importance of agricultural production.’

The Hepburn Planning Scheme[6] aims include:

02.03-4, Agricultural land: Emerging rural industries include locally sourced produce, value added food manufacturing and related products and rural tourism

02.03-7, Rural enterprises: Hepburn Shire is a significant agricultural region and part of Melbourne’s‘ food bowl’. The region’s contribution will become of even greater importance to the State in adapting to a changing climate.

14.01-2S, Sustainable agricultural land use, strategies: Encourage diversification and value-adding of agriculture through effective agricultural production and processing, rural industry and farm-related retailing.

17.01-1S, To strengthen and diversify the economy: Improve access to jobs closer to where people live.

19.01-1S, Support energy infrastructure projects in locations that minimise land use conflicts and that take advantage of existing resources and infrastructure networks. Facilitate energy infrastructure projects that help diversify local economies and improve sustainability and social outcomes.

The Farming Zone Decision Guidelines[7] state:

The need to protect and enhance the biodiversity of the area, including the retention of vegetation and faunal habitat and the need to revegetate land including riparian buffers along waterways, gullies, ridgelines, property boundaries and saline discharge and recharge area.

We plan to plant a diverse range of trees and shrubs in concentric arcs from just beyond the facility to Morgantis Road, creating a silvi-agriculture system for holistically grazing livestock, growing grain, and a market garden. The plantings will create several benefits through increased biodiversity, habitat, shade, fodder, improved soil health, and to beautify the paddock from the perspective of Morgantis Road.

Hepburn Z-NET[8] is a collaborative partnership bringing together community groups, organisations, experts and council to shift the Hepburn Shire to zero-net energy by 2025 and zero-net emissions by 2030. As the only local slaughter facility, the Collective will significantly reduce greenhouse gas emissions with drastically shorter driving times for several farms, with the important additional benefit of less stress for animals transported shorter distances to slaughter (or in the case of our animals, not transported at all). The facility will be on standalone solar and use waste vegie oil to heat water, creating a further significant reduction in fossil fuel reliance.

The Sustainable Hepburn Strategy[9] advocates themes for ‘beyond zero emissions,’ ‘biodiversity and natural environment,’ ‘low waste,’ and ‘climate resilience,’, all of which the Collective’s development will promote and progress.

Alignment with Victorian Policy

Victoria’s new 10-year Strategy for Agriculture[10] emphasises building resilience including to our changing climate. It is structured around the following [relevant] themes:

Recover from the impacts of drought, bushfires and the coronavirus (COVID-19) pandemic and become an engine of growth for the rest of the economy. Including a commitment to: Support farmers with information and tools to build resilience.

Protect and enhance the future of agriculture by ensuring it is well-placed to respond to climate change, pests, weeds, disease and increased resource scarcity. Including a commitment to: Ensure Victorian agriculture is well placed to manage climate risk and continues to be productive and profitable under a changed climate.

The Victorian Animal Welfare Action Plan’s[11] vision is for ‘A Victoria that fosters the caring and respectful treatment of animals.’ It has explicit aims to ensure that ‘the market has confidence in Victoria for ethical and responsible animal production.’ Jonai Farms and our Collective member farms put animal welfare first in all production choices – all livestock are pasture-raised on grass and enjoy the ‘five freedoms of animal welfare’:

Freedom from hunger and thirst: by ready access to fresh water and a diet to maintain full health and vigour.
Freedom from discomfort: by providing an appropriate environment including shelter and a comfortable resting area.
Freedom from pain, injury or disease: by prevention through rapid diagnosis and treatment.
Freedom to express normal behaviour: by providing sufficient space, proper facilities and company of the animal’s own kind.
Freedom from fear and distress: by ensuring conditions and treatment which avoid mental suffering.

The Collective Abattoir will strengthen all farms’ capacity to ensure animals are free from the discomfort of long transport and waiting times at distant abattoirs, and from the fear and distress associated with those activities and environments.

The North Central Victoria Regional Sustainable Agriculture Strategy[12] is a high level strategy that suggests moving towards greater adoption of sustainable agriculture that will require land managers to collectively reconsider current practices.

The North Central Regional Catchment Strategy[13] priority directions include: ‘Continue to increase the uptake of sustainable agricultural practices through implementation of the Regional Sustainable Agriculture Strategy, Soil Health Action Plan and Land and Water Management Plan for the Loddon Campaspe Irrigation Region (LCIR).’ The Collective not only is proposed to support our own sustainable agricultural practices, but also a dozen other local sustainable farms, and deepen all of our sustainable practices through reduced emissions.

The Recycling Victoria: A new economy[14] policy and action plan for waste and recycling includes the following priorities:

Invest in priority infrastructure: Victoria will have the right infrastructure to support increased recycling, respond to new bans on waste export and safely manage hazardous waste.
Provide support for local communities and councils: A new Supporting Victorian Communities and Councils program will support regional growth and community connectivity
Reducing business waste: A new Circular Economy Business Innovation Centre will help businesses reduce waste and generate more value with fewer resources.
The Collective’s nose to tail and paddock to paddock approach will minimise potential waste, and recycle nutrients on the farm through the use of the in-vessel composting drum, creating a healthy circular bioeconomy.

Finally, a 2019 report by the High Level Panel of Experts on Food Security and Nutrition of the UN Committee on World Food Security, Agroecological and other innovative approaches for sustainable agriculture and food systems that enhance food security and nutrition[15], recommends:

adapting support to encourage local food producers, food enterprises and communities to build recycling systems by supporting the reuse of animal waste, crop residue and food processing waste in forms such as animal feed, compost, biogas and mulch. (p.22)

[1] Grandin, T. 2020. Behavioural Principles of Stockmanship and Abattoir Facility Design, CAB International.

[2] https://www.health.vic.gov.au/water/protecting-water-catchments

[3] Co-products Compendium, MLA, 2009.

[4] https://www.fao.org/agroecology/database/detail/en/c/1457735/

[5] https://www.hepburn.vic.gov.au/files/assets/public/building-amp-planning/documents/c80hepb-panel-report.pdf

[6] https://www.hepburn.vic.gov.au/Planning-building/Strategic-planning/Hepburn-Planning-Scheme

[7] https://www.planning.vic.gov.au/__data/assets/pdf_file/0028/8497/35_07-Farming-Zone-Greyhound-consultation-August-2016.pdf

[8] https://hepburnznet.org.au/

[9] https://participate.hepburn.vic.gov.au/sustainable-hepburn

[10] https://agriculture.vic.gov.au/about/agriculture-strategy

[11] https://agriculture.vic.gov.au/livestock-and-animals/animal-welfare-victoria/animal-welfare/animal-welfare-action-plan

[12] https://www.nccma.vic.gov.au/resources/publications/north-central-victoria-regional-sustainable-agriculture-strategy