Don’t be fooled. Burning forest biomass is not a renewable energy source.

Don’t be fooled. Burning forest biomass is not a renewable energy source.

When a native forest is logged there is quite a large quantity of material remaining, and the previous federal government took the view that the burning of such material to generate electricity should be regarded as using a renewable energy source. 

When a power station uses a renewable energy source to generate electricity it receives a thing called a Large-scale Generation Certificate (LSGC).  

Ever since the use of forest biomass was allowed as a renewable energy source the issue has been controversial. 

The present federal government recently sought submissions from the public on the issue of the use of native forest biomass to produce renewable energy and the eligibility of power stations generating electricity from native forest biomass to create LGC’s through the Renewable Energy Target (RET). It asked for comment on a number of specific questions.

Submissions were not sought on the issue of whether native forest logging itself should be permitted.

The Gloucester Environment Group sent a submission to the Government as follows:

GLOUCESTER ENVIRONMENT GROUP (GEG) SUBMISSION

In answer to the Government’s specific questions for consultation –

Should the eligibility of native forest biomass be removed?

Yes.

Native Forest Biomass should not be viewed as a “renewable resource”. The burning of native forest biomass undermines both Australia’s climate goals and the biodiversity of our native forests.

If it should be retained, do the REE Regulations adequately ensure, and provide the public confidence, that electricity generation from native forest biomass is from ecologically sustainable sources?

No.

The recently published research Paper “Burning Forest Biomass for Energy” advises “a major shift to using forest biomass burning for energy comes with grave risks of highly perverse outcomes, including increased CO2 emissions and negative impacts on forest ecosystem integrity”.

There is an urgent need to regenerate what is left of our native forests. Our natural environment is in crisis. Biomass after felling provides habitat for fauna, retains sediment, protects water quality, and stabilises soil fertility.  

Native forests serve great environmental benefits in terms of carbon sequestration and protection of ecosystems. Logging debris from native forests should not be removed.

At the time of writing this submission, a petition has been presented to the NSW State Parliament, signed by over 20,000 citizens, that seeks to (amongst other demands) ban the use of native forest materials as biomass fuel.

If it should be retained, how could the RET Regulations be amended to provide greater certainty and public confidence that native forest biomass comes from ecologically sustainable sources?

GEG opposes the forest biomass industry in any form in Australia. The industry is not ecologically sustainable.

How many times has Government (State or Federal) had to address and intervene with environmental and social breaches by industry, after the community has brought that particular breach to their attention?  Time and again we see vested, polluting industries flouting their conditions of consent. The cost to the community is huge.  This must change.

GEG is well aware that proponents for major infrastructure projects present business models that are supposedly “good for the community”.  The nature of “commercial in confidence” meetings with the government, which exclude the community’s consideration of the proponent’s contractual arrangements, restricts open transparency of the proponent’s project, effectively denying community participation in decision making. This must change.

The consultation paper notes, one power station has “sought and received accreditation”. Our concern is that the Government is currently relying on the power station operator to self-regulate, and that the biomass industry as a whole has the same expectation. 

If native forest biomass should be retained in the RET, the Government must categorically show, based on independent and scientifically sound judgement, that the burning of forest biomass reduces carbon emissions, that environmental offsets can be guaranteed and that the establishment of standards and guidelines can be regulated independently of industry representation.  

Are there proposals for new native forest biomass power stations that are likely to be eligible under the RET and have potential adverse impacts?

The consultation paper notes,  Sub regulation (2) only imposes the condition that native forest biomass cannot be primarily harvested for use in energy production, not that logging and timber industries associated with the collection of forest biomass will be restricted. Last year, Justin Field, NSW MP, stated in the NSW Parliament that there are “increasing efforts” to open up NSW’s forests for energy production.

If the Government removes the eligibility of native forest biomass under the RET, what transitional provisions could provide appropriate support to affected registered power stations?

The consultation paper notes the Government wishes to limit any impact on existing projects proportionate to relevant costs, benefits, risks and opportunities.

However, the external, unqualified costs of the industry to the community include, social and health impacts from burning fuel, environmental impacts, transportation, and contribution to greenhouse gas emissions at a time of climate emergency.  

The consultation paper notes, only one co-generation power station is currently accredited to use native forest biomass and does not use native forest biomass to create LGCs.

We see little need for a transition plan for a native forest biomass industry that is not economically viable without Government subsidies and incentives and that is not currently well established.

We do see the need for the Government to legislate against the potential expansion of the native forest logging industry which enables the progression a native forest biomass industry.

Conclusion

GEG maintains that any power station that relies on native forest biomass will cause environmental harm and therefore should not be eligible under the RET.

GEG also recognises the real threat that the use of biomass may encourage the expansion of logging in native forests.

GEG supports the disqualification of native forest biomass as an eligible fuel source for renewable energy credits under the Renewable Energy Target legislation.

John Watts

President Gloucester
Environment Group.