Carrara has instancing which is nice. Thus using duplicates of a given tree model doesn't have the heavy memory footprint like it does in Bryce. But yeah, if you wanted you could still do the splat method. (It's likely it would render a lot faster at least. Less collisions to detect and all that.)

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Barbequed Pixels?

Your friendly neighborhood Wings3D nut.
Also feel free to browse my freebies at ShareCG.
There might be something worth downloading.