Biomass Action Group
30 June 2009
Environmental Protection Authority
Submission for Mid-Term Audit of the Forest
Management Plan 2004-13: Opposing Use of Native
Forest as Fuel for Biomass Power Plants
SUMMARY AND RECOMMENDATION: There is
demonstrable risk that the Forest Management
Plan 2004-13 will be applied for supply of
unique native forest resource as fuel for
biomass power plants. Use of native forest as
fuel for biomass power plants threatens to cause
further depletion of State forest ecosystems in
a similar manner to depletion of State forest
through woodchipping of marri and karri. It is
recommended the EPA oppose use of native forest
as fuel for biomass power plants and apply a
condition to the Forest Management Plan 2004-13
preventing use of native forest as fuel for
biomass power plants.
I write on behalf of the ‘Biomass Action Group’,
an informal association of persons in the
Manjimup and Pemberton area with agribusiness,
tourism, conservation, property and other
interests in regard to a proposal by WA Biomass
Pty Ltd for a 40MW biomass power plant to be
located at Diamond Mill south of Manjimup. We
are concerned the Forest Management Plan 2004-13
will be applied to large scale exploitation of
unique native forest ecosystems to supply logs
and other wood resource as fuel for biomass
power plants.
Members of the Biomass Action Group made
submissions on the ‘PUBLIC
ENVIRONMENTAL REVIEW
FOR BIOMASS POWER PLANT, DIAMOND MILL, MANJIMUP’
in February 2008 which included submission on
‘Impacts of expansion at Diamond Mill based on
wood fuel from Karri forest’ which is copied
below in an Appendix to this submission
for the mid-term audit of the Forest Management
Plan 2004-13. The submission copied in the
Appendix referred to the misuse of the terms
native ‘forest residue’ and ‘forest waste’ - now
applied to fuel for biomass power plants - which
previously justified production of over 500,000
tonnes per annum of marri and karri woodchips
from the magnificent State forest surrounding
Manjimup and Pemberton. There is substantial
reason to mistrust government agencies and
politicians who use and abuse these terms in
relation to our precious native forest.
In response to
demonstrable public interest and concern that a
biomass power plant located at Diamond Mill
could lead to use of adjacent karri, marri and
jarrah resource as fuel for the power plant, the
EPA applied condition 6-1 that “The proposal
shall only use waste from Eucalyptus Globulus
and Pinus Radiata plantations as a fuel source.”
and the Minister for Environment accepted the
condition. However, this public interest and
concern will persist if a biomass power plant is
located at Diamond Mill at the hub of the road
network for the previous ‘Marri Woodchip
Project’ in State forest. WA Biomass Pty Ltd is
a consortium of Babcock and Brown Limited
related entities, since our February 2008
submissions on the PER for the project at
Diamond Mill, Babcock and Brown Limited has
collapsed into the care of administrators, with
massive outstanding debt, and has been delisted
from the ASX. We believe it is probable Babcock
and Brown related interests will attempt to sell
the ‘approved project’ at Diamond Mill, and that
due diligence by potential buyers will find the
project is not commercially viable based on
transport of Eucalyptus Globulus and Pinus
Radiata on public roads from up to 100
kilometers distant and they will pressure the
State Government for use of adjacent karri and
marri as fuel. The Forests Products Commission
and the Department of Environment and
Conservation support use of karri and marri
‘waste’ and ‘residue’ as fuel for biomass power
plants; we urge the EPA to strongly oppose use
of native forest as fuel for biomass power
plants.
Since our February 2008 submission to the EPA
opposing possible use of karri and marri fuel
for the proposed biomass power plant at Diamond
Mill, it has been publicised that the Forest
Products Commission are in discussion with
Griffin Energy for supply of 250,000 tonnes per
annum of jarrah and marri logs to be burnt as
biomass fuel at the Bluewaters Power Station
near Collie. The discussions include a further
150,000 tonnes of jarrah and marri logs being
available if required by Griffin Energy. We are
aware the Wilderness Society, Western Australian
Forest Alliance and the Conservation Council of
WA wrote to the Minister for Environment in May
2009 objecting to this potential supply of
jarrah and marri to be burnt as biomass fuel and
we strongly support their objections. We urge
the EPA to oppose the use of jarrah and marri as
biomass fuel at the Bluewaters Power Station and
to advise the Minister for Environment
accordingly. Beyond our general concern at
depletion of State forest for use as biomass
fuel, we are specifically concerned use of
native forest as fuel at the Bluewaters Power
Station will serve as a precedent for use of
native forest (karri and marri) as fuel at the
proposed 40MW biomass power plant at Diamond
Mill. Given it is unlikely Babcock and Brown
related entities will proceed with the 40MW
biomass power plant at Diamond Mill using
380,000 tonnes per annum of Eucalyptus Globulus
and Pinus Radiata, that plantation resource
should be offered to Griffin Energy for use as
biomass fuel in the alternative to native
forest.
Biomass Action Group
www.nobiomass.com
…….. APPENDIX ………
Excerpt from submission to EPA on
PUBLIC ENVIRONMENTAL REVIEW FOR BIOMASS POWER
PLANT, DIAMOND MILL, MANJIMUP
by Neil Bartholomaeus, 25 February 2008
5. Impacts of expansion at Diamond Mill based
on wood fuel from Karri forest
There are grounds for concern the Karri forest
will be used as fuel for biomass power
generation at Diamond Mill:
·
the Minister for Forestry
on 29 November 2007 in answer to Parliamentary
Question 5603 said Karri, Jarrah and Marri will
be offered by tender to energy markets;
·
in a 25 January 2008 letter responding to
private questions on this, the Minister for
Forestry said “I understand that the Manjimup
biomass plant in question does not intend, under
its current application process, to utilise fuel
from native forest residues. Should the project
ever reach a stage where it wished to expand its
operation, that expansion would be subject of a
further assessment process.”;
·
it is reasonably foreseeable that such energy
generation using Karri, Jarrah and Marri will be
conducted within the Diamond Mill precinct near
Manjimup, taking advantage of the extensive
network of roads previously used for the ‘Marri
Woodchip Project’, for transport cost savings;
and
·
it is reasonably foreseeable that Karri, Jarrah
and Marri will be burnt in the proposed Biomass
Power Plant at Diamond Mill, as a commercially
advantageous variation to the 380,000 tonnes per
annum wood fuel mix for the 40MW capacity, and
for expansion beyond 40MW output.
In the Minister for Forestry’s answer to
Parliamentary Question 5603 he said Karri,
Jarrah and Marri ‘forest residue’ and ‘forest
waste’ will be used for energy markets. These
‘forest residue’ and ‘forest waste’ terms are
precisely the same terms that were used to
justify the notorious 'Marri Woodchip Project',
where Marri was described as residue and waste
from clear felling, and millions of tonnes were
squandered as woodchips. Now, Marri is in demand
for furniture and flooring; exemplifying 'forest
residue’ and ‘forest waste' is misused
terminology.
The language of the Minister for Forestry of 25
January 2008 re “Should
the project ever reach a stage where it wished
to expand its operation, that expansion would be
subject of a further assessment process.”
is reminiscent of the ‘staged’
development of the Wagerup Alumina Refinery
which has devastated the previously rural
township of Yarloop. Neither the EPA nor a
‘community reference group’ (Public
Environmental Review page 203) saved Yarloop.
The negative impacts on public health (2 above),
on agribusiness (3 above) and the local
agribusiness and tourism economies (4 above)
will compound if biomass power generation
expands at Diamond Mill.
The Forest Products Commission 2006-2007 Annual
Report at
page 21 states:
"Bioenergy development
The Commission is actively working with a number
of parties to develop and promote renewable
energy opportunities."
"Tender process for residues
The Commission continues to work actively to
finalise markets for native forest derived
residues. Due to increasing enquiries
particularly from bioenergy companies, the
Commission decided to call for tenders. It is
expected that tenders will be requested late in
2007."
The Forest Products Commission doesn’t appear to
have offered the tender for Karri, Jarrah and
Marri ‘residues’ yet. It is possible they will
hold that until the Biomass Power Plant at
Diamond Mill has approval of its
Public Environmental Review
based on Tasmanian
bluegum and pine, and then the tender could be
offered for a shift in fuel resource mix and/or
expansion beyond 40MW generation capacity.
In addition to exacerbation of impacts from
pollution, expansion at Diamond Mill based on
fuel from native forest will evoke massive
controversy similar to that which surrounded the
notorious ‘Marri Woodchip Project’. Such
controversy will further discourage tourism and
eco-tourism based on the Karri forest, and also
discourage new residents seeking ‘lifestyle’
based on the Karri forest, for which there are
several developments progressing in the Shire of
Manjimup.
Recommendation 7: The EPA should ask the
proponent of the
Biomass Power Plant at Diamond Mill if it has
intentions of expanding beyond 40MW generation
capacity at Diamond Mill, and if it does, the
EPA should request a supplement to the
Public Environmental Review providing
preliminary information on environmental impacts
and management of impacts beyond 40MW capacity.
Recommendation 8: The EPA should ask the
proponent of the
Biomass Power Plant at Diamond Mill if it or
associated companies have approached the Forest
Products Commission enquiring about access to
native forest derived fuel, and if so, whether
the proponent envisages use of native forest
derived fuel within the wood fuel mix for up to
40MW generation capacity, and/or for expansion
beyond 40MW capacity. The EPA should verify the
proponent’s response with the Forest Products
Commission.
Recommendation 9: The EPA oppose use of Karri,
Jarrah and Marri from native forests as fuel for
biomass power generation at Diamond Mill and
elsewhere in WA.
