SNOWY  MOUNTAINS  BUSH  USERS  GROUP  INC. (“SMBUG”)

Protecting our Mountain Heritage

21 December 2007

The Project Officer, Kosciuszko National Park
Draft Horse Management Plan
National Parks and Wildlife Service
PO Box 472
Tumut NSW 2720

 RE- HORSE MANAGEMENT PLAN DRAFT “A DOCUMENT FOR DISCUSSION” November 2007

 Dear Sir/Madam, 

We hold in conjunction with this response-

•           SMBUG prepared FORM LETTER with 3,786 individual signatures. These letters may be reviewed or copied by NPWS on request. Sample of letter attached.

•           SMBUG prepared PETITION with 2,240 individual signatures. The petition may be reviewed or copied by NPWS on request. Sample of petition attached.

 SMBUG is greatly encouraged by the willingness and the enthusiasm displayed by a broad spectrum of the Australian public to support our campaign to stop your proposal to capture and remove brumbies from Kosciuszko National Park. 

Before we comment on particular segments of the Draft Plan we query if the proper protocols and conventions have been observed in relation to events surrounding the lead up, release and the public comment period, namely:

 1.         Friday, 9 November 2007- C T Edwards receives in the post a hard copy of the Draft Plan with a covering letter dated 7 November saying the Plan “will go on public exhibition on 12 November 2007and that a “series of information sessions will be held”. Same day an email copy of the “KNP Horse Plan Draft Final” is received

Despite written assurances that the Community Steering Group (CSG) members will be given a chance to review the final Draft it is released without that opportunity. As a result the CSG members only saw the exact photographs presented in the Plan when the release was “fait accompli” (confirmed by NPWS media release 13/11/07) and denies CSG members the right to initiate a field inspection. This oversight in our view is clearly unacceptable and unprofessional.

 2.         The hard copy of the Plan, on which SMBUG acted, states that “submissions should be in writing” and provides PO BOX details as did NPWS newspaper advertisements.

 This was queried by SMBUG in writing on 7/12/07, NPWS did not respond. SMBUG followed up by phone on 14/12/07 and was then informed that email responses will be accepted. To change such arrangements after the document is released for public comment is totally unacceptable and unprofessional.

 3.         The Minutes of the 5th CSG meeting held on 4/5/07 under Action 5/9 records “NPWS to conduct open forums in Tumut, Jindabyne and Queanbeyan”. The hard copy of the Plan fails to inform the public of this critical information

  The letter of 7/11/07 that details the “information sessions” and explains the “open house” format is not attached to every hard copy of the Plan collected from Tumut, Jindabyne, Khancoban and Queanbeyan offices. Instead the public is informed by NPWS newspaper advertisements that are poorly scheduled and in our view totally inadequate. For example, we are informed only one ad appeared in the local press for the Jindabyne meeting and in Tumut no ads appeared on 30/11/07 or 4/12/07. You can understand the public’s confusion when NPWS in the media one minute is talking about “open forums” and the next minute “information sessions”. For example refer to Tumut and Adelong Times story on 7/12/07. There is a significant difference between the two formats and clearly what NPWS held were “information sessions”. In our view the public have been misled. 

4.         The KNP Horse Management Plan Draft is titled a “A Document for Discussion”

 In our view it is outrageous for NPWS to be quoted as saying “time for debate is over, brumbies will be removed” (Tumut and Adelong Times, 7/12/07) when the Plan is still open for comment until 21/12/07. As there has been no retraction or correction published we consider such a statement by NPWS is an attempt to stifle public comment regarding the Plan and is unacceptable behaviour from a public entity.

 SMBUG believes that the abovementioned poor conduct by NPWS is both unacceptable and unprofessional and represents sufficient grounds for the Draft Plan to be withdrawn.

 GENERAL OVERVIEW

 Our review confirms that this Draft Plan demonstrates extreme prejudice against the Brumby in its presentation and we highlight that it fails to even mention or consider-

•           The cultural heritage value of the Snowy Brumby

•           The Brumbies legendary and iconic status in the eyes of the Australian public due to “Banjo” Paterson and countless other poets, writers, painters, filmmakers and photographers etc. In addition of course “the Man from Snowy River” theme for the opening ceremony of the Sydney 2000 Olympic Games that showcased Australia to the world

•           That these Brumbies are the descendants of a large contingent of horses that were shipped overseas and faithfully served our troops in the Sudan Campaign, Boer War, the Great War and were never allowed to return

•           The Brumbies tourism value and subsequent contribution to the economy

•           The positive benefits of the Brumby grazing native grasses, the resultant fuel load reduction and sweeter grass for all native herbivores

Other critical deficiencies exposed in the plan are-

1.         Failure to provide analysis of and weighting to the major threats to the environment within the park. We contend that any alleged horse impact would not be of a serious or irreversible detrimental nature. At worst any impact would be temporary and short term and would pale into insignificance when compared to the long term impacts of bushfires, predator feral animals, weeds, roads, dams, powerlines, ski resort development and natural occurrences such as snow, ice, rain, flood, wind, earthquakes/ tremors etc.

2.         Failure to provide the actual number of Brumbies to be culled

3.         Lack of any analysis as to what would be the conservative maximum number of Brumbies the park could sustain

4.         Likewise the minimum number required to remain genetically viable and to cover contingencies such as the 2003 bushfires which destroyed 50% of the Brumby population in the southern end of the park

5.         Failure to provide a cost/benefit analysis or details as to whether or not the money could be more effectively spent elsewhere to protect the park

6.         A number of the photographs provided in the plan to suggest Brumby impact are highly suspect and we are seeking more information from NPWS

7.         Fails to provide a mechanism to facilitate full and proper public debate

SMBUG RESPONSE TO THE DRAFT PLAN IS AS FOLLOWS:

 Page 4- Community Views

 The Plan does not inform the public that the Horse Management Community Steering Group, which totalled ten people, was carefully selected by NPWS to only include two declared brumby supporters. Neither is it mentioned that these two brumby supporters do not support or condone the Plan as presented.

 We do not accept that the brumby should be bundled into “ any vertebrate pest program”.

 History of Horse Management in the Park

 What were the “public and Service concerns” regarding licensed horse roping/brumby running? This has never adequately presented for public debate. 

The “Wild Horse Management Plan for the Alpine Area of Kosciuszko National Park” that was implemented in 2003 and the 2006 Plan of Management for Kosciuszko National Park (POM) sections regarding brumbies were both imposed by NPWS. There was never the opportunity given for broad based public debate and NPWS ignored the majority of respondents to the Draft POM who were against the proposed brumby “exclusion areas”.

 Page 6 - Table of Contents

 4.Community Consultation starts page 20 (not 19)
Page 22 is blank- is this correct?

Page 8 – Background

Correction- Horses have been present in the Snowy Mountains/Kosciuszko area since the 1820’s.

Page10 – Objectives

The Concise Oxford Dictionary defines “exclude”- shut out/expel and defines “eradicate”- remove/get rid of/destroy. So for all practical purposes they mean the same thing.

Excluding brumbies from the Main Range Management Unit has been previously acknowledged and agreed by the local communities.

Excluding brumbies from Yarrangobilly and Cooleman Plain Management Units does not have widespread community support. The inclusion of the additional brumby exclusion areas, apart from the Main Range Management Unit, in the 2006 Plan of Management for Kosciuszko National Park was imposed by NPWS and not publicly endorsed.

We have no knowledge these of these areas being dedicated as “Karst Conservation Areas”.

Where is the independent creditable science to support the exclusion of brumbies?

The 2006 KNP Plan of Management, page 50 lists a host of key karst management issues. Included human use and infrastructure, introduced plants, introduced animals and fire management and we wonder what damage the native wombat and rabbits are doing. Clearly all these threats should be subject to rigorous scientific research and weighted in accordance with impact levels. At this point in time there is no justification to exclude the brumby.

This plan is incomplete for the following reasons-

•           No hard numbers- how many brumbies will be taken, how many will be left

•           No cost/benefit analysis

•           No accountability or transparency measurements- the plan is open ended

Page 13 – Karst Ecosystems

Please refer to our comments above under Objectives.

Page 13 - Historical Overview of Horses in the Snowy Mountains

Paragraph 2- Incorrect on two counts- Firstly, the first horses brought to Australia were thoroughbreds from England. It was about 20 years later that Cape,Timor, Indian and other breed stocks were introduced to produce more stamina and ultimately led to the development of the “Waler” and  an all purpose Australian stock horse. Secondly, horse numbers increased rapidly to meet demand as the population grew and spread inland. Also to supply re-mounts to the British Army in India. Then to mention “Australia has the largest population of wild horses in the world with more than 300,000” smacks of bias and sensationalism.

Paragraph 3- needs re-wording. Delete Australia. The Snowy Mountains are not ideally suitable for horse breeding. The extreme weather conditions in this area greatly reduce foal survival rates and the life expectancy of mature horses. Omitted from mention was the fact that bushfires are a major threat to their survival (50% in the southern end of KNP wiped out in 2003) as are wild dogs. The situation here is unique and comparisons with other locations would be pointless.

Page 14 - Horse Roping

Paragraph 3-In this paragraph NPWS should point out to the public that it is their management practises of preventing “brumby running” and the establishment of wilderness areas by the State Government that has led to the present situation.

Page 15 - Figure 3 Photographs of Horse Impacts

The fact that these photographs are undated, unsigned and insufficient location detail is in our view unprofessional.

Excluding the photograph in the bottom right hand corner of the page we have not as yet been able to carry out our own on site inspection. Despite verbal requests to NPWS personnel on 20/11/07 and 28/11/07 and then an email request on 7/12/07 maps and location details for the other photographs were not provided until a further phone call was made on 14/12/07. Our plans to visit the sites on 16/12/07 had to be cancelled due to approx. 50mm of rain falling at Rules Point that weekend.

We reserve the right to make a separate response regarding these photographs by the 15 February 2008.

Page 16 - Environmental impacts

Drying’s Study

Compacting of Dry Soils

We consider that the alleged brumby impacts to be grossly exaggerated. Please refer to our General Overview comments Item 1.

We believe that there is an insufficient level of current creditable science available to review that relates specifically to brumbies in specific multi use areas of KNP. Nor is there such science available that weights the major threats to the environment within the park.

Therefore we consider that there is no justification on scientific grounds at this point to proceed with this plan.

Page 17 – Stream Bank Damage

In the northern end of KNP the major stream bank erosion occurs to Currangorambla Creek and this is caused by the rise and fall of Tantangara Dam. Soil saturation, falling lake levels and heavy frosts are creating bank collapse and silting up of the stream for many kilometres. This is real and permanent impact caused by the Snowy Mountains Scheme.

Page 17 – Wetlands

Same comments as above apply. There has been no explanation given by NPWS as to how the corroboree frog and the broad-toothed rat survived 120 years of alpine/sub alpine grazing by tens of thousands head of stock and are now threatened by the brumby. What is the evidence? Rank the other major threats to these animals.

Also brumbies and indeed all horses avoid bogs and wetlands. Don’t confuse brumby creek crossings that would be solid and safe with bogs and wetlands.

Page 17 – Concentration in Grasslands

Brumbies like all horses naturally eat grasses. At the present stocking rate of one brumby per 400 hectares you could not imagine why or when they would look for heath.

Grazing is good for native grasses, if not grazed they become stalky, rank and unpalatable for all native grazing animals.

Brumby dung is only compost (digested grass) and an excellent natural fertiliser. There is no evidence that is has changed vegetation patterns in KNP.

Page 17 – Safety Issues

The Plan should disclose to the public we have requesting NPWS for over three years to have RTA reduce the speed limit from 100km per hour to say 80 or 60 km per hour. NPWS has the knowledge of the locations where brumbies frequently cross. The higher risk areas are where timber crowds into either side of the roads and lateral visibility is restricted. 

Likewise, for the same period we have been saying that the signage is totally inadequate. For example on the Snowy Mountains Highway heading south there is one sign just after you cross the Yarrangobilly Creek saying “ caution wild horses next 3 km”. This is the only sign in the 7 km to the Yarrangobilly Caves turn-off. The full 7 km would be considered a higher risk area. The same applies heading further south, it is 4 klm from the Long Plain Road turn-off at Rules Point before the next brumby caution sign appears near Bullocks Hill indicating wild horses next 4 klm.

In summary, in 16 km of highway there are 2 cautionary signs. This is in no way adequate, there should be 8 signs (spaced every 2 km) and at least four times larger than the existing signs.

We have offered to form a delegation with NPWS to go and see the RTA, but that has not been taken up. 

We are certainly concerned with motorist safety and everything possible should be done to encourage drivers to slow down. We can not follow the NPWS logic as they seem to be only concerned with brumbies on roads, where is the same concern for the other wildlife on roads like kangaroos, wallabies, wombats etc. Surely, the consequences of hitting or swerving to miss any of the animals at 100klm per hour can be just as disastrous. 

At these “hot spots” we have suggested various forms of fencing to be trailed from plastic tape mesh, solar/battery powered electric wire to permanent fencing to turn the brumbies back from the road. NPWS have done nothing. 

All landholders surrounding KNP are required to have suitable fencing to keep their stock off the roads. We would have thought that NPWS have a similar obligation under their “duty of care”. 

It seems to us that NPWS are simply using this “safety” pretext justify the removal of brumbies from the park..  

Incidentally, we recently confirmed that there have been no reported motorist accidents with brumbies at Tumut or Adaminaby Police Stations in the last 4 years. On the other hand there have been many accidents involving kangaroos. 

Page 17 - Breeding

There is no independent scientific evidence whatsoever available on actual population growth rates in KNP In the extreme climate conditions of the Snowy Mountains it is fanciful to talk of a 20% annual growth rate.

We estimate possibly 2-3% in ideal seasonal conditions and this is without allowing for extreme weather or other events like the 2003 bushfires that destroyed 50% of the southern KNP brumby population.

Page 18 – Home Range

Brumbies are not highly mobile as stated. They are herd animals living in a well- defined home range. Small numbers will move out due to changes in the family herd composition or other pressures that re-define the range.

Page 18 – Life Span

This is grossly exaggerated to infer that brumbies in KNP could live 30 plus years.

In the Horse Management plan for the Alpine Area of Kosciuszko National Park- January 2003- January 2005, page 7, 2.5.4 The Biology of Horses it states “On average 20% of a horse population dies each year mainly from drought, poisonous plants and parasites…….”(Dobbie and Berman,1992).

A sample test carried out in 2000 and reported in the Draft Horse Management plan- Guy Fawkes River National Park- November 2003, page 9 found that the average age was 4.7 years and confirms Dobbie’s assertion.

Page 18 – Diet

This paragraph cannot be substantiated by NPWS as there is no hard independent scientific evidence available.

In the Horse Management Plan for the Alpine Area of Kosciuszko National Park- January 2003- January 2005, page 5, dot point 5, “Although there have been no studies on the diet preferences of wild horses in the Australian alpine environment…”(Dyring,1990 and Landsberg,1999).

Jennifer Dyring in her Report “Management Implications of the 1988-1990 Study- The Impact of Feral Horses (Equus Caballus) On Sub- Alpine and Montane Environments in Australia”, page 17, 4.5 Grazing Trials and forage utilisation states, “As an extension of habit use, an assessment of activities of the horses is necessary to determine grazing preferences. Exclosures should be established within different habitats to exclude any horses. Long term monitoring is vital, with a minimum of 10 years being necessary to obtain useful results”.

Page 18 – Horse Population and Distribution

The figures in the Plan are heavily qualified.
Lets summarise NPWS provided population figures:-

The figures are impossible to reconcile. What this table shows is that there are 43% less brumbies over the period. The 2003 bushfires reportedly killed 50% of the brumbies in the southern end of KNP and 206 brumbies from the same area captured and removed.

Would NPWS please explain the 30% drop in the northern end of KNP.

Clearly, the figures are outdated and unreliable and should not be used to justify the proposed removal program.

Page 20 – Community Consultation

The whole process in the development of the 2006 Plan of Management- Kosciuszko National Park in our view has been a “sham” and designed purely as a public relations exercise.

This “Clayton’s” consultation process started with three local community workshops and open to all to attend. The majority views of those attending were - relaxing access restrictions, allowing horse riding in wilderness and recognition/protection of the brumby. These views were ignored.

There was then held a closed workshop on 28/5/02 in Sydney with various conservation groups.

In June 2002 the Community Forum was established with a Chairman plus 20 members hand picked by NPWS.

Unfortunately, key issues for example, relating to skiing interests, access, horse riding, brumbies and general recreational usage were constantly deferred and not resolved. We have been advised that senior NPWS personnel manipulated discussion and processes to get the outcomes they wanted. NPWS had their preset vision and agenda and constantly sought only supporting views. There was no voting. Things got so bad that the two Ski Industry representatives resigned in protest from the Community Forum.

The Draft Plan of Management for Kosciuszko National Park went on public exhibition on 17 May 2004 and comments were invited.

We submitted a 44 page detailed response and were responsible in conjunction with other horse  riding and recreational groups in the submission of 10,400 form letters which represented 90%  of all responses received by NPWS

Our efforts were in vain as there were no amendments in our favour to the final approved Plan in June 2006. There has been no initiative by NPWS to sit down and discuss our concerns and issues with the Plan.

In September 2006 the KNP Horse Management Plan- Community Steering Group was established with a Chairman and 10 members. There were only 2 declared pro brumby supporters, one representing the Snowy Mountains Horse Riders Association and one representing SMBUG.

Both parties withdrew their support of the Plan in May 2007 as detailed :-

SMBUG and SMHRA do not support or condone the capture and removal of Brumbies from any area within KNP other than in the Main Range Management Unit until such time as-

•           The current Brumby population is independently assessed

•           Independent scientific evidence is provided as to whether or not 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 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 public community meetings at appropriate times and locations, with the above information provided, and a majority view, say 75%, sought to decide the Brumbies future”.

Now we have the Horse Management Plan Draft that was released in the middle of a Federal Election Campaign, at one of the busiest periods for rural people (eg hay making/carting, harvesting, hand feeding stock and/or carting water up until the last week or so) and the comment period ends one working day before Christmas. Then to cap it off NPWS conducts three “information sessions” on weekdays between 3.30 and 6.30pm.

No wonder we have a cynical view of the so- called public consultation process.

Page 20 – 4.2 KNP Horse Management Community Steering Group

Correction- last dot point- please use our correct name - Snowy Mountains Bush Users Group and make a suitable comment that “we represent horse riders and other recreational users of KNP” (approx. 33% of our members are non horse riders who visit the park or have an interest in protecting our mountain heritage).

Page 25 – Fencing

Do not agree with the comment. In the “hot spots” trial fencing should be used immediately.

Page 25 – Aerial Shooting

Under no circumstances would we support aerial shooting.

CULTURAL HERITAGE

It is unacceptable outcome to us that the 2006 KNP Plan of  Management  and this Draft Plan both fail to recognise the cultural heritage value of the Snowy Brumby.

We strongly believe that a clear majority of the Australian public supports our view that the Snowy Brumby has at least equal and in some instances greater cultural heritage value than the historic homesteads, pastoral, mining and ski huts, gold and mining sites, gravesites, stock routes, wagon and bridle tracks and other footprints left in the Snowy Mountains by our pioneering forefathers. 

The Snowy Brumby is descended from the horses that were brought into the area by the first pastoralists in the mid 1820’s. By the late 1830’s sightings of wild horses were being reported in the Snowy Mountains. So for nearly 180 years the brumby has been caught, used by man and in some cases released back into the wild to see out their retirement years.  

Many an Australian stock horse has brumby blood running in its veins. So does the famous “Waler” that was bred up to meet the re-mount specifications for the British Army in India. Between 1838 and 1918 it is estimated that over 500,000 horses were exported from Australia. Many pastoralists in the Snowy Mountains and Victorian Alps were involved in horse breeding to meet this lucrative trade.  

This Draft Plan is attempting, by stealth, to sever the connection established over nearly 190 years between horse, man and the Snowy Mountains.  

A.B. (“Banjo”) Paterson was inspired by the history, traditions and folklore of these mountains to create what has become our national poem “The Man from Snowy River”. This poem epitomises our national character of mateship, the larrikin spirit, the never-say-die determination, the identification with the under-dog and the national right to a fair go. 

Under no circumstances should the Snowy Brumby be referred to as “feral” or included in any vertebrate pest programs. 

Surely, after nearly 180 years the Snowy Brumby has earned the right to be given citizenship, recognised and protected. 

THE KEY ISSUES 

The following are imperatives that must be resolved before we would support the NPWS plan to capture and remove brumbies from KNP- 

1.         Stop any current removal program, step back and listen to the public 

2.         Provide the Australian public with unbiased and balanced information, based on independent science not ideology. 

3.         Let the Australian public decide if the Snowy Brumby should be recognised and protected for its cultural and heritage value 

4.         With a yes decision. Then independent scientific evidence must be provided to support the maximum brumby population that would be sustainable and what minimum numbers are required to remain genetically viable and to avoid excessive inbreeding. Also what margin in numbers is required to cover contingencies such as the 2003 bushfires that wiped out 50% of the brumbies in the southern end of the park. 

5.         Allow independent science decide if brumbies should be removed from karst areas 

We fully appreciate that if the brumby population exceeds the maximum sustainable levels then pro-active management will be necessary. 

SMBUG would welcome the opportunity to be involved in the process of addressing the key issues mentioned above.

Yours faithfully