October 2022 Opportunity!

Our chance to knock off a destructive industry before it takes hold!

The Commonwealth Government is consulting about whether to remove native forest wood/biomass as an eligible fuel for burning for renewable energy generation.

Here is our chance to say : Burning Native Forest Wood for Electricity is Not Green, Not Clean and Not Renewable.

Submissions close 5pm October 21.

Please make a submission in your own words - even a paragraph or two - stating: Electricity generated by burning wood from native forests must be prohibited from being eligible for Large-scale Generation Certificates (LGCs) under the Renewable Energy Target (RET).

This link takes you to the consultation paper, and the online form where you can have your say. https://consult.industry.gov.au/native-forest-biomass-in-the-ret

See the Submission Guide below for some dot points you might want to include.

Why Burning Forest Wood as a Coal Substitute is Not Clean, Green or Renewable.

Submission Guide

October 2022

Please spend a few minutes of your time to save our forests and our climate by convincing the Federal Government to stop counting burning forests as renewable electricity, to replace coal and displace solar and wind.

In this climate and extinction emergency we need our forests standing so that, over time, their habitat values and carbon storage can increase, rather that allowing them to be cleared and clearfelled to be burnt for electricity under the pretence it is non-polluting renewable energy. The loggers are after an alternative to export woodchipping and the coal-fired power stations want an alternative to replace coal. Together they are threatening our chance to reclaim a future.

Currently they pretend burning forests for electricity has no CO2 emissions what-so-ever and is renewable energy by using an accounting trick that calls this ‘net zero emissions’, based on the assumption that a new tree will grow to replace that burnt. The flaw in this logic is that if a 100 year old tree is burnt it will take 100 years for a new tree to re-sequester the released carbon. We can’t wait that long.

There are currently multiple proposals around Australia to convert aging coal fired power stations to burning native forests. In north-east NSW Verdant Earth Technologies wants to restart the closed Redbank power station and burn more than 850,000 tonnes of wood per year (the current volume logged from all public forests in north-east NSW is 400,000m3 /year). This will release over 1.1 million tonnes of CO2 yearly at the plant and more than that in obtaining the wood, and yet they claim there will be no CO2 emissions and are eligible for Renewable Energy Certificates. 

We are asking that the Commonwealth amend the Renewable Energy (Electricity) Act 2000, and any other relevant instruments, to prohibit “wood obtained from native forests” being eligible for Renewable Energy Certificates, particularly Large-scale Generation Certificates (LGCs).

This link takes you to the consultation paper, and the online form where you can have your say. https://consult.industry.gov.au/native-forest-biomass-in-the-ret

Please make a submission in your own words, starting with a clear statement that: Electricity generated by burning wood from native forests must be prohibited from being eligible for Large-scale Generation Certificates (LGCs) under the Renewable Energy Target (RET).

Here are some other points you may like to include, take your pick :-)


  • Native forest biomass should be removed as an eligible fuel source under the Renewable Energy (Electricity) Act 2000 and electricity generated by burning wood from native forests must be prohibited from being eligible for Large-scale Generation Certificates (LGCs) under the Renewable Energy Target (RET).

  • Burning native forest biomass is inconsistent with the objects of the REE Act in that it produces more emissions than coal per equivalent amount of energy generated and thus does not reduce greenhouse gas emissions in the electricity sector or make a genuine contribution to the achievement of Australia’s greenhouse gas emissions reduction targets.

  • There is a significant time lag between when CO2 emitted in the burning process, would be re-sequestered by new forest: from decades to centuries. Meanwhile there are less trees to do the sequestering.

  • Burning wood from native forests and classing the energy produced as green, clean and renewable, doesn’t pass the pub test. Including it in the RET undermines confidence in and compromises the RET.

  • Native forest management across the country is demonstrably not ecologically sustainable. Evidence of this the up-listing of numerous forest dependent species, moving from threatened to vulnerable to endangered on the National Threatened Species list. There are numerous examples of court cases in Victoria showing VicForests is a serial law-breaker. In NSW, Forestry Corporation have received multiple fines for logging breaches.

  • Recommendations from the 2020 independent Samuels report to “make immediate reforms to the Regional Forest Agreements to ensure environmental protections consistent with the National Environmental Standards, equivalent to those of the EPBC Act, and to provide for effective Commonwealth oversight” have not been implemented.
  • Logging native forests has no social licence. A 2018 study commissioned by the Forest Wood and Products Australia found that 65% of rural based respondents found native forest logging unacceptable, with only 17% of those in the bush supporting logging in native forests. As the climate and biodiversity crises worsen, more and more people want to see our native forests protected for biodiversity and their ecosystem services rather than logged for what are increasingly low-value commodity products such as pulp and potentially biomass for combustion.

  • The REE Regulations do not adequately ensure that native forest biomass is from ecologically sustainable sources. It relies on definitions from the forestry sector that decrees all non-sawlog trees to be ‘waste’ “residue’ ‘pulp’ or ‘salvage’. In some regions of Australia up to 90% of all trees logged fall into this category.

  • Language about being a ‘by-product’ of a ‘high-value’ product is a smokescreen for the removal of a commodity with the overwhelming volume of native forest biomass removed from the forest being non-sawlog material. The viability of commodity production is dependent upon maximising volume and minimising costs. Clearfell logging, which is encouraged by the creation of a market for wood to generate power, maximises volume and lowers unit costs. As demand for Australia’s native forest woodchips wanes, new markets based on high volume, low cost products are sought to cross subsidise native forest logging.

  • All around the world there are examples of forests being cleared, with the vast bulk of the material now going to power stations. This is growing global disquiet about this. Australia can avoid becoming part of the problem.

  • Allowing native forest wood to be included as a fuel source provides an incentive for intensified logging and more land-clearing. It then creates an additional carbon cost with the hundreds of thousands of additional truck movements required to get the wood to the power stations creating further adverse impacts on Australia’s greenhouse gas reduction progress.

  • There are several proposals in the pipeline that propose to burn native forest biomass. One is the reopening of what was the Redbank coal power station. They propose 40,000+ B-double truck movements per year taking the woodchips from depots within a 300km radius to the power station. This doesn’t include the log trucks trips that take the logs to the woodchipping depots. Clearly a cascade of adverse impacts occur under this scenario, most obviously damage to roads and increased vehicle emissions.

  • According to the consultation paper there are no LGCs (Large Generation Certificates) from native forest biomass, so changing the regulation will have no impact on any current energy provider.

  • Burning wood releases more CO2 into the atmosphere compared to coal, per unit of electricity generated. The Chatham House report says “The carbon released into the atmosphere from logging and combustion of forest biomass for energy can be three times higher than using fossil fuels and take centuries for new tree growth to absorb.”

  • More CO2 is released from the waste (tree heads, branches, stumps and roots) left to rot in the forest, from disturbed soils and from the harvesting machines and trucks used to transport it to the power stations.

  • Burning a tree releases CO2, if a tree is grown as a replacement it will take many decades before it re-sequesters the released carbon. It will take 100 years for a regrowth tree to regain the carbon released by burning a hundred year old tree. In this climate emergency we can not afford to wait for the time it takes for regrowth to regain emitted carbon.

  • The older and bigger a tree gets the more carbon it sequesters and stores, we urgently need to leave our native forests standing to take carbon out of the atmosphere to help mitigate climate heating.

  • By stopping logging we can more than double the carbon stored in forests. A recent study of the south-east NSW’s public forests estimated they alone could sequester a million tonnes of carbon per annum if logging were stopped.

  • Larger trees store much more carbon than smaller trees and intensive logging also sees significant carbon lost from the soils that it not readily reabsorbed. Larger trees are targeted in logging operations.

  • Including wood from native forests as a “renewable” energy source displaces genuine renewable sources of energy, such as wind and solar, that don’t release CO2.

  • The claim they ‘only use waste’ from land clearing and logging is a sham, this is what the logging industry said about ‘export woodchipping’ which was an incentive for landclearing, and resulted in far more intensive logging with 80-90% of felled native trees in southern Australia being woodchipped. We need to stop landclearing and clearfelling for woodchips, not provide another market to increase it.

  • Creating a market for trees and parts of trees not wanted for sawn-timber will result in increased logging intensity, removal of trees unsuitable for sawlogs, logging of forests that would otherwise not be economic, and incentivises landclearing.

  • The Multi-Party Climate Change Committee, chaired by PM Gillard, agreed in July 2011 to exclude native forest wood from being subsidised as a renewable energy resource, and not be eligible for Renewable Energy Certificates. This was subsequently over-turned by the Abbott Government. It’s time to over-turn Abbott’s legacy. 

  • The recent NSW parliamentary inquiry into ‘Sustainability of energy supply and resources in New South Wales’ recommended “steps must be taken to ensure [the burning of forest biomass for power generation] doesn't become a major energy source, and that it's not eligible for renewable energy credits”.

  • Hundreds of climate scientists, economists and ecologists have signed open letters to world leaders, the European Parliament and the Australian Parliament calling for wood from native forests to be excluded from renewable energy fuel sources.

  • Australia’s forests have been seriously degraded by logging and roading. The percentage of forest made up of large trees is less than at any time in history. Large trees are vital and irreplaceable habitat for more than 300 species of animals that depend on tree-hollows for shelter, nesting, denning and breeding.

  • Wood from forests needs to be transported to depots for chipping and then to the power stations. For the proposed Redbank power station this would mean 40,000 B-Double truck trips, taking wood from depots up to 300km away to the power station. Log truck trips taking the wood from the forest to the depot will be additional.

  • More landclearing and logging means less habitat for koalas, gliders, owls, cockatoos, parrots, bats, reptiles and amphibians.

  • More and intensified logging means a drier more flammable forest, due to: greater sun penetration; reduction in rainforest and moist forest understoreys; proliferation of more flammable pioneer species and small trees; increased connectivity between ground fuels and canopy, thirstier regrowth; and logging debris left on the forest floor.

  • Younger forests have less ability to provide catchment stability. Young trees use more water and have a shallower root network. The roots of older trees tap into deeper aquifers and release the water through transpiration. Old forests store water in their soils and release it during drier times. Hence catchments with significant areas of older trees have water in their creeks during drought when similar catchments of younger trees do not

  • Where the public have been asked about burning wood, they are strongly opposed and see it as a throwback to the 1800s.

  • Most people recognise there is a biodiversity and climate crisis and protecting forests and leaving them to grow old is a valid form of climate action and absolutely fundamental to an adequate response to the biodiversity crisis.

  • Burning wood from forests to generate hydrogen does not produce ‘green hydrogen’. This is just another facet of the rorting of the renewable energy accounting rules.


There is also a new research paper from Griffith Uni that dispels the myths that burning native forest wood is clean or renewable https://research-repository.griffith.edu.au/handle/10072/417933

On the good news front there have been a couple of excellent programs on the issue exposing the scandal in Europe, the UK and Canada.

The Fifth Estate (2022) ‘The Big Burn’, CBC News, 3 October. Available at: https://www.cbc.ca/news/fifthestate/the-big-burn-1.6603564

And the BBC Panorama: The Green Energy Scandal Exposed https://www.youtube.com/watch?v=qadWRkPkKus

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