SUBMISSION - Burning Native Forest for Power - Due 13 Feb 2009

Renewable Energy Target Scheme – Exposure Draft Legislation

Submissions required to prohibit burning native forests for power

Due 13th February 2009


In 2001 the Australian Government introduced a Mandatory Renewable Energy Target (MRET) scheme. The scheme aims to increase the uptake of renewable energy in Australia's electricity supply.

To deliver on this commitment, the Government is working in cooperation with the states and territories through the Council of Australian Governments (COAG), to implement an expanded national Renewable Energy Target (RET) that will bring the MRET and existing and proposed state and territory targets into a single national RET scheme.

In July 2008, to inform design of the RET scheme, the COAG Working Group on Climate Change and Water released a consultation paper on the key design issues.

Exposure draft legislation on the design of the Renewable Energy Target scheme has been released for public comment. This exposure draft legislation reflects the design being considered by the COAG Working Group Climate Change and Water.

Comments on the draft legislation are due by 13 February 2009:

Send to:

The Director
Renewable Electricity Markets Team
Department of Climate Change
GPO Box 854
Fax 02 6274 2970

Inclusion of Native forest biomass in Draft Legislation

It is planned that the federal Mandatory Renewable Energy Target (MRET) scheme will replace previously introduced state based schemes. In Victoria, for instance, the Victorian Renewable Energy Scheme (VRET), which has reasonably strong disincentives for native forest biomass to be burned, can be abolished without the legislation being taken back to parliament.

In relation to native forest biomass, the draft legislation remains the same as previous federal legislation. Whilst this sounds inconsequential, with the abolishment of state based schemes which have tighter requirements, state based restrictions are weakened. The generation of electricity from burning native forest biomass would be eligible for Renewable Energy Certificates (RECs), despite some rather ambiguous and weak prescriptions.

In various locations around the country, several forest furnace proponents have plans in place which would rely on the MRET legislation to allow native forests biomass to be included as an eligible resource. It is crucial that we make it clear that this is abjectly opposed by the broader community.

Points to make in your submissions:

· Section 17 of the Renewable Energy (Electricity) Act 2000 must be altered to prohibit the use of native forest biomass as an eligible renewable energy source.

· Native forest biomass is not ‘waste’. The key driver behind native forest logging is pulplog production, mainly for woodchips, not sawlogs. In Victoria, 85% of native forest logging ends up as woodchips, waste and sawdust. In a recent parliamentary inquiry, VicForests, the state government agency responsible for commercial sales of Victoria’s native forests, admitted that the industry has been traditionally based on sawlogs, and more recently, on pulplogs. In Tasmania, over 90% of native forest logged ends up as woodchips.

· Logging native forests emits massive greenhouse gas emissions. Recent science from the Australian National University (ANU)[1] has shown that our forests are much more carbon rich than previously estimated. Logging and burning of native forests produces massive greenhouse gas (GHG) emissions and one of the most efficient and cost effective ways of reducing carbon emissions is to protect and restore native forests and natural ecosystems. Inclusion of native forest biomass in the Act will only increase the pressure to log native forests and increase the GHG emissions from them.

· Scientific evidence proves native forests are carbon sinks that continue to sequester carbon for up to 800 years. Research published in Nature[2] “found that old-growth forests accumulate carbon for centuries and contain large quantities of it. We expect, however, that much of this carbon, even soil carbon, will move back to the atmosphere if these forests are disturbed.” Scientific evidence is now clear, native forests should not be disturbed by logging due to the huge amount of carbon they store and the ongoing role they play in sequestering carbon. MRET legislation must be updated to reflect the latest scientific evidence.

· Current logging practices are not ecologically renewable. Clearfell logging does not mimic natural disturbance processes and hundreds of thousands of hectares of native forests have been turned into young re-growth forests which will be logged again prior to ever reaching the ecological maturity of pre-logged levels. Many forests are not even regenerating successfully and therefore clearly not being “renewed”.

· The market needs to receive clear signals to guide investment in truly renewable industries. Not only does the inclusion of native forest biomass have huge GHG emissions and biodiversity impacts, it allows subsidised native forest logging to compete on a non-level playing field with emerging, value added renewable technologies.

· Native forest biomass should not be eligible as a renewable energy source as it compromises the intent of the Renewable Energy Act. The emergence of the renewable energy sector is critical to reducing our reliance on fossil fuels, and it cannot be contaminated with native forest biomass.

· Burning forests will increase pollution and levels of dangerous particulates in the atmosphere. Wood smoke and particulates are recognised as major threats to human health.

· The MRET legislation should be brought in line with the current nationally recognised and accredited “GreenPower” program which prohibits outright the use of native forest biomass in green energy programs.

The renewable energy targets are too low. They need to be massively increased to ensure at least 40% of Australia’s energy comes from renewable energy sources by 2020.

Additional points, not related to native forest biomass:

* Individuals and groups should propose whatever they desire – 100% is the latest call from the Climate Conference in Canberra.
* Renewable energy targets need to be increased to ensure that the business community is given clear incentive to invest billions of dollars in truly renewable energy generation, creating tens of thousands of jobs in the industry
* Electricity-intensive, trade-exposed companies should not receive preferential treatment or compensation. Many of them already receive extremely generous tax benefits and electricity subsidies from both state and federal governments.

[1] Mackey, B G., Keith, H., Berry, S L., Lindenmayer, D B. (2008) Green Carbon: the role of natural forests in carbon storage. Part 1, A green carbon account of Australia’s south-eastern Eucalypt forest, and policy implications. ANU Press

[2] Luyssaert, S. (September 2008) Old-growth forests as global carbon sinks. Nature 455, 213-215

For further info contact:

Geraldine Ryan
The Wilderness Society Victoria Inc
Ph 9038 0888

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