Submission to the National Bioenergy Feedstock Strategy Consultation
EFF strongly supports National Bioenergy Feedstock Strategy's objective to grow domestic feedstock supply chains in ways that maximise opportunities for agriculture and forestry while remaining complementary to food and fibre. We also recognise this work sits alongside Government initiatives such as the Cleaner Fuels Program, expansion of the Guarantee of Origin (GO) scheme to low-carbon liquid fuels, and the new Paraffinic Diesel Standard.
Our submission proposes three practical integrity guardrails to help the Department deliver these aims while creating new, diversified income streams for Australian producers:
Make ILUC accounting mandatory within the GO scheme using Australia-specific defaults, with pathways to project-level data where producers can demonstrate low-ILUC risk.
Establish a feedstock merit order for aviation and maritime through eligibility and crediting settings, while road transport continues to electrify.
Back advanced feedstocks and pre-processing infrastructure (residues, lignocellulosics) to unlock the 38.5–114 Mt/year residue potential identified by CSIRO, reducing competition with food and water.
This submission draws closely on the work of our partner, T&E. In particular their paper CrOP30 - Why burning food for land-hungry biofuels is fueling the climate crisis as well as primary academic research conducted by Ceurology, available here.
