Cullenward’s resignation letter goes a step further, accusing the Protocol of covering up an internal complaint he and a fellow board member filed, and of handing the reins of at least one of the organization’s standards to “a secret, industry-dominated drafting process.”
The Greenhouse Gas Protocol declined to comment on Cullenward’s resignation or answer questions about his account of events leading up to it.
The Protocol launched in the late 1990s as a joint project of the World Resources Institute, an environmental group, and the World Business Council for Sustainable Development, an industry association. Today it is the world’s leading standard-setter for corporate carbon accounting. More than 22,000 businesses rely on its methodologies to calculate and report their emissions. While adhering to the Protocol’s standards is still mostly voluntary, it will soon become a requirement under European Union and California disclosure rules.
Cullenward’s accusations arrive in the middle of a major revamp at the organization that began in 2022, designed specifically to improve the integrity of its corporate accounting standards. As part of the overhaul, it also put in place a new governance structure to improve transparency and accountability. Technical working groups made up of external experts would develop proposals to revise the standards to more accurately capture companies’ full carbon footprints, and then an Independent Standards Board would review and ultimately approve them. The Protocol appointed Cullenward to the independent board as one of its inaugural members in September 2024.
Cullenward’s reasons for leaving, as described in his letter, center around the development of a forest accounting standard to be used by companies that manage forests or have wood in their supply chains. The technical working group assigned to develop the standard could not reach a consensus, and ultimately submitted two competing proposals to the Board. Members associated with landowner groups and the forest products industry authored one of them, while the group’s research scientists primarily wrote the other.
According to Cullenward’s letter, as well as memos written by the academic scientists in the working group reviewed by Heatmap, the industry proposal, known as the “managed land proxy” method, would enable companies to claim they were removing carbon from the atmosphere when they cut down trees or used virgin wood. “This is the opposite of what physically happens when a forest is cut down,” Cullenward writes.
The method produces this counterintuitive result by allowing companies to take credit for all the carbon sucked up by the forests they manage, or in some cases by all the forests in a region, even if the company had no part in boosting that sequestration. If companies were to apply this accounting method to their products, Cullenward adds, not only would making virgin paper appear to involve zero carbon emissions, it would also apparently help to restore the climate. It would also look much more advantageous to the climate than producing recycled paper.
His concern is not just with this proposal, but also with how the Protocol handled a complaint filed by a proponent for the managed land proxy approach that challenged the scientists’ expertise. In response, the organization quietly solicited opinions from additional outside scientists on the two proposals.
Cullenward’s letter asserts that this was a decision made solely by the board’s chair, Alexander Bassen, alongside Protocol staff and without the rest of the board’s input. He writes that when these external comments were later shared with him and his fellow board members, the authors were “presented as neutral arbiters of a contested scientific debate,” even though they had been specifically referenced in the complaint as supporters of the managed land proxy approach.
Cullenward says he tried to “pursue internal accountability” but faced retaliation. In February he and another board member, an Australian forest ecologist named Heather Keith, filed an official complaint. The Protocol enlisted an outside mediator to resolve their dispute, but Cullenward says the hired adjudicator failed even to read the full complaint before meeting with him. The mediator also did not review any of the recordings of key board meetings referenced in the complaint, and was barred from speaking to technical working group scientists.
Cullenward and Keith eventually received a response to their complaint from the mediator but were told they could not share it, and the matter was deemed closed. According to a spokesperson for the Greenhouse Gas Protocol, who reached out to me with an update on the matter in late May, an independent review found “some process shortcomings” but “no material breach” of the organization’s rules or of due process. They added that “recommendations to address process shortcomings and strengthen conflict resolution are being reviewed and implemented.”
I reached out to Keith, who told me in an email that she was “deeply concerned about Danny’s resignation.” She praised his “wide-ranging expertise” in carbon accounting, law, and governance, and his “extensive contributions” to the board’s discussions. “One of the most valuable assets in a Board member is his demonstrated independence in making judgements that is based on a sound knowledge of climate science,” she wrote. The board “should be encouraging more people with Danny’s expertise and motivation for climate action to benefit the global community, not losing such valuable people.”
Cullenward’s primary concern moving forward is a new partnership between the Greenhouse Gas Protocol and the International Organization for Standardization, which establishes technical specifications for a range of industries and purposes, to unify their emissions accounting rules. The two groups’ first joint undertaking is to develop a standard for assigning emissions to specific products, which will include forest carbon accounting.
While the Greenhouse Gas Protocol has publicly listed the members it assigned to the joint working group, the ISO is under no obligation to do so. Cullenward asserts in his letter that the new joint groups “operate with confidential membership that is heavily tilted in favor of industry interests.” He says a representative from the World Business Council for Sustainable Development told him that the group may draw on an existing ISO standard based on the managed land proxy approach.
Meanwhile, over a year after the corporate forest accounting technical working group submitted its proposals, the Independent Standards Board is now contemplating kicking off a seven-month public comment period on the recommendations, Cullenward writes. He concludes that this elongated comment period is just for show, and that the issues “have already been delegated” to the joint working group with the ISO.
I asked the Greenhouse Gas Protocol how it planned to ensure “transparency and accountability for its stakeholders,” as it has previously promised, when the membership and meeting minutes of the joint ISO working groups are not disclosed to the public. I also asked, for the second time, whether the organization plans to publish meeting minutes from Independent Standards Board meetings — a requirement under the board’s governing rules that it has not followed. The Protocol declined to answer.
