Boundary changes lack integrity, will result in the conversion of native forests to plantations, give carbon credits to deforestation, and fail to protect the Koala

Submitted by the Koala History Research Cluster and Friends Groups

Summary of issues

This is a formal submission to the Premier of NSW, relevant ministers and associated agencies notably the National Parks & Wildlife Service, Forestry Corporation of NSW, Environmental Protection Agency and Department of Primary Industries.

Previous submissions have pointed to the fact that the areas zoned plantation within the boundaries of the park contain some of the best koala habitat. Without them:
- The park will be full of holes; and
- The impacted Koala populations will be decimated as a consequence of ongoing forestry operations.
The most recent (December 2025) changes to park boundaries have annexed over 2,000 hectares of forest into the areas zoned plantation. Of this, the overwhelming majority is within Friends Reserves.
- This is in addition to annexations which occurred in 2023 and 2024, immediately before and during, park negotiations.
- Forestry operations within and surrounding the park are not compatible with management for conservation.
The latest boundary changes are particularly disturbing, as they have:
- Severed connectivity in a number of locations;
- Removed several Koala Hubs; and
- Show no understanding of reserve design. Rather, they
- Consolidate the opportunities for clearing and conversion.
It is understood that the announcement of the park is waiting for the finalisation of the Federal Government’s Initiative on Improved Forest Management in Multi-Use Public Native Forests, on the assumption that the park, and surrounding forestry, will somehow be eligible as Australian Carbon Credit Units for inclusion in the country’s nationally determined contributions to emissions reductions under the 2015 Paris Agreement of the UN Framework Convention on Climate Change. This assumption is flawed:
- Native forest operations will not generate credible emissions reduction units, as timber extraction is carbon positive not negative, due to fugitive emissions arising from soil disturbance, and transportation;
- Annexation of native forests for conversion to plantations will also result in increased emissions from ongoing operations and will result in the loss of original forest and biodiversity;
- No units generated will have sufficient environmental integrity to warrant trading.
There has been no meaningful consultation on any element of park development, with any impacted communities. The Community Advisory Panels process was:
- Not inclusive of the community; but rather
- Designed to manage sectoral interest groups; and
- Created to replace community involvement, rather than encourage it.
Given this lack of consultation, it is particularly disappointing that, according to NPWS the ‘have your say survey’ is

“Not intended to seek feedback about proposed park boundaries, as this is a decision that rests with the NSW Government, who has already consulted extensively with Advisory Panels.”

This only serves to emphasise the alienation the scientific community and local residents feel about the park creation process.

In the light of these issues, the signatories urge the NSW Government to

Hear and heed the voices of those excluded from the park creation process, notably the scientific community and local residents;
Rescind the annexation of forest into areas zoned plantation;
Protect all koala habitat within the areas zoned plantation;
Abandon the questionable quest for carbon credits;
Adopt the boundaries of the World Heritage Proposal; and
Expand the park from 475,000 to 492,000 hectares.

Without these actions, the viability and integrity of the Great Koala National Park remains in jeopardy.

Details of boundary changes are in the annex below.

Sincerely Yours,

Tim Cadman, KHSRC
Ian Clark, KHSRC
Danielle Clode, KHSRC
Michael Danaher, KHSRC
Alexandra McEwan, KHSRC
Flavia Santamaria, KHSRC
Rolf Schlagloth, KHSRC

Dee Wanis, Friends of Conglomerate
Nikki Read, Friends of Coffs Coast Koalas
Meredith Stanton, Friends of Dorrigo Koalas
Paul Parkinson, Friends of Kalang Headwaters
Tilly Sloane-Lees, Friends of Never Never
Jodie Armytage, Friends of Newry
Paul Healy, Friends of Orara East
Renate Turrini & Margie Collett, Friends of Scotchman
Paul & Adele Hemphill, Friends of Tarkeeth Koalas
Karlee Brown, Friends of Tuckers Nob