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2021 Plantation Forestry Method Submission
Schedule 3, Age limit on harvesting of existing plantation.
Schedule 3, Part 1, 3 (2) (b) (ii) requires existing plantation to be harvested within 24 months of the
default clearfell age for the particular species in the region of interest. This requirement ignores the
sub-economic prospects of “abandoned” plantations, for example:
(a) Plantations growing so poorly that the prospects of them ever producing an economic harvest
are remote to non-existent. Many E. globulus plantations established east of Albany in WA
fall into this category. They grew reasonably well during their first rotation but, due to the
extremely low natural nutrient content of the regional soils and often poor second rotation
silviculture, the second rotation sees them growing at less than 30% of the first. Furthermore,
many were not properly coppice managed after the first harvest and now sport multi-
stemmed trees that will be uneconomic to harvest regardless of size.
To grow these plantations on to age 10 (default age 12) is futile. They will never produce an
economic crop and the best thing is to harvested them and replaced them with a long rotation
sawlog eucalypt incorporating appropriate silviculture, particularly nutrient management.
(b) Plantations of species for which there is insufficient volume to warrant investment in
processing infrastructure in a region. There are a number of pine plantations around Albany
and Esperance in WA that are too far from the one modern softwood sawmill in WA at
Dardanup to see them ever become economic. They were mostly established in small
woodlots on farms by the predecessor of the Forest Products Commission (FPC) in the hope
that this would encourage further investment to generate a resource of sufficient volume to
support new saw mills in the regions.
The FPC is now offering to clearfell 16-21 year old trees because they recognise that they’ll
never get anything other than chip value for them, even if grown on to 30 years of age
(compounded by the poor silviculture that saw no thinning undertaken when normally due).
If that was the case, the plantation area would be excluded from growing another production
forest, despite the prospects being sound (the resource required to feed a modern hardwood
mill being significantly smaller than that required for a softwood mill).
We submit that the eligibility criteria for a continuing plantation project to qualify under Schedule 3
be expanded to take account of situations similar to those described above. This could involve an
independent Registered Forestry Professional making a statement that the existing plantation has no
prospect of improving its economic performance by leaving it to grow to its default harvest age, be it
for growth, species or lack of infrastructure reasons.
Furthermore, we contend that if a plantation is cleared by a previous owner of a property before the
default age minus 24 months, this should not exclude the area from qualifying for a new Schedule 3
plantation in the hands of a new owner of a property. That is, a purchaser of a property that has been
cleared within the past 7 years (and after 26 October 2021), should be able to undertake a Schedule 3
project if all other eligibility requirements are met.
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Species Selection
It is not clear from the Draft Methodology Determination 2021, the Draft Simple Method Guide or the
FullCAM Guidelines for the 2021 Methodology which species can be used for continuing plantations
under Schedule 3 (or conversion under Schedule 2).
Page 23 of the Guide suggest there is no restriction on the selection of species that can be used to
convert a short rotation planation into a long rotation plantation (Schedule 2). No such statement is
made about species selection for continuing plantation forestry under Schedule 3 and it is not clear
from the Determination if any restrictions apply.
The FullCAM Guidelines, however, states (page 15) that species can only be selected that are within
its current data set for the location being modelled (and restricts projects to NPI regions, despite the
statement in the Method Guide that projects can be up to 50km outside NPI regions). In WA, the only
eucalypt species listed are E. globulus and E. saligna. Therefor E. saligna is the only species that can
be used for a long rotation continuing plantation (or conversion) project. This makes no sense. The
WA NPI is far from a homogenous environment and E. saligna is not the most suited species for long
rotation crops in many of its sub-regions.
The FullCAM Guidelines seem to contain further contradictions -the species listed in Appendix 2 for
WA include “Other eucalypts” and “Spotted gum species”, even though such species are not included
in the FullCAM species options for WA.
We submit that any species, independently verified by a Registered Forestry Professional to be suitable
for a long rotation plantation, be allowed for Schedule 1, Schedule 2 and Schedule 3 projects.
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