NCC, AFCA to ARENA Bioenergy Roadmap: “Exclude forest derived biomass … FDB is not a credible or desirable energy source or route out of fossil fuel dependence.”


The Nature Conservation Council and the Australian Forest and Climate Alliance have made the following joint submission to the ARENA Bioenergy Roadmap: 

“Exclude forest derived biomass.” 

FDB is not a credible or desirable energy source or route out of fossil fuel dependence. 

We call on ARENA to contribute to responsible action on the climate crisis by ruling out forest derived bioenergy (FDB) or biomass. 

FDB is: 

  • more emissive than coal at the point of combustion
  • not carbon neutral, (within time frames identified by the IPCC to reduce atmospheric carbon, if ever)
  • not clean
  • harmful to people and biodiversity

The best way to deploy native forests to tackle climate change is to protect and restore them to slow emissions and increase the removal of carbon dioxide (CO2) from the atmosphere.

In 2013, the Australian Government explained their policy on native forest bioenergy in their publishedresponse to the Climate Change Authority’s Renewable Energy Target (RET) Review:

“Wood waste from native forests was removed from the RET as an eligible renewable energy source in 2011. This amendment was made to ensure that the RET did not provide an incentive for the burning of native forest wood waste for bio-energy, which could lead to unintended outcomes for biodiversity and the destruction of intact carbon stores.”

These specific concerns remain despite subsequent policy revisions reversing that exclusion.

This joint submission summarises the key reasons to rule out FDB. We refer ARENA to the more detailed submission to the ARENA Bioenergy Roadmap by the Australian Climate Forest Alliance (AFCA), and to the AFCA position statement on forest bioenergy,2 and thank them for the contribution of their research to this document.

Investment in FDB would directly undermine genuine low emissions, clean energy sources like wind and solar if it competes for limited government incentives.

1. Forest biomass is not zero emissions

Burning biomass emits CO2 to the atmosphere, just as burning fossil fuels does. In fact, generating a unit of energy from wood emits between 3% and 50% more CO2 than generating it from coal.3

Figure 1: The two charts above are derived from data from various sources for units burning biomass for fuel, assembled by Mary S Booth, Partnership for Policy Integrity

2. The claim of carbon neutrality is based on simplistic assumptions and flawed carbon accounting

The false claim that emission reduction targets can be met through the clearing and logging of forests has seen the FDB industry grow. This claim is based on erroneous assumptions and flawed forest carbon accounting protocols. 4 A detailed explanation by the Australian Forests and Climate Alliance is at Appendix 1.


In sum, carbon emissions are accounted for when trees are logged, rather than when they are burned. When accounting for emissions due to logging and tree loss, offsetting conventions are oversimplified and inaccurate.

Combustion: Under international carbon accounting conventions, emissions from biomass combustion for energy generation are not recorded in the country that consumes the wood, nor are they attributed to the energy sector. Bioenergy emissions are instead supposed to be accounted in the land use sector. As a result, a zero appears on energy sector accounts under biofuel emissions. FDB CO2 emissions appearing as zero in energy sector carbon accounting is not the same as an outcome of zero emissions.

The Intergovernmental Panel on Climate Change (IPCC) warns:

“The IPCC approach of not including bioenergy emissions in the energy sector total should not beinterpreted as a conclusion about the sustainability or carbon neutrality of bioenergy.”5

Recapture: Accounting procedures associated with the Kyoto Protocol estimate changes in carbon stocks of forest estates when logged. Old growth forests, secondary and natural forests and plantations are treated as equivalent. The replacement of old growth forest with monoculture plantation is deemed to have offset the forest carbon loss, yet the carbon carrying capacity of these different categories is vastly different. This simple estimate of forest cover fails to account for the vastly different densities of carbon stock across forests.

The implications of these accounting flaws are significant. A false zero emission signal has led to increased biomass burning under the guise that it reduces emissions.

3. Carbon from the loss of trees is not recaptured within critical timeframes

Claims that forest regrowth nullifies the impact of forest biomass combustion on climate change are incorrect.

We have less than a decade to vastly reduce emissions. Carbon from the combustion of FDB cannot be recaptured within this timeframe.6

When trees are removed from forests, we remove their function as a living carbon sink, and we damage the ability of forest soils to store carbon. Any industrial logging depletes native forest carbon stores by up to 70 per cent.7

Trees utilised for FDB may regrow but reaching their equivalent carbon storage capacity could take decades or even centuries. Replanting trees does pull carbon from the air, but not as much as letting existing forests keep growing. The longer trees are left to mature the more carbon they capture and store.8 Meanwhile the immediately increased concentrations of CO2 from FDB add to global warming, jeopardising our ability to prevent irreversible ‘run away’ climate change.

FDB has a massive opportunity cost in terms of emission reduction. It will increase, not decrease emissions, undermining the aim of the ARENA Bioenergy Roadmap.

4. FDB is not cheap or efficient

FDB energy is expensive in comparison to genuine renewable energy sources. It requires large scale infrastructure, air pollution control equipment and constant maintenance.9 Constant, huge volumes of feedstock must be purchased, unlike the free ‘feedstock’ of wind and solar energy. As the practice exists internationally, enormous volumes of wood are taken directly from forests as whole logs, limbs, tops and stumps.10

FDB requires intensive production, distribution and consumption of forest resources.11 To supply only 3 per cent more energy from FDB globally, the world would have to double its commercial wood harvests,12 pitting the fuel against food security and biodiversity protection.13

In countries that have classified FDB as ‘renewable’, the industry relies on substantial governmentsubsidies for economic viability.

5. FDB has negative and unjust health impacts

6. International experience tells a story of deforestation and forest degradation

Europe’s renewable energy policy is substantially built on burning trees. Biomass has expanded rapidlythis century to provide approximately half Europe’s ‘renewable’ energy. Most of the fuel is being harvested from North American forests.17

Despite damaging combustion emissions, the error that allows FDB to be accounted for as ‘renewable’ isresulting in hollowed out and degrading forests in British Columbia, Estonia, Romania, Russia, Europe and North America all while increasing CO2 emissions.18, 19, 20, 21 Europe is burning 21.7 million tonnes of wood pellets annually.22

Without intervention, tree burning for fuel is predicted to escalate from 14 to 36 million tonnes per annum.23, 24

Australia runs the risk of sacrificing its forests to the international wood pellet trade.

Particulate pollution kills people.14 There is evidence that coal fired power harms the health of

populations around power stations.15 Burning biomass also has significant public health impacts. Data

from the Drax power station in the UK shows that biomass burning has increased particulate pollution

by 400% since switching four of six boilers to FDB, while power output has remained constant.16



Figure 2 & 3: These global threat maps show the projected supply of wood pellets and the growing demand for pellets in Asia and Europe (Forest, Climate and Biomass Energy working group of the Environmental Paper Network).

Swift and wise policy reversals in multiple jurisdictions, including Australia, can stop our global forest carbon stores being felled to supply the unnecessary wood pellet trade. Compelling and authoritative scientific opinion is now leading the call to review laws and regulations that incentivise FDB.25 This has occurred in two jurisdictions recently, in Slovakia and in the US state of North Carolina.

7. Risks to Australian native forests increase with adding FDB in the product mix

Australia is already exporting native forest biomass for FDB. The logging industry, supported by governments, is planning to increase domestic uptake and exports.26

Proponents argue that FDB will not be a driver of increased native forest logging in Australia because it is derived from residue and waste materials. However the definition of ‘residue’ in Commonwealth and some state legislation is based on the economic value of a harvest, rather than on whether the biomassis real waste or mill ‘residue’. These definitions can include whole logs. NSW has specifically defined immature native forest trees (pulp logs) as ‘residue’. Such logs are available for subsidy when combusted or otherwise processed as a ‘renewable’ energy feedstock.27,28

Any incentive for logging native forests in Australia is a risk to human life and biodiversity. Industrial logging of forests is identified as a factor contributing to fire severity. Logging is likely to haveexacerbated Australia’s recent catastrophic summer bushfires.29 It is now impossible to justify logging in native forests, and in particular not for a purpose that will exacerbate global warming and put our wilderness under yet more threat. Native forest carbon stores need to remain intact.

8. Vested interests

Around the world, companies operating under the aegis that forest bioenergy is carbon neutral have profited from the subsidies it attracts. The public purse has been depleted and the world’s forests havefallen. 30

The industries and advocates that are driving FDB expansion in Australia are those who benefit from flawed forest carbon accounting protocols, policy and legislation. Logging and wood product businesses have been pushing for FDB through lobby and advocacy groups including the Australian Forest Products Association, Forest and Wood Products Australia and the Commonwealth Government’s Forest IndustryAdvisory Council. 31 These groups represent the interests of businesses that sell wood and paper products. They have financial interests in the continuation and expansion of logging in Australia.

No groups with expertise in clean and renewable energy, whose primary mission or vision is emissions reduction, advocate for FDB. Evidenced by the signatories to this submission, they see FDB as potentially catastrophic.


The ARENA Bioenergy Roadmap excludes forest derived bioenergy from consideration as an energysource in Australia’s future; for on- or off-shore consumption.

Governments across Australia review and amend references to the use of native forest materials for fuel in legislation and regulation with a view to preventing this industry from taking hold.


Intact, mature and recovering native forests are our best hope for taking   FDB harms the climate, harms forests, harms people and harms the clean energy transition. To avoid catastrophic global warming, we need to reduce

It is incredibly exciting that Australia is moving to replace fossil fuels with renewable energy. However, any engagement with FDB would be a gross misdirection of government subsidies and an assault on the climate. A roadmap that considers forest derived biomass in any form would derail, delay and undermine genuinely clean energy development. It would simultaneously be a great injustice to communities that love their bushland, workers who deserve sustainable industries and the flora and fauna that we need to survive.

We must move to secure a genuinely sustainable future for subsequent generations. Energy from forest derived biomass will add to the problems we are setting our sights on overcoming. This bioenergy has no place in our roadmap to a solution.



Chris Gambian
Chief Executive
Nature Conservation Council


Frances Pike Co-ordinator AFCA

End industrial logging of native forests in Australia carbon out of the air. emissions sharply and increase the uptake of carbon into natural ecosystems.



Appendix 1 – AFCA explanation of flawed carbon accounting and the concept of Carbon Neutrality.

All countries that are party to the United Nations Framework Convention on Climate Change (UNFCCC) are required to report on inventories of nominated Green House Gases (GHGs) that comprise net emissions from nominated sectors, i.e. energy, transport, industry, land management etc. Guidelines forinventory reporting are developed by the IPCC.

In relation to implementation of the Kyoto Protocol, developed country parties are required to accountfor their emissions reductions against their target. Accounting rules have been developed by the UNFCCC, with some advice from the IPCC. For the category Land Use, Land Use Change and Forestry (LULUCF) this accounting is not equivalent to inventory reporting; instead these rules have been elaborated to include a range of policy constructs and other considerations beyond purely technical matters.

Under the Convention, accounting methodologies have also been developed for implementation of the REDD+ mechanism (Reducing Emissions from Deforestation and Forest Degradation), to be applied by developing countries to their forest emissions.

The Paris Agreement, in developing its rulebook thus far, adopts extant land use accounting methodologies in use under the UNFCCC or its instruments to be applied in relation to Nationally Determined Contributions (NDCs), and aims for economy-wide accounting of emissions and removals. Whilst advocates hope for development of better accounting rules and guidance this has not been forthcoming to date.

Issues relevant to forest biomass energy

Emissions do not appear in energy sector accounts – optics matter

Emissions generated by combustion of biomass for energy generation are not reported nor accounted in the energy sector of the consuming country. A zero sits alongside emissions of combustion of forest biomass, whereas figures for the emissions of combustion of fossil fuels do appear in inventory reports and country accounts. This creates a false impression of zero emissions of combustion for biomass energy in comparison to fossil fuels.

In fact the combustion of forest biomass for energy generation emits as much or more carbon as coal (actually 3-50% more than coal, depending on feedstock). It immediately emits large quantities of greenhouse gases into the atmosphere. In contrast it takes decades to centuries for forests to regrow and sequester the carbon, which is far too long to effectively contribute to the 1.5°C Paris Agreement target (if in fact those forests ever regrow to their previous carbon carrying capacity). Direct and indirect emissions from logging and the bioenergy supply chain also negatively affect its overall carbon balance.

The assumption behind this zero accounting in the energy sector is that all emissions are instead to be accounted for when the biomass is logged. Thus, all accounting for emissions and removals from anthropogenic actions associated with forests and forest materials is to be consolidated within LULUCF accounts. The rationale is that this avoids double counting of emissions.

Unfortunately the signals sent by a zero emissions record in the energy sector have been misconstrued to wrongly claim carbon neutrality for burning forest biomass. Further, this accounting convention  places the burden for emissions directly attributable to energy production on the forest producer rather than the biomass consumer.

The implications of this accounting flaw are significant, leading to an encouragement of biomass burning as if it reduces emissions, and to major loopholes in carbon accounts.

Consumer responsibility: consuming countries that generate GHG emissions from energy they utilise should take responsibility for those emissions. That way there is an incentive to reduce emissions. Yet big biomass consumers such as the UK and EU, and increasingly Japan and South Korea are heavily reliant on imports of forest biomass to fuel their generators. They essentially get a free ride with their accounts showing a reduction in emissions, whilst the country that grew the trees takes the emissions hit.

This will become increasingly problematic as developed countries get to claim emissions reductions reliant on developing countries supplying forest biomass and taking responsibility for the ensuing emissions generated in developed countries. Vietnam has emerged as a bug supplier and Indonesia and Malaysia are amongst those whose forest biomass exports are growing. Australia is predicted to supply 3 million tonnes per annum of wood pellets to Japan by 2027.

Loopholes: The assumption that emissions from forest biomass will be accounted by the producing country is also flawed. For example, the US is a major supplier of forest biomass to Europe and the UK, and increasingly to Japan. Those countries do not account for the emissions, but neither does the US as it is not a party to the Kyoto Protocol. All the emissions of combustion arising from that forest biomass simply disappear in a huge accounting loophole. The same will be true for the emissions of biomass from Canada and Russia exported for energy production during the second Commitment Period of the Kyoto Protocol.

Accounting for forestry: emissions accounting of forests in the land sector generally understates emissions.

First, use of stock change accounting never explicitly identifies emissions from forestry (officially knownas ‘forest management’) that are attributable to use of particular volumes of forest biomass for energygeneration. Instead there is a reliance on the fact that forests continue growing in the country of origin as sufficient to offset the emissions of combustion in the energy sector. Yet, that same growth is also netted out against emissions in the land use sector – clearly this is double counting of removals when it is also claimed to offset emissions of combustion incurred in another country.

Second, the bioenergy industry is trying to claim sequestration from forests that were growing anyway, whether or not wood was logged and burnt for bioenergy. As the IPCC has said

“If bioenergy production is to generate a net reduction in emissions, it must do so by offsetting those emissions through increased net carbon uptake of biota and soils”1 (emphasis added).

There is no claim, nor effort to quantify, such an additional uptake of carbon.

Third, rules that allow countries to use forward looking (rather than actual historic) baselines, also known as Business as Usual (BAU) Baselines or Forest Reference Levels (FRLs), assume increases in emissions due to various factors, including policies to increase production and use of forest biomass for energy. This has provided an opportunity to hide emissions from more intensive management practices entailed in using wood for bioenergy, has occurred in Europe. If reference levels are not set on genuine historic emission levels but on levels that will be ‘adaptive’ to future policy change with assumedincreases in future emissions, emission increases will be hidden, unaccounted for and/or unpenalised. So far reference levels have been allowed to take into account ‘assumed’ future emissionlevels under KP LULUCF accounting, and in the case of FRLs for REDD+.

1 IPCC AR5 WG III 11.13.4 GHG emission estimates of bioenergy production systems, 2014 ( p. 877)

Lastly, old growth forests, secondary forests, natural forests subject to wood production regimes, and plantations are treated as equivalent under a forest definition and accounting conventions that assess tree cover and fail to differentiate the carbon density of the forest carbon stock. Hence replacement of old growth forest by monoculture plantation is deemed to have offset the forest carbon loss, although the carbon carrying capacity of these different categories is vastly different. This also fails to consider the opportunity cost associated with logging native forests instead of allowing previously logged forests to recover their natural carbon carrying capacity. It renders impotent the single most important strategy for increasing forest carbon sequestration and establishing relatively stable forest carbon storage.

Appendix 2 – References and endnotes

1 Australian Government Department of Industry, Science, Energy and Resources. 2020. Report of the expert panel examining additional sources of low-cost abatement. Available at: low-cost-abatement.pdf

2 Available at: bioenergy.pdf
3 Biofuelwatch, 2018. Biomass basics – what are the problems with big biomass?

4 DeCicco, J. M. & Schlesinger, W. H. 2018. ‘Opinion: Reconsidering bioenergy given the urgency of climate protection’ PNAS, 115:39:9642-9645 heat-impacts-global-climate, power-and-heat-climate-and-forests

5 Intergovernmental Panel on Climate Change Taskforce on National Greenhouse Gas Inventories.

6 Bowd, E.J., Banks, C.S., Strong, C.L. & Lindenmayer, D.B. 2018. Long-term impacts of wildfire and logging on forest soils. Nature geoscience.

7 Bowd, E.J., Banks, C.S., Strong, C.L. & Lindenmayer, D.B. 2018. Ibid.8

9 Budischak, C., Sewell, D., Thomspon, H., Mach, L., Veron, D. E. & Willett, K. 2012. ‘Journal of Power Sources’, inBremmer, J. 2016. Ibid.

10 Kulman, W. & Putt, P. 2018. Are forests the new coal? A global threat map of biomass energy development.Environment Paper Network.

11 Dooley, J. H., Wamsley, M. J. & Perry, J. M. 2018. ‘Moisture content of baled forest and urban woody biomassduring long-term open storage.’ Applied Engineering in Agriculture 34:1:225-230

12 Dooley, J. H., Wamsley, M. J. & Perry, J. M. 2018. ‘Moisture content of baled forest and urban woody biomassduring long-term open storage.’ Applied Engineering in Agriculture 34:1:225-230

13 Field C. B. & Mach, C. B. 2017 ‘Rightsizing carbon dioxide removal’ Science. 356:6336:706-707

14 Ewald, B. 2018. The health burden of fine particle pollution from electricity generation in NSW, University of Newcastle. cle_pollution_from_electricity_generation_in_NSW.pdf

15 Environmental Protection Authority NSW, 2016. Clean Air for NSW consultation paper. Available: /media/epa/corporate-site/resources/air/clean-air-nsw-160415.pdf

16 EU Biomass Legal Case, 2019. Drax (UK): 1000 tonnes of deadly particulate pollution a year, a 400% increase since they switched from coal to biomass. particulate-pollution-a-year-a-400-increase-since-they-switched-from-coal-to-biomass/

17 Statista, Export volume of wood pellets in the US from 2008 to 2015

18 Birdlife International, The Black Book of Bioenergy.

19 Meyer, C. 2020. B.C. says firms can chip down whole trees for pellet fuel if they are ínferior’. Canada’s NationalObserver. pellet-fuel-if-they-are-inferior

20 Danielsen, C. L, Ravno, L. & Ditzel, E. E., 2019. Når Danmark brænder træer af, bliver der ikke altid plantet nye, Nyheder. Available: plantet-nye?fbclid=IwAR2XmET2FTbxm27nr7O2XK3xzOK1ohbdMRykdz2-abvysjDBWDNKiwccsXI

21 Birdlife International, The Black Book of Bioenergy. Wolfgang K. & Putt, P 2018. Are Forests the New Coal – a Global Threat Map of Biomass Energy Development.Environmental Paper Network. Briefing-Are-Forests-the-New-Coal-01.pdf

22 Stephenson, N., Das, A., Condit, R. et al. 2014. Rate of tree carbon accumulation increases continuously with tree size. Nature 507:90–93.


23 Wolfgang K. & Putt, P 2018. Are Forests the New Coal – a Global Threat Map of Biomass Energy Development.Environmental Paper Network. Available: Map-Briefing-Are-Forests-the-New-Coal-01.pdf

24 Wolfgang K. & Putt, P 2018. Ibid

25 See appendix to full submission by the Australian Forests and Climate Alliance

26 Australian Forests & Timber News, Australia-Japan forest products trade strengthened, 20 December 2018

27 The NSW Protection of the Environment Operations (General) Amendment (Native Forest Bio-material) Regulation 2013 changed the definition of native forest bio-material in order to permit the burning of any biomaterial obtained from forestry operations carried out on land to which an Integrated Forestry Operations Approval (IFOA) applies under Part 5B of the Forestry Act 2012. Available at

28 Ximenes, F. Coburn, R., McLean, M., Samuel, J., Cameron, N., Law, B., Threllfall, C., Wright, K. & Macintosh, S. 2017. Forestry biomass for bioenergy generation in three regional hubs in NSW. Powerpoint presentation for NSW Department of Primary Industries.

29 Lindenmayer, D., Kooyman, R. M., Taylor, C., Ward, M. & Watson, E. M., 2020. Recent Australian Wildfires made worse by logging and associated forest management. ‘Nature, Ecology & Evolution’ Published online 5 May 2020at


31 For example, Forest Industry Advisory Council (FIAC) wrote a blueprint for the management of Australian forests to 2050. FIAC recommends that all levels of government remove regulatory barriers to using FDB as a renewable energy source and that FDB be eligible for Renewable Energy Certificates in Transforming Australia’s Wood Products Industry’ 16/Transforming_Australias_forest_products_industry_- _Recommendations_from_the_Forest_Industry_Advisory_Council_May_2016_reduced.pdf