Forestry Australia is raising serious concerns about the new Improved Native Forest Management in Multiple-use Public Native Forests Method (INFM Method), after technical analysis by its forest carbon experts identified material flaws that could systematically, and significantly, overstate carbon abatement.

Analysis by Forestry Australia’s forest carbon experts indicates the INFM Method could potentially over-credit projects by 40 to 100 per cent, even before the full effects of leakage and carbon stored in harvested wood products are taken into account. Forestry Australia President Dr Michelle Freeman said the findings raise serious concerns about whether credits issued under the INFM Method would represent genuine climate benefit

“There are fundamental problems with this Method. Its prescribed accounting and modelling framework is structurally biased towards issuing more carbon credits than the genuine climate benefit achieved,” Dr Freeman said.

“Forestry Australia supports credible investment in forest carbon and does not dispute that avoiding native forest harvesting can generate genuine abatement in some circumstances. But every ACCU issued must represent a real, additional and accurately measured tonne of emissions reduction.”

“That is why the maths must add up.” Dr Freeman said.

Forestry Australia’s assessment identifies three central problems:

The 15-year accounting period is too short: This is significantly shorter than the periods commonly used in forest carbon accounting; for example, the Plantation Forestry Method uses a 100-year accounting period. While harvesting causes an initial loss of forest carbon, regrowth captures carbon over many decades. Ending the accounting after 15 years excludes much of this regrowth, making the baseline appear to store less carbon and inflating the estimated carbon benefit of the Method.

The accounting structure over-credits projects upfront and relies on future deductions: The INFM Method over-credits projects up front. Later reporting periods then deduct some of the earlier credits as regrowth occurs to claw back some of what was over-credited. The appearance of continuing carbon benefit therefore depends on repeatedly adding new areas; if that flow slows or stops, the underlying shortfall becomes visible.

FullCAM is applied incorrectly: The Method prescribes clearfall harvesting assumptions to be implemented in FullCAM, Australian Government’s tool for estimating greenhouse gas emissions and carbon stored in forests and land. Given the vast majority of native forest harvesting in Australia is implemented as selective or partial harvest, the INFM Method adopts an approach that does not reflect on-ground outcomes and is inconsistent with the settings used in Australia’s National Greenhouse Gas Inventory. This misapplication of the model in FullCAM exaggerates the difference between the project and baseline forests and inflates the estimated carbon benefit.

Forestry Australia’s testing indicates that correcting the short accounting-window issue alone could reduce estimated abatement by more than 40 per cent. Correcting the FullCAM modelling could reduce estimated abatement by more than 50 per cent.

“These are not marginal differences arising from professional judgement. They are material and cumulative problems embedded in the Method’s prescribed calculations,” Dr Freeman said.

Millions of ACCUs could be issued without a genuine carbon benefit.

The consequences could be significant because ACCUs generated under the Method may be used to offset real greenhouse gas emissions elsewhere in the economy.

“If the Method overstates the carbon benefits achieved, emissions offset through the purchase of ACCUs will not be balanced by an equivalent climate benefit. That weakens confidence in the ACCU Scheme, makes it harder for Australia to genuinely meet its emissions-reduction targets and means the Safeguard Mechanism will not work as intended.”

New South Wales has promoted that it could generate approximately 22 million ACCUs over 15 years by ending timber harvesting in relevant public native forests. If the Method overstates abatement by around half, approximately 11 million ACCUs could be issued beyond the genuine carbon benefit achieved.

Forestry Australia raised its concerns more than 12 months ago and repeatedly requested representative FullCAM files, modelling assumptions and sufficient technical detail to independently reproduce and test the claimed abatement outcomes. These materials have not been publicly released by the proponent, and material changes introduced by the proponent after consultation were not exposed to further independent testing.

“A method with the potential to materially affect Australia’s carbon market should be transparent, reproducible and scientifically defensible. This is what is expected of a high-integrity ACCU Scheme method, yet the INFM Method has not met this bar,” Dr Freeman said.

Forestry Australia has also identified broader integrity risks relating to leakage, additionality and double counting. The Method caps indirect leakage at 40 per cent even where an independent assessment might find a higher rate. Furthermore, it does not provide sufficient safeguards to objectively demonstrate that harvesting reductions would not have occurred anyway. In addition, it creates a risk that state governments could generate and sell ACCUs while also counting the same emissions reductions towards their own reporting and targets.

“In raising these concerns, Forestry Australia is seeking to safeguard the ACCU Scheme, not undermine it. The fastest way to damage confidence in a carbon market is to issue more abatement than is really there and try to resolve the problem later. It is far better to address it openly now.” Dr Freeman said.

Based on the evidence currently available, Forestry Australia considers that the INFM Method should not be relied upon for ACCU issuance until its accounting and modelling problems have been resolved.

Forestry Australia remains ready to provide technical expertise to government and supports the development of credible carbon methods that reward genuine improvements in forest management, health and resilience across all forest types and land tenures.

• Briefing Note: Forestry Australia’s analysis of Improved Native Forest Management Method (INFM Method)
• Submission: Response to the NSW Government on the proposed Improved Native Forest Management in Multiple-use Public Native Forests Method (INFM Method), July 2025
• Submission: Response to the Emissions Reduction Assurance Committee (ERAC) on the proposed Improved Native Forest Management in Multiple-use Public Native Forests Method (INFM Method), January 2026

ENDS

Contact: Jason Ross Marketing & Communications Manager M: 0448 190 055

ABOUT FORESTRY AUSTRALIA

Forestry Australia is an independent, not-for-profit professional association representing more than 1,150 forest scientists, managers, professionals and growers. Operating across native forests, plantations, farm forestry and environmental services, our members bring deep scientific knowledge and practical experience in forest, fire, carbon, tree-growing and landscape management. Through their work, they study, manage and care for Australia’s forests and are committed to delivering positive environmental, social, cultural and economic outcomes across all forest types and land tenures.