Date: 6^th October, 2022

The Department of Climate Change, 
Energy, the Environment and Water
renewableenergy@industry.gov.au

Submission To the Consultation Paper on Native Forest Wood Waste in the Renewable Energy Target (RET)

Introduction.

The Clarence Environment Centre (CEC) has a proud 32-year record of environmental advocacy, with climate change action and biodiversity conservation as key platforms.

As a result, we are compelled to make a submission strongly opposing any consideration of burning wood for electricity generation being considered renewable energy under the RET.

Discussion.

The CEC finds the term “wood waste” completely unacceptable, particularly that taken from native forest. It is not waste, it is crucial habitat for Australia’s unique fauna, and the source of essential nutrients for plants to grow and create healthy biodiverse ecosystems.

As explained in Australia’s Biodiversity Management Strategy, biodiversity provides we humans with everything we eat, much of what we wear, and many of the medicines we depend on. Those forest ecosystems store carbon from the atmosphere, and supply us with oxygen, while at the same time filtering the water we drink, the two elements, without which life on Earth could not exist. And, it is provided absolutely free of charge!

Therefore, the renewable energy credits scheme needs to be overhauled to ensure that highly polluting proposals, such as burning wood to generate electricity, should not be included. Not only that, but the CEC strongly believes that the burning of forest timbers should be disallowed entirely, for all the reasons mentioned above.

We should clarify that we are not opposed to all biomass energy production. The harvesting of methane from landfill, for example, is something that has merit, as that methane escapes anyway, and is a high-ranking greenhouse gas.

Recommendations

1. That logging of native forests be phased out as a priority action to 
   1. reduce the volume of what is termed “wood waste” creating a fire hazard, 
   2. allow those forests to naturally store carbon from the atmosphere, and,
   3. to protect biodiversity.

2. Immediately remove the burning of all timber for electricity generation from the RET credits scheme.

3. That the Government move to clarify what exactly constitutes “wood waste”, i.e., those true waste substances that are likely to be burned anyway. e.g., sawmill residues, vegetation that has had to be removed for building and other infrastructure development, and sugarcane waste, bagasse, and.

4. That the relevant authorities explore more environmentally acceptable uses for those unavoidable residues, with burning to generate electricity only undertaken as a last resort.

We thank the Government for granting us the opportunity to provide input through this consultation process, and hope that our comments will be taken seriously.

Yours sincerely, 

John Edwards

Honorary Secretary