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 forestmanagement 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 do. 1The 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 NSWThe 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 included in the RET as a legitimate biomass fuel.

Figure 2. Woodchips have driven the logging of native forests for decades. Maryvale pulp and paper mill in Victoria.
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 on-going 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.
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. 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 control.2 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 stocks.3 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 emissive.4 5

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. 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 change.6 In Australia, logging regimes are far shorter than the time needed for the carbon in trees to replace itself.7
Figure 3. The massive pulse of carbon into the atmosphere as part of logging management burns cannot be recaptured for hundreds of years.
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 strategy.9

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 sources.10 Opposition is also significant in all overseas countries which use biomass electricity.

6. Burning native forests for energy produces toxins injurious 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 USABiomass 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 size.11 The American Lung Association has strongly opposed the use of wood ‘waste’ in the US renewable energy scheme.12 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 generation (Ajani, 2011).

9. Deforestation facts: Our public native forests can sustain no further assault, either for biomass burning or for continued unsustainable logging regimes.

Figure 6. East Gippsland VictoriaAustralian 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 Auditor-General’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 Destruction.13
Figure 5.  Styx Valley  TasmaniaAustralia 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.
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 avery 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 andwind,14and the jobs of the future are in the renewables sector, which has languished under the current federal government.
dont toast native wildlifeThe majority of Australians have historically opposed native forest biomass energy. A 2001 Morgan Poll found that 88% of people opposedthe 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.
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.

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 re-definition of native forest biomass in displayed clearly on the NSW EPA website.

2 http://www.abc.net.au/news/2014-08-04/logging-greatly-increases-fire-risk-black-saturday-study/5646220

3 Re-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.


5 http://globalforestcoalition.org/wp-content/uploads/2010/06/REPORT-WOOD-BASED-BIOENERGY-FINAL.pdf

 6 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.”

7 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 Green 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

11 http://www.pfpi.net/trees-trash-and-toxics-how-biomass-energy-has-become-the-new-coal

12 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?


13 http://www.edovic.org.au/blog/RFA-report

14 http://theconversation.com/renewable-energy-target-can-go-all-the-way-to-100-if-we-let-it-26318

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