Sender: Australian Forests and Climate Alliance
Date: 30/09/2015 03:15 PM
To: <renewable.energy@ecodev.vic.gov.au>
Submission to the Victorian
Renewable Energy Roadmap
The Australian Forests and Climate Alliance welcomes the opportunity to have input into this
initiative. We represent many groups across the country and have a substantial number of
members in Victoria.
We welcome any progressive move towards a genuine renewable energy industry in this
state, however we are concerned to see mention made of a biomass option within the state’s
renewable energy mix.
On page 8 of Victoria’s Renewable Energy Roadmap August 2015:
The document states on page 17:
“The Government is also participating in the Australian Biomass for Bioenergy Assessment
project, funded by ARENA. The project aims to catalyse investment in the renewable energy
sector by providing detailed information about biomass resources across Australia. This will
assist in project development and decision making for new bioenergy projects”
And
“Victoria has a comparative advantage in bioenergy as it has a diverse range of secure and
stable supplies of biomass feedstock available which are capable of being readily utilised for
energy production. A range of bioenergy generators currently operate in Victoria, using fuel
sources such as agriculture, urban and industrial waste. These generators range from microscale at locations such as small farms to large-scale at industrial facilities”.
Given the definition of burning native forest wood as ‘renewable energy’ under the Federal
Government’s RET legislation earlier this year we are extremely opposed to any moves by
more progressive state governments to encourage this use of forests. It would be perverse in
the extreme to be using the country’s best carbon stores to increase air pollution for
electricity which should left to the clean renewable technologies now available.
Please find attached our arguments against using forests for power generation.
Regards,
Lorraine Bower
Convenor
Australian Forests and Climate Alliance
ATTACHMENT: TEN GOOD REASONS TO REJECT
THE INCLUSION OF NATIVE FOREST BIOMASS IN
THE RENEWABLE ENERGY TARGET
1. If the senate allows the inclusion of ‘waste’ from native
forest logging as a biomass fuel for biomass power in the
RET, whole trees will be burnt for electricity in furnaces.
The Australian Forest Products Association (AFPA) stated in the 2009 submission to the
National Energy Policy Framework: 'wherever forests are managed under Commonwealth
and/or State forest management regulations, the products of any harvesting operation
should be eligible to produce renewable energy under the Expanded National Renewable
Energy Target Scheme’.
The native forest logging industry will be using whole trees as biomass fuel for biomass
power generation, rather than offcuts and residues from the forest floor, which it would be
uneconomic to do1. The mechanised infrastructure allowing residues from the forest floor to
be extracted economically is not available, and the cost of manual extraction would be
prohibitive.
Figure 1. The 7 storey high mountain of woodchips at Nippon's export woodchip mill, Eden
NSW.
The logging industry definition of ‘waste’ is crucial to the understanding of what is an eligible
biomass fuel for subsidisation as biomass power. AFPA has consistently adopted the
definition of ‘waste’ as any tree that is not suitable for sawlogging. In many places that
would apply to 90% of all logs taken out of forests.
The NSW Eden chipmill has operated on this basis for 40 years. It was set up to use the
‘waste’ from sawlogging but has only ever used whole logs to make export woodchips –
consuming up to a million tonnes of trees a year.
2. Logging will inevitably increase if native forest wood is
1
Already Australian state governments have commenced the re-definition of ‘biomass’ as eligible for
consideration as a renewable and in NSW the government’s definition includes any form of a native forest
harvested under an Integrated Forestry Operations Approval and not required to be sold as a sawlog. This redefinition of native forest biomass in displayed clearly on the NSW EPA website.
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included in the RET as a legitimate biomass fuel.
Using native forest wood as a biomass fuel for biomass power is extremely inefficient. A lot of
wood is needed to make a small amount of electricity. Biomass power plants require ongoing large amounts of wood for the biomass fuel. This will place increasing pressure on
native forests to provide the biomass fuel regardless of any other environmental outcomes.
Figure 2. Maryvale Pulp and Paper Mill
The native forest logging industry is now in decline for a number of reasons, including poor
management of public native forests, a preference of overseas buyers for higher levels of
certification than it can provide, and the availability of cheaper exports from other countries.
The industry views the biomass power industry as a lifeline – a way that it can keep logging
native forests, despite the massive degradation and destruction that unsustainable native
forest logging has caused. This is a time when forestry should be switching to 100%
plantations for all Australia’s logging needs and protecting native forests for climate, water
and wildlife, not ramping up native forest destruction.
3
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3. Bushfire Mitigation Programs will drive more forest
destruction
The logging industry has been lobbying hard to be able to log native forests under the guise
of ‘bushfire mitigation’, to supply biomass fuel for electricity.
There is now a three year trial in Victoria which will be co-ordinated by forestry agencies and
the Australian Forest Products Association. If this is expanded, yet more government
subsidies will be needed for the logging industry to access areas of public forest previously
out-of-bounds.
There is an increasing body of science and research which questions the burning of large
areas of native vegetation as an effective means of bushfire mitigation. Management
burning is changing the composition of the forests. Thick young regrowth from logged
forests ignite more easily, burn more severely and the fires are harder to control2. The
Victorian fires showed unlogged natural forests have natural ‘fire-proofing’ qualities.
Once our public forests (and National Parks?) become a resource for the electricity industry,
it could become an unstoppable monster, similar to the woodchip industry.
4. Deforestation facts: The logging and burning of native
forests results in enormous CO2 emissions.
The purpose of the Renewable Energy Target is to encourage the reduction of greenhouse
gas emissions, yet burning native forest biomass for electricity generation is contrary to this
purpose as it involves major depletion of forest carbon stocks3. Burning wood biomass is far
from renewable. Most estimates consider it at least 1.5 times more carbon emissive than
burning coal and some estimates consider it 6 times more emissive45.
Figure 3. The massive pulse of carbon into the atmosphere as part of logging management
burns cannot be recaptured for hundreds of years.
The claim that biomass burning of native forest wood is carbon neutral seems to be based on
the idea that when trees grow they reabsorb the carbon that is lost in logging and chipping.
2
http://www.abc.net.au/news/2014-08-04/logging-greatly-increases-fire-risk-black-saturday:-study/5646220
3Re-evaluation of forest biomass carbon stocks and lessons from the world's most carbon-dense forests.
Heather Keith, Brendan G. Mackey and David B. Lindenmayer, Proceedings of the National Academy of Sciences
of the United States of America, vol. 106 no. 28, March 2009 http://www.pnas.org/content/106/28/11635.full
4
http://www.biofuelwatch.org.uk/resources-on-biomass/
"Dirtier than coal?" published by RSPB, Friends of the Earth and Greenpeace.
http://www.rspb.org.uk/Images/biomass_report_tcm9-326672.pdf
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http://globalforestcoalition.org/wp-content/uploads/2010/06/REPORT-WOOD-BASED-BIOENERGY-FINAL.pdf
3
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This may be possible over decades or perhaps hundreds of years, if trees are left to grow,
but it would take much longer than the time we have to address climate change6. In
Australia, logging regimes are far shorter than the time needed for the carbon in trees to
replace itself7.
In addition to the initial huge CO2 emission when the forest is first cut, calculations of
additional greenhouse gasses must include the loss of soil carbon, the massive output in the
post logging site burn, emissions to transport the ‘biomass’ to furnace or processing centre,
emissions created by processing ‘biomass’ to a form suitable for furnace, or for conversion to
a form suitable for transport around Australia or to export overseas must be factored in. No
accurate carbon accounting has taken place in relation to the use of native forest biomass as
an energy source.
Until this occurs no meaningful assessment of the benefits of utilising native (or any other
forest) biomass to reduce climate change impact is possible.
Protecting Australia’s native forests would reduce emissions by tens of millions of tonnes of
carbon per year8. The Climate Commission 2011 report. ‘The Critical Decade’ recognises the
need to protect native forests immediately as a key climate change mitigation strategy9.
5. Biomass burning for energy will mean increased industry
subsidies for an industry that is already heavily subsidized
by taxpayers
The Australian native forest logging industry has historically required large taxpayer subsidies
(Resources Assessment Commission report) and there is no indication that a native forest
biomass industry would be able to stand on its own without government support. The
logging industry in every state is propped up by millions of taxpayer dollars every year and
could be the most ‘entitled’ industry in the country.
US biomass plants using forest 'waste' are inevitably subsidised by taxpayer dollars. There is
a large and growing opposition to the inclusion of this form of power on that government's
list of renewable energy sources10. Opposition is also significant in all overseas countries
which use biomass electricity.
6. Burning native forests for energy produces toxins injurious
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In terms of emission control that is needed now, critically and urgently, native forest trees reach maturity and
maximum carbon storage potential after 150-180 years of growth. Logging rotations of 5, 25, or at best 50 will
not permit maximum carbon uptake from forests and will result in an ever increasing carbon debt. According to
Judith Ajani, Economist, Fenner School at Australian National University, “Logging native forests for energy is
climate negative for virtually the entire logging cycle. Furthermore, the emissions from enacting this scenario
today would max out over the next ten to 20 years: a critical time in our climate challenge.”
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Judith Ajani, Economist, Fenner School at Australian National University, again argues the case against native
forest biomass as carbon neutral in the short or even immediate term: “If we log a 60-year-old stand of native
forest for energy production today, the carbon emissions from logging will occur soon after. The forest will not
regrow enough to return to today’s carbon stock level until 2070. It took this long to grow: it takes this long to
replace.” Compound this with the emissions in transport and processing and it is unlikely to ever be a carbon
neutral energy source.
8
8Green Carbon Part 1' ... role of natural forests in carbon storage. Brendan Mackey, Heather Keith, Sandra L.
Berry and David B. Lindenmayer. ANU Press, August 2008.
9
The Critical Decade” Garnaut, R, 2011.
10
http://www.pfpi.net/trees-trash-and-toxics-how-biomass-energy-has-become-the-new-coal
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to human health and are more polluting than coal per unit of
energy
Burning native forest wood releases toxins harmful to the health of nearby communities.
Wood dust is a known carcinogen and exposure is associated with skin disease, increased
asthma, chronic bronchitis and nasal problems.
Figure 4: Anderson biomass plant, USA
Biomass plants are dirty because they are markedly inefficient. Per megawatt-hour, a
biomass power plant employing “best available control technology” (BACT) emits more
nitrogen oxides, volatile organic compounds, particulate matter, and carbon monoxide than a
modern coal plant of the same size11. The American Lung Association has strongly opposed
the use of wood 'waste' in the US renewable energy scheme12. The available data now
established and documented regarding the hazards of using biomass power to nearby
communities will leave the federal and state governments open to legal challenges by
individuals affected by these toxins.
7. The example of European forests does not apply in Australia
The Australian Forest Products Association argues that Australia should follow Europe’s
example in burning more forest biomass. Most European forests are plantations, not natural
forest. AFPA ignores this fundamental difference, the different geographies, climates, water
supplies, and the industry economics involved. It ignores also a large and growing US
backlash against European imports of logs and pellets leading to forest destruction across
large swathes of the US forest resource.
8. Australia does not need this form of energy and it will
provide disincentives for real renewables.
Energy requirements have been reducing as the uptake of solar grows. Renewable energy
targets can be more than met by wind, solar and other genuinely renewable energy sources.
If burning what some see as the ‘lungs of our land’ can be termed renewable, it would take
credits and assistance from the genuine renewables industry. If all the native forest log
production in 2009 in Australia had been burned for electricity it would have
displaced only 2.8% of total black and brown based power generation13.
9. Deforestation facts: Our public native forests can sustain no
further assault, either for biomass burning or for continued
11
http://www.pfpi.net/trees-trash-and-toxics-how-biomass-energy-has-become-the-new-coal.
Charles D. Connor. President & CEO. American Lung Association. Letter to United States House of
Representatives. June 24, 2009., Massachusetts Medical Society Adopts Policy Opposing Biomass Power Plants”
December 9, 2009. http://www.massmed.org/AM/Template.cfm?
\http://www.pfpi.net/american-lung-association-energy-policy-opposes-biomass-combustion-for-heat-andpower
13
Ajani J 2011 <http://www.youtube.com/watch?v=zwnZwJhUpm0>
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unsustainable logging regimes.
Australian forests have been overcut for decades to meet unrealistic supply contracts. In
northern NSW for instance, there are so few sawlogs left that the state government has
regularly paid compensation to Boral for inability to meet contracts. In the south the
industry has admitted that they have virtually run out of sawlogs. The NSW AuditorGeneral’s report in 2011 clearly stated that trees are being logged faster than they can grow.
This is the picture in Victoria, WA and Tasmania as well. Multiple reports and documents
support this statement, such as One Stop Chop: How Regional Forest Agreements
Streamline Environmental Destruction14.
Figure 6. East Gippsland Victoria
Australia now faces a wildlife crisis in many regions, and loss of habitat from logging is a
major cause. Throughout the country logging is contributing general environmental
degradation of vast tracts for native forest, water yields from catchments and rain-making
capacity.
Figure 5. Styx Valley Tasmania
Now is the time to switch to 100% plantations for all of Australia’s timber needs and let our
native forests rest and regenerate.
10. It would have poor employment outcomes and the
majority of Australians don’t want it
The native forest biomass power industry would be a very small employer. For instance, the
proposed 5MW biomass power station in Eden using native forest wood would have
employed 6 people. The Eden Chipmill itself employs less than 40 workers.
Australia has the capacity to power the whole energy sector with real renewables like solar
and wind15, and the jobs of the future are in the renewables sector, which has languished
under the current federal government.
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15
http://www.edovic.org.au/blog/RFA-report
http://theconversation.com/renewable-energy-target-can-go-all-the-way-to-100-if-we-let-it-26318
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The majority of Australians have historically opposed native forest biomass energy. A 2001
Morgan Poll found that 88% of people opposed the use of native forest for wood-fired
power. A follow up Galaxy poll in 2010 revealed that 77% of Australians want an end to the
logging of Australia’s native forests in order to conserve their carbon stores.
A 2015 poll conducted by the Wilderness Society showed that many voters in key Liberal
marginal seats of Corangamite and Eden Monaro, both with large forestry areas, did not
support the burning of native forests for electricity16.
For a developed nation to now go backwards 150 years to the beginning of the industrial era
and burn forests for energy production is absurd. Our incomparable public native forests are
more valuable for their contribution to climate change mitigation, for carbon capture and
storage of carbon stocks, protecting soil from erosion and for clean reliable water supplies,
than as fuel for a furnace to generate electricity we don’t need.
Our elected representatives must start work on a strategy for moving out of industrial native
forest logging completely, and into the profitable plantation sector, where the future of the
industry lies. Real renewable energy produced by solar, wind, geothermal and tidal power is
the way of the future, and the sector that will produce the energy jobs of the future.
16
http://www.theaustralian.com.au/national-affairs/climate/forest-waste-in-the-ret-is-burning-votes/storye6frg6xf-1227355660838
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Central West, NSW
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South East Forests NSW
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