Independent Review of Australian Carbon Credit Units: Call for submissions

Submission to the Independent Review of Australian Carbon Credit Units

Introduction:

This submission is informed by my experience:

As the former Managing Director of Forests Alive Pty Ltd, a project development company that successfully transitioned Tasmanian ‘avoided harvest’ projects developed under the then VCS voluntary standard into the compliance system - making a successful bid on behalf of landholders in the first ERF Reverse Auction;

My role on the boards of two of the worlds largest connectivity conservation programs that deliver holistic outcomes for climate mitigation, adaptation, biodiversity protection, community well being and ecosystem integrity, Gondwanalink ltd and the Great Eastern Ranges Connectivity Initiative (gondwanalink.org; ger.org.au);

Almost two decades of experience in UNFCCC policy and practice on LULUCF and REDD+; and

Current involvement through the Australian Rainforest Conservation Society in the international policy component of a global research program lead by Griffith University on primary forests which has taken me into the heart of the nexus between biodiversity loss and climate change, including understanding how each crisis amplifies the other and the importance of tackling both crises together.

The purpose of this submission is to ensure that the significance of recent developments in scientific understanding and international policy and practice, are taken into account in re-designing the framework for ACCU generation from natural and agricultural ecosystems.

Australia has paid scant attention to the implications of the biodiversity crisis for the supply of every ecosystem service on which humanity relies, including the retention of ecosystem carbon stocks. Too little attention has been paid to the functional role of biodiversity in maintaining ecosystem integrity, stability and resilience and the factors that influence risks to and longevity of, carbon storage in land, forests and other ecosystems.

The changes recommended are focused on future needs and opportunities to ensure ACCU’s generated from land, forests and other ecosystems contribute high integrity, low risk outcomes to Australia’s national emissions reduction targets and “to ensure the scheme remains appropriate and fit for purpose over the decades ahead”.

They are also made in the knowledge that there is little remaining GHG budget in which to limit warming to 1.5 degrees (Spratt & Dunlop 2021a, b), that gross emissions reductions from all sectors must be the highest priority for action and that what we do in this decade will likely determine success or failure in ensuring an equable climate close to that in which humanity evolved and thrived.

It must not be forgotten that Nature is integrally part of a complex, interacting, adaptive social, economic and Earth systems each with transition thresholds to alternative stable states. Just as integrity and resilience of natural ecosystems are fundamental to addressing climate change, failure to control fossil-fuel carbon emissions resulting in increased intensity and frequency of droughts and fires can undermine Nature’s critical role (Brando et al. 2019). New forms of governance that holistically and adaptively manage all these factors will be essential.

The role and limits of Nature in climate mitigation

There is a long tail from CO2 emissions, with emissions persisting in the atmosphere for centuries. The imperative must be to, wherever feasible, prevent emissions now and from all sectors – including from loss and damage to carbon rich ecosystems as the carbon stored in them is “irrecoverable by 2050” (IPCC AR6 WG 111, chpt 7; Goldstein et al. 2020). In addition to keeping fossil carbon in the ground, we must do everything possible to improve the integrity, stability and resilience of ecosystems to retain existing carbon stocks and facilitate expanded carbon retention capacity.

Internationally, climate focus is increasing on the benefits of protecting and restoring natural ecosystems through so called Nature based solutions (Nbs). While welcome, the global promotion of Nbs creates a false sense that business-as-usual fossil fuel emissions can continue, with Nature picking up the bill. Any meaningful discussion of Net Zero goals must include the severe risks and dangers of assuming fossil fuel emissions can simply be offset by increased uptake of CO2 in land, forests or other ecosystems. Moreover, priorities for retaining and recovering ecosystem carbon stocks must be based on new scientific knowledge, which reveals that:

● The Mitigation value of forests and other carbon rich ecosystems resides in their ongoing capacity to sequester and store carbon.

● It is not just the rate at which carbon is input to an ecosystem (e.g. uptake by trees through photosynthesis) that matters, but also the rate of carbon output (respiration) and the carbon residence time.

● It is the size and longevity of the accumulated stock of carbon that matters most for climate mitigation.

● Biodiversity provides natural resistance, resilience and adaptive capacity to ecosystems and enables larger and longer-lived ecosystem carbon stocks. (Mackey et al 2022)

The natural carbon dynamics of ecosystems – and the factors that affect their stability and resilience – determine carbon residence time and the ability of ecosystems to resist threats that are increasing as the Earth warms (Keith et al 2021). Given that there is more carbon held in ecosystems than there is in known reserves of fossil fuels (Mackey et al 2013), it is critically important to retain ecosystems that are in good condition and improve the integrity of fragmented and otherwise damaged or degraded ecosystems to increase the stability of current and future ecosystem carbon storage.

It is scientifically incorrect to assume that geo-carbon and bio-carbon are fungible or that even within land, forest and other ecosystems, all carbon is equal. The ERF has failed in a serious and fundamental way, to reflect ecosystem dynamics and understand let alone promote, the fact that maintaining and improving the integrity of all ecosystems - both agricultural and natural – is essential for effective, long term mitigation outcomes and improving the ability of ecosystems to adapt to climate change.

Recommendation 1: Separate goals, targets and ERF indicators should be established for biogenic and geocarbon that seek to reduce gross emissions from all sources of emissions including from agricultural and natural ecosystems and to help retain and increase carbon storage through improved protection and conservation management of ecosystems to improve their integrity and stability.

The functional role of biodiversity in successful climate mitigation

Both rapid reductions in burning fossil fuels and increased synergistic climate and biodiversity action are essential for limiting warming to 1.5°C degrees,

Failure to understand the functional role of biodiversity in climate mitigation has fostered the myth that all carbon is equal and led to perverse outcomes where biodiverse, high integrity and relatively stable and resilient ecosystems – such as older forests – are converted to agricultural land (deforestation) or degraded by logging or converted to agricultural tree crops (forest degradation). Current definitions of forest used by agencies like the UNFCCC are distinctly unhelpful in this regard – failing to account for the loss of forest ecosystem integrity and resilience when damage and conversions take place.

Naturally evolved patterns of biodiversity (composition, distribution, structure and abundance) are the most stable and resilient and, within their system limits, have natural resistance to threats that are increasing with climate change, particularly drought and fire. If we maintain and restore biodiversity, we lower the risk of ecosystems releasing carbon to the atmosphere. Conversely, monoculture plantings are at high risk of loss and damage and if planted to supply timber or fuel on short cycles, as is usually the case, are of negligible climate benefit – the exception being agro-ecological plantings designed to deal with severe land degradation such as salination, desertification, wetland recovery and soil erosion.

The importance of structure (age) for resisting escalating threats driven by severe drought and loss of soil moisture such as catastrophic fires is illustrated by scientific findings that older forests are more resistant to drought and fire and reduce fire severity compared to young previously logged forests (Wilson and Bradstock 2022; report no 3 www.bushfirefacts.org)

Biodiversity plays an essential and functional role in underpinning every ecosystem service, including relatively stable carbon storage, on which we rely. The fact that we are facing a biodiversity crisis that is just as destabilizing to future Life on Earth as the climate crisis (IPBES 2018/19) requires that improved conservation management of all natural ecosystems is at the core of climate action in land, forests and other ecosystems.

The findings of the IPBES/IPCC workshop held in 2021 should be heeded, notably that the biodiversity and climate crises amplify each other; that neither crisis can be solved unless they are solved together – ‘if we fail on one we fail on both’; and that synergistic climate and biodiversity action must be encouraged. The workshop clearly identified a cascading set of priorities for synergistic action, namely improve protection first, followed by restoration of carbon and species rich natural ecosystems, “especially forests, wetlands, peat-lands, grasslands and savannahs; coastal ecosystems such as mangroves, salt marshes, kelp forests and sea grass meadows; as well as deep water and polar blue carbon habitats”. (IPBES-IPCC Co Sponsored Workshop on Biodiversity and Climate Change, Workshop Report, DOI: ID.5281/zendos.4782538 and ipbes media release 10 June, 2021)

Existing programs in Australia which foster integrated climate mitigation, adaptation and biodiversity outcomes through buffering and reconnecting natural ecosystems include the largely voluntary work of initiatives like:

Springbrook Rescue lead by the Australian Rainforest Conservation Society (sprinbrookrescue.org.au) working to buffer, reconnect and restore Gondwanan World Heritage Rainforests;

Gondwanalink Ltd (gondwanalink.org) working to protect and restore natural ecological processes and landscapes across more than 1000kms in the south of Western Australia; and

The Great Eastern Ranges Connectivity Initiative (ger.org.au) working with 250 partner organisations on projects spanning the entire east coast-slopes zones of Australia - some 3,600kms.

The resilience of these programs and their significance for maintaining and restoring carbon in landscapes and the adaptive capacity of ecosystems has been entirely overlooked by governments over the past decade – a tragic failure of policy for climate, biodiversity, heritage and community resilience that must be rectified.

Successful long term, climate mitigation in land, forests and other ecosystems can only be achieved if action is built upon the protection and restoration of biodiversity and ecosystem integrity and supported by indigenous and local communities.

Recommendation 2: Synergistic climate and biodiversity action must be encouraged with improved conservation management of existing ecosystems fostered ahead of and linked to ecologically based restoration action by developing appropriate guidance, mechanisms and metrics to evaluate integrated climate and biodiversity action and more directly support local community action.

Accounting Reform

Successful implementation of the ecosystem provisions of the UNFCCC and the Paris Agreement and of decisions made at COP 25 (1.CP 25 para. 15) calling for integrated action to prevent biodiversity loss and climate change; and COP 26, (CMA/3 para. 21 and 1.CP/26 para. 38), emphasizing ” the importance of protecting, conserving and restoring nature and ecosystems, including forests …” depends upon understanding the significance of ecosystem integrity for stable long term carbon storage and the overall health of the biosphere.

Current UNFCCC accounting rules on land and forests (LULUCF) are unsuited for encouraging integrated climate and biodiversity action or for guiding priorities for Nbs in NDC’s (Keith et al 2021). At a time when it is critical to implement the ecosystem provisions of the Paris Agreement and the Convention, revised approaches to carbon accounting in land forests and other ecosystems are urgently needed.

Fortunately, the new ecosystem accounting framework developed and adopted last year by the UN Statistical Commission (the UNSEEA-EA) can fill crucial information gaps in UNFCCC approaches, enabling the integrity of ecosystems to be assessed against a natural reference level and countries to include and value the ecosystem service of carbon retention, based on the relative condition (or integrity) of ecosystems, in the balance sheets of their National Accounts. By doing so the superior value of ecosystems with high integrity and the recovery potential of those that are not, can be fully revealed. Already 37 countries, including Australia are moving to implement the UNSSEA-EA and it is being strongly supported by the G7 as an important bridge between the Rio Conventions.

The integrity of ecosystems is being promoted by civil society (CAN International) as an important factor to consider in the UNFCCC Global Stock take (GST) - a central pillar of the Paris Agreement against which its success or failure will be judged. Utilizing the UNSEEA-EA to benchmark protection and restoration actions would provide critical information needed in the GST to inform high benefit/low risk Nbs in NDC’s.

These recent international policy developments point to the importance of maintaining and restoring ecosystem integrity for achieving the goals of all the Rio Conventions and all of the SDG’s but in particular SDG 15 (Life on Land). Increased focus on integrating climate and biodiversity action provides an opportunity to deliver multiple societal goals through ensuring the integrity of ecosystems.

The IPCC Sixth Assessment Report, Mitigation of Climate Change, Chapter 7, Agriculture, Forestry and Other land Uses (AFOLU) reached important conclusions for synergistic climate and biodiversity action including that: ‘actions that protect offer the highest total and per area mitigation value of any action in the AFOLU sector’; ‘the protection of high biodiversity ecosystems such as primary forests delivers high synergies with GHG abatement’; ‘most mitigation options are available and ready to deploy and emissions reductions can be unlocked relatively quickly, (through) the protection of natural ecosystems’; and ‘avoiding the conversion of carbon-rich primary peatlands, coastal wetlands and forests is particularly important as most carbon lost from those ecosystems is irrecoverable through restoration by the 2050 timeline of achieving net zero carbon emissions (Goldstein et al. 2020)’.

The IPCC 6th Assessment Report of Working Group II on Impacts, Vulnerability and Adaptation, Summary for Policy Makers (SPM) concluded that ‘building the resilience of biodiversity and supporting ecosystem integrity can maintain benefits for people, including livelihoods, human health and well-being and the provision of food, fibre and water, as well as contribute to disaster risk reduction and climate change adaptation and mitigation’; and that ‘protecting and restoring ecosystems is essential for maintaining and enhancing the resilience of the biosphere’ . The SPM also supported the need to protect up to 50% of the planet to improve the health of the biosphere. “Recent analyses, drawing on a range of lines of evidence, suggest that maintaining the resilience of biodiversity and ecosystem services at a global scale depends on effective and equitable conservation of approximately 30%-50% of Earth’s land, freshwater and oceans, including currently near natural ecosystems…”

Recommendation 3: Utilise the UNSEEA-EA framework to develop methods and approaches to accounting that encourage synergistic/holistic climate and biodiversity action to help maintain and improve the integrity of ecosystems and reduce the risk of losing ecosystem carbon stocks to the atmosphere.

ACCU loopholes in the current scheme

While not a yet a major loophole, the change made by the Abbott government to the previous governments exclusion of native forest biomass as a source of renewable energy is poised to become a major problem with several Australian coal fired power stations either proposing or actively considering replacing coal with native forest biomass (See attached briefing note).

Burning wood is more emissive per unit of energy than coal. It is an industry created by false market signals of renewability and carbon neutrality because emissions are not accounted at the point of combustion. Worse, the impact of this new market has been to increase the area and intensity of logging in Europe, Canada and the US. Certified forest management practices in well regulated countries have not prevented this.

A recent scientific report from Griffith University, (Mackey et 2022) explains the problem. Various peculiarities of LULUCF carbon accounting mean that gross emissions from logging are not revealed, instead being netted out against forests growing elsewhere. Nor is the opportunity cost (the climate benefits of forest protection) ever revealed.

As a result of submissions made on this issue to the recent Senate Inquiry into the Climate Change Bill, the government is considering excluding NF material as a source of renewable energy under the Renewable Energy Act.

Currently, ACCU’s can be generated under several ERF waste management methods through substituting native forest biomass for coal – each of these methods rests on the current flawed regulation under the Renewable Energy Act.

Recommendation 4: Amend all waste management methods to exclude native forest waste as an eligible source of ACCU’s.

Forest Protection – a critical gap in ERF methods

Australia’s native forests are some of the most carbon dense on Earth (Keith et al 2009). One of the lowest cost and highest mitigation pathways would be through a method to encourage long term native forest protection – avoiding annual emissions from logging and enabling additional sequestration from allowing forests to grow past the age at which they are normally logged.

The average carbon stock of logged native forests is 50% below that of unlogged forests and it is noteworthy that Tasmania was the first state or territory to achieve net negative emissions (-4%) as a result of significantly increased native forest protection and reductions in logging due to the 2013 Tasmanian Forest Agreement (Mackey et al 2022).

At the time the Tasmanian VCS projects were transitioned into the ERF, Forests Alive had a list of some 40 landholders interested in protecting and restoring their native forest estates in preference to periodic logging. Political obstruction prevented the development of ERF forest protection methods thus denying landholders the option of improving the protection and allowing full recovery of their native forests. We now know that most forests sequester more carbon in the last two thirds of their life, contradicting the common belief that only young forests play an important role in carbon sequestration (Nexus Report: Nature based solutions to the biodiversity and climate crises, 2020; Moomaw et al 2019)

Developing robust forest protection methods requires utilising data on old growth forests for all forests ecosystems, including rainforests and other carbon dense forest ecosystems – only then can we accurately model forest carbon recovery potential. The starting stock for modelling forest carbon and logging impacts in native forests is not zero, it is the stock that existed prior to the commencement of commercial logging. And the maximum carbon stock in a native forest is not the stock in a wood production native forest immediately prior to logging, as many forest carbon models suggest.

Recommendation 5: Develop appropriate native forest protection methods to encourage private native forest owners to protect and restore their native forests, to protect existing stocks and encourage restoration in all forest ecosystems, including rainforests.

I am happy to answer any questions or provide further information on any of the issues raised in this submission.

Kind regards

Virginia Young

Director International forests and climate program, Australian Rainforest Conservation Society

Chair Gondwanalink Ltd

Board member Great Eastern Ranges Initiative.

(Ph: 0417 223280)

References

Barber C.V., R Petersen,V.Young, B.Mackey, C.Kormos, 2020, The Nexus Report: Nature Based Solutions to the Biodiversity and Climate Crises, F20 Foundations, Campaign for Nature and SEE Foundation.

Brando, P.M., Paolucci, L., Ummenhofer, C.C., Ordway, E.M., Hartmann, H., Cattau, M.E., Rattis L., Medjibe, V., Coe, M.T. and Balch, J. (2019). Droughts, wildfires, and forest carbon cycling: A pantropical synthesis. Annual Review of Earth and Planetary Sciences 47, 555-81.

Goldstein, A., Turner, W.R., Spawn, S.A., Anderson-Teixeira, K.J., Cook-Patton, S., Fargione, J., Gibbs, H.K., Griscom, B., Hewson, J.H., Howard, J.F., Ledezma, J.C., Page, S., Koh, L.P., Rockstrom, J., Sanderman, J and Hole, D.G. (2020). Protecting irrecoverable carbon in Earth’s ecosystems. Nature Climate Change 10, 287-295.

Keith et al 2009, Estimating carbon carrying capacity in natural forest ecosystems across heterogeneous landscapes addressing sources of error, Global Change Biology 16 297-2989

Keith et al 2021, Evaluating nature-based solutions for climate mitigation and conservation requires comprehensive carbon accounting, Science of the Total Environment.

Mackey et al 2013, Untangling the confusion around land carbon science & climate change mitigation policy, Nature Climate Change 3(6) 552- 57

Mackey et al, 2022, Net carbon accounting and reporting are a barrier to understanding the mitigation value of forest protection in developed countries, Environmental Research letters.

Mackey et al 2022, Burning forest biomass for energy: Not a source of clean energy and harmful to forest ecosystem integrity, Griffith University Press (https://doi.org/10.25904/1912/4547)

Moomaw WR et al 2019, Intact forests in the US:proforestation mitigate climate change and serve the greatest good, Frontiers in Forests and Global Change 2(27)

Spratt, D. and Dunlop, I. (2021a). Carbon Budgets for 1.5 and 2˚C: Briefing Note April 2021. Breakthrough National Centre for Climate Restoration.

Spratt, D. and Dunlop, I. (2021b) “Net zero 2050”: A dangerous illusion. Breakthrough National Centre For Climate Restoration. Briefing Note, July 2021.

Wilson and Bradstock, 2022, Past logging & wildfire increase above ground carbon stock losses from subsequent wildfire, Fire

2 September 2022

Briefing Note Re the Climate Change Bill 2022 and Climate Change (Consequential Amendments) Bill 2022

“Native forest wood waste is neither clean nor renewable”

Extract from speeches by Anthony Albanese and Mark Butler on the second reading of the Renewable Energy (Electricity) Amendment Bill 2/06/2015

Public Perception

Research conducted for Forests and Wood Products Australia, published by Canberra University in 2018 found that “Native forest logging was considered unacceptable by 65% of rural/regional and 70% of urban residents across Australia, and acceptable by 17% of rural and 10% of urban residents. Eleven per cent of rural/regional and 9% of urban residents found this neither acceptable or unacceptable, and 8% and 11% respectively were unsure whether it was acceptable. “(Report attached)

A decade ago, focus group research revealed that few people believed anyone could seriously propose to burn wood from native forests for power…”that's like going back to the dark ages” was a common refrain.

Burning native forest wood will be hugely unpopular and a key threat to the credibility of the government’s 2030 and 2050 emissions reduction targets unless the Gillard government regulation excluding NF biomass from the RE Act is urgently reinstated followed by legislative reform

Why is it urgent?

Co-firing wood with coal is already occurring at Vales Point Power station and Cape Byron Power. Three other major coal fired power stations are now well advanced in their planning to substitute wood for coal – two run by Stanwell in Queensland and Loy Yang B operated by Alinta in Victoria. Work is also well underway to resubmit a proposal to reopen the decommissioned Redbank coal fired power station near Singleton in NSW that would burn almost 1 million tonnes of native forest wood per year – more than twice the volume of woodchips ever exported from the forests of northern NSW.

How do we know markets for high volume/ low cost wood products will change which forests are classified as waste and where and how forests are logged?

Woodchips were introduced to Australia in the early 1970’s in the name of utilising waste arising from sawlog production. The resulting changes to logging practices and volumes of trees logged are well documented in Forestry Professor John Dargavels’ book, “Fashioning Australia’s Forests” 1995 – a history of the ways in which ‘markets have always shaped the way in which forests are logged’ and a devastating indictment of the impacts of clear-fell logging introduced to supply the near 40% increase in wood volumes needed to meet demand for woodchips “doubtless leading to more trees being cut …(and) radically refashioned the structure (age) of stands and the landscape of … forests.”. At the same time employment fell by 36% “.

In the logging industry ‘waste’ is commonly defined as any tree for which there is no higher value. It is common in Tasmania for 90% of the trees cut in a logging coupe to be classified as pup logs or waste – and in southern NSW and East Gippsland 80%. With the decline in export woodchipping a new market is needed for ‘pulp logs to provide the economic underpinning to produce an ever decreasing volume of sawn timber,

In 1990-91, 350,000 tonnes of woodchips were exported from Newcastle with a similar volume of sawlogs produced. By 2017 pulp log production had fallen to 21,397 tonnes p.a. and sawlogs to 187,835 tonnes p.a. . In 2019 the entire volume of all native forest wood production in NSW, including pulp logs, was 1 million tonnes per annum - the same amount of wood needed to supply the Redbank Power Station. Yet proponents say they have an assured wood supply from within a 300 km radius around the power plant.

There is no product produced from native forests that cannot be produced from our existing plantation estate.

Consider for a moment the cost of coal for domestic electricity generation and how this cost compares to the cost of wood? What will happen if the price for wood pellets outcompetes not just coal but all but the very highest grade of sawlogs?

Why are claims of ‘renewability’ and carbon neutrality so misleading?

LULCF carbon accounting rules allow emissions from logging to be offset by re-growth in the much larger area of the entire production forest estate. The result is we never see the blindingly obvious that carbon lost in logged areas takes decades to recover. Any forest logged that is older than 30 years cannot recover carbon lost before 2050. Other peculiarities of LULUCF carbon rules include ‘forward looking baselines’ devised to create space for policy change that would result in increases in emissions. Emissions from logging need only be accounted when they exceed that baseline.

Not accounting for emissions from wood at the point of combustion means it counts as zero emissions at the Stack…a truly perverse market signal given that generating energy from native forest biomass results in more GHG emissions per unit of energy than coal. Allowing coal fired power stations to substitute wood would be a get out of gaol free card to energy generators – falsely making their emissions look 10, 50 or 100% lower than they actually are depending on the % of wood substituted for coal. The cost of trying to reign this industry in after the fact doesn’t bear thinking about.

Note that we never see the opportunity cost to carbon sequestration and storage from continuing to log native forests….an important consideration given that we know the average carbon stock in a logged forest is 50% below that in an old growth forest and in cool wet temperate forests as much as 70% lower.

Lessons learned from countries that have welcomed this industry

The short legacy since this industry was introduced in Europe and North America about a decade ago is a devastating increase in volumes of trees logged, including forests previously considered unsuitable for logging – e.g., old growth forests in Romania, Slovakia and other parts of Eastern Europe, the USA and Canada. In Europe logging rotations have been reduced to supply demand – turning forests into a net source rather than a net sink for CO2 - just this year Finland joined the growing list. There will be an expose on the impact of the biomass industry on US Forests next week in the NY Times.

And of course scientists are becoming increasingly concerned about what the atmosphere sees, particularly as demand for wood pellets is expected to grow by more than 250% over the next decade…a market fuelled by forest carbon accounting rules that leave emissions variably accounted for in the country of origin and accounted as zero emissions in the consuming country – giving the entirely false perception that emission have been reduced!

The industry is a creation of deeply flawed carbon accounting rules sending incorrect market signals…It is noteworthy that the US State of Massachusses recently ruled against burning wood being considered renewable or clean.

Virginia Young

Board Member, Wilderness Australia

Summary of facts

1. Science on the climate impacts of logging versus protecting forests is clear

The myth that logging is carbon neutral has been promoted through a carbon accounting sleight of hand that allows emissions from areas logged in any year to be netted out by sequestration in the entire forest estate.

Unlogged forests store 40% to 55% more carbon than logged forests.

Peer reviewed evidence shows native forest logging makes forests more flammable and leads to elevated fire severity.

Allowing forests to grow old, known as ‘proforestation’, is the fastest and lowest risk pathway to increase sequestration in forests, given that they sequester more carbon, more securely in the last two thirds of their life than in the first third.

Protection offers the highest total and per hectare climate mitigation value of any climate action in forests.

2. Markets influence the intensity of logging

Markets have always determined which forests are economical to log.

By providing a market for trees that would otherwise have no commercial value (a flexible concept used to define waste), wood bioenergy will inevitably lead to an intensification of logging of native forests.

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.

The introduction of woodchip markets provides a perfect example of the radical change in area, age and type of forests logged to supply that market.

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.

3. The entwined nature of the climate and biodiversity crises.

The biodiversity crisis is as serious a threat to life on Earth as the climate crisis.

At a joint workshop last year, the scientific advisory bodies to the United Nations Framework Convention on Climate Change and the Convention on Biological Diversity, IPCC and IPBES respectively concluded that each crisis amplifies the other and that neither crisis can be solved unless they are solved together.

The workshop identified priorities for synergistic action – the top two being the protection and restoration of carbon and species-rich ecosystems such as forests.

Given the parlous state of biodiversity in Australia and escalating risks of species loss from a range of interacting threats including logging, fire and climate change, it is imperative we shift the focus of managing native forests to ecological recovery in order to increase their stability and resilience. 10

Intensified logging of Australia’s native forests – a very real risk while native forest biomass remains an eligible source of renewable energy under federal law