TASMANIAN FOREST ESTATE - RMS Timberlands Australia Pty Ltd

TASMANIAN FOREST ESTATE - RMS Timberlands Australia Pty Ltd
RMS Timberlands Australia Pty Ltd

     Forest Management Plan

              For the period
      January 2017 to December 2019

                           PO Box 212 | Prospect | TAS 7250 | Australia
                                 8-2 Trotters Lane | Prospect | TAS 7250
                                                   P: 61 3 6343 0273 | F:
                         E: ausinfo@pfolsen.com | www.pfolsen.com/au
TASMANIAN FOREST ESTATE - RMS Timberlands Australia Pty Ltd
                                                                                                                            Forest Management Plan

Table of Contents

1.       Introduction .................................................................................................................................4
2.       Management System and Objectives ..........................................................................................6
3.       The Regulatory Environment .....................................................................................................10
4.       Forest Estate Description ..........................................................................................................11
5.       Maps and Data...........................................................................................................................13
6.       Social Context and Community Engagement ............................................................................15
7.       Cultural Heritage .......................................................................................................................18
8.       The physical environment .........................................................................................................20
9.       Biodiversity Values ....................................................................................................................23
10.      Non-Timber Forest Products and Values...................................................................................25
11.      Commercial Crop Establishment ...............................................................................................28
12.      Silvicultural Operations .............................................................................................................30
13.      Forest Inventory and Quality Assurance ...................................................................................32
14.      Harvesting Strategy and Operations .........................................................................................34
15.      Property Management and Protection .....................................................................................36
16.      Fire Management ......................................................................................................................38
17.      Monitoring .................................................................................................................................40
18.      Review and Future Plans ...........................................................................................................42

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For the period
January 2017 to December 2019                                      DISCLAIMER                                                                              Page 2
TASMANIAN FOREST ESTATE - RMS Timberlands Australia Pty Ltd
                                                                                   Forest Management Plan

                            Version No           Reason for Review
                            1.0                  Original IFarm Plan
                            2.0                  PF Olsen Australia review

                            Reviewed and recommended by            David Bennett
                            Authorised by                         Stephen Rymer
                            Issue Date                               August 2017
                            Version No                                       2.0

For the period
January 2017 to December 2019                   DISCLAIMER                                          Page 3
TASMANIAN FOREST ESTATE - RMS Timberlands Australia Pty Ltd
                                                                                      Forest Management Plan

1.     Introduction

Purpose                     This management plan:
                                Describes the physical features of the RMS Timberlands Forest Estate.
                                Clarifies the management arrangements and objectives.
                                Outlines the relevant constraints for forest management.
                                Provides a silvicultural framework for optimising value and
                                 minimising risk.
                            Implementing this Management Plan will ensure that the Tasmanian Forest
                            Estate is sustainably managed to achieve the goals of the forest owner
                            within the legislative framework of the region.

Forest Owner               The forest estate is owned by investment funds administered by RMS
                           Timberlands Australia Pty Ltd (RMS Timberlands), a subsidiary of Resource
                           Management Services Inc. Resource Management Services Inc, is a global
                           forest investment manager with significant expertise in all phases of
                           institutional investment funding and has been appointed as property
                           manager by the registered proprietors.

                           There are two registered proprietors of the forest estate. They are:
                               FGI Australia Pty Ltd (Also known as FGI), and
                                RMS Assets Australia Pty Ltd as trustee of the RMS Australia Forest
                                 Fund 1 (Also known as KPI)

Forest Manager             RMS Timberlands as property manager has engaged PF Olsen (Aus) Pty Ltd
                           (PF Olsen Australia) as a specialist forest manager to maximise the
                           investment returns to the forest owners and minimise the risks associated
                           with forest management. The relationship between PF Olsen Australia and
                           RMS Timberlands is described in management contracts.

                                For stakeholders with concerns, PF Olsen Australia should be the first
                                 organisation they contact as they are responsible for day to day
                                 management of the forests.

                           The table below summaries key responsibilities of the different parties.

                                                                             Continued on next page...

For the period
January 2017 to December 2019                    Introduction                                             Page 4
                                                                                         Forest Management Plan


                            PF Olsen Australia                              RMS Timberlands
                                 Neighbour    (stakeholder)           Sales and marketing
                                                                       Resource modelling
                                 Fire preparedness and
                                                                       Authorisation of budgets
                                                                       Development of silvicultural
                                 Weed and pest control
                                 Site establishment
                                                                       Log handling and processing in
                                 Inventory programs                    log yards and chip facilities
                                 Spatial data
                                 Secondary fertilising
                                 Council and       governance
                                  related issues
                                 Certification
                                 Harvesting      and    roading
                                 Transport of timber to log

RMS Timberlands             RMS is committed to leading environmentally sound sustainable forest
Australia Pty Ltd           management practices on all forest lands under its management authority.
                            As a company founded, owned, and managed by professional foresters,
                            RMS has long been guided by a forest stewardship ethic. Exercising good
                            stewardship through responsible management of all forest resources meets
                            the needs of our clients, customers, employees, society, and future

                            In order to apply these principals effectively and systematically to this asset
                            it has engaged PF Olsen Australia. As an independent professional forest
                            manager, PF Olsen Australia has a management system that has been
                            certified against independent standards for forest management.
                            PF Olsen Australia is responsible for ensuring compliance with the
                            requirements of the Australian Forestry Standard. The following document
                            outlines the compliance plan.

Management                 PF Olsen Australia’s Risk and Compliance Manager is the management
representative             representative for the Australian Forestry Standard.

For the period
January 2017 to December 2019                      Introduction                                               Page 5
                                                                                       Forest Management Plan

2.     Management System and Objectives

Environmental               The forests provide a range of benefits, including:
and economic                     Enhanced water quality,
                                 Soil stabilisation and conservation,
                                 Improved aquatic habitat,
                                 Enhanced wildlife and plant habitat leading to increased biodiversity,
                                 A reduction in greenhouse gases,
                                 Local and regional employment opportunities, and
                                 Other economic and social benefits to the community.

Scope                       This management plan covers all forest management activities within
                            Tasmania Forest Estate. Such activities include:
                                 Forest establishment,
                                 Silvicultural activities,
                                 Forest protection,
                                 Monitoring,
                                 Infrastructure maintenance,
                                 Harvesting, and
                                 Fire Management.

Objectives                 The forest management objectives for the Tasmania Forest Estate are to:
                                Grow trees for the production of hardwood chip and other emerging
                                 market opportunities such as biomass, veneer and sawn timber,
                                Ensure that the productivity of the land does not decline,
                                Ensure that environmental values are identified, maintained and
                                 where possible, enhanced,
                                Ensure that historic sites are identified and protected,
                                Optimise the economic return to the forest owner,
                                Replant or ensure regeneration following harvesting in the core
                                 region where it is economically viable to replant or regenerate,
                                Avoid permanent damage to native vegetation,
                                                                              Continued on next page...

For the period
January 2017 to December 2019             Management System and Objectives                                 Page 6
                                                                                           Forest Management Plan

 …continued                     PF Olsen Australia is committed to ensuring that the management of the
                                forest estate is sustainable, from an environmental, social, cultural and
                                economic perspective. These objectives underpin the company’s
                                management culture and its commitment to independent third party forest
                                certification, in particular conformance with the principles and criteria of
                                the Australia Forestry Standard. Table 1 identifies some of the management
                                aims involved with these perspectives.

                            Table 1: Management aims related to listed perspectives

    Perspective                                           Management Aims (not finite)
    Environmental                      Identification and protection of rare, threatened and endangered
                                        species and ecosystems.
                                       Control of noxious pests.
                                       Protection of waterways and reserves.
    Social                             Adherence to occupational health and safety standards.
                                       Adherence to international employment conventions as they
                                        have been legislated in Australian state and federal law.
    Cultural                            Identification and protection of historic and archaeological sites.
                                        Consultation with interested parties.
    Economic                            Suitable species selection.
                                        Appropriate management and harvesting techniques.
                                        Protection of assets.
                                        Providing a reasonable return on investment while minimising
                                         the risks of this investment.

Implementation              The forest management objectives described above are implemented by
                            the Forest Manager, PF Olsen Australia. PF Olsen Australia applies
                            recognised best forestry management practice within a quality
                            management framework to plan for and deliver the required forest
                            management objectives.
                            The Quality management framework includes :
                                      The PF Olsen Australia forest management system, ensuring that the
                                       forest management planning is up to date and operations are
                                       scheduled and undertaken according to the plan.
                                      The PF Olsen Australia environmental management system, ensuring
                                       that high standards of environmental management are recognised
                                       and integrated into every facet of the forest planning and
                                      Certification of compliance with the principles and criteria of the
                                       Australia Forestry Standard to ensure management principles and
                                       practice adhere to internationally recognised and locally adopted
                                       standards for well managed forests.

For the period
January 2017 to December 2019                 Management System and Objectives                                 Page 7
                                                                                          Forest Management Plan

Forest                      PF Olsen Australia resources a Forest Information Planning System (FIPS) to
Information                 assist in ensuring regulatory and certification compliance, including:
Planning System                  transparent management accounting
                                 efficient data capture
                                 effective use of resource information.

Policies and               There are four core policies in the PF Olsen Australia management system:
Standards                      Workplace Health & Safety
                                Sustainable Forest Management
                                Stakeholder Engagement and Communication
                                Learning and Continuous Improvement
                           Standards support these policies and ensure consistency with relevant
                           Sustainable Forest Management Standards. The clauses in these Standards
                           are key requirements which form the basis of internal audit and review.
                           These are publicly available on the PF Olsen Australia website1.

The                        The purpose of PF Olsen Australia’s management system is to:
Management                     Add value to a client’s assets / business via the applications of our
System                          skills and processes.
framework                  It applies a holistic and systematic approach to ensure that prevention of
                           adverse and harmful impacts is effective. Key elements comprising the
                           Management System are:
                                PF Olsen Australia’s Policies and Standards,
                                Manuals (Operations, Administration and Fire Management),
                                Best Practice Guidelines,
                                Management Plans,
                                Contracts,
                                Prescriptions,
                                Operational plans,
                                Procedures for managing emergency situations.

                                                                                  Continued on next page...

 PF Olsen (Aus) Pty Ltd Policies and Standards are publicly available online at

For the period
January 2017 to December 2019            Management System and Objectives                                     Page 8
                                                                                        Forest Management Plan

 …continued                         Periodic internal and external auditing:
                                     –     To check compliance with agreed procedures; and
                                     –     Discuss ways to improve the Management System to better
                                           achieve its targets and objectives.
                                PF Olsen Australia is progressively replacing written manuals with more
                                accessible and descriptive processes maps. The Risk and Compliance
                                Manager is responsible for ensuring that the Management System is
                                maintained and compliant with AS4801, ISO 14001 and ISO 9002 standards.

Management                 An overview of the management system employed by PF Olsen Australia is
System overview            shown in Figure 1.

                                                                    Figure 1 Management System overview

Publically                 Publically available documents can be found on the PF Olsen Australia
available                  website and include:
documents                  •      RMS Forest Management AFS Certificate
                           •      RMS’s Sustainable Forest Management Statement of Intent
                           •      The Regional Management Plan (this document)
                           •      Defined Forest Area maps
                           •      Summaries of recent certification audits
                           Other elements of the Forest Management Plan referenced in this plan are
                           considered private. These may be made available upon request.

For the period
January 2017 to December 2019              Management System and Objectives                               Page 9
                                                                                        Forest Management Plan

3.     The Regulatory Environment

Regulatory                  In order to minimise the risk to forest owners, managers and contractors, it
considerations              is important that relevant legislation and agreements are identified and
                            appropriate measures put in place to ensure that breaches of legislation are
                            avoided. Legislation that currently applies to forest operations are listed in
                            the PF Olsen Australia Legal Register and relevant operational plans where
                            there are specific consents and agreements.

                            The key elements of relevant laws are summarised in our policies,
                            standards, best practice guidelines and prescriptions.

Tasmanian laws             In Tasmania, management and protection of environmental and cultural
                           values is administered through the Forest Practices Act 1985 and the Forest
                           Practices Code (FPC). Forest Practices Officers (FPO’s) undertake a desktop
                           and field verification, on individual properties, of the biodiversity, cultural
                           heritage, soil and water and landscape for prescribed operations. The
                           Forest Practices Authority (FPA) is the regulator charged with implementing
                           the Forest Practices Act.

                           The FPA has biodiversity, earth sciences and cultural heritage specialists
                           who provide advice to FPOs preparing FPPs or supervising forest operations.
                           The FPA also provides a number of planning tools which assist FPOs in
                           preparing FPPs. The FPA monitors compliance with legal requirements
                           under the forest practices system. FPA specialists also work closely with
                           other State and Commonwealth regulators to ensure conservation values
                           are incorporated in advice provided to FPOs.

                           Forest Practices Plans (FPPs) contain specifications of the forest practices to
                           be carried in accordance with the Forest Practices Code. FPPs identify
                           discreet operational phases for which certificates of compliance must be
                           provided to the FPA at the end of each phase. The Threatened Species
                           Protection Act 1995 also recognises FPPs as a means of managing
                           threatened species during forest operations.

Breaches of laws           Where breaches of laws within the scope of certification to AS 4708 are
                           identified on the forest estate the PF Olsen Australia Risk and Compliance
                           Manager will notify RMS Timberlands and the certification body responsible
                           for the RMS Timberlands AFS certificate in writing within five (5) business

Native Title               There is no native title claim on any land owned by RMS within Tasmania.

For the period
January 2017 to December 2019               The Regulatory Environment                                       Page 10
                                                                                       Forest Management Plan

4.     Forest Estate Description

Defined Forest             The Defined Forest Area (DFA) is situated on freehold land under numerous
Area                       titles throughout Tasmania and are included in a single Forest Management
                           Unit (FMU). The FMU is predominantly small scattered properties generally
                           between 10 and 200 ha in size.

                           Land use of the estate, including the net stocked areas have been
                           determined through spatial analysis. Table 2 Land Use as of 30 July
                           2017outlines the key land use categories. Due to pre-existing contractual
                           arrangements, some areas of land managed by RMS are currently under the
                           DFA of other companies. As these areas are harvested, they will be included
                           in the RMS DFA.

Table 2 Land Use as of 30 July 2017
                                Land Use                                         Area (ha)
                                Plantation                                                       24,112
                                Fallow                                                            2,799
                                Remnant Vegetation                                                5,116
                                Other                                                            15,636
                                Total                                                            47,664

Age Class                  The RMS estate was predominantly established during the period 1992
Distribution               through to 2009 with the major period of activity during 2007-2009. Figure
                           2 Age class distribution shows this distribution. RMS is planning to create an
                           even age-class distribution over time through sustainable management of
                           the harvesting and re-establishment programs. This will equate to an
                           approximate annual harvest of 2,000ha.

Figure 2 Age class distribution

For the period
January 2017 to December 2019                Forest Estate Description                                      Page 11
                                                                                   Forest Management Plan

Current                    The planted are comprises 26,832ha hardwood plantations (predominantly
plantation                 Eucalyptus nitens with some E. globulus) and 80ha of softwood plantation
species                    (Pinus radiata). These species have been chosen to best meet the
                           management objectives, given the characteristics of the forest land as
                           described in Section 8.

                           Re-establishment will involve replanting with high quality treestocks
                           suitable for the site and market. These will be investigated during
                           establishment planning.

                           The plantation estate is generally managed for a 15 year rotation for the
                           export of peeler and sawlogs. Currently, the plantation estate is managed
                           to produce solid wood and wood fibre for international markets.

For the period
January 2017 to December 2019               Forest Estate Description                                  Page 12
                                                                                     Forest Management Plan

5.     Maps and Data

Geographic                 PF Olsen Australia maintains a Geographic Information System (GIS). This
Information                comprehensive mapping system and forest inventory database enabling a
System and data            detailed reporting and analysis. The systems are linked such that stand
management                 information is both spatial and descriptive. The system is used to schedule
                           and plan significant changes to the estate, for example: re-planting,
                           fertilising and thinning operations.

Defined Forest             Maps for the DFA are found on the PF Olsen Australia website
Area Maps                  (www.pfolsen.com.au/au).

Mapping                    Mapping will be required from time to time to manage and control
                           operations. PF Olsen Australia foresters create maps with details of:
                                silvicultural operations
                                maintenance operations
                                harvesting operations
                                specific infrastructure
                                roads
                                waterways
                                remnant vegetation
                                protected areas with high conservation values and cultural heritage
                                research trials
                                monitoring locations
                                site hazards and
                                other special values.
                           This will occur on an ongoing basis and all relevant data will be stored

                           Accurate mapping also assists with budgeting, planning and calculation of
                           future revenue and forest values.

For the period
January 2017 to December 2019                      Maps and Data                                         Page 13
                                                                                        Forest Management Plan

Forest records              Forest records are essential for management commercial forests.
                            PF Olsen Australia maintains forest records that include the following
                                historic records of forest operations for each stand
                                quality control data for each operation
                                inventory results.
                                yields harvested from each stand.
                                costs incurred for each operation.

                            Forest Estate records are maintained on a computerised Land Information
                            System which is part of FIPS.

For the period
January 2017 to December 2019                   Maps and Data                                           Page 14
                                                                                      Forest Management Plan

6.     Social Context and Community Engagement

Stakeholder                 PF Olsen Australia has developed a Stakeholder Engagement System which
engagement                  provides a framework for identifying and engaging with different levels of
system                      stakeholders of the forest estate.

Objective                   Our objectives with stakeholder engagement are to:
                                Build a relationship of trust and partnership with stakeholder
                                Assist in the fair assessment and avoidance, remediation or
                                 mitigation of adverse effects upon stakeholders who may have an
                                 interest in or be affected by impacts resulting from management
                                Avoid or minimise the risks of misunderstandings between forest
                                 managers and forest stakeholders or the development of obstructive
                                 or conflict oriented behaviours between the parties.

Previous                   The forest estate is predominantly located on ex-pasture sites. Plantations
management                 were established during the years 1995 to 2009 until the demise of several
                           forestry companies with the collapse of Managed Investment Schemes. The
                           forest owners purchased part of the DFA in 2014 and the remainder in 2015.

Adjacent Lands             The forest estate is widely dispersed across the North and South East of
                           Tasmania. There are 355 individual properties under PF Olsen Australia
                           management and hence a large number of direct neighbours. These
                           neighbouring parcels include crown lands managed for conservation and
                           production forestry, forested lands owned and managed by private
                           companies and individuals, agricultural lands and residential land.

                           The main industries in the northern region of Tasmania are tourism,
                           agriculture, mining and forestry. In the north of the region, the main form
                           of agriculture is beef and dairy farming, as well as vegetable production.

                           Plantation forestry is a major industry in the region. Across Tasmania, there
                           are over 300,000 hectares of hardwood and softwood plantations. Over
                           one-third of the plantations in Tasmania are privately owned. There is high
                           concentration of plantation forests located to the south of Burnie.

                           Mining is another industry in the region, with the active extraction of base
                           metals, coal, iron, gold and silver. Five of the six mineral processors are
                           located in the northern region of Tasmania.

For the period
January 2017 to December 2019         Social Context and Community Engagement                              Page 15
                                                                                          Forest Management Plan

Key stakeholders           Key stakeholders2 include, but are not limited to:
                                Major customers
                                Contractors and suppliers
                                Relevant federal government departments
                                Industry representative bodies
                                Conservation groups and advocates
                                Indigenous communities
                                Relevant state government agencies
                                Local government authorities
                                Neighbours
                                Property level lessees (grazing, house tenants)
                                Local communities and community groups
                                Local fire agencies.

Social impact               A key component of successful stakeholder engagement is social impact
assessment                  assessment in relation to our activities. This undertaken by
                            PF Olsen Australia at three levels of management:
                                This plan identifies and considers regional impacts like road use.
                                Operational Plans and FPPs consider impacts at a local level like
                                 landscape impacts.
                                Best Practise Management Guidelines consider possible social
                                 impacts of particular activities and outline necessary steps to
                                 minimise such impacts and ensure affected stakeholders are
                                 consulted prior to conducting high impact activities.

Employment                 RMS Timberlands and PF Olsen Australia aim to be valuable members of the
                           Tasmanian community. Around 80 FTE’s are engaged to undertake
                           management, silvicultural, harvesting, transport and marketing operations
                           throughout Forest Estate. A large proportion of this workforce are located
                           in smaller rural communities.

Worker’s rights            RMS Timberlands and PF Olsen Australia are equal opportunity employers
                           and recognise the role of unions in the workplace and respects the rights of
                           workers to participate. Unless special conditions apply forest workers will
                           be greater in age than the completion of compulsory school attendance age

 For the purposes of AFS Clause 2.2 key stakeholders are regarded as affected stakeholders and any other
person who engages with the organisation will be regarded as an interested stakeholder.

For the period
January 2017 to December 2019         Social Context and Community Engagement                              Page 16
                                                                                      Forest Management Plan

Health and                 RMS Timberlands and PF Olsen Australia are committed to providing a safe
Safety                     and healthy work environment for workers, customers and visitors. Specific
                           policy standards apply to all operations and these are enforced by regular

                           All incidents and near hits must be reported and these will be diligently

Local                       PF Olsen Australia strives to procure contractors and services from within
procurement                 the local region wherever possible and feasible.

Dispute                    PF Olsen Australia has a dispute resolution policy standard for dealing with
resolution                 complaints and other issues. In addition to this, PF Olsen Australia complies
                           with “The Good Neighbour Charter for Commercial Forestry in Tasmania
                           (2009)”. Disputes often arise from issues such as noise and dust from forest
                           operations, weeds, vermin, fencing, spraying operations and fire
                           management. Best Practice Guidelines exist to minimise the likelihood of
                           disputes. All complaints and disputes are taken seriously and wherever
                           possible resolved as soon as practical. At times the parties may not be able
                           to come to an amicable resolution. In these instances the PF Olsen Australia
                           dispute resolution procedure will be used.

Neighbours                  As responsible neighbours and members of the local community,
                            PF Olsen Australia is aware that our operations may have an impact on
                            others and commit to engage with neighbours and the community.

                            Contact details for neighbours can be accessed as required through Land
                            Information System Tasmania (LIST). Contact will be made with neighbours
                            on behalf of the Forest Owner in accordance with the PF Olsen Australia
                            Stakeholder engagement policy and procedures.

For the period
January 2017 to December 2019         Social Context and Community Engagement                              Page 17
                                                                                          Forest Management Plan

7.     Cultural Heritage

Recognising and             To preserve and protect cultural heritage PF Olsen Australia staff will when
protecting                  developing Forest Practices Plans and other operational plans:
significant values               determine the legal status of any existing rights in forests managed
                                  on behalf of the forest owner.
                                    search relevant government databases and records for identified
                                     sites of significance.
                                    consult with the Aboriginal Heritage Tasmania in relation to existing
                                     legal rights and customary or traditional use rights.
                                    actively seek to identify existing Indigenous peoples with customary
                                     or traditional use rights to forest resources in forests managed on
                                     behalf of the forest owner.
                                    incorporate the results of consultation into relevant operations plans.
                            All aboriginal heritage localities are protected by confidentiality embedded
                            in the Aboriginal Relicts Act, 1975 and information is not accessible to the
                            public. Localities are not normally marked on operational maps – unless
                            required for identification and protection.

Indigenous                           The Forest Owners, RMS Timberlands and PF Olsen Australia
values                          acknowledges and pay respect to the Tasmanian Aboriginal community
                                as the traditional and original owners and continuing custodians of this
                                                          land that we manage.

                           Access to Indigenous site and relicts information is restricted. Only FPO’s
                           trained in “Aboriginal Cultural Awareness” are given access to site
                           information, accessed through either Sustainable Timbers Tasmania (STT)’s
                           Conserve database or Aboriginal Heritage Tasmania (AHT). Known sites
                           from either database are field verified where possible and then managed
                           for harvesting and re-establishment operations as per manuals discussed
                           below. Where known sites are not able to be located, whether due to
                           location accuracy or vegetation cover, these are managed with the advice
                           of the relevant FPA specialists. Any new sites found are protected from
                           operations and reported to the FPA. Generally the sites are then able to be
                           managed through the endorsed FPA procedures manual3, but at times
                           further consultation may be required.

 Forest Practices Authority, Tasmania (March 2016) Procedures for managing Aboriginal cultural heritage
when preparing forest practices plans

For the period
January 2017 to December 2019                      Cultural Heritage                                           Page 18
                                                                                     Forest Management Plan

Non-indigenous             Known non-indigenous cultural heritage site information is currently only
                           available through STT’s Conserve database. Known sites are located in the
                           field and then managed through the manuals described below.

                           New sites discovered during planning or operations, such as water races,
                           tramlines, mine-workings, and habitations are generally managed. Where
                           known sites are not able to be located, whether due to location accuracy or
                           vegetation cover, these are managed with the advice of the FPA specialists.
                           Any new sites found are protected from operations and reported to the FPA.
                           Generally the sites are then able to be managed through procedures
                           manual, but at times further consultation may be required.

                           Non-indigenous cultural heritage, management prescriptions described in
                           FPA endorsed manuals4.

                           Examples of sites from the Tasmanian Forest Estate are the Parrawe sawmill
                           site at Mobbs Road, Mining water races on Saltmarsh and settlers cottage
                           on Big Park.

 Forest Practices Authority, Tasmania (Interim document October 2015) Procedures for managing historic
cultural heritage when preparing forest practices plans,

For the period
January 2017 to December 2019                  Cultural Heritage                                          Page 19
                                                                                      Forest Management Plan

8.     The physical environment

Overview                    Given the complexity of the region, the Regional Management Plan is to be
                            used in conjunction with individual operational plans and FPP’s. Details
                            included in individual FPPs will include:
                                 Location and access
                                 Infrastructure
                                 Geology and soils
                                 Topography
                                 Legal ownership and tenure.

Location and                The Forest Estate is located in the local government areas of:
access                          Break O’Day
                                 Central Cosat
                                 Derwent Valley
                                 Launceston
                                 Burnie
                                 Dorset
                                 West Tamar
                                 Tasman
                                 Meander Valley
                                 Kentish
                                 George Town
                                 Southern Midlands
                                 Northern Midlands
                                 Sorell
                                 Huon Valley
                                 Central Highlands
                                 Waratah/Wynyard
                                 Glamorgan/ Spring Bay
                                 Circular Head

For the period
January 2017 to December 2019                The physical environment                                   Page 20
                                                                                           Forest Management Plan

Infrastructure              Infrastructure located on properties is detailed in the GIS. Plantations are
                            serviced by a mix of state, shire and private roads.

Key markets                There are deep water chip export facilities located at Bell Bay and Burnie.

Topography,                 As the Forest Estate is broadly distributed across the northern side of
geology and soils           Tasmania, topography varies greatly. The topography, geology and soils of
                            specific properties is described in FPP’s when planning operations.

                            Where soils have particular issues such as high erositivity, this is included in
                            FPPs and other operational plans, and specific measure will be considered
                            in operational planning.

Geomorphology              Management of geomorphologic features through harvesting and
                           establishment practices is controlled by the FPC and subsequent FPPs
                           developed in conjunction with FPA specialists.

                           There are two main geomorphologic features known from within the Forest
                           Estate. Both are Karst cave systems in the Mole Creek and Gunns Plains area.
                           These areas have been established with these features in mind and will
                           continue to be managed to minimise the impacts that operations may pose.

Climate                     Climatic data was sourced from weather stations, maintained by the Bureau
                            of Meteorology, within the vicinity of the Forest Estate to provide a guide
                            to general climatic conditions.

                            Figure 3 shows the variation in temperature across the year.

                                                                         Figure 3 Mean monthly temperature
                                                                                   Continued on next page...

For the period
January 2017 to December 2019                 The physical environment                                         Page 21
                                                                                                               Forest Management Plan

…continued                 Mean Annual Rainfall ranges from 775 mm at St Helens to 1068 mm at
                           Marrawah. St Helens, unlike the other locations shown, has significantly
                           reduced rainfall with low variability in mean monthly rainfall (
                           Figure 4).

                                140                                                                            Scottsdale Mean
                                120                                                                            Rainfall (mm)

                                100                                                                            St Helens Mean
                                                                                                               rainfall (mm)
                                                                                                               Sheffield Mean
                                60                                                                             Rainfall (mm)
                                40                                                                             Marrawah Mean
                                20                                                                             Rainfall (mm)








Figure 4 Mean monthly rainfall

Water                      Water quality and flow is affected by numerous natural and man-made
                           factors, such as annual rainfall, vegetation type and age, soils, geology and
                           topography. Human influence stems from clearing, roading, dams,
                           cultivation and any other operation which may alter natural drainage
                           patterns. Inappropriate chemical usage may have adverse impacts on water
                           quality. Storm events and natural disasters may also have a negative
                           influence, through turbidity and erosion processes.

                           In managing the risks associated with forest operations, PF Olsen Australia
                           assesses catchments, categorising streams and applying management
                           strategies to minimise the possible effects. These are implemented through
                           the FPPs and associated operational plans.

For the period
January 2017 to December 2019                           The physical environment                                                 Page 22
                                                                                               Forest Management Plan

9.       Biodiversity Values

Introduction                Indigenous biodiversity management in or associated with plantations is an
                            essential component of PF Olsen Australia’s forest management. Although
                            plantations can provide a level of biodiversity, the areas of native forest are
                            usually the source of most indigenous biodiversity. Rare and threatened
                            species may also be found within planted areas and require special
                            attention for management. This section details protected ecosystems and
                            rare and threatened species found in the Tasmania Forest Estate.

Significant                 PF Olsen Australia is progressively reviewing properties for the presence of
Biodiversity                Significant Biodiversity Values in accordance with its High Conservation
Values                      Value Best Practice Guide and local Tasmanian requirement. The process
                            involves checking government databases for the presence of rare or
                            threatened species or ecosystems and associated ground truthing by
                            suitably qualified professionals5

                            Details of Significant Biodiversity Values and related management
                            objectives are recorded in the GIS, FIPS and on relevant FPPs and
                            operational plans.

                            Operational monitoring will review and assess the appropriateness of these

Protected                   Areas of remnant native vegetation are located throughout the forest
Ecosystems                  estate. These areas are predominantly steep inaccessible land in the North
                            and West, and dry rocky areas in the South and North East, that were too
                            difficult or too poor to convert to pasture by farmers, in years past. In the
                            North and North West, the vegetation type is wet sclerophyll forest, with
                            Eucalyptus viminalis, E. obliqua and some minor patches of rainforest. In the
                            North-East and South, poorer areas are generally dry sclerophyll E.
                            amygdalina forest with some areas of wet sclerophyll containing E. globulus
                            and E. obliqua. These areas are field verified as Forest Practices Planning is
                            undertaken on a property.

                                                                                     Continued on next page...

    PF Olsen Australia employs FPO’s. However, the FPO’s use the expertise of relevant FPA experts to review plans.

For the period
January 2017 to December 2019                      Biodiversity Values                                                Page 23
                                                                                                    Forest Management Plan

 …continued                     Assessments are based on the relevant Bio-regional “Forest Botany
                                Manual” issued by the FPA. At a regional level un-verified forest typing is
                                available on the LIST and Conserve data bases. These are derived from aerial
                                imaging and interpretation, based on the Forest categories from the
                                Tasmania Regional Forest Agreement (1997) with protection given to forest
                                types based on the Comprehensive Adequate and Representative (CAR)
                                reserve system, ensuring that 95%, of the 1996 assessment, is reserved
                                from conversion to other land uses. This addresses the Permanent Native
                                Forest Estate Policy.

                                PF Olsen Australia has a strict exclusion zone policy for areas of remnant
                                native vegetation. This means that areas of remnant native vegetation are
                                not to be damaged or disturbed by forest operation and where possible
                                steps will be taken to enhance the quality of these areas of vegetation by
                                weed management and the exclusion of stock.

                                As a last resort if an existing track through remnant vegetation is required
                                to be upgraded for safe access to or egress from the planted areas, the
                                specific patch of remnant vegetation will be assessed for any significant
                                biological diversity values by a relevant expert prior to any work beginning.
                                Records of vegetation condition before and after shall be maintained on file.

                                Areas of protected ecosystems are identified in the GIS and details of their
                                type, rarity and quality are recorded on in FIPS.

                                Monitoring of native vegetation is undertaken using a series of permanent
                                photo points and the PF Olsen Australia Bio-physical Natural Assessment

Rare and                    Through the Forest Practices System, the identification and management of
threatened                  threatened species is administered and then delivered via Forest Practices
species                     Plans (FPP’s). PF Olsen Australia utilises databases of known sites and
                            predicted zones, administered through, Sustainable Timbers Tasmania’s
                            (STT) Conserve Database and the Department of Primary Industries, Parks,
                            Water and the Environment (DPIPWE) Biodiversity Values Database (BVD).
                            These systems are interrogated by PF Olsen Australia’s Forest Practices
                            Officers and utilised in the desktop and field verification component of the
                            FPP’s. As the possible presence of rare and threatened species is identified,
                            they will be listed in FIPS and management requirements developed.

                            During the management of the plantations our trained staff also record
                            sightings of rare and threatened species that they observe directly or are
                            bought to their attention by other stakeholders.

                                                                                         Continued on next page...

  Knight, R.I. (2013). Rapid assessment method for surveying and mapping biophysical naturalness. A report to PF Olsen
Australia Pty Ltd. Natural Resource Planning, Hobart, Tasmania.

For the period
January 2017 to December 2019                       Biodiversity Values                                                  Page 24
                                                                                       Forest Management Plan

 …continued                     Examples rare and threatened species that are regularly managed through
                                the FPP system are Wedge Tailed Eagle nest searches and operational
                                management around known nests through the breeding season, Grey
                                Goshawk nests searches and Giant Freshwater Crayfish habitat

10. Non-Timber Forest Products and Values

Introduction                Forest plantations may also provide for non-timber forest products that
                            enhance the economic wellbeing of the owner or legitimate forest users.
                            Non-timber products are an important means of maximising the production
                            capacity of the forest whilst maintaining environmental and social values.
                            The forest management plan provides procedures for developing and
                            managing these resources.

                            Forests can also provide many other special values, which are also provided
                            for and managed through the forest management plan.

Non-timber                  The following non-timber products are currently being produced or may be
forest products             produced or developed in the Forest Estate:
                                   building rentals
                                   grazing and hay cutting
                                   apiary
                                   carbon stocks

Building rental             A number of properties have houses or sheds that are rented out. Local
                            real estate agents manage the leases of these assets, with
                            PF Olsen Australia responsible for approving maintenance as necessary on
                            the properties.

                            Details of the infrastructure on the properties that are leased out and which
                            Agent is responsible for them is maintained

For the period
January 2017 to December 2019             Non-Timber Forest Products and Values                             Page 25
                                                                                        Forest Management Plan

Grazing & Hay               Grazing is an effective method of fuel reduction and is conducted (under
Cutting                     agreement between the agistee and PF Olsen) throughout the estate area.
                            Grass levels and stocking rates are to be monitored by the agistee and the
                            forest manager. Hay cutting is also used for fuel reduction on unplanted

                            Consideration of other values on a property, such as native vegetation, and
                            the effect that grazing will have on them will be considered prior to
                            agistment being allowed.

Apiary                      Bee-keeping is another potential source of seasonal income. Apiary permits
                            are managed by PF Olsen Australia.

Carbon                     An estimate of current and future carbon is calculated using equations
                           developed specifically for Tasmanian native forests and Eucalyptus nitens in
                           plantation. The calculations are based on inventory estimates for
                           merchantable volume for native forest and plantation. The equations
                           developed by industry partners, have been based on best available current

                           The carbon cost of extraction relates to carbon emissions for harvesting and
                           transport, equating to 8.36 tonnes of carbon per 1,000 tonnes of wood

                           RMS endeavours to minimise fossil fuel use and maintain or enhance forest
                           carbon by;
                           •     Encouraging the use modern fleets of fuel efficient plant (including
                                 vehicles), having them regularly serviced and maintained,
                           •      Utilise the shortest legal cartage routes where we can, and
                           •      Maintain a productive vigorous plantation estate.

                           A number of strategies to reduce the overall fossil fuel use on the Tasmanian
                           Forest Estate are in place. These include:
                                Working to identify the most efficient combinations of equipment for
                                 harvesting crews
                                Changes to Silvicultural Standards to reduce ripping depth, decrease
                                 use of cultivation and burning.

                           The current year (2017) estimate of current carbon is based on the SOP
                           Carbon Calculation RMS.

                                                                                Continued on next page...

For the period
January 2017 to December 2019           Non-Timber Forest Products and Values                               Page 26
                                                                                       Forest Management Plan


Table 3 Estimate of current carbon
                                Crop                                             Tonnes of C
                                Eucalypt plantation                                            6,948,163
                                Pinus radiata                                                     28,440
                                Native forest                                                    603,386
                                Non forest vegetation                                            495,365
                                Total                                                          8,075,353

                           Based on the annual harvest estimates of 2000ha/year and an average
                           rotation age of 12 and an average MAI of 19 the annual carbon is assumed
                           for eucalyptus plantation to remain relatively stable.

                           The Native forest and non forest vegetation will remain relatively stable
                           within the next rotation of 12 years.

For the period
January 2017 to December 2019            Non-Timber Forest Products and Values                             Page 27
                                                                                         Forest Management Plan

11. Commercial Crop Establishment

Introduction                Crop establishment is a critical sequence of operations that can set up a
                            plantation to achieve its potential. The chosen species has to be suitable for
                            the site and meet the objectives of the Forest Estate. It is also important to
                            ensure that the planting material is of a high quality.

Crop species                The crop species within the Forest Estate is Shining Gum (Eucalyptus
                            nitens) with small areas of Tasmanian Blue Gum (E. globulus).

                            The Tasmanian Blue Gum is endemic to Tasmania and parts of southern
                            Victoria, including the Otway Ranges. Shining gum is endemic to eastern
                            and southern Victoria and NSW as well as small areas in Tasmania.

                            A range of genetic material has been used in the existing RMS Estate. This
                            ranges from wild seed, particularly in the earlier plantings to improved
                            seed. RMS have a number of seed orchards throughout the estate,
                            managed by seedEnergy. These orchards will the main source of seed for
                            new plantings.

                            Shining Gum and Tasmanian Blue Gum are recognised as excellent species
                            for production of high quality chemical pulp that is used in the production
                            of printing papers, due to the whiteness of the wood and short fibre
                            length. Tasmanian Blue Gum has superior pulp yields to Shining Gum.
                            Eucalyptus globulus is the preferred species on most sites. Eucalyptus
                            nitens is suited to high quality high rainfall sites where there is a high risk
                            of frost damage to young seedlings.

                            The estate will be replanted almost exclusively to E. nitens (Shinning
                            Gum). There are no plans to establish Tasmanian Blue Gum (E. globulus) or
                            softwoods (Pinus radiata) on the forest estate. E.nitens has optimal
                            growth on a wide range of sites, well suited to the forest estate.

Wildings                    Eucalyptus globulus seed is one of the largest eucalypt seeds while
                            Eucalyptus nitens has tiny seed. In general seed from these trees does not
                            fall far from the parent tree. Wilding establishment is quite rare. Annual
                            perimeter inspections of planted areas will identify any wildings in adjacent
                            fire breaks or native vegetation and recommend appropriate control

Hybridisation              The risk of hybridisation between plantation E. nitens and susceptible native
                           eucalyptus species adjacent to plantation areas is managed through
                           monitoring as directed by the Forest Practices Code.

For the period
January 2017 to December 2019              Commercial Crop Establishment                                      Page 28
                                                                                      Forest Management Plan

Establishment               The operations undertaken for plantation establishment are dictated by the
                            RMS Silvicultural Standards. Depending on the site quality of the
                            plantation, and harvest type, the operations involved in plantation
                            establishment may include:
                                 Clearing – windrowing of harvest slash. These windrows may be
                                  burnt either the reduce risk or allow the target stocking to be
                                  achieved at planting.
                                Cultivation – depending on the soil type, secondary cultivation breaks
                                 up large soil clods along the planting rows and provides a good micro-
                                 site for planting.
                                Pre-plant weed control – to ensure the planted seedlings have
                                 minimal competition for site resources.
                                Game-control – to minimise impact of browsing by native mammals
                                 on seedlings.
                                Planting – by hand. Planting is closely monitored through Quality
                                 Assessment plotting during the operation.
                                Fertilising – Controlled release fertiliser can be applied by hand
                                 during the planting process or post planting by hand or aerially. This
                                 is required to replace nutrients harvested during the first rotation or
                                 address specific nutrient deficiencies associated with the particular
                                Post-plant weed control – conducted on an ‘as needed’ basis
                                 following site surveys indicating weed competition. When necessary,
                                 post-plant weed control will be achieved through boom spraying over
                                 the planted seedlings, depending on species and chemical options.
                                 More than one post-plant weed control operation may be necessary.
                                Insect control - conducted on an ‘as needed’ basis following site
                                 surveys indicating lower than targeted growth rates. When necessary
                                 insect control will be achieved through spraying over the planted
                                 seedlings, depending on species and chemical options. More than
                                 one treatment may be necessary.
                                Survival Assessment – a survival count is conducted through the
                                 planted area to achieve a minimum survival.

                            PF Olsen Australia Best Practice Guidelines are in place for each of these
                            operations to ensure environmental impacts and health and safety risks are
                            minimised, and all legal and other obligations are met.

Research Trials             The Forest Owners have acquired a plantation estate that has several seed
                            orchards located strategically across the estate. These are managed by a
                            separate entity called Seed Energy. There are numerous progeny and
                            operational trials as well as permanent growth plots. Further research and
                            development with new chemistry and stocking variation is ongoing.

For the period
January 2017 to December 2019             Commercial Crop Establishment                                    Page 29
                                                                                         Forest Management Plan

12. Silvicultural Operations

Introduction                Silvicultural operations are implemented to ensure a good quality forest
                            and maximum growth. Several site specific silvicultural regimes throughout
                            the DFA. Selection of an appropriate regime is pivotal in the pursuit of
                            sustainable forest management. Management objectives, whilst driving the
                            final outcome, are influenced by local conditions (soil, rainfall, altitude and
                            exposure). From this, the estate is broadly broken into four site quality
                            categories with varying stocking rates. These options are determined
                            collaboratively between RMS Timberlands and PF Olsen Australia.

                            All operations require a suitable plan that documents the operation, the
                            expected outcomes, and how these outcomes will be measured (i.e.
                            through quality assessment). The operation plans include:
                                 a written prescription
                                 a map detailing the area to be treated and special values to be
                                 a site safety plan
                            This ensures:
                                 safety of staff and contractors
                                 activities are undertaken consistent with internal and external
                                 a documented history of every activity.

Getting ready               Before silvicultural operations commence a plan is prepared. This plan will
                            be based on the following considerations:
                                 Terrain - what method can be used that is safe for the operators
                                 Soil and water – the impact on soil and water will be minimised
                                  and/or mitigated
                                 Safety – to ensure forest operations are carried out safely and comply
                                  with all legal requirements
                                 Compliance – all relevant legislation and codes of practice must be
                                  complied with.
                                 Wildlife habitat and ecosystems – these will be maintained where
                                  possible or the impact on such habitats will be minimised and/or

                                                                                Continued on next page...

For the period
January 2017 to December 2019                 Silvicultural Operations                                        Page 30
                                                                                      Forest Management Plan

…continued                      Other forest values – to ensure that other forest values such as
                                 recreation and non-timber products are recognised and where
                                 practical protected.
                                Offsite impacts – to identify and minimise the adverse impacts of
                                 forest operations on people and the environment.
                                Financial – to ensure forest operations are carried out in an efficient
                                 and effective manner and consider both short and long term
                           Operations will be undertaken by contractors and supervised by the forest

Chemical usage             Chemicals listed on the World Health Organisation (WHO) class Ia and Ib are
                           not used within the Forest Estate.

                           All pesticides and fertilisers are risk assessed and pre-approved prior to
                           inclusion in silvicultural regimes.

                           Chemical usage is strictly controlled. Operational plans working within
                           legislative framework and Codes of Practice are used to provide neighbours
                           and operators confidence in the procedure. All chemical usage is within
                           label or approved off-label permit requirements. Application contractors
                           are suitably qualified and appropriate PPE is worn.

                           The usage of chemicals on the estate is minimised through the use of;
                                Timing – applying at the most appropriate time for greatest efficacy,
                                Targeted application – applying only where required, and
                                Correct rates – applying minimum quantity to be effective.

                           The forest manager and forest owner are committed to researching
                           alternatives and reviewing the use of existing approved chemicals across the
                           estate. All chemical use is recorded in FIPS.

For the period
January 2017 to December 2019                Silvicultural Operations                                      Page 31
                                                                                         Forest Management Plan

13. Forest Inventory and Quality Assurance

Introduction               Forest inventory and quality assurance checks are critical to ensuring growth
                           is optimised and risk minimised. The following types of checks are
                                Pre-operational assessments
                                Operational quality checks
                                Mid-crop inventory
                                Pre-harvest inventory
                                Permanent growth plots

Pre-operational             Pre-assessment is the collection of stand parameters prior to a silvicultural
assessment                  operation. It allows for:
                                 The calculation of contract rate for the operation.
                                 A final check on the validity of the regime and timing of
                                  commencement of operations e.g. stocking can be achieved or crop
                                  height is sufficient for scheduled coppice thinning.
                            Sampling intensity is low with typically a minimum of five randomly located
                            plots per stand and data is collected from only six trees per plot. Data
                            collected is then used with the time standards set out in the relevant Best
                            Practice Guideline to calculate a man-day target and hence a contract rate
                            per hectare. Contract rates are often set by tender or negotiation, reducing
                            the need to pre-assess each and every block. Pre-assessment however does
                            provide good quality information on the work content involved in each
                            silvicultural operation and sets a base price for negotiation.

Quality control             Quality control is carried out during and after a silvicultural operation. The
                            aims of the quality control system PF Olsen Australia have established are
                               Collect sufficient data to monitor a contractor's performance and
                                correct this if necessary, with minimum delay.
                               Collect sufficient quantitative data to provide reliable estimates of the
                                state of the crop.
                               Provide data as input for growth modelling.
                               Provide data for estimating timing of the next silvicultural operation.

                                                                                 Continued on next page...

For the period
January 2017 to December 2019           Forest Inventory and Quality Assurance                               Page 32
                                                                                      Forest Management Plan

 …continued                     All sampling and measurement is completed in line with procedures
                                developed by PF Olsen Australia.

                                Data is summarised by forest compartment or stand prior to being entered
                                into FIPS – Land Information Module where it is retained as a permanent
                                record. The records can then be directly accessed for growth model and
                                Computer Growth Simulation Programmes, annual reports and valuations.
                                PF Olsen Australia’s "Best Practice Guidelines" detail the procedures to
                                follow pre-assessment and quality control assessments.

Mid-crop                    The principal aim for the mid-crop inventory is to collect stand data for
inventory                   inputs for growth modelling. Under current silvicultural regimes mid-crop
                            inventory is scheduled for between 4 and 5 years of age.

                            Sampling intensity is targeted to achieve an acceptable precision on a stand
                            by stand basis. Smaller stands may be aggregated into crop types to achieve

Pre-Harvest                 The principal aim for the PHI is to obtain estimates of recoverable volume.
Inventory (PHI)             This information can then be used to develop marketing and harvesting
                            strategies. A PHI will be undertaken when stands reach two years or less
                            from harvesting.

                            Sampling intensity is targeted to achieve 15% confidence limits on volume
                            on a stand by stand basis. Smaller stands may be aggregated into crop types
                            to achieve this, as in mid-crop inventory.

Permanent                  Permanent Growth Plots (PGP’s) have been established across the estate in
Growth Plots               order to monitor current and predict future growth and yields. The forest
                           manager will continue to measure and re-establish plantation on existing
                           PGP sites. RMS may also establish new PGP’s where/if they are required for
                           additional data.

For the period
January 2017 to December 2019             Forest Inventory and Quality Assurance                           Page 33
                                                                                        Forest Management Plan

14. Harvesting Strategy and Operations

Rate of harvest            RMS Timberlands is responsible for determining the rate of harvest. It
                           utilises Pre-Harvest Inventory (PHI) and growth models to determine the
                           sustainable level of harvest.

                           RMS currently sells its timber to international customers for both wood fibre
                           and solid wood products. In order to best take of advantage of fluctuating
                           international markets, RMS models a “pool” of possible areas with differing
                           product mixes. These pools are then manipulated around several factors
                           (such as weather limitations, cart distance etc) to give a good spread of
                           differing blocks over the harvest year.

Growth Models              RMS Timberlands uses permanent and temporary plot sampling strategies
                           to guide management decisions and help ensure growth and yield models
                           are appropriate for the properties under management in Tasmania. RMS
                           growth and yield models for Eucalyptus in Tasmania are based on models
                           originally published by Candy (1997), and refit by Musk (2010). Growth and
                           yield system outputs are used in Woodstock planning and optimization
                           software to help produce strategic, tactical and operational plans that meet
                           RMS business goals.

Harvesting                 The optimum timing of harvesting of properties is dependent on a range of
strategy &                 factors including:
Allowable Cut                   Plantation growth;
                                Market conditions;
                                Contractor and port access availability; and
                                Seasonal constraints.
                           A number of different harvesting systems can be used to harvest hardwood
                           plantations for woodchip. These are:
                                Shortwood stystems, where trees are felled, delimbed and forwarded
                                 to roadside where they are loaded into trucks and transported to a
                                 static chipper; and
                                Longwood systems, where trees are felled, skidded to roadside where
                                 they are processed into logs which are loaded into trucks and
                                 transported to a static chipper or export log yards.

                                                                                Continued on next page...

For the period
January 2017 to December 2019            Harvesting Strategy and Operations                                 Page 34
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