SPECIAL EDITION
- BRUMBY SUBMISSION -

     Snowy Mountains Bush Users Group inc   

                       Submission in response to the

      Draft Horse Management Plan for Kosciuszko

                                  National Park.

                             April  2007

Comments on Draft Plan.

We wish to advise that we have thoroughly read your draft Plan of Management and as it emanates blatant bias in most, if not all areas, we will not be endorsing same. 

The Snowy Mountains Bush Users Group Inc opposes the eradication of wild horses from KNP.  These horses have a major role in the cultural heritage of Australia.  They are a very significant tourism draw to the mountain area, with many people going in to this area specifically to view the wild horse in its natural environment.  The public sentiment of the wild horse has not been taken into account in this plan.  No other animal has captured the heart of Australia the way our mountain horses have, with many famous authors and poets telling the story of the wild horse to an audience that to this day has not diminished. 

SMBUG opposes the subsequent waste of public money that has been, and will be, spent senselessly attempting to completely eradicate an animal that does not deserve the vilification that the NPWS, and their props, are attempting.

If the money was spent on a fair and balanced study of the wild horse it would be proved that the benefits economically and ecologically of grazing would outweigh the detrimental effects of areas with no fuel build up reduction method.  Grazing benefits all wild life systems, as well as creating a protection barrier against ‘all destroying’ wildfire.

A Plan of Management is a document that should consist of current, detailed facts and figures to support a reason for taking action.  In order to get to this plan of management the draft should be distributed amongst the community in order to gain non-biased feedback on what the community wants. More importantly, it should be reviewed by the governing body to offer a Plan of Management that is current, accurate and tailored to community needs and wants.

This draft POM for horses contains a large number of scientific errors and more importantly simple errors that would lead to an erroneous and biased POM.

As stated in the draft plan ‘there is a wide range of views in the community concerning horse management’ and for this reason the POM requires thorough thought, analysis and consultation.  These poor calculations, incorrect facts and simple errors only highlight the fact that this is simply ‘procedure’ for NPWS and no one is putting their heart and soul into this plan to ensure it is appropriate, humane or even warranted.

We therefore conclude that the draft POM for horses is of an amateurs level and shows that NPWS have no keen interest in horse management within KNP, they are simply following ‘procedure’ and as a result wasting valuable resources.  

1.    

The Executive Summary states in the second paragraph that ‘Management of horses in the national park began in the early 1970’s with a licensed brumby running program’ yet the Introduction contradicts this statement by stating ‘Before the horse management program was developed for the alpine area in 2003, there had been no active management of horses within the national park since it was reserved’.  To further contradict the statement point 2. 5. 4. states that ‘The removal of horses from the alpine areas of Kosciusko National Park has been ongoing since 2002’. The park was reserved in 1944 according to the Plans introduction.  The facts need to be correct as to whether there was or was not management of horses in the park prior to the horse management program in 2003 otherwise it is confusing to readers and appears to be very misleading and biased.

2.     2.1  

It is stated that ‘drought and heavy snowfalls provided the only real check on horse populations’ in one paragraph and then in another that 2003 bushfires reduced the horse population significantly.  With fire added to drought and heavy snowfalls it appears as though the conditions an KNP are suitable enough on their own to keep horse numbers in check without introducing alternative methods.

Other aspects of this section are extremely contradictory and misleading.  It appears as though you are attempting to portray that there are millions of horses in the park and the population continues to grow despite the fact that, as you are also vaguely stating, the conditions and situations has reduced numbers.  For example, it is stated that by ceasing brumby running the population of horses appears to have increased.  However, the majority of the other paragraphs are pointing towards natural means of reducing populations i.e. capture and use as stock horses, 2003 bushfires, drought and heavy snowfalls.  This highlights the bias of this report, rather than actually stating that horse numbers have been kept firmly under control by natural occurrences within the park you have skipped around it instead by insinuating numbers are increasing at a great rate.

3     2.2

More information as to what species in particular is being endangered and what exactly is happening to them that could be attributed to horses when all native species that exist in the area have survived 130 years of general grazing.

What is the impact of wild fires, in comparison to wild horses, has a comparative study been done?

How much of this damage is being done by bushwalkers? 

2.2      How did the karst area survive the dinosaur era, seismic activity, run off from an ash covered landscape, burrowing wombats?  Has a study been carried out on just how robust the karst systems are? 

The most damaging impact to the cave eco system is people, cavers, speleologists carrying foreign spores and human bacteria into this sensitive system, and something must be said about the introduced rabbit though not as large as the native wombat could have some impact, but do we really know?

More horses would keep the grass down reducing the risk of fire which causes damaging smoke and carbon to flow through the cave systems.

What is going to happen to the Karst when it becomes overgrown with blackberry?

4.     2.3

This section includes some very vague facts and speculations that should not be included in a plan of this nature without evidence.  For example,  ‘as selective grazers of grasses and forbs, it can be expected that they would impact’ Evidence of this is essential or do not include it in the report, once again this appears to be a biased statement.

In addition the statement regarding recent collisions with horses on roads and incidents of stallions acting aggressively towards bushwalkers.  This is a very elusive statement and can not be taken as fact without evidence.  A POM should not contain statements that are not supported by facts.

This section although headed to cover the environmental impact of the horse, is quoting studies on grazing in general, which involves thousands of sheep and cattle per year, nothing to compare with one horse per 400 hectares as it is today. 

The native flora and fauna has evolved and adapted over the past 50 – 100 – 1000 years to survive as it is today, despite the conditions presented to them, which has included grazing.

What are the results of the studies that have been done on the detrimental effects on this areas flora and fauna because of the total loss of grazing?

Why is the study done by NPWS included in this plan when it is obviously targeting domestic horses used by recreational horse riders?    Be specific…. What weeds are present at the horse camps that can be attributed to brumbies, as they introduce no weeds? 

A further study should be done on the multiple uses of these sites over the past 170 years.  For example Cooinbil used since the beginning of the grazing era, site of cattle and sheep yards and innumerable traffic of vehicles.  Old Camp, an ex Snowy Camp for the building of the Aqueduct.  Coolamine , now a popular tourism tool by NPWS.  All these areas are subject to infestation from weeds carried in on vehicles, including NPWS from weed infested Blowering

2.3     Many paragraphs listed here are supposition of the impacts of grazing and are not indicative of the impacts of the decreased horse numbers present today.

There are also positive effects of grazing by wild horses.  Why is there not a balanced view given?

There is no damage to Long Plain or Currango Plain that will not naturally re-generate.

Major Creek Bank erosion to Currangorambla Creek caused by the rise and fall of Tantangara Dam, soil saturation, falling lake levels, heavy frosts creating bank collapse, silting up the stream for many kilometres.   This is real and permanent impact, caused by the biggest perpetrator of all, the Snowy Mountains Scheme.  You accept the SMA so accept the wild horses, many tourists come to see both!  What an appalling vision a high country plain would be without wild horses, sad and sterile.

Horse dung is no more than processed grass, human and canine faeces are another matter, has a comparative study been done on both. Perhaps such should be included in the Plan so as to take away any idea of bias.

In every other instance the person with the animal is responsible for containment of said animal.  If everyone ignored the law and cried broke there would be a lot more than a few horses on the roads. This is the case at Blowering where many accidents happen because of kangaroos crossing the road.  Is there also a plan to cull all these kangaroos?

Why are the sections of highway where the horses cross not simply fenced? The money spent on collecting data of the horses and trapping already would be more effective if spent on fencing.

Also, so called sensitive areas could be fenced, fencing required to stop horses would not restrict movement of native animals.

5.     2.5.2

Two texts and one study were sited as valuable reference material in the formation of this plan.  These are all in the negative, where is the unbiased scientific evidence that deals fairly with both sides of the issue?

6.     2.5.3. 

This section states that horses  ‘…can tolerate a wide variety of foods and grazing patterns. They prefer to feed in areas with the greatest concentration of high quality green food and when this is sparse they seek out perennial and herbaceous plants…’ How can this statement be made when it clearly states under point 2.3 that…‘there have been no studies on the diet preferences of the wild horses in the Australian Alpine environment’?

7.     2.5.4  

Despite the implementation of this plan not yet being in place, 18 horses have been taken out of the northern end of KNP in the past six weeks.

SMBUG  will not support or condone the removal of brumbies from any area within KNP other than the Main Range Management Unit until :-

·        The current Brumby population is independently assessed

·        Independent scientific evidence is provided on the alleged impacts from brumbies are of a serious or irreversible detrimental nature in areas other than “true” Alpine altitudes.

·        Independent evidence is provided as to the maximum brumby population that would be sustainable and what minimum numbers are required to remain genetically viable, to avoid excessive inbreeding, and to cover contingencies such as the 2003 bushfires which wiped out 50% of the wild horses in the southern end of the park.

·        There is full independent consideration of the brumbies cultural heritage , the benefits of grazing to the park biodiversity and reduction in fuel loads, value to tourism and the flow on to the economy

·        Independent scientific comparison of the alleged brumby impacts to the impacts of wildfires, weeds, predatory feral animals, native animals and the natural elements of wind, water, snow, ice, seismic activity, drought etc

·        Independently chaired community meetings at appropriate times and locations, with the above information provided, and a majority view sought to decide the brumbies future.

8.     2.6   

The horse population figures need to be clarified.

The 2005 report states there are a total of 1715 horses within KNP.

The 2006/2007 cull resulted in a reduction of 64 horses from KNP.

That left a total of 1651 horses in KNP.

With a park size of 673,542 hectares or 6,735.4 square kilometres there is 0.24 horses per square kilometre, which appears very miniscule considering the effort and resources going into this exercise and reflects that NPWS has a large amount of funding and resources in excess to even bother undertaking this plan for what it is worth.

N.B. These figures do not include 18 horses trapped recently plus 7 destroyed after back burning operations in February. 

As Montague –Drake’s study,  conducted in 2005, to determine specific horse numbers in the northern and southern regions of  KNP  gave a total of 1715 horses, this number means that there is only one horse per 400 hectares. Why then is the horse being targeted as the main cause of any changes occurring to soil structure and vegetation ?

9.    3.1

The establishment of the steering committee composed of members who supposedly represent key stakeholders and community interests, has not resulted in a fair and unbiased Draft Plan being compiled.  Those who have opposing views to that of the green movement are not being listened to.  This plan reflects the view of the minority, not that of the Australian community in general.    

Is the outcome a forgone conclusion identical to the P.O.M? Is the Agenda set and therefore no chance of AN INDEPENDENT SCIENTIFIC EVALUATION POSSIBLE?  For this to be possible studies should also be conducted, and released, on the positive aspects of the horse to the environment.

 The mention of ‘information sheets for the general public will be made available on the NPWS website and local offices’ is the web link to these sheets available?  All public documents pertaining to this draft plan process should be made available to the community for scrutiny at all times so they can be responded to with any changes to reflect public wishes.

The objectives of the Horse Management Plan would appear to be the total removal of all wild horses from all areas, if not please include in the plan the areas where they will be allowed to remain.

As custodians of the ‘peoples park’ NPWS must have thorough consultation with the community through public meetings before any horses are removed.

One of the guiding principles of a this draft POM is  ‘To ensure that there is community consultation in, and support for, the removal process.

We would respectfully like to draw the Committees attention to the N.P.W.S. practice of removals from so called sensitive areas and the disastrous results.

1.                  Pilliga          Complete removal of loggers and subsequent increased levels of fuel loads resulted in colonies of koalas being burnt in wild fires.

2.                Montague Island       Complete removal of goats resulted in Fairy   Penguin habitat becoming overgrown with long grass.  Burn off conducted by National Parks caused Fairy Penguin colony to be roasted.

3.                 Macquarie Island      Complete removal of cats, leaving rabbits and rats       to over populate caused erosion and land slides and had disastrous effects on the native flora and fauna.

This subject alone requires a whole case study.

                                                 -------------------------------

Following is an Estimated Brumby Population Growth Rate    

 Calculated by Clive Edwards – March 2007

1700           Brumbies in KNP

 850            50%   Male

 850            The number of breeding females

 425            New foals per annum on the basis that the females are only

                    giving birth to a live foal every 2 years

 170            Live foals per annum based on a 40% survival rate due to the harsh climate conditions

So we have          1700

Plus new foals                 170

                                      1870

Less natural deaths      130      based on average life of 14yrs = 7% pa

                                      1740

From 1700 to 1740 equals a net increase of  2.35%

A far cry from the  15 - 20%  that the NPWS quote.

No allowance has been made for extreme weather events such as the 2003 wildfire that killed 50% of the brumbies in the Southern end of KNP

The wild horses of the Snowy Mountains are part of our heritage, and should hold a place equal to the karst and the flora; they belong to us and to future generations.  In the Draft Plan wild horses in other states are used as examples.  The Kosciusko situation cannot be compared to what is happening in Queensland and the Northern Territory, where the economic viability of those states and the individual land owners may be at stake.  The reverse is the fact in K.N.P. where the wild horse attracts countless visitors and therefore dollars to the region and enhances the image of the Australian way of life.

Myles Dunphy, Selected Writings, compiled and annotated by Patrick Thompson, Sydney, 1986 page 137. BRUMBIES

“All through these wild and cold highlands wild horses roam free in innumerable mobs, matching their horse-sense against their deadly enemies, the Freebody rifles.  There is a scheme at foot and started, to wire fence the summit of the Great Divide; so soon the poor, haired beast will be unable to change their grounds to accord with the seasons, and henceforth icy winds, deep snow and that awful barbwire fence will spell doom to the thundering mobs.  It ought not to be so, it does not seem right that the last of the Monaro brumbies be wiped out because of some sheep and cattle. Surely posterity would care to view their running free in land which had been theirs for so long.  The ‘Man from Snowy River’ will never die, why then the horses?!!