2021 Work Programme - FGLT Secretariat, PO Box 10986, Wellington 6143 www.fglt.org.nz - the Forest Owners Association

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2021 Work Programme - FGLT Secretariat, PO Box 10986, Wellington 6143 www.fglt.org.nz - the Forest Owners Association
2021 Forest Growers Levy Annual Work Programme | 1

2021 Work Programme

FGLT Secretariat, PO Box 10986, Wellington 6143
www.fglt.org.nz
2021 Forest Growers Levy Annual Work Programme | 2

CONTENTS

Forest Growers Levy Trust Budget                                                              3

Operational ($363,000)                                                                        4

 Integral and database maintenance ($225,000)                                                 4

 Integral Software Amortisation ($0)                                                          4

 Business Compliance and Reporting ($138,000)                                                 4

Secretariat Costs ($90,000)                                                                   5

Programme Management Costs ($1,441,000)                                                       5

Work Programme Costs ($8,479,922)                                                             7

 Fire ($47,147)                                                                               7

 Forest Biosecurity ($825,614)                                                                8

 Forest Resource & Environment ($136,500)                                                    14

 Health and Safety ($754,357)                                                                17

 Promotion ($892,957)                                                                        20

 Research Science & Technology ($5,143,347)                                                  22

 Small & Medium Enterprise ($118,044)                                                        26

 Training & Careers ($471,473)                                                               27

 Transportation & Logistics ($90,483)                                                        33
Forest Growers Levy Work Programme | 3

Forest Growers Levy Trust Budget

                              2019 Actual     2020 Budget      2021 Budget
                            1 Jan – 31 Dec   1 Jan – 31 Dec   1 Jan – 31 Dec
 Commodity Levies            9,710,253        9,000,000        9,240,000
 Other income                     75,836          55,000             1,500
 Total income               9,786,089         9,055,000        9,241,500

 Operational                    419,047          344,500          363,000
 Secretariat                     90,000           90,000           90,000
 Programme                    1,122,793       1,468,000         1,441,000
 management fees
 Work Programme
 Costs
 Farm Forestry
 Information Transfer
 Environment                     76,526          119,700          136,500
 Fire                            52,144           50,000            47,147
 Forest                         854,876          802,250          825,614
 Biosecurity/Surveillance
 Health & Safety                941,269          807,000          754,357
 Marketing & Promotion          860,973          625,000          892,957
 Research, Science and        5,277,726        5,538,000        5,143,347
 Technology*
 Transportation                 130,505          145,000           90,483
 SME Committee                  124,392          132,450          118,044
 Training & Careers             335,927          360,000          471,473
 Woodco and SAP
 Market Access &
 Development
 Communications
 Resource Mgt/Licence
 to operate
 Total Work Programme        8,654,338        8,579,400        8,479,922
 Total Expenditure          10,286,178       10,481,900       10,373,922
 Less income tax on                     0
 interest
 Net Surplus/(Deficit)        -500,089       -1,426,900       -1,132,422

The comparative figures for special projects are shown according to the general headings only.
Special projects, by definition, are not comparable year by year. Actual project spending falls within budget categories that are
consistent with the referendum budget categories.
Forest Growers Levy Work Programme | 4

Operational ($363,000)

Integral and database maintenance ($225,000)

Integral set up a stand-alone company “Levy Systems Limited” (LSL) to operate the Forest Growers Levy data and levy
collection system. This separate company ensures individual company data is kept confidential and secure.
LSL is responsible for collecting data on harvested wood products and invoicing the owner of these products. The levy is
paid by forest owners directly into the Forest Grower Levy Trust bank account.

Funding for 2021 covers the operation of LSL and the funding of minor enhancements to the collection systems.

Integral Software Amortisation ($0)
Covers amortisation of software used by LSL to upload data and invoice levy payers. The original software programme
that commenced 1 January 2014 has been fully amortised. This expense remains here in case there are any enhancements
required in the future.

Business Compliance and Reporting ($138,000)
Covers the cost of the Levy Trust administration including bank fees, legal, Xero accounting subscription, audit fee,
business advisory, board and secretariat travel, chair, compliance audits, AGM and other meetings and an associated
communications programme.

This expenditure consists of:

   Chairman’s fee and other Board costs                                                                       52,000

   Legal expenses, including legal support for the Work Programme                                             20,000

   Audit fee, accounting and tax advice                                                                       12,000

   Communications                                                                                              18,000

   Other (bank fees, communications, insurance, website)                                                       16,000

   Compliance audit                                                                                           20,000

                                                                                                             $138,000
2021 Forest Growers Levy Annual Work Programme | 5

Secretariat Costs ($90,000)
FOA with support from the FFA provides a secretariat service to the Levy Trust Board. The Chief Executive of FOA
currently serves as the Chief Executive of the secretariat, but is answerable to the Trust Board, not to FOA. The secretariat
has a responsibility for liaising between the Trust and the two associations delivering the levy-funded work programme
including tabling the annual work programme and regular reports, as well as oversight of the levy collection process,
constitutional matters, financial arrangements and accounting, legal and tax compliance. The Secretariat fee was reduced
in 2016 to reflect operational efficiencies achieved by the Board and Secretariat.

Programme Management Costs ($1,441,000)
Changes to Programme Management Costs:

1.   Management costs were reviewed and have been adjusted up for 2021 (to account for new biosecurity and research
     resources allocated to levy) to comprise 86% of total costs. The remaining 14% is attributable to either FOA or
     secretarial activities although it can be argued that there is a considerable industry good component within that 14%.

2.   To be consistent, FFA Work Programme administration is now included in Programme Management costs and not
     shown under the SME committee.

The management costs include FOA resources and are broken down as follows:

 FOA Staffing                                                                                                   1,193,000
 Approximately 9 FTEs based in Wellington and Rotorua and managing the Levy Trust approved
 programme of work in collaboration with the FOA/FFA membership committees, communicating with
 forest growers and the wider industry and coordinating efforts with the Farm Forestry Association.
 This includes the management of R&D activity.
 Phones                                                                                                          11,500
 Fixed and cellular, line charge and usage
 Stationery and Printing                                                                                         14,000
 General                                                                                                         14,500
 Depreciation and other
 R & M premises and equipment                                                                                    26,000
 IT costs, meeting and storage SaaS costs and office maintenance
 Occupancy                                                                                                      102,000
 Includes portion of office rental, power, cleaning services, office consumables
 Travel and meetings                                                                                             73,000
 Catering for committees, flights, accommodation, rental vehicles, workshops, stakeholders meetings,
 expert/contractors travel when required, venue charges
2021 Forest Growers Levy Annual Work Programme | 6

International travel
Includes a provision for engagement with International Council of Forest and Paper Association and       7,000
FAO Advisory Committee on Sustainable Forest and with the Australian industry (AFPA)

Programme Management Total                                                                            $1,441,000
Per month                                                                                                120,083
2021 Forest Growers Levy Annual Work Programme | 7

  Work Programme Costs ($8,479,922)
  Fire ($47,147)

                                                                                                         2021        2021
Projects within the portfolio allocation
                                                                                                        Funding     Funding
                                                                                                       Requested    Approved
                                                                                                                      By
                                                                                                                   Committee

Fire Prevention Campaign                                                                                $47,147     $47,147
Forest industry ongoing support for summer fire awareness campaign conducted by FENZ,
targeting high risk lifestyle block owners and tourists in particular with a multiplatform publicity
and education. Provides backing for major industry input into the awareness campaign with ‘feet
under the decision making table’. This budget allocation allows for contingency spending directly
by FOA to support the awareness campaign where there are perceived direct forest interests
particularly in communicating with industry stakeholders.

     Note: Fire Research is managed and reported via the Research Committee. The Fire Committee monitors the research
     programme and strongly supports the Scion programme.
2021 Forest Growers Levy Annual Work Programme | 8

Forest Biosecurity ($825,614)

                                                                                                 2021        2021
Projects within the portfolio allocation
                                                                                                Funding     Funding
                                                                                               Requested    Approved
                                                                                                              By
                                                                                                           Committee

Forest Biosecurity Consultant                                                                   $40,000     $30,000
Funding for regular monthly time allocation for the forest growing sector to provide forest
biosecurity technical support and advice, including the Forest Biosecurity Surveillance
Programme, a cost-shared national programme with the Ministry for Primary Industries.
Time is allocated for work on biosecurity matters for FBC, GIA, liaison with Scion and SPS
Biosecurity on the diagnostics and surveillance programme including reporting,
governance, technical working groups, biosecurity research, and other tasks as required.

Forest Biosecurity Surveillance (FBS) Programme                                                $707,500    $652,500
The annual surveillance for pests and pathogens of plantation forest species. The work is
undertaken for the forest industry by SPS Biosecurity and Scion. The objectives of the
survey are to protect the forest estate through early detection of new-to-New Zealand and
new-to-region pest (insects and pathogens) incursions and to protect trade from the
potential negative impacts of any new incursions. (This includes being able to confidently
establish Area Freedom).

Costs for the FBS field surveillance and diagnostics activities are currently cost-shared
50/50 with MPI. Figures in the table below represent the funding requested, and account
for FGLT cost increases resulting from GIA transitional discounts (40 FGLT/60 MPI) ceasing
in June 2020. Non-model allocated surveillance costs are included as this represents an
integral component of the wider forest biosecurity surveillance system. Costs for this
activity are not currently cost shared with MPI.

Diagnostics costs have increased due to increased sample volumes from the surveillance
programme and the changing dynamics of diagnostic testing. The allocated budget has
been exceeded in both 2019 and 2020. These costs have now been factored into this
year’s budget and the service contract.

Non-model allocated surveillance

This funding is for the proportion of the FBS Programme listed below (line 2) that is not
cost-shared. This component is referred to as “non-model allocation surveillance” (NMA)
and is largely in-forest high risk site surveillance. The NMA expands the Forest Biosecurity
Surveillance (FBS) programme to include high risk forest areas and risk pathways based on
a risk profiling approach developed by SPS Biosecurity. This involves a risk-based
approach to identify where to focus surveillance effort within forests surrounding high risk
areas. The system targets sites with high visitor numbers, high industrial activity, or
proximity to major transport routes. The NMA addresses some of the acknowledged
2021 Forest Growers Levy Annual Work Programme | 9

shortcomings in the FBS risk model and enhances the forest biosecurity surveillance
system by increasing the chances that new pests and pathogens will be detected early
enough for eradication or containment to still be an option.

Cost (FGLT share) are broken down as follows:

    1.   Surveillance model allocated (SPS Biosecurity)                             300,000
    2.   Surveillance non-model allocated (SPS Biosecurity)                         180,000*
    3.   Contract management/reporting (SPS Biosecurity)                            10,000
    4.   Diagnostics, Model Management, Forest Health Database (Scion)              162,000

* Note that items 1, 3 and 4 are cost-shared with MPI but item 2 is currently fully funded by
FGLT.

Biosecurity Communications and Annual Conference                                                $6,000       $3,500

Funding for the annual conference with Scion, MPI and FOA, plus external stakeholders
The annual workshop is the flagship collaborative meeting with MPI, industry, research
partners, and local and regional authorities. Funds contribute towards the travel expenses
for a keynote speaker, and catering and associated charges for the event held over two
days at Scion in Rotorua. Attendees register and pay for the conference, but a small
amount is allocated for funding for any shortfall. This cost is usually in the region of $2-
3,000.

Funding for communications to the wider biosecurity network
PineNet is an alliance between the Forest Biosecurity Committee and Wood Councils. It is
designed as a communications conduit, with a central administrator based at FOA.
PineNet has been developed to act as a contact network for biosecurity so in the event of
an incursion a network of connected forestry resources is readily available. It also serves
to enable the rapid distribution of biosecurity related information across this network. The
funding is used for external costs only (printing, airfares, web development) as all FOA
time contributions are in-kind. This cost is usually in the region of $3,000. However, due to
potential budget constraints this has been reduced to $500-$1000 for the coming year.

Tauranga Moana Biosecurity Capital Sponsorship                                                  $2,000      $2,000
The funding is for the forest growing sector to continue to contribute to the collaboration
between Tauranga Moana iwi, local industry and business sectors, science institutions,
educators, and central and local government. Its purpose is ‘leading and taking
collaborative action towards biosecurity excellence’ in, and around, the Tauranga Port
environs. The initiative is a national exemplar for regional collaboration and partnership,
and it is one of the lead initiatives for “Biosecurity 2025” and Strategic Direction 1 –
“building a biosecurity team of 4.7 million”. The contribution from this funding provides
visibility via the use of the FOA and FGLT logos in the communications for the programme
and shows our support for biosecurity in an area where a number of sectors are exporting
and need to be aware of biosecurity at ports and other high-risk entry points. It is an
annual and ongoing request.
2021 Forest Growers Levy Annual Work Programme | 10

Port of Tauranga Biosecurity Excellence B3 Project Contribution                                $2,000      $2,000
The funding is for the forest growing sector as a partner to continue to contribute to the
Port of Tauranga Biosecurity Excellence research work programme being delivered under
B3. This initiative is closely associated with the TMBC but focuses on port biosecurity. The
B3 collaboration (Scion and AgResearch) aims to undertake research to support the goals
of these two initiatives. This modest investment leverages a much larger investment to
support research into a range of port related biosecurity initiatives from sentinel plant
monitoring trials and distribution modeling, through to trialing different insect trap types
and deployment strategies to maximise early detection in port environments. While this
has not been specifically identified in previous work programs, it has been an ongoing
component of the biosecurity work programme.

Operational Log Study (P. ramorum) – cost of Stage II (write up)                               $20,000    $10,000
The fieldwork and analysis of this project was completed by Oregon State University in the
USA in 2019, and results of the study communicated to the sector via Scion, a collaborator
in the project. OSU repeated the fieldwork in 2020 to provide more robust results and was
intending to write up the findings in an international peer-reviewed journal. The fieldwork
was completed at no cost to FGLT but the cost of the write up is included here. The write-
up was deferred until 2021 in order to find savings due to financial uncertainties arising
from Covid 19. This work was subsequently bought forward to be initiated in late 2020,
incurring half the costs in 2020 and 2021, respectively. Once the findings are published,
they will support trade requirements for exporters as the results from the study
demonstrate that logs exported do not represent a risk of carrying P. ramorum, should the
pathogen arrive and establish in New Zealand.

Find a Pest (general surveillance app)                                                         $10,000    $10,000
The find-a-pest app will allow foresters to easily and quickly report and rapidly identify
potential forest and other pests, including insects and fungal pests of plants, pest weeds
and other animal pests. This will enable key frontline forestry staff, owners, managers
etc., to actively participate in biosecurity surveillance to protect our forests, and New
Zealand potential biosecurity threats by detecting them early.

Development and piloting of the Find-a-Pest app has previously been resourced (levy
funding and in-kind) alongside several other primary industry, local and regional
government, and central government agencies. This included the transition from a
minimum viable product through to a fully developed App ready for deployment. Once
launched this funding for the forest industry cost share of the App will ensure that the app
is maintained and remains functional and that the forestry specific “skin” can be deployed
by the forest growing sector as a key surveillance and biosecurity engagement tool for
frontline forest sector staff.

GIA Secretariat Support (Communications, Plant Council)                                        $30,000    $20,000
The GIA Secretariat is now funded by all GIA signatories, including MPI and industry. This
funding is for the core services only and is in the form of a minimum club share that all
signatories pay with remaining cost shared across all signatories proportionally by industry
2021 Forest Growers Levy Annual Work Programme | 11

value. The forest industry’s cost is estimated to be around $15,000. Any user pays services
(i.e., supporting or administering industry specific initiatives or operational agreements)
will need to be paid for separately.

The Plant Council is a new amalgamation of plant sector GIA partners which aims to
ensure improved coordination and efficiencies in GIA related activities across plant
sectors. This council will be part-funded by the sector (via FGLT lev funding). The cost is
estimated to be around $5000.

Plant Production Biosecurity Scheme (PPBS) Operational Agreement (GIA)                         $25,000    $21,000
The Plant Production Biosecurity Scheme (PPBS) is a certification framework to help plant
producers/nurseries identify, control, manage and avoid biosecurity risk. It aims to support
a professional approach to biosecurity across the plant production industry, which aims to
minimises biosecurity risk within practical operational constraints, build industry and
producer resilience, trust and social license, and aims to harness the critical skills and
observations that exist in the industry to protect and grow producers, their customers and
ultimately New Zealand. Since 2018 the forest growing industry has worked alongside
government and other primary industry sectors to develop the PPBS to enable
improvements in biosecurity risk reduction along the nursery pathway. Fusarium
circinatum, the cause of pine pitch canker, is an example of a significant threat to the
exotic forest growing industry in New Zealand that this scheme aims to minimise. The
nursery pathway is a key mechanism of spread for this pathogen should it arrive here.
Currently there are no pathway risk management programmes in place that would reduce
this risk, both within, and external to, the forest growing sector other than seed import
restrictions at the border. The PPBS will be implemented as a five-year multisector
Operational Agreement under GIA to which the forest growing industry will be a signatory
alongside other industries and MPI and as such will contribute a forest industry cost share.

Biosecurity Training Programme                                                                 $10,000     $5,000
The FBC has worked with, and funded, SPS to develop some general introductory
biosecurity training modules that can be delivered and administered online. These are
focused on raising the general biosecurity awareness of frontline staff but are targeted at
upskilling staff to help them identify and know when and how to report pests or pathogen
expression that could indicate a new biosecurity incursion. There is now a need to roll out
this training and to start realising its benefits. This will require the development of a
rollout/implementation plan and approach and an evaluation plan as well contributing to
the costs of maintaining and administering the existing delivery platform.

Review of Forest health information management system (Forest Health Database)                 $20,000    $20,000
The forestry growing sector needs a modern database to be able to rapidly and accurately
determine where pests and pathogens currently are in our forest to (a) provide trade
assurances to countries importing our logs and lumber, and (b) reliably track new
incursions as they establish and spread. There is increasing pressure from trading partners
to provide assurances that our forests, even at a stand level, are free of unwanted
organisms of trade significance. This need is going to increase in the future as our ability
to use border treatments such as methyl bromide diminish and the reliance on our
2021 Forest Growers Levy Annual Work Programme | 12

surveillance systems and information increases as an evidence base to demonstrate that
our forests and logs are free from pests and pathogens of trade significance.

The current forest health database, that stores data from 1960 to the present day, has
reached the end of its usefulness as a management and retrieval system for forest health
information and is no longer fit for purpose.

There is a need to review the existing information management system to identify how to
improve it and to realise and enable the potential value of the forest health information it
contains to the forest growing sector. This review will also scope out what would be
required to develop and deliver a more modern, interoperable and functional forest health
information management system and what enhancements could or should be
incorporated to maximise the value and utility of current and future data. This is just the
initial stage of improving the system and does not include building or implementing any
solutions. The cost is an estimate only.

With an enhanced forest health database individual forest owner should ideally be able to
readily access data relating to their forests, or potentially access consolidated regional
data, to be able to demonstrate to managers and investors that their stands, forests or
regionals are free of specific pests. This may also enable greater real time and
customisable trend analysis and reporting.

FBS Programme additional work on the model [note this work can be sized to meet                  $30,000    $30,000
available budget]
Scion and collaborators from UK and Australia will by December 2020 define an optimum
level of model allocated surveillance effort. This effort will be placed almost exclusively in
urban areas where pest arrivals are highest. However, the model currently does not allow
for forests that are close to high risk urban areas. The team will add a spatial component
to the model so that the higher risk forests growing near major ports and risk sites is
recognised. This will result in high risk forests in the peri-urban and nearby locations
receiving an appropriate level of surveillance, thereby increasing the probability of early
detection and eradication of serious pests and pathogens before they spread into rural
forests.

Diagnostics - Enabling Nursery Participation                                                     $30,000    $19,614
Forest nurseries represent a critical part of the forest growing sector, they are also a
significant biosecurity risk pathway. There is currently a gap in the forest biosecurity
surveillance system in that forest nurseries are not included. Forest nurseries are currently
charged market rates for any suspect pest or pathogen notifications that they make to
SCION, or to investigate any potential issues that they may encounter within nurseries.
This represents a significant disincentive for them to participate in the biosecurity system
and thus presents a biosecurity risk to the entire industry.

This proposal aims to enable their participation by providing them with a set number of
identifications per year per nursery for issues that they may encounter. The focus will be
on the rapid identification of new or emerging issues of biosecurity concern, and any
further work (if not a new or unwanted organism) will be at their own cost. This will
2021 Forest Growers Levy Annual Work Programme | 13

contribute to removing the cost barrier to participation and increase the likelihood that a
pest or pathogen of concern is reported in a timely way. This activity would represent a
first step in integrating nurseries into the broader forest biosecurity surveillance system
while also removing a potential reporting barrier, which will be a key requirement of the
PPBS. A logical next step would be to integrate forest nurseries into the Forest Biosecurity
Surveillance programme.

Note: This could be implemented immediately, and cost share arrangements could be
explored (i.e. 50% cost share with nurseries) to minimise FGLT funding requirements while
still achieving the same outcomes.
2021 Forest Growers Levy Annual Work Programme | 14

Forest Resource & Environment ($136,500)

                                                                                                  2021        2021
Projects within the portfolio allocation
                                                                                                 Funding     Funding
                                                                                                Requested    Approved
                                                                                                               By
                                                                                                            Committee

Environmental Consultant                                                                         $10,000     $10,000
The Forest Resources & Environment Committee calls on the services of an expert RMA
environmental consultant for ad hoc advice on issues that affect the sector. Time is billed
on a quarterly basis and includes attending Committee meetings, advice on RMA and
planning matters, and biodiversity management in light of a number of regulatory
changes under the RMA that affect the forest growing sector. The Committee seeks
funding for this activity as a core benefit to the forestry sector, as advice given can be
applied nationally and provides support for a range of consultations and submissions on
environmental legislation.

National Environmental Standard for Plantation Forestry (NES-PF) Review of S6 (Plan              $20,000     $20,000
rule stringency)
Since the NES-PF came into effect in 2017, the FOA and Environment Committee have
been monitoring when regional planners and local councils have applied Section 6, which
allows for rules that provide greater stringency, to determine the impact on forestry
operations (including afforestation, harvesting, etc). The stringency rule creates
complexity in the regulation, and can be applied inconsistency across plans, creating
uncertainty and cost for forest owners operating across multiple plans and regions.

The funding sought will support legal and planning advice on the effect of the stringency
regulations so that forest owners can provide better evidence to local and central
government regarding their concerns about this section of the Standards.

The funding will provide any forest owners operating under the NES-PF with greater
clarity of the rules, and greater consistency of approach across plans and regional councils,
reducing costs and operational management time.

Forest Practice Guides – Additional - New Forest Practice Guide (Fish Passage)                   $15,000     $15,000
Funding for 2021 is sought to add a further guide to the set of 28 to provide fish passage
guidelines, as the regulations for this have changed under the new Freshwater Reforms.
The forestry sector would benefit from clear and up-to-date guidance on fish passage for
managing fish in streams and waterways across the forest estate that fits with the current
NES-PF and other regulatory requirements.

Funding was allocated in 2019 to update the Environmental Code of Practice (ECOP).
However, it was determined that the 28 Forest Practice Guides developed earlier would
replace the ECOP. The Forest Practice Guides, and the NZ Forest Road Engineering
2021 Forest Growers Levy Annual Work Programme | 15

Manual and Operators Guide complement each other and provide comprehensive
environmental guidance to forest owners, stakeholders, and the wider sector (for
example, local councils).

Electricity Regulations Consultation                                                            $20,000   $20,000
In 2019 the Ministry of Business, Innovation and Employment initiated a review of the
Electricity (Hazards from Trees) Regulations 2003. The aim of the review is to address any
concerns that either lines companies or tree owners have with the current legislation. The
Ministry has formed a stakeholder group of lines companies and tree owners (councils,
forestry, DOC) in order to determine how to improve the way the regulations work.

The committee has engaged the RMA consultant, who advises them on regulatory
matters to attend these stakeholder meetings. While COVID-19 has postponed the
consultation process, it will proceed in 2021. It is important that forest sector
representation presents our concerns at this review, as there is the potential for wide-
ranging regulatory changes to provide less protection for rural tree owners in terms of
requiring lines corridors that inhibit planting under, and a distance away, from power lines.
The funding supports attendance at the meetings by the RMA consultant, feeding back to
the committee, and gaining the mandate for decision-making so that forest owners
property rights, if they have lines crossing their forests, are not eroded.

FSC Cluster Group Support and FSC Standards Development Group Support                           $3,000    $3,000
The FSC Standards Development Group meets as a forum to engage across a range of FSC
and wider industry topics and is Chaired by an FOA representative, who manages the
meetings with environmental, Māori, and social chamber representatives. The funding
includes reimbursement of travel costs, catering, and attendance fees for these
representatives to meet with the FOA representatives up to four times a year.

The FSC Cluster is the group of 22 FSC-Certified companies in New Zealand and the
funding supports some of the costs of the Cluster to meet such as venue hire and catering.
The FSC Cluster is mainly funded by certified companies but a small contribution is made
to the logistics of the meetings.

Falcon Management Study                                                                         $41,000   $41,000
The objective of this study is to inform better management of kārearea/New Zealand
falcon in commercial conifer plantations. The aim is to measure nesting success, adult
survival rates, and habitat use because these allow us to test management actions to
mitigate conflict between nesting falcons and forestry operations (roading, site
preparations, harvesting and windrowing).

The study will experiment with habitat manipulation, aiming to reduce conflict between
forestry operations and falcon nesting by refining nest disturbance mitigation, and assess
if predator control could offset impacts of operations on falcon populations. The project
has been funded previously wholly by Rayonier Matariki, City Forests, and Wenita Forests
in the Dunedin region. The output will be updated management guidelines for falcon in
plantation forests.
2021 Forest Growers Levy Annual Work Programme | 16

This project was funded for 2020 with the potential for fieldwork to extend to 2021 and
2022.

RMA Review Discussion Paper and Planning Advocacy                                               $25,000    $25,000
In 2021 a number of regulations are likely to come into effect that have wide-ranging
implications for forestry management, afforestation, and harvesting operations in New
Zealand. These include the National Policy Statement on Freshwater, amendments to the
National Environmental Standards for Plantation Forestry, the potential for the Resource
Management Act Reform, the National Policy Statement on Indigenous Biodiversity, and a
number of planning changes in regions where forestry operates.

Funding will facilitate advice and engagement from a number of legal and planning
consultants as required in order to inform evidence and data to support the forestry sector
in any consultations with government officials regarding the consequences to forestry of
any proposed legislation.

Environmental Fact Sheets                                                                       $2,500     $2,500
This is to provide funding for Scion to produce an additional fact sheet to add to the series
of fact sheets already completed. The proposed topics include fish passage and
freshwater aspects.
2021 Forest Growers Levy Annual Work Programme | 17

Health and Safety ($754,357)

                                                                                                2021        2021
Projects within the portfolio allocation
                                                                                               Funding     Funding
                                                                                              Requested    Approved
                                                                                                             By
                                                                                                          Committee

Forest Industry Safety Council (FISC)                                                                      $754,357
Committed liability for 2021 including an admin resource and accounting support for FISC
Trust. FISC has operated successfully to date and has commitment from ACC and
WorkSafe for project funding up to June 2022. This includes funding for a full-time project
manager. FISC requires core funding for 2021 to continue the programme of work.

(Note that WorkSafe NZ and ACC will be contributing in addition to the budget recorded
here. The work programme for FISC is a work-in-progress but key budget lines will include:

 FISC operating costs (National Safety    $334,000
 Director, administrative support
 costs and office overheads

 Stakeholder engagement via regular       $72,000
 newsletters, regional workshops,
 attendance at industry events and an
 annual Safetree conference

 Costs associated with the operation      $65,000
 of the Council and their governance
 of the agreed work programme and
 projects

 Safetree Certification (Bravegen         $209,494
 licensing, Governance panel and
 certification costs)

 IRIS (Injury Recording Incident          $54,000
 System) enhancement to align the
 database with the new legislation
 and expand its coverage within the
 sector beyond FOA members

 Operational Action Group                 $19,863

 Total                                    $754,357

FISC Individual and Contractor Company Certification Scheme
Embed certification in industry
2021 Forest Growers Levy Annual Work Programme | 18

The Independent Forest Safety Review (IFSR) made key recommendations that the forest
industry, led by FISC, implement the following:
    • a contractor company certification scheme
    • individual competency standards for high risk tasks; tree felling and breaking out

Schemes have been developed, Safetree Contractor Certification and Safetree Worker
Certification, along with governance of both schemes.

In developing these certification schemes a key focus has been to educate the wider sector
in the following areas: leadership, risk management, worker engagement and current
competency for high risk tasks.

In developing Safetree Contractor Certification, the following matters have been taken
into consideration:
     • There is sufficient industry support for the schemes to become self-sustaining;
         development work has been supported strongly by FICA and FOA have also taken
         a keen interest. Uptake is initially aimed at FICA members (Year 1 - 50% and Year
         2 - 75%) although the scheme will be open to non-FICA members.
     • Maintain costs at an accessible level to ensure smaller companies will be able to
         participate; currently costs for individual companies to join the certification
         scheme are estimated to be in the region of $800 - $1000.00

It is recognised that support for the scheme will rely largely on forest owners and other
supply chain participants acknowledgement and acceptance of the certifications.

The FISC Council continues the “roll-out” and embedding of these schemes with industry
participants nationwide which will require additional infrastructure requirements. In order
to accomplish this FISC requires funding for

Certification:
    • Training sufficient assessors for Safetree Worker Certification and conducting
         peer review workshops*
    • Training sufficient auditors for Safetree Contractor Certification and conducting
         peer review workshops *
    • Regional workshops
    • System administration costs

* Peer review workshops are vital to ensure consistency of approach and to discuss learnings,
good practice and any system modification that may be required

Governance
    • Maintenance of governance processes via the established Certification Panel

Plan for delivery - This project will be managed by FISC and will require additional
administrative support to be fully effective.

In addition, a review of Safetree Contractor Certification has been commenced focusing on
the software provider, the quality of the assessment tool, other possible tiers, extending
reach in the sector and where the operation of certification sits.

Estimated Timeframe - 1 January 2021 – 31 December 2021.

Note that Competenz (the forest industry ITO) has been a service provider in respect of
managing the database that will be required to provide system integrity for Safetree Worker
Certification, as well as assisting in the training of assessors and moderators.
2021 Forest Growers Levy Annual Work Programme | 19

Certification
 Activity                               Product                         Cost
 Training sufficient   Training sessions and peer review workshops    $45,000
 assessors for
 individual
 certification and
 conducting peer
 review workshops
 Training sufficient   Training sessions and peer review workshops    $54,494
 auditors for
 contractor company
 certification and
 conducting peer
 review workshops
 System                        Management and reporting               $55,000
 administration
 Bravegen                              IT provider                    $50,000
 Governance panel        Maintenance of governance processes,          $5,000
                         appointment of auditors and review of
                                      standards
 Total cost                                                           $209,494

Certification
 Year                                Costs
 2018                               $140,000
 2019                               $180,000
 2020                               $180,000
 2021                               $209,494
2021 Forest Growers Levy Annual Work Programme | 20

Promotion ($892,957)

                                                                                              2021          2021
Projects within the portfolio allocation
                                                                                             Funding       Funding
                                                                                            Requested      Approved
                                                                                                             By
                                                                                                         Committee

Facts & Figures publication                                                                   $15,000      $15,000
The flagship industry one-stop-shop annually updated information source, published with
MPI, on all aspects of forest industry. Data covers production, exports, world forestry,
comparisons with other sectors of the primary industries, contact lists, biodiversity
monitoring, employment, health and safety progress, environmental monitoring,
employment, health and safety progress and environmental monitoring.

External Membership                                                                           $10,000      $10,000
Membership of other organisations, such as Business NZ, ICFPA

Sponsorship                                                                                   $10,000      $10,000
Funding available to support events, either regularly or one-off events, which enhance
industry messaging and networking

FFA Communications                                                                            $65,000      $65,000
Grants to FFA in its work in publishing and distributing Tree Grower and Newsletters, the
extension and maintenance of the small-scale forester contact list, the updating of the
FFA website and Farm Forestry E-News.

Social Media                                                                                  $40,000      $40,000
Since early 2019 operated by GrassRoots Media, with Twitter and Facebook activity to
develop an on-line profile for the forest industry.

Love our Forests Campaign                                                                    $307,957      $307,957
The project is examining the cohesion, branding, efficacy, and focus of FGLT funded
activities to maintain industry social license and in particular to consider adequacy of
resources and strategy to counter recent media and political antagonism towards the
forest industry including a perception that forestry does not engage with people and
communities the way other primary industry players do.

TNZ Campaign Ongoing Love our Forests campaign, using broadcast and on-line, high-
visibility and big impact television commercials This campaign is designed to create an
impact largely through utilising the existing set of television commercials and library
footage. Similar campaigns are, or have recently been, conducted by the seafood and
dairy industries.
2021 Forest Growers Levy Annual Work Programme | 21

Key messaging will be on the environmental positives of the forest industry, in particular
carbon sequestration.

Print Radio Ongoing targeted print/radio Love our Forests social licence campaign with
regular issue theme-change outs, with greater emphasis on profiling participants in the
industry. To include possible billboard installations.

Website Development                                                                            $30,000    $30,000
A proposed URL which is necessary to fill a major information gap to provide Love our
Forests extended text, video and image messaging reference from the tv, print and radio
campaigns, wider based than NZ Wood site.

Central Districts Fieldays Forestry Expo                                                       $25,000    $25,000
Proposal to highlight forestry advantages and promotion of forest careers as a one-off
response in March to 50SoG propaganda in the region.

Update FFA Forest Owner Address Database                                                       $50,000    $50,000

The project will refresh the accuracy of the forest owner address database. Address lists
from this database are used by a number of government and industry agencies (WorkSafe,
MPI, Forest Growers’ Levy Board, NEFD Committee etc) to communicate with small forest
owners both regionally and across the country.

The forest owner address database currently holds the public domain postal addresses of
10,000 of the known 14,500 forest owning entities in NZ. The addresses fall out of date at
the rate of around 6-8% a year and are regularly updated. However the satellite imagery
which identified the forests was taken in 2010. Over the last 10 years new forests have
been planted while others have been harvested and not replanted. The project will use a
GIS specialist to access new satellite imagery, identify the plantation forests, and overlay
the forest polygons on the cadastral database so that the owner address database can be
refreshed. The project should capture new small forests, provide higher resolution data
(at present 5 ha), increase the accuracy of the ownership list and act as a cross check on
the rate of ‘address attrition’.

Small Scale Levy Payer Work Programme Admin grant                                              $40,000    $40,000

Administration, reporting and support for the activities listed below; support for the
broader levy work programme. National co-ordination of levy related information and
regular activity reporting to small scale growers, and interaction with the public and
government agencies.

Residual components to be confirmed by FGLT Board in 2021                                                $300,000
2021 Forest Growers Levy Annual Work Programme | 22

Research Science & Technology ($5,143,347)

As with prior years, the majority of the existing projects set out below, represent continuations of long term, co-funded
research and have obtained consistent funding from the Trust since their establishment. These programmes continue to
receive strong industry support and are considered highly relevant to achieving the recently finalised (2020), Forest
Growers Science and Innovation Plan. It should be noted that changes to this funding will have significant implications,
especially where MBIE co-funding is directly leveraged to commercial money.

Over the last 12 months the Forest Research Committee (FRC) has established a strategic assessment framework designed
to complement the Science and Innovation Plan and ensure consistent and deliberate assessment of requests for funding
from FRC (and subsequently to FGLT). The model uses a weighted assessment to measure each project’s ability to
contribute to a set of drivers and was used to assess all programmes requesting funding in 2021. Only projects making the
highest overall strategic contribution were recommended for funding.

Two new programmes were developed during 2020 and submitted to funding agencies for government funding support.
The first is the Tree Microbiome programme which aims to develop a new model system based on P. radiata using the root
microbiome to alter a tree’s response to changing environmental conditions. This was submitted to the MBIE Endeavour
programme and was announced as successful in September 2020. The second is a project looking to create precision
forestry tools for the improved management of weedy vegetation. This was also submitted to the MBIE Endeavour fund as
a programme but was not successful, however this work is currently being re-developed to have a more applied focus for
plantation forestry and will be submitted to MPI’s Sustainable Food, Fibre Futures fund during 2021. The co- funding for
both of these programmes is included in the proposed work programme.

Ongoing work in areas of mutual interest with the Radiata Pine Breeding Programme (RPBC) is expected to be supported
via the Next generation Genetics and Deployment project, that in its current phase will focus on assessment of RPBC large
plot trials as a way of gathering data on genetic performance for incorporation into industry growth models.

Small grower efficiency and subsequent access to automation and/or innovative new technology is seen as an area of
opportunity by the SME committee, however validation of system suitability and understanding the capability of the
various systems is out of reach for many small growers. A project aiming to review and report across many critical aspects
of small grower activity will look to help address this knowledge gap and serve as a valuable resource for small growers
moving forward.

                                                                                                 2021            2021
 Projects within the portfolio allocation
                                                                                                Funding        Funding
                                                                                               Requested       Approved
                                                                                                                  By
                                                                                                             Committee

 Specialty Wood Products Partnership (SWP)                                                      $395,000       $395,000
 A six-year partnership with MBIE and a number of forest companies who are investing an
 equivalent level of funding as FGLT. Partnership is focused on raising the confidence of
 growers in other species. These are Douglas fir, Cypress species, durable eucalypts and
 non-durable eucalypts. The programme will enter its fifth year of a six year programme
 and in addition to breeding and site to species matching it also has a focus on new wood
2021 Forest Growers Levy Annual Work Programme | 23

product opportunities from these species. Funding request in 2021 has increased by
$50,000 due to reduction in direct industry investment by one company.

Automation and Robotics in Harvesting and Logistics                                           $1,130,000   $1,130,000
 A Primary Growth Partnership(PGP) between industry and MPI with a focus on
automation and robotics post tree felling to improve the safety and efficiency of
operations in the log supply chain, reduce repetitive manual tasks and make harvesting
and logistics jobs a more attractive option for a new generation of workers. Projects
include hauler automation, log tagging, residue management and automated log sorting
and transport. The Partnership commenced on 1 January 2019 and will enter its third year
of seven years with industry contributing 60% and MPI 40%. As per the work plan
submitted to MBIE industry funding increases from $0.9m to $1.13m in 2021.

Somatic Embryogenesis Propagation and Automation                                              $600,000     $600,000
A six year partnership with MBIE that commenced on 1 July 2019 and is focused on
improving the efficiency of tissue culture plant production through automated bioreactor
and propagation systems. Building on the significant past investment in breeding and
genomics this programme aims to considerably shorten the time required to deploy the
best genetics from breeding programmes to the forest. It will also broaden the selection of
improved genotypes that can be propagated efficiently and is a perquisite for gene editing
and other genetic technologies.

Tree Microbiome                                                                               $300,000     $300,000
A five year MBIE funded endeavour programme that aims to take scientific learnings from
the human microbiome and use them to guide research on the root microbiome of radiata
pine with the goal of understanding how the root microbiome can alter a tree’s response
to changing environmental conditions.

Integrating Forestry and Pastoral Farming for Profitable and Sustainable Land Use              $10,000      $10,000
A small SFF programme involving Dairy NZ, Scion, AgResearch, Beef and Lamb, Landcorp
and others that we are committed to with the aim of investigating means of integrating
forestry into pastoral farming systems to improve overall profitability for landowners.

Wilding Conifer Management                                                                    $225,000     $225,000
This is a six year MBIE funded programme in its final year, ending 30th September 2021,
with collaborations between LandCare Research, Scion, DOC and MPI. Whilst the
programme has improved detection and control objectives the primary focus of the
industry investment is prevention through production of sterile Douglas fir. The
programme is utilising GE technologies – gene editing and transformation – to engineer
sterility so the threat of wilding spread from new planting of Douglas fir is eliminated.

Extreme Fire                                                                                   $60,000      $60,000
An MBIE funded programme, ending in September 2022, focusing on improved
technologies and tools to respond to an increasing threat of extreme fire events. Since the
programme commenced there have been 2 such events. Improved real time detection
2021 Forest Growers Levy Annual Work Programme | 24

tools, improved fire spread and fire behaviour tools, UAV applications for monitoring fires
and hot spot detection and smoke spread modelling are key components of the
programme. Strong collaboration with US Forest Service.

Bio Control                                                                                   $180,000     $180,000
This innovative programme is researching the role that beneficial soil organisms, in this
case Trichoderma, can play in improving forest health and productivity. An extensive
range of trials have been established throughout the country and we are beginning to see
positive results from this work. Increased growth and tree health are being observed,
Industry uptake of this research is occurring with many nurseries now routinely treating
seed. The programme is also investigating whether it is feasible to introduce Trichoderma
to mid rotation stands and their potential application to improving health and vigour in
Douglas fir and cypress species.

Next Generation Genetics and Deployment                                                       $160,000     $160,000
Agreement has been reached with Radiata Pine Breeding Company to work with them on
collecting information at stand level on the performance of the latest genetic material
coming out of the breeding programme. RPBC are establishing the trials and assessing
individual tree performance to determine breeding values and FGLT is measuring the
PSP’s established in the stands for growth modelling purposes to demonstrate the value
of genetic improvement. The programme also includes a nursery automation component
aimed at speeding up the planting of elite tree stocks coming out of the tissue culture
programmes in small plugs to reduce the reliance on nursery labour.

Hosting and Supporting On-line Radiator Calculator                                             $25,000      $25,000
Hosting the Radiata On Line Forecaster Calculator that is used by small growers and
consultants to develop yield estimates and to evaluate alternative silvicultural regimes.

Forest Growers Conference and Workshops                                                        $20,000      $20,000
Support for workshops and conferences where the full cost cannot be recovered through
user pays.

Forest Operations and Disease Control                                                          $45,000      $45,000
The aims of the project are to undertake a detailed study to quantify the movement of
pathogens on logging trucks and forestry equipment during operational activities and
Investigate patterns in logging truck movements to provide information on potential
pathogen movements. This will aid decision making if biosecurity zones are to be set up in
response to a biosecurity threat or emerging disease. The proposed programme will also
assess the threat of other human pathways, such as the movement of machinery, other
vehicles, equipment, gear, and personnel apparel. This programme will target an SFFF
application.

Resilient Forests                                                                             $2,600,000   $1,764,847
A continuation of the 2020 interim programme, the 2021 Resilient Forests programme
aims to investigate ways to improve the resilience of planted forests to increased risks
2021 Forest Growers Levy Annual Work Programme | 25

emerging due to climate change, political and market volatility and changing social norms.
In the coming period, the programme will specifically look at developing risk models and
decision support tools, further characterise genetic performance by site, create new
strategies to manage wood properties, disease and tree nutrition, as well as improving
knowledge on the above-ground microbiome.

Environmentally Sustainable Vegetation Management                                             $75,000     $75,000
A modified SFFF proposal will be created (from the original Endeavour proposal that was
not funded), that seeks to combine advanced real-time vision systems and plant-
recognition algorithms to spatially quantify the intensity of competition between trees
and weeds; then produce new precision forest vegetation management systems by
integrating this information with highly accurate unmanned aerial herbicide-application
systems able to deliver optimal herbicide doses.

Small Grower Harvesting Innovation                                                            $96,000     $96,000
Supported by the SME committee, this study will undertake a practical review of 4 new
small forest harvesting systems (broadly encompassing all aspects of harvest cycles e.g.
road construction, felling, extraction, processing, handling, load-out and transportation).
The study will establish production capacity and cost models for each system, and
ultimately design 2-3 optimal harvest systems suited to small grower needs.

N-fixing Bacteria                                                                             $57,500     $57,500
This funding would contribute to a 5-year Endeavour research programme that aims to
extend current Trichoderma research, by exploring co-infection of synergistic n-fixing
bacteria with Trichoderma as a way of enhancing tree growth and therefore reducing the
need for artificial fertiliser.
2021 Forest Growers Levy Annual Work Programme | 26

Small & Medium Enterprise ($118,044)

                                                                                               2021        2021
Projects within the portfolio allocation
                                                                                              Funding     Funding
                                                                                             Requested    Approved
                                                                                                            By
                                                                                                         Committee

Travel and Incidentals                                                                        $5,000      $3,104
Costs to support participation by FFA members’ attendance at meetings in Wellington.

TreeFarmer Web Tool - Completion of TreeFarmer                                               $114,940    $114,940
TreeFarmer is an innovative prototype geospatial web tool developed in 2020 with the aim
of improving the harvesting experience of small-scale forest grower’s (SSFG). It does this
by raising the grower’s awareness of the issues and decisions they will encounter with
harvesting on their property. It will engage them in the process of rudimentary harvest
planning while providing underpinning spatial information that drives costs and suggest a
checklist of things to consider. This tool operates on the principle that most forestry
decisions are driven by factors that are local and spatial, i.e. they are site specific.

To complete an accurate production version of TreeFarmer, more functionality is needed
that drive decisions, e.g. complex slope calculations from exiting terrain layers and more
web links made to complete access to sets of harvesting related spatial information.

New functionality that will support forest establishment decisions and builds forest
growing knowledge, with full environmental compliance, will be prototyped this year to
encourage new forest investment.
2021 Forest Growers Levy Annual Work Programme | 27

Training & Careers ($471,473)

This program is managed and overseen by the Training and Careers Committee whose purpose is to consult on and
support a coordinated program on plantation forestry training delivery and training needs. The committee has
representation from forest grower representatives (FOA, FFA, Future Foresters, Wood Councils), plus, industry
representatives comprising FICA, Competenz (the industry’s ITO), government as well as training providers (School of
Forestry, PolyTechs) to ensure the Work Program supports standards and training solutions that deliver on current
industry needs.

The committee actively supports the promotion of forestry careers, both directly and by working with and through other
agencies.

                                                                                                   2021        2021
 Projects within the portfolio allocation
                                                                                                  Funding     Funding
                                                                                                 Requested    Approved
                                                                                                                By
                                                                                                             Committee

 Training Material                                                                                $20,000     $15,000
 Ongoing sourcing, preparation, presentation, promotion of training materials.
 High quality resources are required to attract suitable high-quality people to the forest
 industry. Sourcing this information, amalgamation and dissemination is complex as the
 resources are from a wide range of institutions, geographically spread and must be
 appropriate to the audience i.e. there can be literacy and numeracy issues. The funding
 resources sourcing, targeting, creation and delivery. Materials are available for Expos,
 Schools, etc.and include folders, brochures, and videos (via the T&C portal and data-
 sticks). Funded activities include promotional activities in Job/Training media.

 Portal Maintenance and Development                                                               $20,000     $20,000
 Forestry Careers Portal update, maintenance and expansion. Ongoing sourcing of
 data, management of the site, responding to queries and site promotion are key to the
 success of the portal. Active projects include:

     •    Identification, sourcing and dissemination of training materials.

 To keep the portal functional, up to date and fresh requires a focus to consistently actively
 promote the site . Due to the number of individuals / institutions, and the geographic
 spread throughout NZ, keeping the site fresh is complex.

 National Recruitment Campaign                                                                    $60,o00     $50,000
 To continue the collective promotion and recruitment campaign funded in part for 2020-
 2021. Targeting improvement in public perception. A vehicle that has been used by other
 organisations namely the wood councils, NZFOA and MPI in companion campaigns.
 Directs activity to the Forestry Careers portal. Covering national media, radio, print and
 digital. Organised and managed by FICA.
2021 Forest Growers Levy Annual Work Programme | 28

NZIF Future Foresters Support.                                                                  $30,000    $10,000
Future Foresters is a Special Interest Group within the NZ Institute of Forestry. They play a
pivotal role in expanding the New Zealand forestry industry by attracting school leavers,
and others, into careers in forestry and by supporting them in their early career
development.

Future Foresters has 5 main objectives:

    1.   Provide a community for young people in forestry
    2.   Connect young foresters with those more experienced
    3.   Provide a relatable face to promote forestry to younger generations
    4.   Provide a collective voice for young people in forestry
    5.   Provide career development opportunities to young people in forestry

Future Foresters will continue to develop the community of young (or new) entrants into
forestry through Future Foresters. It will:

    •    Use the community to promote the industry and play an active role in attracting
         new entrants to the industry whether school leavers or others considering a
         career change to forestry.
    •    Develop appropriate resource material through Future Foresters to help
         encourage school students in their final years of study to consider forestry as a
         career option.
    •    Provide training to designated Future Foresters members to promote the
         industry in schools and careers events. Additionally, Future Foresters will
         facilitate members in receiving early career development opportunities

Give members a chance to have their say on industry issues through the communications
channels of Future Foresters.

University of Canterbury - Support of Teaching and Research in Forest Engineering /             $100,000   $50,000
Operations at the School of Forestry (SoF)
2019 – Year 1 of 3 years $100,000
2020 – Year 2 0f 3 years $100,000
2021 – Year 3 of 3 : $70,000
The three year request for a yearly grant to the University of Canterbury School of
Forestry commitment will complete in 2021. The School of Forestry (SOF) goal is to
provide their graduates with a high standard of knowledge and understanding of harvest
planning, harvest system productivity and cost, safety in all aspects of forestry and
environmental protection for the landscape we work in. They are consistently identified by
the NZ Forest Industry as important skills for young professionals entering the industry.
The SOF also looks to continue the learning opportunities for those engaged in forestry by
running professional development courses and have developed a graduate level
programme with quality research outputs. Currently the SOF only has two staff members
that specialise in forest operations (that includes safety and environmental performance),
with the second academic position created based on FGLT providing strong industry
financial support. With continued Forest Grower Levy investment, the SOF is able to
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