Feral horses in national parks

A survey taken in 2019 found over 25,000 horses in NSW’s Kosciuszko National Park and Victoria’s Alpine National Park. Around 5,000 of those were estimated to be in Victoria’s eastern alpine region, with a much smaller population (80-100) on and around the southern Bogong High Plains.

That constituted a 23 percent annual increase since the previous survey in 2014; the population in the Australian Alps more than doubled between 2014 and 2019. The fires of the summer of 2019-20 may have reduced the population to a degree (horses do die in bushfires), but post-fire recovery will inevitably lead to even higher populations unless effective action is taken to control horses.

Due to a strict horse control program in the ACT there are no feral horses at all in Namadgi National Park, the ACT’s only alpine region park.

This remarkable park protects close to 30,000 hectares of River Red Gum forests, box eucalypt woodlands and extensive seasonal wetlands along the Murray River. The park’s remarkable and extensive wetlands are protected under the international Ramsar convention.

An aerial survey taken in 2018 found around 800 horses in Barmah National Park, well above local estimates.

There are many native species and communities listed as threatened in Victorian and national law that horses seriously impact.

In the Alpine National Park:

• Four threatened alpine plant communities (Ecological Vegetation Classes or EVCs) have been listed as threatened by hard hooved animals. They are:

- Alpine Bog Community (mossbeds)
- Alpine Snowpatch Community
- Caltha introloba (Alpine Marsh Marigold) Herbland Community. This community is associated with alpine wetlands and late-lying snow patches.
- Fen (bog pool) Community

• Horses graze alpine grasslands and other native alpine plants, many rare or threatened, that live in the grasslands. Animals that need these grasslands include the Alpine She-oak Skink (endangered), Guthega Skink (endangered), Tooarrana (vulnerable). (The Tooarrana was once called the “Broad-toothed Rat” but it’s a beautiful fluffy, plant-eating mammal, and deserves to be called by its original name.)
• Their hard hooves trample peatbeds and wetlands and the animals and plants that live there. These include the Alpine Water Skink (endangered), Alpine Bog Skink (endangered), Alpine Sheoak Skink (endangered), Alpine Tree Frog (vulnerable).
• They also trample small mountain streams, the headwaters of many of our major rivers, causing siltation. This is turn affects threatened species such as the Alpine Stonefly and Alpine Spiny Crayfish.
• There are around 25 native plants, variously listed as endangered or vulnerable, that are affected by horse grazing. They include: Marsh Leek-orchid, Bogong Apple-moss, White Billy-buttons, Carpet Willow-herb, Bogong Eyebright, Cushion Rush, Snow Daphne, and Blue-tongue Greenhood.

In Barmah National Park:

One significant feature of the wetlands of Barmah National Park is Moira Grass, a seasonal wetland grass that provides important habitat for a number of threatened plants and animals. Over the last 80 years, partly due to the increase in horse numbers, Moira Grass has reduced in extent by around 95 per cent. Another significant cause of Moira Grass decline is changed flooding regimes along the Murray River, but river regulators are unlikely to re-instate a more natural environmental flooding regime for Barmah until the impact of horses has been controlled.

Animals that depend on Barmah’s wetlands include the Broad-shelled Turtle (Bayadherra in Yorta Yorta language) and the Murray River Turtle (Dhungalla watjerrupna). The wetlands also protect eight frog species and four water-dependent reptiles, as well as around 70 waterbirds, seven of which are protected under international migratory bird treaties. The Barmah wetlands and floodplain marshes are protected internationally as a Ramsar Wetland site.

Scientists have been studying Victoria’s flora and fauna since early in the 19^th century, and the amount of recorded information now accumulated about Victoria’s native plants, animals and their critical habitats is extraordinary. There is less knowledge about fungi, and invertebrates (insects, spiders and worms etc.) even though the majority of native species are in these groups.

When the Alpine National Park (along with the other mainland Australian alpine parks) gained National Heritage listing, the citation referred to the “outstanding heritage value of the scientific research that has taken place since the 1830s, demonstrated by the density and continuity of scientific endeavour”. That work includes many published research projects documenting the impact of hard-hooved grazers.

In a recent Federal Court case brought by the Australian Brumby Alliance (ABA) against Parks Victoria, the integrity of alpine science was raised as an issue. However, the Federal Court judge said in his May 2020 decision that the evidence presented by alpine ecologists outlining the significant damage caused by feral horses was “supported by scientific studies and their expertise was persuasive”. On the other hand, the judge found the claim by the ABA’s witness that the horses were not causing significant damage “was not supported by science and was not persuasive” and that it “relied on conjecture”.

While the number of scientific studies performed in Barmah National Park is not as extensive as those performed in the alps, there is nevertheless a wealth of knowledge about horse impacts in the Barmah wetlands and associated woodlands. That knowledge has contributed to the state, national and international protection the park has won.

Horses, goats, pigs and deer are all feral, introduced animals in Australia.

There are no native hard-hooved animals in Australia.

Horses were introduced in the area of the current Alpine National Park as early as the mid 19^th century, either deliberately for cheap summer grazing, or as farm escapes. Over the decades, sometimes their numbers were quite large, at other times there have been very few horses in Victoria’s high country. The current population includes horses escaped from, or abandoned by, nearby farms.

Horses were introduced to northern Victoria’s Barmah forest and wetlands from about the 1840s, largely as farm escapees.

There is a degree of cultural association with the horses, but there is no need for an ever-increasing population of them in a national park which was proclaimed to protect native ecosystems and threatened flora and fauna. Horses can be kept, if need be, in a suitable area outside the park.

Many claims made about the heritage value of the ‘brumbies’ are highly questionable.

• There is no evidence that they are a special breed; horses of many breeds, shapes and sizes have been released into the Alpine National Park and Barmah National Park over the years. If you wanted to protect a special breed you would keep horses fenced, not roaming wild.
• Perhaps the largest population of horses on the Bogong High Plains was during the First World War, where horses were bred before being sent overseas in various campaigns. Horses sent to war were not returned. Claims that feral horses in Barmah and the high country are direct descendants of horses sent to war are lacking in evidence.
• The idea that feral horses have been valued throughout recent history is also not backed up by evidence. Mountain cattlemen and others used to shoot horses because they competed with cattle for feed. Wild horses were generally seen as a pest. (Read 'Blinded to the real? from Park Watch, September 2019, pp.18-20)
• Elyne Mitchell’s brumby books were largely fantasies about talking animals. And The Man from Snowy River poem scarcely mentions wild horses; it’s about retrieving a prized stock horse that escaped from a farm, and stopping it from joining feral wild horses.

This has always been the first priority for captured horses, but very few horses have proved re-homeable.

• Many are old, diseased, underfed or otherwise in poor condition.
• There are limited numbers of good homes available for horses – certainly not for the 25,000+ horses involved.

Parks Victoria will still make suitable horses available for rehoming, if reliable good homes are available.

While feral horses do well under good conditions, when the weather turns bad (and alpine weather often turns bad) they have a very hard time. Horses can die after heavy snowfalls, die in bushfires and suffer terribly from starvation in periods of drought. A farmer who left horses to die in those circumstances would face prosecution.

In the past, Parks Victoria arranged for ‘brumby runners’ to catch feral horses, and rehome as many as possible.  Welfare experts considered that to be unnecessarily cruel, as most horses weren’t rehomed. Instead, having already been chased, roped and trucked out of the park on rough 4WD tracks, they were then trucked long distances to an abattoir.

Other management options include:

• Mustering by horses, motorcycles and/or helicopters to various types of trap yard. This is no longer used, as the rough terrain of much of the high country usually makes this ineffective.
• Passive trapping. In this method, horses are lured into traps using salt or other attractants. However, this is an ineffective way of dealing with large numbers of horses, especially in remote areas because the traps have to be tended and water has to be available. Also, many horses become trap-shy.
• Fertility control. This could be useful for a small contained mob. However, because contraceptive vaccines have to be delivered close to each horse, and because they have to be re-applied every few years, it’s considered an ineffective control method for large or remote populations. Even if successful, it will leave the current population in place for many years.
• Lethal ground shooting. Animal welfare organisations have said for many years now that shooting, done expertly under well-advised protocols, is a least stressful method of control.
• Lethal aerial shooting. This has been similarly considered by welfare experts and organisations to be a least stressful option. Opposition to culling has sometimes resulted in misinformation being spread; claims have been made that an aerial cull of horses in Guy Fawkes River National Park in 2000 resulted in many untended wounded animals. However, an independent report on the cull tells a different story.

Currently, Parks Victoria’s strategy for controlling feral horses is to have horses rehomed when possible. Otherwise ground shooting by professionals under strict protocols for animal welfare will be employed, as well as aerial shooting in more remote areas, or if ground shooting fails. This strategy is supported by animal welfare experts, including the RSPCA.

Horses will be removed entirely from smaller isolated populations such as the Bogong High Plains, and numbers reduced as much as possible in other much larger populations, such as those in the eastern alps.

Deer are another big problem. Deer, goats, pigs and many other feral animals cause harm to national parks, and all are treated in various ways by Parks Victoria and the Department of Environment, Land, Water and Planning. For example, after the Black Summer fires of 2019-2020, around 1,000 deer were shot from helicopters in eastern Victoria. Horses are far from the only animal being culled. All pest plant and animal programs should be more realistically resourced, so feral populations can be reduced to levels where damage is minimal, and maintenance costs are more manageable.

Yes, very thoroughly. Between 2010 to 2019, Parks Victoria ran a series of public consultation processes involving Brumby support groups, scientists, traditional owners, heritage authorities, animal welfare authorities, tourism organisations and environment groups. Throughout that process, all methods of horse control were discussed, most at great length.

Parks Victorian also ran consultation programs, with interest groups and the general public, on the development of three planning processes. All were made available for public comment.

• The Protection of the Alpine National Park Feral Horse Strategic Action Plan 2018-1021 (2017)
• The Greater Alpine National Parks Management Plan (2016)
• Protection of floodplain marshes. Barmah National Park and Barmah Forest Ramsar Site Strategic Action Plan 2020-2023 (2020)

And in 2020 the Yorta Yorta Traditional Owner Land Management Board, together with the Victorian Government, produced the Joint Management Plan for Barmah National Park. A draft of this plan was also made available for public comment.

All of the above plans strongly acknowledge the damage horses bring to natural systems and species, and all call for strong horse control. Parks Victoria is not required to consult on every change to its management of particular threats, especially when those changes are consistent with current management plans.

There are many laws that oblige Parks Victoria to control the impacts of horses in the Alpine National Park and Barmah National Park. That legal framework exists at an international, national and state level.

International treaty

The International Convention on Biological Diversity (CBD), which Australia signed in 1992 and ratified in 1993, obliges Australia to protect its biological diversity. In the extract below, we have selected a number of clauses from the Convention that most clearly relate to the management of feral horses in the alps.

Each Contracting Party shall, as far as possible and as appropriate:

(a) Establish a system of protected areas or areas where special measures need to be taken to conserve biological diversity;…

(d) Promote the protection of ecosystems, natural habitats and the maintenance of viable populations of species in natural surroundings; …

(f) Rehabilitate and restore degraded ecosystems and promote the recovery of threatened species, inter alia, through the development and implementation of plans or other management strategies; …

(h) Prevent the introduction of, control or eradicate those alien species which threaten ecosystems, habitats or species; …

(k) Develop or maintain necessary legislation and/or other regulatory provisions for the protection of threatened species and populations.

Notably, in regard to clause (a) above, the Alpine National Park fits within the International Union for the Conservation of Nature (IUCN) definition of a Category II protected area: a national park:

[National parks are] large natural or near natural areas set aside to protect large-scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Primary objective: To protect natural biodiversity along with its underlying ecological structure and supporting environmental processes, and to promote education and recreation.

As IUCN Director General Julia Marton-Lefèvre said, in November 2012:

“Simply put, large healthy protected ecosystems are the best tool we have to conserve biodiversity, especially against the backdrop of climate change. We are in the middle of a global extinction crisis, with rates of biodiversity loss up to 1,000 times above pre-human levels. Well managed protected areas are the most robust proven solution to turn the tide of extinction.”

Most of Barmah National Park is declared a protected wetland of importance under the international RAMSAR Convention. As such it is given additional protection under Australia’s Environment Protection and Biodiversity Conservation (EPBC) Act.

National legislation

Under the Federal Environment Protection and Biodiversity Conservation (EPBC) Act, the Alpine National Park has National Heritage listing as part of the Australian Alps National Parks.

The citation for that listing includes:

“The Alps are one of eleven sites recognised in Australia by the IUCN as a major world centre of plant diversity… The AANP is a vital refuge for alpine and sub-alpine flora and fauna species, with a high level of richness and endemism across a wide range of taxa, and therefore has outstanding value to the nation for encompassing a significant and unique component of Australia's biological heritage.”

Importantly, in the context of this submission, the citation also points out that:

“The AANP has outstanding heritage value for the scientific research that has taken place since the 1830s, demonstrated by the density and continuity of scientific endeavour.”

The significance of that scientific endeavour should not be underestimated, and certainly not ignored, in the development of a wild horse management strategy for the alps.

Under the same EPBC Act, Alpine Sphagnum Bogs and Associated Fens are listed as a nationally threatened ecological community. The policy statement for that listing can be found at:

www.environment.gov.au/epbc/publications/pubs/alpine-sphagnum-bogs.pdf

It lists one significant threat as “trampling, browsing and grazing by hard-hooved animals”, and the impacts as:

• Vegetation removal
• Compaction of soil and sphagnum moss
• Increased runoff and other changes to hydrology
• Accelerated erosion and exotic weed invasion

The statement continues:

“…significant threats to the Alpine Sphagnum Bogs and Associated Fens ecological community include exotic weed invasions, grazing and trampling by non-native animals…” and further

“…trampling by feral animals such as horses, deer, goats and pigs is a threat to the ecological community… In particular, sphagnum moss is easily crushed and broken up by trampling and wallowing. These activities cause channels to form in the disturbed sphagnum moss, resulting in erosion and changes to natural drainage patterns, which can ultimately lead to the bog drying out.”

And the statement specifies these management actions:

• Maintain fencing to prevent domestic stock from accessing areas known to contain the ecological community
• Implement existing management plans* for the control and eradication of feral non-native animals in alpine and subalpine regions
• Manage known sites to exclude non-native animals

*Note: the current management plan for the Alpine National Park (on p. 41) clearly says:

“Implement humane feral horse control in consultation with the community to:

• Prevent new populations of feral horses establishing across the planning area where they do not currently occur (Alpine NP)
• Remove isolated populations of feral horses where eradication is feasible (Bogong and Wonnangatta areas, Alpine NP)
• Contain and reduce feral horse numbers in core, larger populations in Alpine National Park to prevent spread and minimise impacts on high-value vegetation communities and fauna habitats (east alps, Alpine NP)
• Consider all control options and use the most humane and effective techniques, including lethal and non-lethal methods (Alpine NP)
• Cooperate with DELWP and NSW NPWS to remove populations from adjacent forest areas and Kosciuszko NP.”

According to the EPBC policy statement, the Federal listing of Alpine Sphagnum Bogs and Associated Fens is equivalent to a range of Victorian alpine Ecological Vegetation Classes (EVCs), including:

• EVC 171: Alpine Fen;
• EVC 210: Sub-alpine Wet Heathland
• EVC 221: Sub-alpine Wet Heathland/Alpine Fen Mosaic
• EVC 288-61: Alpine Valley Peatland (Raised Bog)
• EVC 288-62: Alpine Valley Peatland (Valley Bog)
• EVC 917: Sub-Alpine Wet Sedgeland
• EVC 1011: Alpine Peaty Heathland

State legislation

There are several important ways in which Victorian legislation calls for action on feral horses in the Alpine National Park, and other associated areas.

Firstly, and importantly, most of Victoria’s high country is given the protection of national park status under the National Parks Act, 1975.

The objects of the Act are:

(a)  to make provision, in respect of national parks, State parks, marine national parks and marine sanctuaries-

(i)  for the preservation and protection of the natural environment including wilderness areas and remote and natural areas in those parks;

(ii) for the protection and preservation of indigenous flora and fauna and of features of scenic or archaeological, ecological, geological, historic or other scientific interest in those parks; and

(iii) for the study of ecology, geology, botany, zoology and other sciences relating to the conservation of the natural environment in those parks; and

(iv) for the responsible management of the land in those parks;

Further, the Act requires the Parks Victoria to (among other things):

(a)  ensure that each national park and State park is controlled and managed, in accordance with the objects of this Act, in a manner that will-

(i)  preserve and protect the park in its natural condition for the use, enjoyment and education of the public;

(ii) preserve and protect indigenous flora and fauna in the park;

(iii) exterminate or control exotic fauna in the park;

(iv) eradicate or control exotic flora in the park; and

(v)  preserve and protect wilderness areas in the park and features in the park of scenic, archaeological, ecological, geological, historic or other scientific interest;

(aa) have regard to all classes of management actions that may be implemented for the purposes of maintaining and improving the ecological function of the park;

If there is any doubt that addressing the growing numbers of feral horses doesn’t fit with Parks Victoria’s obligations, especially those underlined in section (a) (iii) above, an FFG listing should end that doubt.

Victoria’s Flora and Fauna Guarantee (FFG) Act lists Degradation and Loss of Habitats Caused by Feral Horses as a ‘potentially threatening process’, the highest threat listing available under the Act.

The FFG listing cites two broad ways in which feral horses threaten, and continue to threaten, native habitats:

• Via direct consumption of native plants, in particular grazing impacts on threatened species and ecological communities, and
• Through degradation of natural habitat, including fouling of waterholes, accelerating gully erosion and trampling and consuming native vegetation. Of particular concern is the degradation of habitats important for the survival of threatened species and communities.

The listing adds:

“The environmental impacts of horses around the world are well documented, and include damage to riparian systems, erosion, pugging, soil drying, soil compaction, weed invasion, reductions in plant biomass, decreases in plant species richness and abundance, and reductions in ground-dwelling fauna.

“Notably, the FFG’s Scientific Advisory Committee (SAC) found that, in relation to alpine and sub-alpine areas, feral horse impacts significantly affected 10 federally and/or state-listed plant species, 13 federally and/or state-listed animal species, and four federally and/or state-listed communities.”

In a final note the SAC adds that:

“The survival and future evolution of the affected species and communities depends on appropriate management actions that will reduce local feral horse concentrations in the affected areas to levels that no longer pose a significant threat.”

In addition to the National Parks and FFG Acts, Victoria’s Catchment and Land Protection (CALP) Act 1994 sets unequivocal obligations for management of catchment condition, and pest management, across the state.

Among the objects of the CALP Act are:

• aim to ensure that the quality of the State's land and water resources and their associated plant and animal life are maintained and enhanced, and
• to provide for the control of noxious weeds and pest animals

Importantly, according to the CALP Act, the owner of any land is required to: “prevent the spread of, and as far as possible eradicate, established pest animals.” And in the case of national parks, the Act makes it clear that ‘the owner’ is: “the Director within the meaning of the National Parks Act 1975, for Crown land in a national park or park within the meaning of that Act.”

More about Parks Victoria’s feral horse management plans can be found on their website.

Parks Victoria's feral horse FAQs