11 February 2009
The Director
Renewable Electricity Markets Team
Department of Climate Change
GPO Box 854
CANBERRA ACT 2601
Email RET@climatechange.gov.au

Submission on the exclusion of native forest biomass from the Mandatory       
Renewable Energy Target (MRET) Scheme – Exposure Draft Legislatio

Inclusion of native forests as an eligible energy source within the Renewable Energy (Electricity) Act 2000 is of major concern to the Coastwatchers Association.  All biomass feedstocks derived from native forests should be added to the list of energy sources that are NOT eligible renewable energy sources in Section 17 (2) of the Act. This amendment must also be added to the Renewable Energy (Electricity) Amendment Bill 2008.
Coastwatchers considers that native forests should be excluded from any MRET scheme for the following reasons:

• Scientific and public opinion is moving to support the call for deep, rapid cuts in emissions in order to avoid catastrophic climate change. Given the urgency, any flaws in relevant legislation will seriously damage efforts to combat climate change. They will also significantly undermine community support and confidence in government efforts to reduce emissions.

• One of the most efficient and cost effective ways of reducing carbon emissions is to protect and restore native forests and natural ecosystems. Scientific evidence shows that native forests should not be disturbed by logging because of the huge amount of carbon they store and the ongoing role they play in sequestering carbon.  A recent study by Australian National University (ANU) scientists (1) has shown that Australian forests are much more carbon rich than previously estimated. Research published in Nature (2) also found that native forests are carbon sinks which continue to sequester carbon for up to 800 years.

• MRET legislation must be updated to reflect this latest scientific evidence.

(1) Mackey, B.G., Keith, H., Berry, S.L., Lindenmayer, D.A.  (2008)  Green Carbon: the role of natural forests I carbon storage. Part 1, A green carbon account of Australia’s south-eastern Eucalypt forest, and policy implications. ANU Press, Canberra.  Accessed from http://epress.anu.edu.au/green_carbon/pdf/whole_book.pdf on 3.02.2009.

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

• Industry claims regarding the carbon neutral status of logging native forests are based on flawed accounting methodologies.  They exclude emissions from forests which existed prior to 1 January 1990 but include emissions uptake from young, managed forests and plantations. When full carbon accounting is applied, emissions from logging mature and regrowth native forests far outweigh the uptake of carbon dioxide.

• Inclusion of native forest biomass in the Act will only increase the pressure to log native forests.The main driver behind native forest logging has been pulp log production, mainly for woodchips, not sawlogs. Across Australia more than 80% of logs are used for woodchips. Now the forestry industry needs to seek new markets and subsidies in order to support a native forest woodchipping industry threatened by changes in market (particularly in Japan) and consumer demand;  a lower social approval rate  and recent market downturns (3). The industry, represented by organisations such as the National Association of Forest Industries, is attempting to use the 2008 Amendment to remove legislative impediments to native forest fired power generation.

• Logging practices are not ecologically renewable. Current extraction is severely impacting on the biodiversity, hydrological and other ecosystem values of our forests. Increased extraction of wood from native forests, either through expanded logging or increased extraction volumes would cause even greater damage.

• Public dissatisfaction is apparent in the controversy over native forest fired power generation. There has been widespread public opposition to previous and current power station proposals. (eg Raymond Terrace, Southwood, Eden, Manjimup etc.)  (4)(5)

• MRET legislation should be brought in line with current nationally recognised and accredited “GreenPower” programs which do not allow the use of native forest biomass in green energy programs. Its rejection by energy retailers and the exclusion of native forests from the Victorian and NSW RET schemes is recognition of the perverse environmental outcomes that result from native forest fired power generation.

• Native forest biomass should not be eligible as a renewable energy source as it compromises the intention of the Renewable Energy Act. The legislation as is currently stands creates unfair competitive advantages over truly renewable sources, thus undermining the aims of the scheme.

• This legislation in its current form will extend the survival of an ailing, unsustainable, heavily subsidised and widely unpopular native forest industrial logging and woodchipping industry. Any measures which allow the industry to continue in its current form will continue to have immense negative impacts on Australia’s native forests and their value to us.

(3) NAFI (2008). Submission To COAG Working Group on Climate Change and Water On Design Options for the Expanded National Renewable Energy Target Scheme. Association of Forest Industries, Australia.

(4) ABC (2008) Primary producers oppose Manjimup biomass power plant. ABC Online. Accessed from http://www.abc.net.au/news/stories/2008/07/21/2309296.htm on 3.02.2009.

(5) Cubby, B. (2009). “Blow for Energy Proposal”.  Sydney Morning Herald.
Accessed from http://www.smh.com.au/articles/2009/02/02/1233423135554.html on 3.02.2009.

The South Coast of NSW, which is the base for Coastwatchers Association, is blessed with extensive public and private forested lands. We see these forests as an important tool in the international fight against human induced climate change.

This association cannot underestimate the importance to Australia, the economic, environmental and social sustainability of society and our responsibility to future generations, of having a robust system of accounting for carbon use. Putting more carbon into the atmosphere via the burning of wood for electricity generation is repeating the mistakes of the industrial era. We strongly urge the Australian Government exclude the burning of native forests for electricity from the MRET scheme.

Yours Sincerely

Mark Fleming (President)