P.O. Box 160, Canberra City, A.C.T. 2601

The Hon. Mark Speakman SC MP
Minister for the Environment
office@speakman.minister.nsw.gov.au

Subject: Canberra Bushwalking Club: Comments on KNP Draft Wild Horse Management Plan

Thank you for the opportunity to put in a submission on the Kosciuszko National Park (KNP) Draft Wild Horse Management Plan (WHMP).  As frequent bushwalkers and contributors to some NPWS conservation activities in KNP, the Canberra Bushwalking Club (CBC) has an active interest in promoting the park’s considerable environmental values, while ensuring that this is balanced with the humane treatment of its non-native wild (feral) horse population.

Several of our members have seen the damage caused to KNP’s rare and delicate alpine environment by invasive species of animals and plants, and the CBC supports the humane/ecologically sensitive management of all feral animals and invasive plant species from the park to the full extent possible.  At the same time, we recognize that a reasonable compromise needs to be made between the different values of KNP’s various stakeholders.  We think that the draft WHMP largely has achieved a sensible balance between these values and endorse its adoption and implementation.  However, we remain disappointed that the NSW government did not allow consideration of the use of the method of wild horse culling demonstrated to be the most humane, cost-effective and safe for NPWS staff – aerial shooting among the other methods to be employed to reduce wild horse numbers.

While supportive of the WHMP, the CBC feels that there is room for further refinement and improvement of the draft plan and offer the following suggestions:

  • Incorporate an assessment and grading of the relative degree of severity of the eight described impacts of the wild horses (pp 13-21), especially over the longer-term, as this should be one of the key factors in the choice of culling methods and targets; for example, while cultural values may change over time, the loss of a native animal species is irreversible; further substantiation of the link between wild horses and the endangerment of the two native mammal species cited (mountain pygmy-possum and broad-toothed rat) also would be useful as an element of the grading process;
  • Related to this, conduct and include some modelling that could predict the impact on net wild horse numbers of the various culling methods with particular attention to natural reproduction rates and possible horse incursions from Victoria. Also model which methods are the most effective in reaching the targets in the plan (ie 50% reduction over 5-10 years followed by 90% reduction over 20 years); and
  • Balance the assessment of the importance of European cultural values regarding the presence of wild horses with the values held by Aboriginal people for KNP.

Most importantly, the view of the CBC is that the WHMP needs to include detailed information about the budget and resources required in order to successfully implement and monitor the WHMP.  This information is particularly required, given the historically limited budget given to NSW conservation services and the higher cost of using culling methods other than aerial shooting.

It is clear from the extensive and systematic analysis commissioned by the NSW government, which has informed the preparation of the WHMP, that the current strategy for wild horse management is not effective.  The CBC holds the strong view that the finalisation, adoption and implementation of the WHMP must be a high priority, as action is needed as soon as possible to minimise the further spread of the wild horses and the related damage they are causing to KNP.

We look forward to seeing a new, and more effective, wild horse strategy in the near future.

Yours sincerely

Lorraine Tomlins

President

15 August 2016