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Landari’s submission: Comments provided directly to the Clean Energy Regulator via email on 30 November 2022.
We have a series of questions/observations on the released documents.
1) Assuming that all other Schedule 3 eligibility rules are met; is there a requirement that the new species is the same species as the old species? For instance, can an ex-nitens block be planted with radiata? It seems like there are no restrictions based on species, which is good.
2) Species lists: Schedule 3 Part 3 requires "within 24 months or older than the default age" to be calculated and a nominal default age is required. It is intended the "Commercial Species" list (new Schedule 6 - Part 3) be used for this purpose but note that radiata is listed only as 30 years (= long rotation) with no short-rotation option.
This remains problematic for pulp log radiata sites in NSW and Tasmania which are at risk of conversion to agriculture, and the fact that radiata is often grown as a pulp log is acknowledged in the new FullCAM guidelines.
Also note that nitens is listed as 12 years (SR) and 25 years (LR) respectively, which is excellent.
Acacia mangium is in the NT as a SR species (excellent).
Pinus pinaster is listed in all the NPIs that listed LR radiata previously (excellent)
Eucalyptus regnans has a 50 year default age in Part 3 (not ideal, for one of our clients - shorter better, say 35 years), but as a short rotation crop (Part 1) in Central Gippsland it is only 12 years (min) to 21 years (max)!
3) The FullCAM guidelines now have specified values for radiata pulp log rotations, yet we cannot identify radiata as a pulp log (ie short-rotation) species for Schedule 3 and 4 purposes [refer point 2 above]. Can we perhaps use the "other evidence" option in this case?
4) The maximum default age for globulus remains unchanged at 21 years. This is unfortunate as many of the ex-MIS plantations in Victoria are being harvested now at ages 21+, but they are still a pulp crop (ie short rotation for woodchips not sawlogs). An increase to say 24 years in the case of globulus would be helpful.
5) The FullCAM guidelines are full of errors: for Tasmania all hardwoods are full of zeros, even for sawlogs; same with NT, same with north coast, same with east gippsland, murray valley...
Further to the point about the FullCAM guidelines:
6) The sum of the rows in some areas is not 100%. This is probably due to rounding errors, but where do we deduct or add the 0.1% to make the plots work...?
7) The proportion of radiata sawlog (hence long-lived carbon, hence ACCU yields) has dropped in many cases especially the following NPI regions: Green Triangle and Central Victoria
This is particularly concerning as these two areas are perhaps the most efficient at growing sawlogs in Australia and hence if anything the results should have increased, not decreased.
8) In the central Tablelands (NSW) the only radiata sawlog silviculture is a 1 thin then clearfell. In most cases this will be a 2T then clearfell, like East Gipps/Bombala. The sawlog % of the T1 is only 13.9%. If we use the T1 settings for a T2, then this is unreasonably low (ie the T2 will have a higher % sawlog than T1)
This point works the other way: that is, if our client deploys their standard 32 year 3thin silviculture in the CT, then we are required to use the T1 values for each of the thins T2 and T3, followed by the clearfell. This increases the total HWP pool in excess of reality. That is, there is no sawlog at all from T1 in the CT. For clarity, compare the Green Triangle and Central Tablelands radiata sawlog tables... Quite different.
