I agree that sometimes not using a tree is just too contrived. For example, this climb in the Argadells (Flinders Ranges):
Damage Control 12m 18T1 Begin 2m R of a large Callitris and climb to the third horizontal. When nerve fails, move L to a stance in the tree, place an RP and continue up. Paul Badenoch, Des Norman, Chris Oerman 30/6/07
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