The Greenhouse Gas Protocol has “delegated forest carbon accounting standards to a secret industry-led working group”

Danny Cullenward has resigned from the Greenhouse Gas Protocol’s Independent Standards Board.

Danny Cullenward, a Senior Fellow with the Kleinman Center for Energy Policy at the University of Pennsylvania, has resigned from the Greenhouse Gas Protocol’s Independent Standards Board.

“The Protocol is openly violating its own rules,” Cullenward writes on BlueSky, “and has effectively delegated forest carbon accounting standards to a secret, industry-led working group.”

Cullenward posted his resignation letter on BlueSky — it is also available in full below.

The Greenhouse Gas Protocol was launched in the late 1990s. It is run by the World Resources Institute and the World Business Council on Sustainable Development. It is the leading standard for corporate carbon accounting with more than 22,000 companies using its methodologies to report their emissions.

The land sector standard

The Greenhouse Gas Protocol has been working on a land sector standard for several years. In January 2024, The Washington Post reported that the draft guidelines, published in autumn 2023 were criticised by dozens of environmental groups and academics. The proposed rules would allow companies to claim destructive products such as timber, paper, beef, and milk are “carbon neutral” by making small changes that don’t actually reduce emissions.

William Moomaw, an environmental policy professor at Tufts University, told the Washington Post that,

“The process was incrementally eroded until it became fully captured by the companies who want to get credit for addressing climate change without changing what they are doing.”

“Kafkaesque”

Kate Dooley, a lecturer at the University of Melbourne’s School of Geography, Earth and Atmospheric Sciences, is a member of the Greenhouse Gas Protocol’s technical working group on forest carbon accounting. In April 2026, she spoke to Emily Pontecorvo, a journalist with Heatmap, about a discussion over how companies should account for carbon emissions from harvesting forests, land management and buying wood products.

There were two proposals, one from forest industry and landowner organisations and one from independent scientists. The technical working group held a series of meetings over a six month period, but could not reach consensus.

In spring 2025, the technical working group gave both proposals to the Independent Standards Board. But the board also could not reach consensus. In January 2026, the Greenhouse Gas Protocol published the land sector standard without any guidance for forest carbon accounting. Companies could use whatever method they wanted, Heatmap reports, as long as they disclose how they calculated the emissions.

Dooley and other scientists in the technical working group referred to scientific papers that supported their position. Another member of the group, Nathan Truitt, executive vice president of climate funding at the American Forest Foundation, argued that the same papers made the opposite point. It was “Kafkaesque,” Dooley told Heatmap.

In January 2026, Dooley received a copy of a formal complaint made by Truitt in April 2025 challenging the scientists’ expertise and impartiality. She also found out that the Independent Standards Board had asked outside scientists for their opinions on the two proposals. Dooley told Heatmap that she was shocked that she hadn’t known about this at the time.

Cullenward and Keith’s formal complaint

In April 2026, Cullenward wrote a report about the Greenhouse Gas Protocol’s governance structure published by the Kleinman Center. He wrote that,

Limited representation from scientists and environmental NGOs, along with an opaque grievance process, risks undermining the enforcement and integrity of the Protocol’s own governance rules.

He recommended mandatory representation from independent scientists and environmental NGOs in the Protocol’s decision-making bodies and that additional transparency measures should be put in place.

Cullenward and another board member, Heather Keith, an Australian forest ecologist, filed a formal complaint with the leadership of the Greenhouse Gas Protocol. Cullenward wrote in the Kleinman Center paper that the complaint alleges “multiple violations of the Protocol’s governance rules”.

A spokesperson from the Greenhouse Gas Protocol told Heatmap that an independent review found “some process shortcomings” but “no material breach” of the organisation’s rules.

“They buried it,” Cullenward writes.

Cullenward’s resignation letter:

08 June 2026

Geraldine Matchett
Chair, Steering Committee
Greenhouse Gas Protocol

Craig Hanson
Managing Director
World Resources Institute

Dominic Waughray
Executive Vice President
World Business Council on Sustainable Development

Dear Ms. Matchett, Mr. Hanson, and Mr. Waughray,

I write to resign my position on the Greenhouse Gas Protocol’s Independent Standards Board, effective immediately. I no longer have any confidence in the Protocol’s governance structure and strenuously object to your organisations’ treatment of scientific information — and scientists themselves — in the deliberations over forest carbon accounting.

Last year the Board received two competing proposals from the experts appointed to a technical working group. One proposal was authored by the group’s independent scientists and the other was produced by landowner and forest industry organisations.

Remarkably, the forest industry proposal would assign carbon removals to forest harvests. This is the opposite of what physically happens when a forest is cut down: forest harvests and wood consumption cause emissions, not removals. But under the industry rule, recycled paper would be counted as a climate harm while cutting down an old-growth forest to produce virgin paper would be counted as a climate benefit.

The independent scientists in the technical working group gave you consistent feedback that the industry proposal would create severe environmental impacts. They stressed that it is scientifically invalid and far exceeds already-incorrect claims that wood use is “carbon neutral” — a position that has been widely rejected by forest and climate scientists, including in comments to the Protocol from the European Academy of Sciences.

These concerns should have been addressed by the Board in a careful deliberation that centers scientific integrity, as is required by the Protocol’s decision-making hierarchy. But before transmitting the competing proposals to the Board, the secretariat staff and Board Chair acted on a confidential industry complaint that falsely alleged the technical working group scientists were biased and unaware of relevant academic literature.

In response, the Board chair and secretariat unilaterally determined that the Board needed to hear from outside experts, who were presented as neutral arbiters of a contested scientific debate. What the Board was not told is that these outside experts were named in the industry complaint as individuals who would support the industry position.

Before filing a formal complaint in February 2026 about these and several other concerning matters, I worked with Mr. Hanson for months in an attempt to reach a resolution. Mr. Hanson stated his belief that my concerns would harm the reputation of the Protocol if they were made public, and I agreed to work with him constructively to resolve matters internally. I hoped that Mr. Hanson and the World Resources Institute cared sufficiently about scientific integrity to prevent this process from devolving further, but my efforts to pursue internal accountability were met with retaliation. I then had no choice but to file a formal complaint along with my Board colleague, Dr. Heather Keith — the only other Board member with scientific expertise in climate change and forest carbon accounting.

As Chair of the Steering Committee, Ms. Matchett had a choice about how to handle the complaint Dr. Keith and I filed, along with its 200-page appendix of primary sources. She chose to cover it up. She appointed an outside mediator who:

• Was not allowed to speak with the scientists on the technical working group;

• Had not read the full complaint when he met with me to discuss it;

• Refused to meet with me after reading the full complaint;

• Stated that he was only authorized for 30 hours of work, and that he did not have time to watch recordings of key Board meetings as a result; and

• Provided Dr. Keith and myself with a brief, 5-page response that we were told we cannot even share with other Board members without violating on our non-disclosure agreements.

Ms. Matchett then declared that the Protocol’s complaints and concerns procedure does not require any public documentation of “internal” Board member complaints (or their official responses) and closed the matter without any public accountability — despite disclosure being required for “external” complaints.

Meanwhile, it has been five months since the Land Sector and Removals Standard was published without any guidance on forest carbon accounting and more than a year since the technical working group shared its proposals with the Board.

Although the Board approved a set of questions for public comment earlier this month, Board members were advised that the Steering Committee may now be considering a public comment period that could last up to seven months. In nearly two decades of work in public and private regulatory processes around the world, I have never encountered a comment period of this length.

Rather than serve a legitimate purpose, I believe this delay will further delegate control to industry interests. And to be clear, these concerns are not speculative. At a Board meeting earlier this month, a World Business Council on Sustainable Development (WBCSD) representative confirmed that forest carbon accounting is within the mandate of a joint working group operating between the Protocol and the International Organization for Standardization (ISO). As documented in a recent report I wrote for the Kleinman Center for Energy Policy, these new joint working groups operate with confidential membership that is heavily tilted in favor of industry interests. Specifically, the WBCSD representative said that the joint working group may draw on existing ISO standards that appear to allow the industry proposal to assign carbon removals to forest harvests and wood consumption.

After manipulating the Board’s decision-making process on forest carbon accounting and withholding the technical working group documents from the public for more than a year, the Protocol is now planning an extended public comment period on issues that have already been delegated to a secret, industry-dominated drafting process.

I again reiterate my request that the Protocol publish all documents from the forest carbon accounting technical working group, all related complaints and official responses, all pilot testing results evaluating the industry proposal, and any written agreement(s) documenting the Protocol’s working relationship with the ISO that may exist.

I regret that we have reached this impasse, but I will not be intimidated or silenced about what is happening. Nor will I take any further part in it.

Danny Cullenward, JD, PhD
Shleifer Senior Fellow
Kleinman Center for Energy Policy
University of Pennsylvania