| November 1, 2022

Submission Re: Native Forest Wood Waste in the Renewable Energy Target

The Smart Energy Council welcomes the opportunity to provide a submission on the matter of native forest wood waste in the Renewable Energy Target.

Native forests should be removed for eligibility under the Renewable Energy Target. It harms the integrity of the energy transition and runs contrary to the greenhouse gas reduction objective of the Act.


About the Smart Energy Council

The Smart Energy Council is the peak independent body for Australia’s smart energy industry, representing around 1000 household, commercial and large-scale renewable energy, renewable hydrogen and smart transport companies.

Hydrogen Australia, a subdivision of the Smart Energy Council is the industry representative for renewable hydrogen, leading the advocacy for all Hydrogen to be produced from exclusively renewable energy based. This work has culminated in our World Leading Zero Carbon Certification Scheme for renewable Hydrogen and ammonia and metals. 


Social License 

Securing and maintaining the social license for the renewable energy transition has never been more important than now. The colossal buildout of new infrastructure and developments across the country will test the acceptability of the transition where projects come into conflict with our most treasured natural environments. The Smart Energy Council and Hydrogen Australia work closely with a number of the hydrogen producers, many of whom rely upon LGCs in order to produce renewable hydrogen and qualify under our Zero Carbon Certification Scheme. These producers rely on the quality and integrity of these certificates. This of particular importance as the emerging industry for decarbonisation in Australia comes under scrutiny. Native forest burning for electricity threatens the integrity of the LGC scheme and those who rely on the purchase of LGC’s for the integrity of their production and Zero Carbon Certification.

Beyond threatening downstream integrity within the renewable industry, there are a number of other local issues which provide no reasonable basis for the use of native forest for electricity. 

“Reduce greenhouse gases in the electricity sector”

The use of native forests also runs contrary to the second objective of the Act. Section 3 of the Act, “To reduce the emissions of greenhouse gases in the electricity sector’. The burning of native forests has a similar carbon intensity of burning coal, our most carbon intensive fuel in the electricity sector. 

The future for Australia is as a renewable energy powerhouse. This future will be driven by solar, wind, storage and a range of enabling technologies, as well as the greater production of renewable Hydrogen. The underlying objective of the Act is to drive the uptake of renewable energy sources, with the condition of reducing greenhouse gases in the electricity sector. Any increase in the use of native forest for electricity production firstly increases greenhouse gas emissions and secondly distracts from the renewable energy technologies which will ultimately make up Australia’s decarbonised electricity sector. 

The Council is yet to have seen the use of native forest for electricity where the use of the fuel consumption was consumed at the replenishment rate of the resource, the regrowth of native forests. If it does not meet this basic definition for renewable energy, it should not be included in the Act. 


Falling behind Government and Industry standards

The NSW and Victorian Government provide evidence to the lack of tolerability for the use of native forest in the production of electricity. The two state governments in the delivery of their renewable hydrogen highway have excluded the use of wood waste or biomass from the burning of native forests as part of their ‘renewable hydrogen’ definition. See page 20 of the application guidelines. This position is shared by Hydrogen Australia, and the Federal Government needs to follow suit if it is to not fall behind industry and state government standards for what is acceptable for renewable energy production.



Native forest should be removed for eligibility under the Renewable Energy Target. It harms the integrity of the energy transition, it runs contrary to the greenhouse gas reduction objective of the Act. Furthermore, it does not hold credibility in the energy transition in the emerging standards from government agencies, peak bodies, and businesses. 

Should you wish to discuss these matters further, please contact Wayne Smith, External Affairs Manager, on 0417 141 812 or at wayne@smartenergy.org.au



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