CarbonCurious Transcript - Are you LUC-y? - July 2025

In this CarbonCurious session, we break down the proposed ETS rule changes around exotic forest planting on different LUC land types.

We cover what restricted forest land means, what the draft legislation includes, and how exemptions like the 25% rule, ballot, and qualifying forestry investments work. Nick also explains how these rules apply across farm boundaries, land titles, and land use classes, and why planning ahead matters.

If you're involved in forest planning, land use decisions, or ETS registration on behalf of landholders, this session will help you understand the risks and pathways under the new draft rules.

Watch the recording or read the full transcript below.

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[00:00:00] Nick Butcher: All right. Good afternoon everybody. That's a pretty solid chunk of attendees already, so I think I'll dive straight into it because this is a fairly big topic. So what we're covering today, the, the name is a riff on back in January when we talked about the. Some of the draft policy around these restrictions is the, at the time it was, are you feeling lucky?

[00:00:26] And now it's “are you lucky?” or “Were are you lucky?”. So, this relates to the whole farm conversions to exotic forestry proposed rule changes. Well to limit whole farm conversions and teasing through what some of the still draft legislation. Still pre committee. Would mean if and active as it is. And my feeling is that it's probably going to end up fairly close to what's drafted.

[00:00:47] So it's a good time to be thinking about it for future forest planning. Usual story webinars recorded, it'll be shared on our website. Your microphone or video are muted. If you have questions, and I suspect there will be questions about [00:01:00] this, whether or not you feel like asking 'em this forum is another question, but use the, use the q and a button at the bottom.

[00:01:05] And it we'll try and answer questions that we don't manage to cover in the session later on. Right, this is me. People have seen enough of me already. A key thing in relation to all of this is don't suddenly run out and plant a forest based on what I'm telling you today. So this is an incomplete summary.

[00:01:19] The legislation is, I think about 30 pages long, and it exists within the much larger general Climate Change Response Act legislation. I'm not covering all of the details today. It's kind of the stuff which I think will be the most relevant and most. Important to at least be conscious of. But it's an incomplete summary and it's just our interpretation and opinion and it's of a draft bill, so this isn't law yet, and it may change before it's, it's also a very complicated topic, so don't just go.

[00:01:46] Yeah. Oh cool. Sounds simple enough to me. Put some trees over there. I'm sure we'll be right. If you want to talk to us about it in more detail, that's part of the purpose of this, is to make sure that you're conscious and we can, you can get in touch with us and [00:02:00] help and certainly do this before you make a big investment decision.

[00:02:03] So in a nutshell, what this is, and this is simplifying things, but just to give you the broad strokes, the. Upcoming changes will mean that there is a ban on ETS registration of forest on LUC one to six land, but it's not all forest and it's not all LUC one to six land. There's a, a new thing being defined called restricted forest or restricted forest land.

[00:02:27] And even if your forest is restricted forest, there are exemptions proposed under which you can still register that forest. So these are the things that you need to know about in order to figure out the pathway through it. It's also important to note that these restrictions are on ETS registration and not on planting.

[00:02:43] Restrictions on planting are also extremely important to be conscious of, and I'm not covering any of them today. But the last thing that you want is to plant a forest that you think you'll be able to register in the ETS and then find that you're noncompliant with the RMA, although noting that the ETS registration does actually require a [00:03:00] declaration that you've complied with all RMA requirements so you can plant and then find out that you're unable to register.

[00:03:06] And this is probably gonna be very bad for your investment case. And as I mentioned before, yeah, it also covers only the ETS registration part. So think about the establishment restrictions. On top of that, here is the rough decision process that we think you'll be going through in relation to any new forest.

[00:03:25] Firstly, do you care about ETS registration? If you don't, you can carry on. This, this is a restriction on ETS registration not planting, as I mentioned. However, if you do, then the next question is. Will the forest that I'm intending to establish be restricted If it's not, again, this, this legislation that you're basically excluded from the scope of it.

[00:03:48] But if it is, then the next question is, will I have an exemption that I can use in the case of this specific forest? If you do and you're happy to use it, carry on. Otherwise at [00:04:00] this point you should be reconsidering whether you want to put that forest there because you basically, you do care about ETS registration and you probably can't register it in the ETS, so that's bad.

[00:04:10] Onto that point then, do you care about ETS registration? The answer is probably you do. You might not think you do right now, but I'd encourage you to look into it and as a rough indicative number. Obviously we've spent entire webinars talking about the different scenarios here, but. The ability to register a rotational average radiator forest in New Zealand, considering only the 16 year carbon yield with a $60 per ton NZU price and a 7% discount rate is worth about $9,000 per hectare.

[00:04:42] Which is, well, I'll let you consider whether that's a lot or not. Most foresters, and most farmers consider that to be a very large amount, which means that you do care and you do have to consider this. Is my land going to be restricted forest land? Right? So here are the restrictions. LUC [00:05:00] seven to eight land is not restricted.

[00:05:02] LUC one to six land can be restricted, but there are various scenarios in which it's not restricted. First of all, if your land was forest land on the 31st of October this year, then it is not restricted forest land. So that means all of these current this helps to resolve One of the questions that came out when the policy was launched last year around ongoing investment.

[00:05:24] Existing forest wasn't specifically flagged as a qualifying investment for transitional exemption, but this now makes it very clear if you already have forest that's in the ground, regardless of whether or not it's registered in the a TS, it is forest land on the 31st of October this year. So you still got, what's that, four more months?

[00:05:41] Then. You, you're not affected by these changes, or at least not directly. If you don't turn it into forest land until the 1st of November, then you are affected. So like, be very careful with the timelines And also although they'd be a bit late in the year to be planting forest probably but also make very sure that you have [00:06:00] clear evidence of the planting dates because if it gets to the 28th of October and you are trees go on the ground.

[00:06:06] That's pretty close to the line. So you wanna make sure that you can prove that when you make an application later on and say these, this was forest land on the 28th of October. It has not restricted forest land under the regulations. Don't require me to be compliant with this particular part. If the forest species are not predominantly exotic, which is the same definition as the rest of the CCRA, it is also not restricted forest land.

[00:06:29] There are various different classes of Maori land which are exempt. I haven't detailed these because it's like about two pages of text, but if you think that could be a pathway for you, make sure you look into it in detail and check the legislation. Erosion prune land with a very specific definition is exempt, or rather it is not restricted forest land, but.

[00:06:48] This is specifically land that is spatially identified as high or severe erosion risk layer in a regional plan or district plan. This does not mean land necessarily that you think is at high risk of erosion or [00:07:00] is erosion prone. It also doesn't even mean land necessarily that is got a a dash e classification under the LUC classes, or that it's got an erosion susceptibility class of high or very high.

[00:07:12] It may well be that those areas of land are also designated as high or severe. The regional plan, but it's not the same thing. So don't leap to a conclusion. Also, from what we are finding, depending on the region that you're in, these layers may not yet be finalized. So it's not like you can find this out right tomorrow for sure.

[00:07:31] And either way, the legislation's not in effect yet, and it could even be that it's modified to refer to one of these other layers. We don't know. Unmapped land is also exempt, and this is land that does not have an LUC class definition under the nz. LRI, which is land resource information. I think mapping this in particular includes Stewart Island in the Chatham Island, and it may include other areas.

[00:07:57] I'm not sure. Although it's worth [00:08:00] noting that if mapping is released for those areas, they are no longer unmapped land and exemptions will not be available to them on an ongoing basis through this. Unharmed land is also not restricted forest. If you establish, if you establish forest, that would otherwise be restricted on unharmed land.

[00:08:18] So how do you tell if your land is unharmed? There's a very clear definition of this as well in relation to a record of title. So it's title specific that is the subject of an ETS application. It means that no land described in the record or title as opposed just like half of it was. Half of it wasn't.

[00:08:36] No land described in the record of title has been used for farming purposes in the five year period before the ETS application, and contains predominantly exotic forest species planted in the five year period after use of the farm of land for farming purposes. Ceased farming purposes here. Include pretty much the full envelope of what you might consider to be farming purpose.

[00:08:59] My [00:09:00] interpretation of this is that it's essentially a minimum five year stand down of farming practices before you plant the exotic species. So it's not like a wait for registration alone, it has to be five years from stopping farming for all of the land on the title until the trees go in the ground.

[00:09:19] And the idea here is I think to provide some facility for. Less restrictions on genuinely retired unproductive land, but not allow people to just go, oh, well my land's unharmed. Actually, I got the sheep off it last week. I'm now exempt. Offsetting land is the definition as per the ETS generally. I won't go into detail on that.

[00:09:44] If it's, if you don't know what it is, it's probably not useful to you. And Crown a Forestation land, so this is in relation to the, at least partly the Crown, a forestation partnership. But the key thing to note is that, so this is Crown land isn't subject to this restriction, [00:10:00] but this restriction does not apply to Pamu held land or to crown pastoral release land.

[00:10:06] They're specifically excluded, so they are still restricted, those two categories, all else being equal. So that finally leaves us with actually, actually a very small sliver, which is restricted for us. But unfortunately, or fortunately, depending where on the scale you sit, this is not to scale. Those exemptions are probably going to be the relatively minor fraction of all of the LUC one to six land.

[00:10:31] So it, we've, I've said LUC a lot in the last, dunno what we're up to now. 20 minutes, 10 minutes. Which LUC is a key question. So LUC is land use classification. I think land use categorization, I think it's classification. Basically one is tip top. Land eight is very difficult land. That's probably the side of a mountain or a cliff space.

[00:10:52] Excuse me one second. Or something along those lines. And then there's the various levels in between. What we, here we're, we're [00:11:00] sort of seeing the region level nz, LRI map. And you see that this is a, it's a fairly broad brush across a relatively, like all land is pretty complicated and nuanced and has little nooks and crannies and things.

[00:11:13] And the region level layer doesn't capture all of that. It's just in general, what is this fairly large patch? This might well work for you in the case of your particular property. If they called a whole bunch of stuff LUC seven and you're like, ah, it's actually pretty good. But that gives me a lot of flexibility.

[00:11:28] It could also work against you though, if you really want and, and we get to this later on with the 25% allocations. Really you have to calculate all of this in the context of what you would like to be able to achieve within the rules and then see what your options might be given the data that's in place.

[00:11:45] The other thing to note here is that the, in terms of this policy. L seven and eight are the same thing, and LUC one through five are the same thing. And LUC six is actually the same as LUC one through five unless you're talking specifically [00:12:00] about the ballot process which, which simplifies things further.

[00:12:03] And they've also flipped the colors here because while green is good and red is bad in terms of the standard LUC color coding doing in terms of land quality, it's actually the other way around when you're talking about levels of, around your freedom to plant. So in this, in this middle one here, the green is the LUC seven and eight.

[00:12:20] The yellow is LUC six, and then the red is LUC one through five. And if we combine one to six altogether, we get the picture right over there on the right. So you can see that the green areas, you can do whatever you want. All else being equal. And the red areas you are subject to, well you, you at least have to see whether you've got one of these other UN restrictions or you're gonna have to use one of your exemptions, and it's quite a lot of the fun, obviously, in this case.

[00:12:46] It also misses a whole lot of detail, so this is a little bit hard to see, but it's the same farm looking up one of the gullies. And while it might be, you can see that some of this is actually quite steep. And what I noticed when I was picking this picture out is that quite a lot of it's actually recently been [00:13:00] planted, but to just call all of this LUC six, there's really missing a bunch of the subtleties that are extremely important to good land management and right tree, right place.

[00:13:12] When I flick this over to show the, the much more local layer, which is the highly erodible land with high landside risk with delivery of sediment to streams. It actually includes a lot of this area, which is called LUC six, and it's quite likely that this land would be designated high or severe erosion risk on a.

[00:13:32] On sort of a regional council plan, and the point is that it's not captured in the, the regional level, LUC layer. What you can do and what might capture this and call it say, LUC seven, is a property scale, LUC map. The legislation specifies that this can be undertaken in accordance with any methodology specified in regulations, which means that if you already have one that's been prepared for you in combination with some sort of farm planning or similar, it's likely to qualify.

[00:13:59] It's needs to [00:14:00] be done at your cost. You can't call up NPI and ask them to do one for you as part of these changes. It's gonna be much more precise and representative that might be in your favor, but it might also work against you. So, really, oh, oh. And you have to choose for your entire application when you put it in, say which kind of planning you're gonna use, and there's no back seats.

[00:14:19] This has implications beyond the single application. It's going to stick. With the title over time. Yeah. Also, if you use a property scale map, you have to make various declarations when you do the submission and you have to retain the assessment records for 20 years. So you, I think you provide them in the submission.

[00:14:39] I can't remember the exact details there, but either way, you have to hang onto it so that later on when you make another application, you can't just kind of keep shuffling the records that you're using. In terms of how to choose which of these LUC pathways you want to use for a given farm, consider if, and we you might want to establish exotic forest both now and into the future because this has [00:15:00] ongoing implications.

[00:15:01] Assess that against the NZ LRI map and then assess it against the property scale map. And if you don't have one, consider whether it's likely to beat your benefit to get one or not. Based on some your understanding of the farm and what might or buy I'd actually. Get some advice before you even make an assumption.

[00:15:19] But then choose an option. I say per title, which is probably the way to think about it. But just be aware that if an application spans multiple titles, then that approach sticks with the title and pick what's, what's gonna best support your plans, really. And you wanna do this before you do the first registration that leverages.

[00:15:38] Actually the first registration on that title at all. I think regardless of which exemption pathway you're using, because this is, you can't sort of use one LUC map to determine whether or not your foresters on LUC six, seven or eight land and then a different LUC map to determine what your 25% allocation is.

[00:15:56] Also just remember that separately from the LUC [00:16:00] designation, when the region level erosion maps become available, they might also give your LUC six land. For example, what we were looking at before, it could be that all of that LUC six stuff is actually declared high or severe erosion risk, and then it's no longer restricted forest land that probably has other restrictions.

[00:16:18] Okay, so you want to register in the ETS. And you've established after going through this whole process that your forest is gonna be restricted. Can you get an exemption? I've obviously stuffed up the animations here, but there are three different types of exemption. Sorry. Four is applications that are received prior to the commencement date.

[00:16:39] So I only actually noticed this when I was rereading the legislation this morning. In preparation for this, if you make your application prior to the 31st of October this year, then that application must be processed as though these new legislation doesn't exist, basically, or at least that's what's currently drafted.

[00:16:57] You can also get an LUC six permit. I'll [00:17:00] get into the details of that later on, but there's up to 15,000 hectares per year of LUC six land as proposed to be allocated an exemption and through a ballot process. There's also a 25% allowance whereby up to 25% of the LUC one to six land per individual farm, which we'll get to in a moment can be exempt.

[00:17:19] And then there's a transitional exemption for qualifying forestry investments. And if I'd done my animation properly, that one would've been first. It is the first one we're gonna talk about. Key there is what's a qualifying forestry investment. So this is detailed in great detail. There's actually some exceptions to the first January to fourth December thing, which I'll talk about, but this has to relate to the specific area of land for which exemption is sought.

[00:17:43] You can't just say like, oh, I. My grandfather gave me $200,000 at some point and said that I should get into forestry. Doesn't that count? It has to be related to the specific area looking to establish forest on. And then I won't go through. Well, I'll, I will quickly summarize [00:18:00] these. A registered lease or a forestry right, could work.

[00:18:02] Or an agreement to obtain one, a ruling, sorry. A, a sale and purchase agreement, either conditional or unconditional, an Emissions ruling. For a resource consent application or grant or a permanent activity notice investment in preparation for a forestation, a grant to a forest land that you've received, or third party having been contracted to do due diligence for the purpose of either a foresting land or purchasing land with the intent to a forest it.

[00:18:35] Whether or not what you've done specifically neatly fits into one of those classes is a decision that you'll have to make and it's an investment risk. So if you're not sure, I don't actually know of a way you could possibly, you could get an Emissions ruling on this in advance of planning to check whether your evidence was sufficient, and they would say either yes or no.

[00:18:55] But yeah, I think certainly be cautious if you're planning to use this pathway. [00:19:00] But as long as it's a fairly clear cut case, then it seems like a fairly robust way to get an exemption. There are deadlines for it though, so you'll note before that. I said from the 1st of January, 2021 to 4th of December, 2024.

[00:19:16] That is intended to exclude cases from prior to those dates. But just remember that as I mentioned before, anything planted or anything that is forest land as of the 31st of October. This year is not restricted for us, so you don't need to use this. So if you made an investment in the 20th of January, sorry, 1st of January, 2020.

[00:19:39] And then the forest is now on the ground. You don't have to worry about this. What you have to worry about is if your qualifying investment was prior to January, 2020, you don't have any subsequent qualifying investment that you can also point to, and the forest still isn't in the ground and still hasn't been registered.

[00:19:54] There, you've got this extended deadline to the 31st of December, 2027, where you can still use this [00:20:00] pathway if you can demonstrate that you couldn't register it prior to that date due to circumstances beyond your control. And this is to the satisfaction of the EPA, which then delegates that decision making power to MPI.

[00:20:14] The, the more common pathway, which also has a larger window is if you make a qualifying investment between 1st of January, 2021 and the 4th of December, 2024 last year, which is when the specifics of this policy were announced. Then you've got a standard deadline up until the December 20, 27 and your extended deadline in the case of delays that are beyond your control is to December, 2030.

[00:20:40] This one here, it doesn't even have its own special slide, but as I mentioned before, applications received prior to the commencement date will be processed as though this legislation was not in effect. So if you've got forest where you, I'm not sure why this would be the case, because if it's forest, then.

[00:20:55] It's just non-restricted forest, but belt and braces, I guess. 25% [00:21:00] allowance. This is where we're gonna spend at least the next 10 minutes, but we're not too far off timing. This is up to 25% of the LUC one to six land per individual farm. Now we spent quite a bit of time of this on January. I'm gonna run through it fairly quickly now.

[00:21:13] If you're wondering what on earth I'm talking about, then feel free to go back to the older, older webinar. But. So the Ls that matter for the purposes of this the distinction between the LUC six and five to one doesn't, but there's LUC seven and eight, which is unrestricted forest land, and there's LUC one to six, which is restricted forest land.

[00:21:33] The 25% is of the LUC one to six land. So if you've got 50,000 hectares of value C seven, it means you can do whatever you want with that, but it doesn't give you 12 and a half thousand extra that you can sort of allocate to your one to six. Questions that we had when we were looking at this back in January is how is existing forest treated in this?

[00:21:54] So is it, is it 25% of all of your LUC one to six land or just of [00:22:00] your un forested, LUC six, one to six land, which could be quite a lot less because you'd have to subtract all your forested land first. How about. The relationship with your existing registrations. If, if you've got land that's forested but it's not registered is it 25% of that or and how does it work when you've got multiple different farms?

[00:22:19] Because there's like a, it's of your one to six land. Is that, let's assume that you own land all across the country. Can you aggregate it all together? Is it by individual title? Is it like the titles have to be touching each other? This all of these dramatically change the options for an individual farmer.

[00:22:36] Our hope we indicated at the time is that. Farm groups are treated independently and that the new, the rules are applied only to New Forest and it's based on your whole farm. And, well, I didn't get the color right there, but we certainly got the outcome right. This is basically what's been drafted according to our understanding of it.

[00:22:57] So if we have it in writing, this is from the [00:23:00] legislation. 25% allowance in relation to an individual farm means an area or areas of restricted forest land that are in total up to 25% of all areas of LUC class, one to six land within the farm boundary. So all areas is, it doesn't matter whether it's forested or un forested or whether that area is registered or unregistered, but remembering that all of your, all of your existing forest as of the 31st of October this year that has a separate, pathway to registration that doesn't rely on this 25%. So you'll note a word in there. Individual farm. What does that mean? It is land that includes LUC Class one to six, and it is actively farmed and it is described in a record of title or in more than one record of title for adjacent land. And it's owned by the same person and person here.

[00:23:52] I think, I can't remember if this is actually clarified in the legislation, but it's gonna have a pretty narrow specific. Interpretation [00:24:00] I expect. So if you have a farm, which from your perspective is a single operating entity, but it's owned by two different companies across the titles, I suspect that that will end up being distinct individual farms.

[00:24:12] I could be wrong, and that could be that this is revised, but, and that this is not a part, particularly uncommon circumstance/situation either in some of the cases we've seen for, for big properties or, or different people have owned it at different points over time. And it also, there's a sneaky little word in there, which I skipped past.

[00:24:29] It's adjacent. I'm not gonna go in detail through what adjacent means, but it essentially is. If it's separated by basically a paper road or whatever, and it's otherwise pretty much touching read the legislation. If you want the full detail, then it's Aja adjacent and you've got one individual farm. If it's on the other side of the valley, let alone the other side of the region, it is not adjacent and it is not going to be part of the same individual farm.

[00:24:52] So here we've got two different persons owning six different titles. This is our interpretation of [00:25:00] how that will break up without worrying about the details of scale. Ann has two individual farms. The first are all grouped together, and the second is the one that's a bit too far away. So it's its own entity and Barry has one individual farm because the titles are all close together.

[00:25:16] Obviously your situation is going to depend on the details of your land ownership and titles and orientation, and you're gonna have to work that out farm by farm, which again, we can help with and we've built some tools for this. In regard to the 25% allocation, so the, basically the way it works is, let's say you've got a thousand hectares of LUC one to six land, you get 250 hectares worth of 25% allocation exemption that you can apply where you like across that land where needed to restricted forest.

[00:25:44] And you can do that incrementally over time. More than one 25% allowance application is permitted. But there's a big, unless in this, which means you have to be very careful with planning and sequencing. If since the first application in respect of an individual farm, the [00:26:00] ownership of the record or records of title has changed, or the farm boundary has changed if either of those things has happened, the remaining 25% allocation is gone.

[00:26:10] Even if you haven't used it up, and I th. My understanding is that that's the only the case if you've started and this, this exemption utilization stasis stays with the property. So once you, if you sell the land and it's got recorded on the title that it's used up some of this 25% exemption, and that's gonna be noted on all of the titles.

[00:26:30] And that remains through transfer and subdivision. So it sort of spreads. An interesting thing I only saw today though, which seems a little bit inconsistent with this, is that. I guess it works if you sell the farm, but if, if you look to consolidate farms, then there's this one 90 KE, which says that if a landowner of an individual farm becomes the landowner of additional adjacent land, then the 25% allowance for the individual farm does not increase.

[00:26:58] I don't know if [00:27:00] they still get the 25% allowance for the adjacent farm, I presume so. But I think the intent of this is to stop people sort of doing mass aggregations to allow a big conversion and then sort of separating the land away again. But it's one of the other sort of hooks that we are still coming to fully understand.

[00:27:18] I. So I know that sounds very complicated. I just want to emphasize that overall we think that this 25% entitlement is going to be by far the most accessible and no risk pathway to restricted forest registration for most farmers for new investments. So you'll note this s in there for unrestricted forest, you don't need this.

[00:27:40] And for existing investments, you also don't need it. That said, it is very important to plan ahead carefully and properly. But if you fancy your chances, there is also another way. I'm gonna give this a fairly light touch because it's a big complicated topic on its own, and there are also some parts of it where the implementation has been [00:28:00] delegated to regulation rather than the legislation.

[00:28:02] So there's, there's still details we're gonna find out, but this is the. 15,000 hectares per year on LUC six land where it's available in addition to the stuff that we've talked about above. So I don't think I mentioned this in the details, but key to note, this is on top of your LUC 25% allowance, if you had any.

[00:28:22] So these land permits up to 15,000 hectares a year. That number can be adjusted through, I forget the mechanisms, but basically some order and council are similar. These permits will be issued on an annual basis. There are certain various provisions for what can and can't be carried forward of un isssued amount.

[00:28:38] You can, and I would certainly suggest you should, if you are relying on this, apply ahead of your planting and you don't need to own the land to apply, but you do need the consent of the landowner. The legislation makes provision for fees. I think it's pretty safe to assume that there will be a fee for application.

[00:28:59] [00:29:00] Unknown whether it's gonna be for application and it's refundable in the case of an unsuccessful application or whatever, but there's gonna be some cost. And the permits are randomly allocated to the ballot applicants. They're not transferable. And once you have a permit, it's good for support of an application for up to three full years.

[00:29:17] And there's some provisions in there, I think for extension to six years or something in the case that you get delayed due to adverse weather events or so like. There's a huge amount of extra detail under the permit pathway. I think we'll just do another session on this by itself because we're already at one o'clock.

[00:29:35] And that was. Enough to cover. But it's another basically option, but it's harder to determine in advance if you're going to have access to that option because it's not something that's specific to your farm. It's a ballot. If you're unsuccessful in the ballot, then you come away with nothing and you have to try again another year.

[00:29:50] Some people have talked about planting and then applying through the ballot, and if they're unsuccessful, applying again the next year, and if they're unsuccessful, [00:30:00] applying again the next year and eventually hoping to get lucky and get an allocation. I would not do that if it was my land. There's no guarantee that you'll be successful at any point in the next 10 years.

[00:30:10] And this, as we talked about before, can be pretty important for the investment case. But, you could do it. All of this is really complex. I appreciate. It's also really important if you get this wrong, it can have significant commercial implications, so. General guidance. Make sure that you understand what your options are and that you've got a clear kind of mapping out of those options and their implications independently of the person who's planning to implement any given one of them for you.

[00:30:42] Because those people doing the implementation could change over time. The decisions you make though the echoes through time will remain. So you're, you're gonna be stuck with this stuff. You wanna make sure that you've got a clear picture and it's a picture that's in your hands. You wanna make sure that your plan [00:31:00] covers the future and lets you explore various different pathways.

[00:31:02] What you do now does have implications for later on. So yeah, in a nutshell, make a plan, get some independent advice. We can certainly help with this. We. A lot of the complexity is stuff that is record keeping related and calculation related. So we're building out tooling for this. Also final point, if you do want us to work through this for your catchment group, please get in touch with us.

[00:31:23] We're having a number of these discussions and they fit very well with the group context. Thank you very much for your time. I'm going to quickly see if there are any questions that have come in. Alright. So the question was regarding the 31st October deadline. If I want to be exempt, I should rush to get the trees in the ground no matter what their survival potential is, get them registered and worry about filling in the gaps of the trees that didn't survive later.

[00:31:48] I wouldn't necessarily recommend that that's what you do, but if you have trees in the ground. On the 31st of October, my understanding, and they qualify as forest [00:32:00] land, my understanding is that that land would be forest land and that even if some of them die, it's potentially temporarily destocked forest land, but still forest land and as long as you maintain it as forest land, you'll still have been forest land from 31st of October and onwards.

[00:32:15] If they all die and you don't replant them, you are going to probably, I imagine no longer be forest land and. I actually don't know what that would mean as of the date, because it's a point in time. In a nutshell, I don't think this is the ideal pathway but it's at least one that's worth exploring if this is the situation you find yourself in and you don't have another option that you see.

[00:32:37] But it's like, it's certainly not good forestry practice to plant trees that you know are gonna die. So I'd look up one of these other possibilities as well. We're not going to go through the other questions that we had come in just in the interest of time and that we've already covered a fairly large amount of information.

[00:32:51] And none of them were specific to this, but the, there was one question around exotic species generally, I'd say certainly if you're about to plant exotics or you are [00:33:00] considering planting exotics, this is what you need to figure out. Like basically those questions like, am I restricted? And do I have an exemption that I'm happy to use in this context?

[00:33:13] All right. Given there's no other questions, we'll get to finish up slightly early for once. Thanks so much for your time. This is certainly a ongoing developing topic. We will be continuing to do work on it and in the fairly near future, we'll be demonstrating some of the tooling that we've built to simplify this for all of the different parties that are involved in planning and analysis and tracking.

[00:33:34] So thanks a lot for your time.