NPA NSW’s position statement: Public Plantations in NSW
NSW’s public State Forests have a variety of different land-use histories:
- Softwood plantations are established by clearing land and planting with a monoculture of exotic species, mostly Pinus radiata.
- Hardwood plantations occur in a similar way, but instead of pine they are usually planted with one or more native trees. In many cases, the plantation stock is sourced from another bioregion, such as Tasmanian Blue Gum.
- Public Native Forests occur in State Forests where no logging has occurred, or where areas that have been historically logged have regenerated into a vegetation community, similar to the original floristic composition.
Substantial areas of State Forest don’t fall neatly into one of these categories. The major difficulty is determining the level of clearance, artificial planting, and suppression of regrowth that distinguishes between a modified Public Native Forest and a Hardwood Plantation.
Unfortunately, NSW legislation offers little clarity on this issue. The Plantations and Reafforestation Act (section 5) defines plantations as ‘an area of land on which the predominant number of trees or shrubs forming, or expected to form, the canopy are trees or shrubs that have been planted ( ) for the purpose of timber production’.
The Act does little to tighten this loose definition by going on to state ‘To avoid doubt, a natural forest is not a plantation for the purposes of this Act. However, an area is not a natural forest merely because it contains some native trees or shrubs that have not been planted.’
The consequence of this imprecise definition is that NSW Forestry Corporation is able to change the classification of Public Native Forest into Hardwood Plantation to remove limitations on logging. These reclassifications are subject to little if any independent regulatory oversight.
The international Forest Stewardship Council (FSC) provides a much tighter definition of plantations. FSC defines a Plantation as “a forest area established by planting or sowing with using either alien or native species, often with one or few species, regular spacing and even ages, and which lacks most of the principal characteristics and key elements of natural forests.”
The FSC recognises the conversion of native forests to plantations as a serious global issue 1 that undermines the integrity of their sustainable forestry certifications. The FSC currently lists NSW as a risk to the FSC supply chain and brand.
All other Australian states restrict the definition of plantations to sites where trees have been planted for the specific purpose of wood generation. For example, Tasmania refers to a plantation as ‘a forest established by the planting of seedlings or cuttings of trees selected for their wood producing properties and managed intensively for the purposes of future timber harvesting.2
The FSC guidelines note that ‘Areas which would initially have complied with this definition of ‘plantation’ but which, after the passage of years, contain many or most of the principal characteristics and key elements of native ecosystems, may be classified as natural forests’ and “Plantations managed to restore and enhance biological and habitat diversity, structural complexity and ecosystem functionality may, after the passage of years, be classified as natural forests.’ 3
NPA regards FSC’s definition of plantations as far more fit for purpose than those in NSW legislation. Importantly, it provides a means of identifying areas that are operating in ecological terms as functional native forest with the maximum potential to protect biodiversity, maintain ecosystem service, and sequester atmospheric carbon.
Case study:
Pine Creek State Forest is an example of Forestry Corporation inappropriately classifying public native forest as plantation. It contains areas classified as ‘plantations’ that are indistinguishable from native forest in structural and floristic terms. FC clear-felling activities will have a significant negative impact on the koalas in the adjacent national park.
To learn more, please read NPA NSW’s letter below (February 2023) addressed to the shareholder ministers of Forestry Corporation.

Natural forest misclassified as plantation – Pine Creek State Forest compartment 16
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