Open letter to Premier Chris Minns and Minister Penny Sharpe, regarding the G.K.N.P and the INF Methodology 2025.

Dear Premier Minns and Minister Sharpe,

I write to you not only as a concerned regional resident, but as an agricultural data management and compliance consultant who works directly with primary producers across New South Wales. Through my business, Agri Assist Support Services, I assist farmers to navigate complex regulatory frameworks, improve compliance systems, and explore participation in carbon markets as a means of diversifying and strengthening their farming enterprises. Having reviewed the proposed Great Koala National Park, the Improved Native Forest Management (INFM) Methodology, relevant provisions of the Carbon Credits (Carbon Farming Initiative) Act 2011, and publicly available government information, I have identified a number of significant questions and concerns that I believe warrant clear and transparent answers. Given the potential economic, environmental, social and carbon market implications of this proposal, I believe it is essential that affected communities, landholders and stakeholders are provided with sufficient information to fully understand both the opportunities and risks associated with the creation of the Great Koala National Park. The following questions are submitted in the interest of transparency, accountability and evidence-based decision-making.

1. Is the Great Koala National Park financially viable as a long-term carbon project?

The proposed carbon project relies on the Improved Native Forest Management (INFM) Methodology,

which only allows eligible areas of forest to generate ACCUs. Significant areas of the proposed GKNP

footprint may be excluded from credit generation due to reserve status, old-growth classification,

operational constraints, or other methodology requirements. My concern is whether sufficient creditable

land exists to support the revenue projections being discussed publicly.

Relevant References:

• Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act), Sections 106–113 (Methodology

Determinations)

• INFM Methodology, Section 2 (Eligible Project Activities)

• INFM Methodology, Section 24, Table 1 (Carbon pools and emission sources)

2. Does the project genuinely satisfy the additionality requirements of the Carbon Farming Initiative?

The INFM methodology relies upon avoided harvesting compared to a historical baseline scenario.

However, native forest harvesting volumes in NSW have already been declining for many years. My

concern is whether the project can legitimately claim substantial additional carbon abatement if harvesting

was already trending downward before the project was proposed.

Relevant References:

• CFI Act, Section 107 (Baseline Determination)

• CFI Act, Sections 106–113 (Methodology Integrity Requirements)

• INFM Methodology, Sustainable Yield Baseline Provisions

• INFM Methodology, Section 2 (Harvest Deferral and Harvest Cessation Activities)

3. How will the Government manage the financial risk of future bushfires?

Large portions of the proposed GKNP footprint were affected during the 2019–2020 Black Summer

bushfires. The methodology acknowledges the risk of carbon stock loss through disturbance events. My

concern is whether future bushfires could significantly reduce the project's ability to generate ACCUs and

undermine its long-term financial viability.

Relevant References:

• INFM Methodology, Section 24, Table 1

• INFM Methodology Explanatory Statement (Bushfire Risk Discussion)

• CFI Act, Sequestration Project Permanence Requirements

4. What is the taxpayer exposure if carbon credits must be repaid?

If carbon stocks are lost through future bushfires or other disturbance events, there may be obligations

associated with reversal events. My concern is whether the Government has assessed the potential

financial liability if ACCUs need to be replaced or surrendered at significantly higher future market values.

Relevant References:

• CFI Act, Section 54 (Sequestration Offsets Projects)

• CFI Act Permanence and Reversal Provisions

• INFM Methodology Disturbance and Reversal Framework

5. Is the carbon accounting system sufficiently independent and transparent?

Carbon projects rely heavily on modelling, auditing and regulatory oversight. My concern is whether the

public has access to sufficient information to independently assess the assumptions, modelling inputs and

projected outcomes associated with the GKNP carbon project.

Relevant References:

• CFI Act, Sections 106–113 (Methodology Determinations and Integrity Standards)

• FullCAM Carbon Accounting Framework

• ACCU Scheme Audit Requirements

6. Does the Government intend to pursue biodiversity credit stacking within the GKNP?

There has been significant discussion nationally regarding biodiversity markets, Nature Repair Market

projects and biodiversity-linked carbon products. My concern is whether the proposed park may eventually

be used to generate multiple environmental products from the same land base.

Relevant References:

• Nature Repair Market legislation

• Biodiversity Conservation Frameworks

• INFM Methodology Project Boundary Provisions

7. How will koala translocation and biodiversity reporting be managed transparently?

Koala translocation is a recognised wildlife management tool. My concern is how future biodiversity

outcomes within the park will be measured and reported, and whether population increases will be clearly

distinguished between natural population growth and management interventions.

Relevant References:

• NSW Koala Strategy Documentation

• Biodiversity Monitoring and Reporting Frameworks

8. Why are most koalas currently located outside National Parks?

NSW Government habitat mapping indicates that a significant proportion of koala habitat occurs on

private land and within State Forests. My concern is that this reality appears inconsistent with claims that

large-scale reservation is the only viable pathway to koala conservation.

Relevant References:

• NSW Koala Strategy Mapping

• Great Koala National Park Assessment Data

• INFM Methodology Project Area Definitions

9. How will the Government manage koalas that live on private land?

If most koala habitat occurs outside reserve systems, then the long-term future of koala conservation must

involve private landholders and working landscapes. My concern is what strategy exists to support koala

populations outside the proposed park boundary.

Relevant References:

• NSW Koala Strategy

• Private Native Forestry Frameworks

• Biodiversity Conservation Act Provisions

10. Could the park create unintended timber market consequences?

The INFM methodology recognises leakage risk. My concern is that removing substantial volumes of

native hardwood supply could shift harvesting pressure elsewhere, increase imports, or accelerate

plantation expansion onto productive agricultural land.

Relevant References:

• INFM Methodology Leakage Provisions

• INFM Methodology Section 3 (Emission Sources and Accounting Boundaries)

• CFI Act Methodology Integrity Requirements

11. Has the impact on regional employment been properly assessed?

Forestry, agriculture, transport and manufacturing remain significant contributors to regional economies.

My concern is whether the Government has publicly released independent modelling that accurately

quantifies the economic impacts of the proposal.

Relevant References:

• CFI Act, Section 56 (Material Adverse Impacts)

• Regional Economic Impact Assessment Requirements

• NSW Forestry Industry Data

12. What impacts will the park have on agriculture and food security?

The Carbon Farming Initiative framework specifically recognises the importance of considering impacts

on agricultural production and regional communities. My concern is whether adequate assessment has

been undertaken regarding the effect of the proposal on agricultural resilience.

Relevant References:

• CFI Act, Section 56 (Material Adverse Impacts on Agricultural Production and Communities)

• Regional Land Use Planning Frameworks

13. What happens to crown grazing leases and farming resilience?

Many producers rely on crown grazing leases during drought and seasonal shortages. My concern is

whether sufficient consideration has been given to the role these leases play in maintaining agricultural

resilience.

Relevant References:

• Crown Lands Management Framework

• CFI Act, Section 56

• Regional Drought Resilience Policies

14. Could plantation expansion place additional pressure on agricultural land?

As Australia increasingly relies on plantation timber resources, reduced native timber supply may increase

pressure to establish plantations on productive agricultural land. My concern is whether this consequence

has been adequately assessed.

Relevant References:

• INFM Methodology Leakage Provisions

• National Forestry and Plantation Strategies

• Agricultural Land Protection Frameworks

15. How will tourism emissions be accounted for?

The proposed GKNP has been promoted as a significant tourism destination. My concern is how

emissions associated with visitor infrastructure, roads, waste management, maintenance activities and

increased visitation will be incorporated into the overall carbon accounting framework.

Relevant References:

• INFM Methodology Section 3 (Carbon Pools and Emission Sources)

• INFM Methodology Section 24, Table 1

• FullCAM Accounting Requirements

• CFI Act Operational Emissions Accounting Provisions

16. Why was meaningful consultation not undertaken before the proposal was announced?

Perhaps the most important concern relates to process. Many farmers, contractors, forestry workers,

leaseholders and regional businesses believe they were not adequately consulted before the proposal was

publicly advanced. Regardless of one's position on the park, major land-use decisions should be supported

by transparent consultation and genuine engagement.

Relevant References:

• Principles of Best-Practice Regulatory Consultation

• CFI Act Section 56 (Community Impact Considerations)

• NSW Government Consultation Guidelines

As an agricultural data management and compliance consultant who assists farmers in exploring carbon market opportunities and implementing carbon project compliance frameworks, my concerns are not with carbon farming itself. Rather, my concerns relate to whether the proposed GKNP has been subjected to sufficient scrutiny regarding its carbon accounting assumptions, additionality claims, bushfire risk, economic impacts, biodiversity outcomes, agricultural consequences and long-term governance arrangements.

These questions are intended to encourage transparency, accountability and evidence-based decision

making before a proposal of this scale permanently reshapes regional New South Wales.

Kind regards,

Jaimie Vidler.

Agri Assist Support Services.