Bushfire emissions? Not counted against Net Zero, don’t you know

Australian Rural & Regional News asked some questions of the Department of Climate Change, Environment, Energy and Water which are set out below, together with the department’s response.

Australian Rural & Regional News asked some questions of the Department of Climate Change, Environment, Energy and Water which are set out below, together with the department’s response.

he emissions from the Black Summer bushfires alone amounted to over 800 Mt CO₂-e, close to double Australia’s entire current annual accountable GHG emissions from all sources this last year to June (437.5 Mt CO₂-e), more than five times all Australia’s Land Use, Land Use Change and Forestry (LULUCF) emissions savings for 20 years (150.6 Mt CO₂-e) and more than 16 times the country’s electricity emissions savings for 20 years (49.1 Mt CO₂-e). (It is even more than 18 months of emissions from the Ukraine war.)

Even allowing for the recovery of some of those emissions through regrowth, emissions from bushfires can dwarf reduction efforts.

But bushfire emissions don’t count towards Australia’s National Greenhouse Gas Inventory. That must be a relief for those keen for Australia to be seen to be reducing or at least managing its emissions, especially in the light of the bad bushfire season over the summer of 2025-2026.

However, perversely, prescribed burning and other land management done to minimise bushfire risk does count towards Australia’s emissions inventory.

This apparent anomaly is clear from the Quarterly Update of Australia’s National Greenhouse Gas Inventory: June 2025, released on 27 November 2025 (Quarterly Update 6/2025), when read with the National Inventory Report 2023 (National Inventory 2023).

The government announcement highlights the (comparatively slight) year-on-year decreases in electricity emissions (down 3.3 per cent; 5.0 Mt CO₂-e), fugitive emissions (down 4.3 per cent; 2.1 Mt CO₂-e), stationary energy (excluding electricity) (down 2.0 per cent; 2.0 Mt CO₂-e), from industrial processes and product use (down 2.2 per cent; 0.7 Mt CO₂-e), from agriculture (down 0.6 per cent; 0.5 Mt CO₂-e) and the (slight) increase in transport emissions (up 0.3 per cent; 0.3 Mt CO2-e).

There, on page four, is a graph described as “Emissions by quarter, September 2004 to June 2025”. The graph records a significant decline around June 2019 and a further slight decline around June 2025. Really? What about the emissions from the catastrophic and tragic Black Summer bushfires across Australia in 2019-2020, so vast and intense that they were visible from space?

Footnote 3 points to the explanation: “National emissions levels are inclusive of all sectors of the economy, including Land Use, Land use Change and Forestry (LULUCF). LULUCF emissions are held constant at the levels from the most recent National Inventory Report and include the application of the IPCC’s natural disturbance provision.”

“Natural disturbance.” An arguably inaccurate term to cover events such as bushfires caused or exacerbated by various factors, human or otherwise. Causes of bushfires can include arson, power line and machinery sparks, prescribed and back burns gone wrong as well as combustion and the indisputable Act of God, lightning. Drought and weather may be exacerbating factors beyond (immediate at least) human control. However, poor land and forest management, be it through a failure to act or positive action that results in or fails to minimise bushfire, is certainly not beyond human control.

Classing all bushfires as “natural disturbance” is an oversimplification. It implies that nothing can be done to prevent them. It paves the way to blame all bushfires on factors beyond human control and on climate change. Many foresters and firefighters might be shocked to learn that for the purposes of Australian GHG accounting, bushfires are treated as a event about which we can do nothing.

Assessing the contribution of poor land and forest management to bushfire is a fraught and contentious issue, without doubt (as demonstrated by the debate on ARR.News), and quantifying it in a particular instance highly arguable. As is the effectiveness of fire suppression, also within human control, to an extent. But should this complexity justify these factors being disregarded for the purposes of all national GHG accounts and therefore national and international climate action?

There is no indication of any significant emissions from bushfire in the Quarterly Update released in November 2025. So what happened to the emissions from the bushfires? Are they anywhere to be found in Australia’s National Greenhouse Gas Inventory?

After a search, they can be found at page 293 of the National Inventory Report 2023:

The Black Summer bushfire emissions – over 800 Mt CO₂-e alone – amount to close to double Australia’s annual accountable emissions estimated up to June 2025 quarter, 437.5 Mt CO₂-e. The subsequent sequestration (removals) of emissions from regrowth below the line are longer term, uncertain and in this graph do not appear to be expected to recover the full amount. The emissions from the bad 2025-2026 bushfire season and their impacts on the removals are yet to be accounted for. What assumptions are made here about the frequency of catastrophic fire seasons? The “one in 100 [or/50/30/20 etc] year” line to dismiss natural disasters is wearing thin in Australia, as disasters repeat even before there has been recovery from the one before. According to this graph, the “long-run average net CO₂-e emissions from wildfire after the natural disturbance provision” results in the bushfire emissions being treated as nil. For the purposes of the national GHG inventory, bushfires are emissions neutral, they are “free”.

The rationale is that “forest land remaining forest land is subject to significant, non-anthropogenic natural disturbances including wildfires that are beyond control despite extensive efforts of emergency management organisations” and so “(f)or these fires, carbon stock loss and subsequent recovery from non-anthropogenic natural disturbances are modelled to average out over time, leaving greenhouse gas emissions and removals from anthropogenic fires as the dominant result.” (p 291 National Inventory 2023)

However, prescribed burning, which would include even mild burning such as aboriginal cultural burning, and land management undertaken to minimise bushfire risk, is considered anthropogenic in nature and so not emissions neutral. Emissions and sequestration from human activity on the land are accountable. (See p 33 Quarterly Update 6/2025)

So, in terms of national GHG accounts, bushfires are free but active land management (that causes emissions) costs.

Insofar as this UNFCCC GHG accounting disincentivises land management that can minimise bushfire risk and the strength of a fire and volume burnt if a fire does take hold, and as a result bushfire emissions are released that outweigh the land management avoided, it is perverse. The opposite outcome to that intended is achieved.

As mentioned at the outset, in a single summer, the Black Summer bushfire emissions at 800 Mt CO₂-e amounted to more than five times all Australia’s Land Use, Land Use Change and Forestry (LULUCF) technical emissions savings for 20 years (150.6 Mt CO2-e) (Quarterly Update 6/2025). Any emissions benefits from the vast industry level changes in forestry and agriculture over the last 20 years are totally overshadowed by bushfire emissions. What are the emissions from the 2025-2026 bushfires in Australia so far? What would the emissions from land management to reduce this risk have been? Such questions do not seem to be part of the public national or international discussion as yet.

Bizarrely, the Quarterly Update and the Inventory Report both highlight the emissions savings, the decline in emissions from LULUCF. The Inventory Report states (p 283), “The underlying trend of declining emissions from LULUCF since 1990 has been mainly driven by the decline in emissions from forest land conversions to other land uses and the increase in removals through forest regrowth on previously cleared land (Figure 6.1.3) as well as, in recent years, declining net emissions from the harvest of native forest.”

Has this inaccurate and perverse GHG accounting been a driving factor in the closure of the native forestry industry in Western Australia and Victoria and its decline in other states? Has it been a factor in the acquisition of farmland across Australia and its conversion to national park or “protected areas”? In the “Achieving 30 by 30” policy? In the reduction of prescribed burning and active land and forest maintenance across some states? Again, these questions do not seem to be part of the public discussion, as yet. Who can really know?

It does fit neatly though, if being seen to achieve Net Zero is the priority.

It fits neatly also with the unprovable hypothesis that if the forest is left untouched from now, in 40 years it will be less likely to burn. This in effect supports no prescribed burning or land management and bushfires – all zero emissions for the purposes of GHG accounting – over accountable, active land management.

What one can say with more – horrible – confidence, is that, 40 years from now, if the concentration of CO₂ in the atmosphere continues at its current rate – despite the Brundtland Report, “Our Common Future” in 1987 (when atmospheric CO₂ levels were around 347-350 ppm), despite the Rio Conventions in 1992 (around 355-359 ppm) and the entering into force of the United Nations Framework Convention on Climate Change (UNFCCC) in 1994 (357-360 ppm), the adoption of the Kyoto Protocol in 1997 (362-364 ppm) and its entry into force in 2005 (377-380 ppm), despite the adoption (2015, 398-402 ppm) and entry into force of the Paris Agreement (2016, 400-404 ppm), and despite all the conferences of the parties through to COP30 in November 2025 (around 424-430 ppm)* – then, in 40 years time in 2065, failing a paradigm shift either way, the concentration of CO₂ in the atmosphere is on track to exceed well over 500 ppm. By then we could expect to have a clearer idea of how this affects our world.

Atmospheric CO₂ levels haven’t reached 300 ppm for between 300 and 400,000 years, and not reached 420 ppm for about 3 million years, during the Pliocence.

All emissions and sequestrations, from all countries and all sources, count. Bushfire emissions do count.

COP 31 will be held in Antalya, Türkiye in November 2026. Excluding bushfire emissions while perversely including emissions from active land management to minimise bushfire is but one instance of the current inaccurate and misleading national GHG accounting. It may be high time to reconsider whether this accounting is driving the right outcomes for sustainable productivity, land use, management and care, for safety and biodiversity and for actual reductions in GHG emissions and the indisputable measure, atmospheric CO2 levels.

* Ed. My rough approximated levels using data from the observatory at Cape Grim, Tasmania and at Mauna Loa Observatory, Hawaii.

Australian Rural & Regional News asked the following questions of the Department of Climate Change, Environment, Energy and Water and received a brief response to be attributed to a DCCEEW spokesperson:

ARR.News asked:

• Can you confirm that emissions as a result of a bushfire (or other fire) that is not planned, are not taken into account at all in the national inventory of GHG emissions, but that emissions as result of intentional burning, such as prescribed burning (including Aboriginal cultural burning), are taken into account?
• I see from the recent National Inventory Report, p 293, that the emissions from the Black Summer fires have not been taken into account, ie counted for the purpose of Australia’s inventory of GHG emissions. Is that so?
• Can you confirm that emissions from other land management undertaken to reduce fuel loads are taken into account?
• Can you give any background to the exclusion of bushfire/ wildfire emissions from national emissions accounting under the UNFCCC? In particular, which country moved that they be excluded and what was Australia’s position?
• What are the estimated emissions so far from the current 2025-2026 bushfire season? Or when will these be available?
• What are the estimated emissions from prescribed burning and other land management carried out to reduce bushfire risk in 2025?
• What is the department’s and Minister’s response to the following:
• Excluding bushfire emissions from the national inventory of GHG emissions but including emissions from prescribed burning and other land management undertaken to reduce bushfire risk 1. rests on a false proposition that the risk of bushfire cannot be minimised, that bushfires are beyond any human control; and 2. amounts to a penalty and disincentive to undertake prescribed burning or land management to reduce bushfire risk?
• Different Australian states have different policies and practices regarding prescribed burning and bushfire mitigation. What is the government’s policy regarding the different states’ bushfire emissions (not counted) and prescribed burning and land management emissions (counted)?

DCCEEW spokesperson: The National Greenhouse Accounts estimate and report emissions and sequestration from post-fire recovery for all fires across Australia, consistent with guidance by the Intergovernmental Panel on Climate Change.  These estimates are reviewed by international experts.

Australia’s target under the Paris Agreement applies the accounting rules under that Agreement to cover human-induced emissions and carbon sequestration.

Australia’s accounting of extreme natural disturbances beyond control and not human-induced, such as the black summer fires, is transparently reported and managed in accordance with the Paris Agreement rules.

The department referred as background to provisions in the Paris Agreement dealing with the reporting of “natural disturbances”, paragraphs 55 and 75(d)(i) of the Annex to Decision 18/CMA.1 of the Parties to the Paris Agreement, and to the departmental document “Estimating greenhouse gas emissions from bushfires in Australia’s temperate forests: focus on 2019-20 (April 2020)“.

The first three “key points” of this 2020 departmental document are:

• “The 2019-20 bushfires will have negligible impact on Australia’s progress towards its 2020 or 2030 target.
• Bushfires release significant amounts of carbon dioxide, but generally recover over time, generating a significant carbon sink in the years following the fire.
• Australia’s National Greenhouse Accounts include carbon emissions and post-fire sequestration associated with bushfires, based on satellite monitoring of fires across Australia and advanced carbon modelling of fire-prone ecosystems.”

Another “key point”: “The future recovery of the forest is expected to be complete. However, the department will actively monitor the forest recovery from the bushfires to ensure that any future human disturbances, such as salvage logging, future fire disturbance and the impacts of changes in climate are taken into account.”

The department, with this brief, superficial response and background references has failed to address the substantive issues raised in the questions, and has failed to provide any real figures to support the discounting of bushfire emissions.

The critical issues raised in this article warrant a fuller and more transparent discussion.