The scientist who helped build the carbon model behind Australia’s greenhouse accounts has told the federal government to withdraw the funding for the Great Koala National Park. That is according to John Raison, a former CSIRO chief research scientist, whose second open letter on the method reached Climate Change and Energy Minister Chris Bowen on Monday, in a copy obtained by Wood Central.
“Establishing the GKNP will do nothing for the protection of koalas,” Raison wrote of the 176,000 hectares of state forest the park will take in. He cites work by NSW government scientists and the CSIRO that he says finds koala numbers in the state’s north-east abundant, and no different between harvested and conserved forest.
Raison wrote to Bowen on the same method on 7 July, warning then that it would mint bogus offsets, and returns with concerns he says are now shared across the science community, industry, and regional communities. Passing it in its present form would damage trust in Australia’s carbon offsets, he argues, and any new method would face external review before the committee sees it again.
“There are fundamental problems with this Method,” Michelle Freeman, President of Forestry Australia, said last week of a finding putting 11 million of the 22 million credits New South Wales has promoted at risk. Raison puts the over-crediting of forest carbon stocks at 50 to 100 per cent, and says the settings were never adjusted for the selective harvesting that dominates Australian native forests.
Senators vote on 18 August on the disallowance motion lodged by NSW Nationals Senator Ross Cadell against the method, 15 days after the letter reached Bowen, and the result decides whether New South Wales can register the koala park as its first project.
Wood Central has been granted permission to publish John Raison’s letter to Minister Bowen in full:
The INFM method is flawed on science and fails on integrity, and if enacted would erode the credibility of carbon offset programs in Australia
Dr John Raison, Former CSIRO Chief Research Scientist
Dear Minister
I wrote to you earlier (7 July 2026) highlighting the serious flaws with the recently determined Improved Native Forest Management in Multiple-use Public Native Forests (INFM) ACCU method that would lead to it creating ‘bogus’ carbon offsets. My views are now widely shared by many other scientists, industry and others, and hence I am writing to you again.
Serious concerns with the INFM method include the inappropriate application of FullCAM for estimating change in forest carbon in both ‘baseline’ and ‘project’ forests, as well as underestimates of carbon leakage (to harvested domestic forests outside the project area, to imports and to higher emissions construction materials). These would result in major over crediting – consequently, any ACCUs generated would overestimate the real abatement of carbon in the global atmosphere.
Recent assessments by forest carbon scientists within Forestry Australia (FA) show that the INFM is structurally biased toward over-crediting and that the prescribed FullCAM settings are not appropriately applied. They also found that FullCAM has not been properly applied to reflect changes after selective harvesting, which is the dominant harvesting system used in Australian native forests. Furthermore, the use of FullCAM within the INFM is inconsistent with how it is used in Australia’s National Greenhouse Gas Inventory.
The FA assessment found that in relation to within-forest carbon stocks, over-crediting may be of the order of 50-100%. This is excluding either carbon stored in wood products or leakage which will also markedly erode estimated credits. The treatment of leakage within the INFM is totally inadequate and does not reflect either scientific principles or information based on imports of wood products and their sources. An arbitrary cap of 0-40% is applied, despite abundant evidence that this is unrealistically low.
Forestry Australia stressed that the potential impacts of INFM projects have not been properly assessed and that there are significant risks of creating harm to both the environment and to regional communities. All major industry groups have alerted that there will be highly negative impacts on regional communities. The moratorium on harvesting in areas proposed to be added to the GKNP is already resulting in loss of jobs within FCNSW and the private sector. Doubtless there will be many more if transfer of those areas proceeds. We witness these outcomes, while there is increasing robust scientific evidence from NSW government scientists and CSIRO that koala populations in NE NSW are abundant and there is no difference in their populations between forests subjected to regulated harvesting and conserved forests. Thus, establishing the GKNP will do nothing for the protection of koalas.
A recent peer reviewed paper (Raison et al., 2026) illustrated that proposals for a total ban of all harvests from native forests has no scientific basis and that sustainable harvest from small, selected areas would provide net benefit on environmental and rural socio-economic grounds. There is no evidence that harvesting causes any net emissions of carbon when the accounting is done using a full Life Cycle Analysis approach.
Unfortunately, the INFM is not built on our understanding of the disturbance ecology (responses to fire and harvesting) of native forests evolved over many decades, or contemporary approaches to correctly estimating complete carbon accounts after forest harvesting. The weak science and methodology upon which INFM is based, sadly, is a disservice to Australia.
Given the serious concerns over facts, science and integrity, the INFM method if legislated would seriously erode Australia’s credibility on carbon-offset programs and emissions reduction. I join the call by many others for Government to withdraw the INFM method in its present form. Should the proponent decide to submit a new method, it should be subjected to rigorous, independent and transparent scientific review before it is considered by the ERAC.
Thank you,
Dr John Raison
Former Chief Research Scientist, CSIRO
Relevant qualifications of the author to comment on the INFM method
Raison studied the ecology of Australia’s native forests during a 40-year career with CSIRO and has detailed knowledge of forest C cycling and of how this is changed by forest disturbance, particularly harvesting and fire. He was a major contributor to the development of the initial versions of FullCAM that underpinned Australia’s National Carbon Accounting System. Working with the IPCC, he was a major author of both Good Practice Guidance (2003) and the GHG accounting Guidelines (2006) for the land sector, which are used by countries for reporting to the UNFCCC. In 2024, he published a major scientific review on carbon dynamics in disturbed Australian native forests.
