Chapter 5Management of feral horses in the Australian Alps

Overview

5.1The management of feral horse populations in the Australian Alps is a challenging matter due to different perceptions of the needs of the region and its use. These different views, which have been considered in the formation of state and territory policies, have led to a range of management methods of varying suitability to control the population size.

5.2Without active management, feral horse populations are left unchecked to increase by 15–20 per cent per annum. The RSPCA noted the impacts of large populations competing for dwindling food sources due to drought:

You have not only physical impacts but also mental impacts associated with loss in body condition and probably an increased prevalence of disease conditions. You also have animals competing aggressively over limited food resources, which can lead to fear, stress and anxiety. There's a combination of quite significant impacts in terms of animals being faced with limited food resources.[1]

5.3In September 2023, the Bureau of Meteorology declared that an El Niño is underway, due to which Australia will experience warmer and drier conditions.[2] This will likely lead to a loss of food resources and competition for water between animals in the Australian Alps.

5.4The Australian Government considers feral horses to be a serious environmental pest.[3] The Australian Government’s Australian Pest Management Strategy 2017–2027 sets out best practice management of pest animals (including feral horses) as one which ‘balances efficacy, target specificity, safety, humaneness, community perceptions, efficiency, logistics and emergency needs’.[4]

5.5The strategy’s priorities focus on national action and coordination, best practice management, and increased participation in a coordinated management approach.[5] The two key stages of effective management of established pest animals are set out as containment and asset protection.[6]

5.6The Commonwealth Department of Agriculture, Fisheries and Forestry (DAFF) noted that animal welfare is essential when considering control techniques, and that animal welfare is a matter for the states and territories to legislate (except for livestock animals).[7] DAFF stated that ‘differing perceptions about the suitability of control methods in the broader community…contributes to a challenging management environment’.[8]

5.7The three land manager governments have significantly different approaches to the management of feral horses in the Australian Alps. The Victorian Government requires that exotic fauna are exterminated or controlled when they are found to be residing within the boundaries of a national park.[9] Active feral horse management is undertaken by Parks Victoria, with a target of the complete removal of feral horses from the Bogong High Plains, and a significant reduction in the number of feral horses in the other Victorian Alpine areas.[10]

5.8The ACT has no current known populations of feral horses, and undertakes active monitoring of borders shared with NSW. The ACT’s zero-tolerance policy towards feral horses is discussed below.

5.9Contrary to the approach taken by the ACT and Victorian Governments, the NSW Kosciuszko Wild Horse Heritage Act 2018 (NSW Wild Horse Heritage Act), which was enacted under the former Berejiklian Government, has the sole object to ‘recognise the heritage value of sustainable wild horse populations within parts of Kosciuszko National Park’.

5.10This chapter examines:

current management methods for feral horse population control in the Australian Alps;

existing feral horse management arrangements in New South Wales, Victoria and the ACT;

staffing levels in the Australian Alps National Parks and Reserves; and

evidence relating to the treatment of staff in these parks and reserves.

Current management methods

5.11The need for active management of feral horse populations reflects their high reproduction rate, lack of natural predators, and prevention of poor animal welfare outcomes associated with prolonged drought and starvation. Feral horses are also impacted by major climatic events such as bushfires.

5.12Associate Professor Richard Swain, Indigenous Ambassador for the Invasive Species Council, described a situation in 2018, in the lead up to the Black Summer bushfires, in which feral horses were suffering from extreme weather conditions:

We had to paddle [on the alpine rivers] through all the dead horses. There were dead and dying horses all through the water. I did learn from a horse expert that they'd come down because their stomachs were irritated. They drank a lot of water and then they collapsed into the water.[11]

5.13Mr Jack Gough, Advocacy Manager at the Invasive Species Council, explained that human intervention in the feral horse population size is critical:

The only way we will get on top of this population is through human intervention. As I said, it's a difficult decision, and we acknowledge that. It is not something that is easy to talk about—killing feral animals. We find that to be an issue when talking to the public about the management of feral pigs and feral deer—the fact that this is a choice we have to make because if we do not make it then we see the decline of our native species and our native environments.[12]

5.14The need for immediate action was set out by the Australian Veterinary Association (AVA), which stated that ‘the next year or two is critical, as delaying implementation of control carries a welfare cost due to the number of horses born in that time only to be subsequently culled’.[13]

5.15The main methods currently employed in controlling populations of feral horses include: ground or aerial shooting; trapping, transportation and then either re-homing or euthanising if rehoming is not available; and limiting the animal’s ability to reproduce through fertility control.

5.16DAFF set out that a range of factors are considered in the selection of a management method, including: number of horses; mob size and age structure; accessibility; terrain; impacts; and, season. When considering control methods, the humane treatment of horses, the safety of people involved in operations, efficiency, and available resources (including existing infrastructure) are key.[14]

5.17In all control methods, the consideration of animal welfare should be taken into consideration to ensure that the techniques are performed humanely. Model Codes of Practice (CoPs) and Standard Operating Procedures (SOPs) were developed by the Environment and Invasives Committee (EIC), and led by the NSW Department of Primary Industries, and endorsed by the former cross‑jurisdictional Ministerial Standing Council on Primary Industries in 2012. These CoPs and SOPs are consistent with the Australian Animal Welfare Strategy.[15]

5.18The CoPs note the high level of public scrutiny that the management of feral horses receive, and consider that control strategies need to take into account the viewpoints of interested groups. The CoPs set out that control methods should be sustained and take into account ‘three essential requirements’: necessity, effectiveness and humaneness.[16]

5.19When choosing the control technique to be employed in feral horse management, consideration of the animal and the potential to suffer must be considered, along with the type of terrain and the need for the method to be undertaken correctly:

Feral horse control techniques have the potential to cause animals to suffer. To minimise this suffering the most humane techniques that will achieve the control program’s aims must be used. This will be the technique that causes the least amount of pain and suffering to the target animal with the least harm or risk to non-target animals, people and the environment.[17]

5.20Control techniques have been assessed for the acceptability of the technique with regard to humaneness (when used correctly), efficacy, target specificity and cost-effectiveness.[18]

5.21The Independent Technical Research Group (ITRG) in 2016 reviewed the range of control methods for feral horses, and assessed their impact on animal welfare. The ITRG found three methods not to be sufficiently humane for application in the park: roping (brumby running); loading and transport (long journeys); and aerial shooting where the animal cannot be rapidly shot.[19]

Ground and aerial shooting

5.22Specific SOPs are in place for both ground and aerial shooting of feral horses. With regard to both ground and aerial shooting, the SOPs set out that the timing is recommended to be timed to avoid the death of mares with young foals.[20]

Ground shooting

5.23For ground shooting, the following has been set out:

Ground shooting is best suited to accessible and relatively flat areas where there are low numbers of problem horses. It is also used for euthanasia of sick or injured horses. It involves the shooter approaching a group of horses on foot with the intention of culling all the animals in the group. Shooting from a helicopter is considered a more humane control method, as mobile wounded animals can be promptly located and killed. It is also a more effective method of quickly reducing feral horse populations.[21]

5.24Under the CoPs, ground shooting has been rated as being acceptable with regard to humaneness but not effective in general, nor cost-effective.[22] Animal welfare considerations in the SOPs relating to ground shooting include:

the skill of the shooter will determine the humaneness of the method

appropriate firearms and ammunition should be used

the animal must be clearly visible and the shooter must be assured that a single shot can be taken

only head (brain) and chest (heart/lung) shots must be used

the humaneness of the killing of the animal will be affected by group flight responses, and all horses in the group should be killed before the next group is targeted

wounded horses must be located and killed as quickly as possible[23]

Aerial shooting

5.25Aerial shooting of feral and pest animals is widely used in Australia as it can be a humane and cost-effective method of managing invasive species.[24] Aerial shooting is rated in the CoPs as being acceptable with regard to humaneness (conditional on the skill level of the shooter), effective in general but expensive in some conditions. It is a target-specific method of control, ‘[s]uitable for extensive areas and inaccessible country’ and is the ‘[m]ost effective way of achieving quick, large scale culling’.[25]

5.26Aerial shooting SOPs set out that it can be a humane method when conditions are met, and that shooting should be part of a coordinated program to achieve sustained effective control.[26]

5.27Animal welfare considerations in the SOPs relating to aerial shooting are similar to those for ground shooting, but with the additions that the terrain should suit the method, and a ‘a deliberate policy of “overkill” should be used, in which a minimum of two shots should be used per animal’.[27]

5.28The RSPCA noted a study which set out that, in relation to aerial shooting of horses, an ‘instant’ death was achieved for 63 per cent of horses. The mean time of a ‘non-instantaneous’ death was 19 seconds (with a range of 3 seconds to 4minutes). The total time, including the pursuit of the horse, had a mean of 80seconds (with a range of 2 seconds to 10 minutes).[28] Regarding ground shooting, the RSPCA submitted that there are ‘currently no published studies on the welfare outcomes for…feral horses’.[29]

5.29The ITRG found that aerial shooting would be the most suitable lethal control method, if certain conditions were met, such as shooter and pilot training:

If lethal control is required, we found that best practice aerial shooting had the least potential adverse impact on wild horses, noting however that this is currently out of scope for KNP. This was dependent on a number of conditions being in place including suitable vegetation, adherence to specific standards and the use of highly trained and competent pilots and shooters. Where these conditions are not achievable, ground shooting, or passive trapping/mustering followed by on-site humane killing were the next best options.[30]

5.30In NSW, aerial shooting is used to control a variety of pest species including cats, foxes, deer, pigs and goats. The NSW Government submitted that aerial shooting was used for more than 87 per cent of the feral deer and pigs removed from KNP under its feral animal control program, the largest program it has conducted.[31]

5.31In the three years to the end of 2022, more than 10,000 pigs and 6,800 deer were removed from KNP. In the last twelve months, more than 1,500 hours of shooting were conducted without ‘any significant welfare issues’.[32]

5.32The Invasive Species Council outlined feral animal aerial control arrangements in other parts of NSW, including for feral horses:

…while aerial control of feral horses is not currently permitted in Kosciuszko National Park, it is both a routine and effective part of feral animal management across the state.[33]

5.33The Invasive Species Council’s analysis of NSW Government data, covering the activities of NPWS and the Local Land Services, show that aerial shooting was used for 88 per cent of a total of 271,959 feral animals removed across NSW over the three-year period between July 2020 and June 2023.[34]

5.34The Kosciuszko National Park Wild Horse Heritage Management Plan (Kosciuszko Management Plan) does not approve its use in KNP. It does however note that ‘if undertaken in accordance with best practice, aerial shooting can have the lowest negative animal welfare impacts of all lethal control methods’. The plan sets out that the risk in using aerial shooting is the potential ‘loss of the social licence to remove the wild horses from the national park’.[35] As noted below, the NSW Government has recently conducted public consultations on a proposal to use aerial shooting.

5.35In Victoria, Parks Victoria is responsible for reaching the target of the complete removal of feral horses from the Bogong High Plains and a significant reduction in the number of feral horses in the other Victorian Alpine areas.[36]Feral horses are removed via a mixture of ground shooting by skilled professional shooters, capture and rehoming, and euthanasia on welfare grounds. All feral horse management operations follow strict safety and welfare protocols.[37] As noted below, aerial shooting of feral horses is permitted in Victoria but has not been used.[38]

5.36In the ACT, ACT Parks staff are authorised to trap, muster, remove and lethally control feral horse population in Namadgi National Park. The preferred and most ethical method is via ground and aerial shooting.[39] Since 2020, two horses have been shot within Namadgi National Park, and there are no established populations of feral horses in the ACT.[40]

Views on aerial shooting

5.37Deakin University highlighted that feral horses face the threat of starvation during drought, and that aerial shooting is an option used to control populations in other jurisdictions:

Ethically, aerial culling trades off a small and quantified level of animal suffering against the more prolonged suffering of horses that die during drought, while suffering of native animals displaced by feral horse damage to water catchments and degradation of threatened ecosystems continues, as does the risk of extinction of threatened native species.[41]

5.38The Australian Veterinary Association (AVA) supported the use of aerial and ground shooting ‘in the appropriate circumstances, if that method is justified and is used in connection with the most relevant, best practice standard operating procedures and codes of practice’.[42] Further, where there are large numbers of horses, ‘the advantages of aerial culling are significant to improve the welfare outcomes of the horses, because they significantly shorten the lead-up time’.[43]

5.39The AVA also addressed suggestions that barbiturates would be more humane than shooting, given that this approach would involve mustering, positioning the animal and then administering the drug. Although the final death from barbiturates would likely be swift, the first two of these interventions could be prolonged and cause unnecessary stress for the animals.[44]

5.40The high feral horse population, which has resulted from the failure to control animal numbers in KNP, has led to a greater overall challenge in reducing the current population. Restoration Decade Alliance expressed the view that:

It is important to understand that far fewer horses would ultimately be killed if higher proportions of the total population were culled earlier in a control program rather than leaving these animals to breed higher populations, which would require higher levels of culling to bring the population down to an acceptable level.[45]

5.41Many organisations and academics highlighted the need to move to aerial shooting, in addition to ground shooting, of feral horses in the Australian Alps in order to address the high numbers currently present.[46] For instance, DrBraysher and MrKorn, experienced pest policy managers, advocated for aerial shooting and aerial mustering to be added as control methods in NSW.[47]

5.42Snowy Vale Incorporated, a group of 30 individuals who make use of a rural property adjacent to KNP, stated that it was time to move to aerial shooting:

Animal welfare does not need to be compromised but all means should be adopted to reduce the horse population as humanely as possible, including through aerial shooting by qualified professionals. The problem is so vast and urgent that if only constrained population management approaches are employed there will be further detriment to the environment.[48]

5.43Deakin University set out that aerial shooting was now necessary due to the high and increasing population of feral horses:

Aerial culling should be among the set of tools available for horse control, because it is a humane method that can facilitate the urgent, rapid reduction of horse numbers. Aerial culling is cost effective and can be applied at the large scale that is necessary, after decades of inaction. Rapid reduction of horse numbers is critical to enable the Australian Alps to begin recovering from feral horse impacts.[49]

5.44Regarding cost effectiveness, the Invasive Species Council highlighted the vast cost differential between aerial shooting and trapping and live removal. According to the Council’s cited figures, the former is 13 times more cost effective than the latter:

Trapping and live removal of feral horses cost over $1,116 per horse in Kosciuszko National Park, while aerial shooting was estimated to be $85.50 per horse if used in the Australian Alps and found to be $143 per horse when used at the Singleton Army Base.[50]

Trapping and rehoming of feral horses

5.45Advocates of retaining feral horses in the Australian Alps often argued for ‘rehoming’ into a domestic setting. The Kosciuszko Management Plan and Victorian feral horse management plan provide for the use of trapping and rehoming of feral horses. The Kosciuszko Management Plan sets out that removal from the park for rehoming is approved in the following circumstances:

Where there is pre-identified demand from suitable and approved individuals or organisations for removed horses for rehoming.

Areas that are safely accessible by vehicle with trailer and/or truck and where transport of live horses does not cause unacceptable welfare impacts.[51]

5.46Where feral horses have been removed from KNP for rehoming, but that rehoming did not occur, they may be transported to an abattoir or knackery that meets specific animal welfare criteria. Between February 2022 and August 2023, 35 per cent of the 2,201 feral horses removed from KNP have been rehomed.[52] Parks Victoria ‘does not support the live capture and transport of feral horses with an ultimate destination of culling at a knackery or abattoir’. Feral horses are not sent from the Victorian Alpine National Park to knackeries.[53]

5.47In NSW, a person may apply to rehome more than five feral horses from KNP. Since 2002, more than 1,500 feral horses have been rehomed:

These horses are removed from the park as wild and unhandled animals, unfamiliar with the human environment. Potential rehomers will need to ensure they have the necessary skills, facilities and resources to care for these wild animals and transition them to domestic life.[54]

5.48Professor Don White argued that rehoming had been used in the Alps for over a decade but had ‘consistently failed to reduce the population’. Professor White stated that the population of feral horses is too high for this method to be effective.[55] Similarly, Dr Peter Coyne, member of the World Commission on Protected Areas and the IUCN Invasive Species Specialist Group, commented that ‘capture and removal of live horses is impossible in much of the park, would cause them immense stress, and faces limited potential rehoming horses’.[56]

5.49Many inquiry participants highlighted the lack of options for taking feral horses from the Alps and rehoming them, with minimal demand for feral horses, and limited numbers of trainers with the skills, space and capacity to rehome large numbers of animals.[57]

5.50No feral horses have been rehomed in the Victorian Alpine area since 2020, due to a combination of ‘legal challenges (injunctions), the impact of bushfires and COVID-19 restrictions and the closure of the Bogong High Plains Road’.[58]

5.51Save the Brumbies has rehomed more than 400 horses from KNP, and noted the challenges of operating this service:

The problems facing the numerous rehoming groups are many, firstly the lack of interest and funding by Governments to enable such dedicated people to continue their life saving work to preserve such a vital and important part of our national Heritage.

The financial costs to such groups that are animal welfare approved is high, many are unable to continue long term, i.e., the cost of transportation, initial horse handling, gelding of colts and stallions, adequate land, fencing, veterinary attendances, all of which are frequent and ongoing, creates a severe drain on available resources, thus resulting in well-meaning people being unable to continue to take horses for rehoming. Some initial seed funding and financial assistance by Government is an essential necessity going forward into the future.[59]

5.52Due to the stress placed on feral horses during trapping and transport, Save the Brumbies no longer rehomes feral horses from KNP, and noted that the last group of feral horses they sought to rehome require high level care and have resulted in significant veterinary costs.[60] Ms Jan Carter, the President and Founder of Save the Brumbies, elaborated on these circumstances:

We took 29 horses from Kosciuszko 18 months, two years, ago. Those wild horses were two days on the trucks. When they arrived, we had several injuries. Our vet bills were enormous. We still have three of those horses from those 29 that we will never be able to place on because of their injuries…[61]

5.53The AVA advised that ‘[t]echniques which involve mustering, transportation and prolonged handling of the animals contribute significantly to the stress of those animals prior to the finality of the situation’.[62]

Other management methods

5.54Passive trapping is currently used in NSW in working towards its reduction targets. However, NSW Government officials explained that passive trapping for rehoming or which ended with the horses sent to a knackery does not have the effectiveness of other measures. Challenges facing passive trapping include identifying suitable trap locations, accessing areas with sufficient numbers of horses, and the introduction of ground shooting. Overall, these obstacles had led to higher total numbers of feral horses needing to be removed from KNP.[63]

5.55Fertility control methods were also raised during the course of the inquiry. Fertility control has been investigated for use in Victoria, but was not found to be a solution.[64] The Kosciuszko Management Plan states that reproductive control is a potentially viable option, but only where the density of a feral horse population is low, and the objective is to reduce the population slowly, or maintain a low density.[65] Fertility control of feral horses is not undertaken in the ACT.[66]

5.56Ms Jan Carter told the committee that fertility trials had been conducted privately:

At the cost of $35,000, we ran a four-year fertility trial at our Armidale and New South Wales sanctuary…and we had a 95 per cent success rate… We presented this to the national parks… Parks were not interested. They said, 'No, we can't go there because, under legislation, once horses are trapped, they have to be removed from the park.' The horses can be trapped and darted with a 3 ml injection straight into the rump. I've done it myself. On top of that, we can inject a microchip number with a GPS tracker in their neck. Horses can be released. Using GPS, the park rangers can track those horses and follow the results. Parks were not interested. They said, 'No, we can't go there; it's too expensive.' It's not. This injection cost us $3 per shot. They wouldn't even listen to us.[67]

5.57However, the Kosciuszko Management Plan that states:

Currently, there are no reproductive control methods available that are highly effective, easily delivered, affordable and do not alter the behaviour or physiology of horses in some way.[68]

5.58In addition, Professor White explained that fertility control is unlikely to work on large populations:

Fertility control as a management tool is only effective for a small, geographically isolated population of feral horses where the management outcome sought is to maintain the population at its current size. It is not a viable option to reduce the feral horse population in the Alps.[69]

Feral horse management in New South Wales

5.59The NSW Parks and Wildlife Service (NPWS) has an obligation, under the Wild Horse Heritage Act, to implement the associated Kosciuszko Management Plan and reduce the feral horse population in KNP to 3,000 by 30 June 2027. The Kosciuszko Management Plan sets out that over 30percent of KNP (more than 220,000 hectares) will be a horse retention area, to preserve what the plan describes as ‘wild horse heritage values’ such as past grazing and stock routes, association with historical stories, and viewing areas for the public to see feral horses.[70]

5.60The Kosciuszko Management Plan divides the KNP into three ‘management areas’:

feral horse retention areas (3,000 horses in 32 per cent of the park by 30June2027);

feral horse removal areas (21 per cent of the park); and

feral horse prevention areas (47 per cent of the park), which will have the population of zero horses maintained.[71]

5.61A map of the areas is available at Appendix 3.

5.62The feral horse retention area of KNP contains Commonwealth and/or state-listed threatened flora, fauna and ecological communities. The Kosciuszko Management Plan notes that threatened flora and fauna present in the horse retention area include species which are directly at risk from the impact of feral horses as set out in the ‘Habitat degradation and loss by feral horses’ key threatening process listing under the NSW Biodiversity Conservation Act 2016.[72]

5.63For example, the only population of the Stocky Galaxias (Galaxias tantangara), listed as critically endangered under the EPBC Act, is within the horse retention area.[73] The Latham’s Snipe (Gallinago hardwickii) migratory bird species is also known to be present in the horse retention area, and is listed as vulnerable under the EPBC Act.

5.64Important sites for First Nations peoples and water catchment areas are also in this area, including ‘sites of particular cultural significance identified by Aboriginal custodians, including the Snowy River corridor, Kalkite Mountain and the headwaters of the Murrumbidgee and Goobarragandra Rivers’.[74]

5.65The Kosciuszko Management Plan, which is prescribed by the Wild Horse Heritage Act, was adopted in November 2021 following consultation with the NSW community, the Wild Horse Community Advisory Panel and the Kosciuszko Wild Horse Scientific Advisory Panel.[75]

5.66The Kosciuszko Management Plan acknowledges the difficulty in simultaneously recognising heritage values of feral horses and environmental values:

The overlap between the location of wild horses (and their heritage values) and the full range of other environmental values in the park presents a challenge in meeting the requirements of the Kosciuszko Wild Horse Heritage Act. That is, it is a challenge to both recognise and protect the heritage value of sustainable wild horse populations within identified parts of the park, while also ensuring other environmental values are maintained.[76]

5.67The Kosciuszko Management Plan must, among other things, take into account the objects of the National Parks and Wildlife Act 1974 (NSW), including the conservation of biodiversity, the protection of catchment values, and the identification and mitigation of threatening processes.[77]

5.68The Wild Horse Heritage Act, however, states that the adopted Kosciuszko Management Plan ‘prevails to the extent of any inconsistency between the adopted [Kosciuszko management] plan and a [National Parks] plan of management’.[78]

Required removal rate

5.69The rate of removal of feral horses has increased since the implementation of the plan, with additional resources expected to assist the rate of removal. The rate of removal of horses, however, has been affected by significant challenges and remains lower than required to meet targets.[79]

5.70With the implementation of the plan in February 2022, by August 2023 a total of 2,201 feral horses had been removed from KNP by the NSW Government.[80]

5.71Reducing the overall numbers to 3,000 by mid-2027 would require an 84 per cent reduction in the current feral horse population, according to the NSW Government, which estimates that around 4,000 feral horses will require removal per annum from KNP in order to achieve the target.[81] The Australian Government view, which is shared by the NSW Government, is that the NSW Government is not currently on track to reach its target.[82]

5.72The Invasive Species Council estimates, that given the known reproduction rate of feral horses, ‘somewhere in the order of 6,000 horses per year’ will need to be removed to achieve the target set by the previous NSW Government.[83]

5.73Further, the Invasive Species Council pointed to the likely consequence of not achieving the required removal rate:

If we continue at that level of removals—about a thousand per year—within the next four years, by June 2027, we will be at 32,000 horses. So, at a thousand removals a year, we will still see continued growth in the number of horses. Even doubling that rate of removals [to 2,000 per annum], we will end up at about 22,000 horses.[84]

Consultation on aerial shooting

5.74Aerial shooting is not currently authorised under the Kosciuszko Management Plan. In August 2023, the NSW Government opened public consultation on a proposed amendment to the plan which would authorise this control method. The amendment is being considered in order to achieve the statutory goals of a reduction to 3,000 feral horses by 30 June 2027.

5.75The proposed amendment to the plan would ‘authorise aerial shooting as an available method to control wild horses, in addition to existing methods such as ground shooting, trapping and rehoming’. The NSW Government set out that the ability to conduct aerial shooting is ‘essential’ to meet the target.[85]

5.76The NSW Government highlighted that the recognition of heritage values of feral horses (as defined by NSW) would not be impacted by the proposed amendment:

The wild horse retention areas contain evidence of wild horse heritage values, including the role of horses in pioneering history and pastoralism, traditional mountain practices, and the legends, stories and myths of the Snowy Mountains. This evidence includes tangible (for example, huts, campsites, yards, traps and tracks) and non-tangible (for example, personal and community connections) elements.[86]

5.77Consultations on the proposed amendments closed on 11 September 2023. At the time of writing, the NSW Government had not published the results of its consultations.

Other relevant NSW legislation and policies

5.78The NSW Government has in place a range of legislation and policy measures to protect native species from the impacts of feral horses, including:

the ‘Habitat degradation and loss by Feral Horses’ Key Threatening Process;[87]

the Saving our Species program which seeks to increase the number of threatened species (including critically endangered Southern Corroboree Frogs and Spotted Tree Frogs in the Australian Alps) that are secure in the wild, and to protect them from threats like invasive species;[88]

Assets of Intergenerational Significance (AIS), including 49 sites in the Alps, which protect the habitats of 14 threatened species;[89]

conservation action plans (CAP) for each threatened AIS species, set out risks to the area of habitat, actions to measure and report on the health of the species, as well as the priority actions to reduce risks to the habitat. These risks to the habitat can include feral animals; and

the NSW National Parks and Wildlife Service (NPWS) Threatened Species Framework, which sets a target of zero new extinctions and recognises the threat posed by feral animals. The framework outlines actions to secure and restore threatened species in NSW-based national parks. NPWS is the ‘first national park agency in Australia to set a zero extinctions target, and one of the first in the world’.[90]

Views on the Kosciuszko Management Plan

5.79Many submitters including environmental groups, conservation bodies and individuals were critical of the current management of feral horses in the Australian Alps.

5.80The Australian Veterinary Association (AVA) told the committee that the NSW Wild Horse Heritage Act provides a ‘disproportionate weight’ to feral horses over ‘obligations to protect native habitats, fauna and flora within the park’:

The objectives of the plan now are essentially to reduce environmental damage to an acceptable level and to preserve the heritage value of sustainable wild horse populations, while ensuring that the environmental values of the park are maintained. Unfortunately, there is doubt that these two objectives can be achieved simultaneously.[91]

5.81Professor Don Driscoll from Deakin University stated that the biggest barrier to implementing a coordinated approach to feral horse management in the alps is the NSW Wild Horse Heritage Act.[92] Professor Michael Archer from the Australian Academy of Science concurred, and stated that the act stands out ‘like a sore thumb’.[93]

5.82Dr Mike Braysher and Mr Terry Korn argued that the current management approach in KNP had failed, and referred to the management strategy as ‘an unsuccessful political solution to a complex socio/political issue’.[94]

5.83Mr Ian Pulsford, a connectivity conservation and protected area specialist, submitted that ‘apart from climate change, in NSW the [Wild Horse Heritage Act] is the single greatest current threat to the National Heritage values of KNP’.[95] Further, Mr Pulsford highlighted the contrast between NSW and Commonwealth legislation:

[The NSW Wild Horse Heritage Act] is fundamentally contradictory to the intent and purpose of the establishment and management of the Australian Alps national parks, and works in opposition to the Commonwealth responsibilities for the protection of National Heritage listed places and the conservation of threatened and endangered ecological communities and species.[96]

5.84South Endeavour Trust, a conservation land trust that owns and manages private conservation reserves, argued that the issues in NSW stemmed from both the operation of the NSW Wild Horse Heritage Act, as well as the previous NSW Government’s inadequate approach to population control:

In NSW the problem is not just policies and programs but obviously laws. But it must be recognized that even before the [NSW Wild Horse Heritage Act] was passed, the policies and programs enacted in NSW were grossly inadequate and totally ineffective. Just repealing the Act will in no way address the real onground shortcomings caused by the policy decision to exclude aerial shooting.[97]

5.85The ACF submitted that the decision of the NSW Government to protect feral horse populations in the Australian Alps had led to a degradation of the natural environment, and argued that the Commonwealth should be empowered to ensure that natural heritage areas are protected.

Feral horse management in Victoria

5.86The land manager for Victoria’s national parks is Parks Victoria, which has a legal obligation to protect and manage national parks in Victoria.[98] Active feral horse management is undertaken, with a target of the complete removal of feral horses from the Bogong High Plains, and a significant reduction in the number of feral horses in the other Victorian Alpine areas.[99] Overall, Victoria manages 500,000 hectares of the Australian Alps National Parks.[100]

5.87Parks Victoria has trialled and delivered a range of control methods for feral horse management in the last decade, including preparing action plans and control program implementation, working with Traditional Owners and community partners, and monitoring and reporting on the issue.[101]

5.88Parks Victoria noted obligations under a range of state and Commonwealth legislation, and international obligations such as the Convention on Wetlands of International Importance and the United Nations Declaration on the Rights of Indigenous Peoples. The National Parks Act 1975 (Vic) is a key piece of legislation for management of the Alpine area.

5.89In Victoria, feral horses are found in the Victorian Alps, with feral horse populations established in the Eastern Alps (adjacent to KNP), and the Bogong High Plains and adjacent Crown land.[102]

5.90The management strategy for feral horse control in these areas is detailed in the Protection of the Alpine National Park: Feral Horse Action Plan 2021. It reflects Victoria’s experience with a low interest and uptake for feral horse rehoming, bushfires, and the doubling of the feral horse population between 2014 to 2019, from 2,300 feral horses to more than 5,000.[103] Under the plan, Victoria will:

continue to trap feral horses for rehoming to the extent that suitable rehoming applicants can be found;

implement the most humane, safe and effective horse control techniques, including using professional shooters, to remove feral horses ranging across areas of high conservation value;

conduct all horse management operations according to strict standards for animal welfare and public safety;

periodically repeat surveys of feral horse populations in the eastern Alps and in the Bogong-Cobungra area; and

monitor the condition of sensitive vegetation and habitats including alpine mossbeds, peatlands and streambanks.[104]

5.91Parks Victoria told the committee that it had been working for more than a decade to address the damage caused by feral horses on vulnerable wildlife and ecosystems of the Australian Alps. There has been ‘substantial investment by the Victorian government in feral horse control to protect vulnerable Alpine landscapes since 2008’.[105]

5.92Aerial shooting is an approved method of managing feral horses in Victoria, but has not been used in the Alpine National Park to date.[106]

Feral horse management in the ACT

5.93The ACT Government’s zero-tolerance policy to feral horses in Namadgi National Park has a strong focus on managing pest animals, and to eradicate them from the park through control programs. The first plan to manage feral horses in Namadgi was prepared in 2004, and referred to management techniques including barrier fencing, trapping and removal, and ground-based shooting.

5.94The Namadgi plan was updated in 2007 and worked to prevent the re‑establishment of feral horse populations. Since 2007, 24 feral horses have been trapped and humanely euthanased in Namadgi, and there are no remaining animals present.[110]

5.95The current Namadgi plan uses population control methods such as trapping, mustering and removal, as well as ground and aerial shooting. The ACT Government noted that these control methods are endorsed by the RSPCA.[111] The ACT Government described the technology used to support its zero-tolerance approach:

The ACT uses advanced thermal technology to assist in the detection of vertebrate pests including feral horses in remote and heavily forested areas of the ACT. Due to the density of horses on the ACT border, the ACT Parks and Conservation Service aerially surveys the border area using thermal imaging to detect horse incursions, and targets horses during aerial shooting operations. The ACT has also used remote cameras and remote trapping yards to monitor and prevent incursions.[112]

5.96Further, the ACT works with conservationists and land managers to implement habitat restoration and the creation of feral horse exclusion zones, in recognition of the ‘critical role’ that the headwaters of the Murray, Murrumbidgee, Snowy and Cotter rivers have in the ACT region’s ecological health.[113] The importance of Indigenous culture is also recognised in the ACT through consultation with local Indigenous communities to identify areas of cultural significance, and ensure that traditional ecological knowledge is incorporated into management strategies.[114]

Staffing levels in national parks

5.97As noted above, the NPWS has a legal obligation to significantly reduce the feral horse population in KNP to 3,000 horses by 30 June 2027, and reduce the area in which feral horses occur from 53 per cent to 32 per cent. To this end, NPWS staff have been authorised to ground shoot feral horses in accordance with strict operating procedures based on expert animal welfare advice.[115]

5.98During its inquiry, the committee received evidence that the current feral horse control program in KNP is ‘chronically’ under-resourced.[116] According to the Public Service Association of NSW (PSA NSW), although there are around 200 staff working in KNP, there are only 5 to 10 staff involved in the feral horse control program.[117]

5.99According to the PSA, an additional 11 staff are expected to join the NSW program but this figure may not be enough to meet the legislative obligations relating to removal numbers.[118]

5.100The Community and Public Sector Union (CPSU) highlighted that staff conducting pest management ‘are on revolving contracts under one-off funding’ of between 6 months and 3 years, despite the existence of 10 year plans for feral horse control. The ability to plan ongoing activities has been hampered by the uncertainty around the availability of suitable staff to carry out the work.[119] Further, the CPSU drew attention to the reduction in staffing numbers in national parks over time, which adds ‘immense pressure to deliver the control plan’:

Where formerly there were a number of pest animal rangers assigned, now there is only one per region in NSW. With merging of regions there were further cuts with several of these NSW regions being larger than European Countries. Victoria appears to have an even smaller number of staff dealing with their Alpine feral horse plan, even when you include the contracted professional shooters.[120]

5.101Ecologist numbers have also been reduced, which slows down efforts to repair the damaged environment.[121]

Treatment of national parks staff

5.102The health and safety of government staff undertaking feral horse control programs in the Australian Alps has been threatened by some members of the community dissatisfied with the management strategies.

5.103The PSA NSW reported that ‘threats have included statements and images posted on social media; threats of violence to individual staff and the threat to firebomb the Jindabyne Visitor Centre and NPWS office and all staff therein’.[122]

5.104According to the PSA NSW, the severity of the threats has resulted in NPWS managers:

issuing advice to staff on how to assess threat levels and stay safe;

deploying security guards at NPWS buildings;

installing emergency duress alarms at the front counters of all NPWS offices in and adjacent to KNP; and

directing staff not to wear uniforms outside of the workplace.[123]

5.105The CPSU, drawing on the anonymous input of park rangers, raised concerns at the level of abuse faced by rangers and how it had affected their lives, and the lives of their families. Some contracted professional shooters had applied for intervention orders against pro-brumby activists ‘for having been falsely 'outed' on social media and being harassed, stalked, abused and threatened online’:

Members have had to resort to extra security measures at home at their own expense, lying to friends, family and associates about what they do for Parks and what it entails, keeping a low profile and retreating from other community roles. The secrecy is accepted knowing they are part of something meaningful for the environment, but the deleterious safety environment is not acceptable.[124]

5.106The NSW Government advised that various measures have been taken to protect the safety of NPWS staff involved in feral horse management, including regular engagement with NSW Police, non-release of operational program details, and provision of mental health and wellbeing support.[125]

5.107Indeed, the NSW Government’s 2022 review recognised ‘the risk posed by members of the community placing themselves in shooting areas with the aim of intentionally disrupting operations and or using social media to harass those involved with the operations’.[126]

5.108The committee heard that the abuse and targeting of staff extended beyond rangers, and included project officers, administrative support staff and visitor centre staff.[127]

5.109Mr Kim de Govrik, a former park ranger, explained that the children of national parks staff ‘can get bullied at school’, and ‘can be abused in the street, even if they are just walking with someone in uniform’. Mr de Govrik recounted hearing members of the public speaking ‘aggressively’ about NSW park rangers after the introduction of the Wild Horse Heritage Act in 2018:

I travel around New South Wales and meet at depots and offices and talk to the national parks staff. Not long after that legislation was passed, I was having a coffee in Tumut. I couldn't help but hear this conversation, and it was just terrible. It was scathing of national parks' employees.[128]

5.110Similar abusive treatment of staff was reported in other jurisdictions. For example, Parks Victoria explained that community challenges to feral horse management included ‘high levels of abuse and threats (direct and virtual) to on-ground and managerial staff...Traditional Owners and, in some cases, their families’. Parks Victoria elaborated that this involved ‘threats of violence, including death threats, and resulted in Victoria Police involvement and ongoing vigilance to protect staff’.[129]

5.111In a similar vein, the National Parks Association of the ACT advised that the management of feral horses in the Australian Alps can be ‘an emotive issue in neighbouring communities’ and that the association ‘had been advised by rangers living in these communities that they and their families have been the subject of threatening behaviour due to their involvement in control activities’.[130]

5.112The CPSU asserted that although park rangers work with police in each state and territory, the threats faced by rangers are not taken seriously enough, and that ‘[t]he current regulations and law enforcement are unable to adequately deal with these behaviours’.[131] The CPSU recommended that a national campaign be trialled in the Australian Alps to generate respect for rangers, and put an end to violence, ‘similar to the “Thin green line” international campaign that combats violence against our ranger colleagues around the world’.[132]

Committee comment

5.113The Australian Government, and the state and territory governments who share the responsibility for the Australian Alps National Heritage place, have legislative responsibilities to protect the threatened native species and Indigenous heritage values of the area. The committee is of the view that fulfilling these obligations must be a key priority.

5.114To meet these responsibilities, active management of feral horses is critical, as the only natural threats to the feral horse population are bushfire and drought.

5.115The committee heard that the restrictions placed on NPWS were the biggest barrier to cooperative engagement to manage the threat of feral horses in the Australian Alps.

5.116NSW’s reduction target is to reach 3,000 from the estimated population in 2022 of 19,000 in just under four years. This reduction is a much-needed step towards the protection of the Australian Alps. Unfortunately, the historical record has shown that urgent reduction cannot be reached solely with methods previously relied upon, such as rehoming.

5.117The committee acknowledges that shooting any animal is a potentially confronting and an unfortunate reality faced by land managers. However, evidence has been clear that feral horse population control is urgent, and aerial shooting under strict conditions is the most humane and effective management option. Given the urgency of the task at hand, with El Niño conditions underway and the imminent threat of extinction faced by several critically endangered species, the committee supports the use of aerial shooting as a management option if deemed appropriate under strict safety, scientific and humane practice.

5.118The committee takes this opportunity to highlight the important work of conserving the heritage values of the Australian Alps being undertaken by the dedicated staff of the NSW National Parks and Wildlife Service, Parks Victoria and the ACT Environment, Planning and Sustainable Development Directorate. It is critical for the staff who work in Australia’s national parks to be safe when doing their jobs.

5.119The committee heard that staff have performed their work against a backdrop of threats, abuse, and harassment. The evidence highlights that the staff who work in national parks, in ranger, policy, program and visitor service roles, have been impacted by abusive and threatening behaviour. The committee heard that digital stalking, abuse via social media, and other forms of threatening behaviour are taking place. This behaviour is criminal, and those responsible should be held responsible for their actions. The committee condemns violence, or threats of violence, towards staff of our national parks. Everyone has the right to feel safe in their workplace, no matter where their workplace is or what their work requires of them.

5.120Further committee comment and recommendations are made in Chapter 7.

Footnotes

[1]Dr Dianne Evans, Senior Scientific Officer, RSPCA Australia, Proof Committee Hansard, 23 August 2023, p. 10.

[2]Bureau of Meteorology, El Niño and positive Indian Ocean Dipole (accessed 20 September 2023).

[3]Department of Agriculture, Fisheries and Forestry (DAFF), Submission 29, p. 3.

[4]Department of Agriculture and Water Resources, Invasive Plants and Animals Committee, Australian Pest Animal Strategy 2017 to 2027, 2016, p. 5.

[5]Department of Agriculture and Water Resources, Invasive Plants and Animals Committee, Australian Pest Animal Strategy 2017 to 2027, 2016, p. 6.

[6]Department of Agriculture and Water Resources, Invasive Plants and Animals Committee, Australian Pest Animal Strategy 2017 to 2027, 2016, p. 25.

[7]DAFF, Submission 29, p. 5.

[8]DAFF, Submission 29, p. 4.

[9]Parks Victoria, Submission 91, p. 3.

[10]Parks Victoria, Protection of the Alpine National Park: Feral Horse Action Plan 2021, p. 3.

[11]Associate Professor Richard Swain, Indigenous Ambassador, Invasive Species Council, Proof Committee Hansard, 23 August 2023, p. 22.

[12]Mr Jack Gough, Advocacy Manager, Invasive Species Council, Proof Committee Hansard, 23 August 2023, p. 5.

[13]Australian Veterinary Association (AVA), Submission 58, p. 4.

[14]DAFF, Submission 29, p. 4.

[15]DAFF, Submission 29, p. 5.

[16]PestSmart, Model Codes of Practice (accessed 28 August 2023).

[17]PestSmart, Model Codes of Practice (accessed 28 August 2023).

[18]PestSmart, Model Codes of Practice (accessed 28 August 2023).

[19]Office of Environment and Heritage (OEH), NSW, Final report of the Independent Technical Reference Group Supplementary to the Kosciuszko National Park Wild Horse Management Plan, 2016, p. 15.

[20]PestSmart, Ground Shooting of Feral Horses (Hor001) Standard Operating Procedure, p. 1.

[21]PestSmart, Ground Shooting of Feral Horses (Hor001) Standard Operating Procedure, p. 1.

[22]PestSmart, Model Codes of Practice (accessed 28 August 2023).

[23]PestSmart, Ground Shooting of Feral Horses (Hor001) Standard Operating Procedure, p. 1.

[24]Dr Mike Braysher and Mr Terry Korn PSM, Submission 8, p. 5.

[25]PestSmart, Model Codes of Practice (accessed 28 August 2023).

[26]PestSmart, Aerial Shooting of Feral Horses (Hor002) Standard Operating Procedure, p. 1.

[27]PestSmart, Aerial Shooting of Feral Horses (Hor002) Standard Operating Procedure, p. 2.

[28]RSPCA, Submission 84, p. 8.

[29]RSPCA, Submission 84, p. 8.

[30]OEH, NSW, Final report of the Independent Technical Reference Group Supplementary to the Kosciuszko National Park Wild Horse Management Plan, 2016, p. 15.

[31]NSW Government, Submission 361, p. 9.

[32]Mr Atticus Fleming, Acting Coordinator-General, Environment and Heritage Group, NSW Department of Planning and Environment, Proof Committee Hansard, 23 August 2023, p. 27.

[33]Invasive Species Council, Supplementary Submission 76.2, p. 1.

[34]Invasive Species Council, Supplementary Submission 76.2, p. 1.

[35]National Parks and Wildlife Service (NPWS), Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 20.

[36]Victorian Government, Protection of the Alpine National Park: Feral Horse Action Plan 2021.

[37]Victorian Government, Submission 91, p. 3.

[38]Parks Victoria, answers to questions on notice, 7September 2023 (received 15 September 2023).

[39]ACT Government, Submission 83, p. 2.

[40]ACT Government, Submission 83, p. 3; ACT Government, answers to questions on notice, 7September 2023 (received 15 September 2023).

[41]Deakin University, Submission 25, p. 2.

[42]Dr Michael Banyard, Conservation Biology Special Interest Group Representative, Australian Veterinary Association (AVA), Proof Committee Hansard, 23 August 2023, p. 11.

[43]Dr Michael Banyard, AVA, Proof Committee Hansard, 23 August 2023, p. 11.

[44]Dr Michael Banyard, AVA, Proof Committee Hansard, 23 August 2023, p. 12.

[45]Restoration Decade Alliance, Submission 86, p. 2.

[46]A sample of submissions advocating for aerial culling includes: Conservation Council ACT, Submission 11, p. 2; Monaro Acclimatisation Society, Submission 12, p. 3; Professor Don White, Submission 17, p. 2; Public Service Association of NSW, Submission 20, p. 4; Dr Peter Coyne, Submission 22, p. 2; Victorian National Parks Association, Submission 24, p. 1; Deakin University, Submission 25, p. 1; Bushwalking NSW Inc., Submission 26, p. 2; Willoughby Environmental Protection Association, Submission 30, p. 3; Canberra Bushwalking Club, Submission 31, p. 2; Australian Wildlife Society, Submission 33, p. 1; Nature Conservation Council, Submission 34, p. 2; and the Australasian Cave and Karst Management Association, Submission 40, p. 3.

[47]Dr Mike Braysher and Mr Terry Korn PSM, Submission 8, p. 2.

[48]Snowy Vale Incorporated, Submission 38, p. 1.

[49]Deakin University, Submission 25, p. 1.

[50]Invasive Species Council, Submission 76, p. 19, in-text references omitted.

[51]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 20.

[52]NSW Government, answers to questions on notice, 23 August 2023 (received 22 September 2023).

[53]Parks Victoria, answers to questions on notice, 7 September 2023 (received 15 September 2023).

[54]NSW Government, Rehome a Kosciuszko wild horse (accessed 7 August 2023).

[55]Professor Don White, Submission 17, p. 5.

[56]Dr Peter Coyne, Submission 22, p. 2.

[57]For example: Victorian National Parks Association (VNPA), Submission 24, p. 1.

[58]Parks Victoria, answers to questions on notice, 7 September 2023 (received 15 September 2023).

[59]Save the Brumbies, Submission 3, p. 2.

[60]Save the Brumbies, Submission 3, p. 4.

[61]Ms Jan Carter, President, Save the Brumbies, Proof Committee Hansard, 23 August 2023, p. 19.

[62]Dr Michael Banyard, AVA, Proof Committee Hansard, 23 August 2023, p. 11.

[63]Mr Atticus Fleming, NSW Department of Planning and Environment, Proof Committee Hansard, 23August 2023, p. 27.

[64]Parks Victoria, answers to questions on notice, 7 September 2023 (received 15 September 2023).

[65]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 20.

[66]ACT Government, answers to questions on notice, 7 September 2023 (received 15 September 2023).

[67]Ms Jan Carter, Save the Brumbies, Proof Committee Hansard, 23 August 2023, p. 18.

[68]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 20.

[69]Professor Don White, Submission 17, p. 5.

[70]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 13.

[71]NSW Government, Submission 361, p. 5.

[72]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 14.

[73]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 14.

[74]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 14.

[75]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 2. In 2008, the NSW feral horse management framework was finalised in the form of the 2008 Horse Management Plan (under the 2006 Kosciuszko National Park Plan of Management). In 2016, a draft management plan for feral horses in KNP was shared publicly but not finalised.

[76]NPWS, Kosciuszko National Park Wild Horse Heritage Management Plan, 2021, p. 13.

[77]Kosciuszko Wild Horse Heritage Act 2018 (NSW) (Wild Horse Heritage Act), para. 5(2)(d). Subsection 72AA(1) of the National Parks and Wildlife Act 1974 (NSW) lists 23 matters which must be taken into consideration when management plans are prepared for national parks, including, relevantly: theconservation of biodiversity; the protection of catchment values; the identification and mitigation of threatening processes; the regional, national and international context of the national park; the maintenance of any national and international significance and compliance with national and international agreements; and the social and economic context of the national park so as to ensure that pest species management programs are co-ordinated across different tenures.

[78]Wild Horse Heritage Act, ss. 12(1).

[79]NSW Government, Submission 361, p. 5.

[80]Mr Atticus Fleming, NSW Department of Planning and Environment, Proof Committee Hansard, 23August 2023, p. 25.

[81]NSW Government, Submission 361, p. 4.

[82]Mr James Barker, Branch Head, World and National Heritage Branch,DCCEEW, Proof Committee Hansard, 23 August 2023, p. 44.

[83]Mr Jack Gough, Advocacy Manager, Invasive Species Council, Proof Committee Hansard, 23 August 2023, p. 4.

[84]Mr Jack Gough, Invasive Species Council, Proof Committee Hansard, 23 August 2023, p. 4.

[85]NSW Government, Amending the Kosciuszko National Park Wild Horse Heritage Management Plan: public consultation (accessed 7 August 2023).

[86]NSW Government, Amending the Kosciuszko National Park Wild Horse Heritage Management Plan: public consultation (accessed 7 August 2023).

[87]Schedule 4, Biodiversity Conservation Act 2016 (NSW).

[88]NSW Government, Submission 361, p. 10; NSW Government, Saving our Species Program(accessed 15 September 2023). See also, NSW Government, Saving our Species: Year in Review 2021–22, 2022, pp.5–6.

[89]NSW Government, Assets of Intergenerational Significance (accessed 31 May 2023).

[90]NSW Government, Threatened Species Framework for zero extinctions (accessed 29 August 2023).

[91]Dr Michael Banyard, AVA, Committee Hansard, 23 August 2023, p. 9.

[92]Professor Don Driscoll, Professor of Terrestrial Ecology, Deakin University, Proof Committee Hansard, 7 September 2023, p. 4.

[93]Professor Michael Archer, Fellow, Australian Academy of Science, Proof Committee Hansard, 7September 2023, p. 6.

[94]Dr Mike Braysher and Mr Terry Korn PSM, Submission 8, p. 2.

[95]Mr Ian Pulsford, Submission 89, p. 5.

[96]Mr Ian Pulsford, Submission 89, p. 5.

[97]South Endeavour Trust, Submission 41, pp. 2–3.

[98]Parks Victoria, Submission 91, p. 3.

[99]Parks Victoria, Protection of the Alpine National Park: Feral Horse Action Plan 2021, p. 3.

[100]Parks Victoria, Protection of the Alpine National Park: Feral Horse Action Plan 2021, p. 13.

[101]Parks Victoria, Submission 91, p. 1.

[102]Parks Victoria, Submission 91, p. 2.

[103]Parks Victoria, Protection of the Alpine National Park: Feral Horse Action Plan 2021, p. i.

[104]Parks Victoria, Protection of the Alpine National Park: Feral Horse Action Plan 2021, p. i.

[105]Mr Matthew Jackson, Chief Executive Officer, Parks Victoria, Proof Committee Hansard, 23 August 2023, p. 27.

[106]Parks Victoria, answers to questions on notice, 7 September 2023 (received 15 September 2023).

[107]Parks Victoria, Feral Animals (accessed 29 August 2023).

[108]FeralScan, FeralScan (accessed 25 August 2023).

[109]Centre for Invasive Species Solutions, About CISS (accessed 25 August 2023).

[110]Namadgi National Park Feral Horse Management Plan 2020 (ACT)

[111]ACT Government, Submission 83, p. 2.

[112]ACT Government, Submission 83, p. 2.

[113]ACT Government, Submission 83, p. 3.

[114]ACT Government, Submission 83, p. 3.

[115]NSW Government, Submission 361, pp. 6 and 7.

[116]Public Service Association of NSW (PSA NSW), Submission 20, p. 10.

[117]PSA NSW, Submission 20, pp. 2 and 10.

[118]PSA NSW, Submission 20, pp. 2 and 10.

[119]Community and Public Sector Union (CPSU), Submission 87, p. 3.

[120]CPSU, Submission 87, p. 3.

[121]CPSU, Submission 87, p. 3.

[122]PSA NSW, Submission 20, p. 11.

[123]PSA NSW, Submission 20, p. 11.

[124]CPSU, Submission 87, p. 3.

[125]NSW Government, Submission 361, p. 10.

[126]NSW Government, Submission 361, p. 10.

[127]Mr Kim de Govrik, Organiser, PSA NSW, Proof Committee Hansard, 7 September 2023, p. 9.

[128]Mr Kim de Govrik, PSA NSW, Proof Committee Hansard, 7 September 2023, p. 10.

[129]Parks Victoria, Submission 91, p. 4.

[130]National Parks Association of the ACT, Submission 53, p. 6.

[131]CPSU, Submission 87, p. 8.

[132]CPSU, Submission 87, p. 9.