The Honourable Lily D'Ambrosio The Honourable Lisa Neville
Minister for Energy, Environment Minister for Water
and Climate Change
Both Level 17, 8 Nicholson St, East Melbourne 3002 23 August 2016
First the Reef – Now the Alps
Eastern Alpine National Park is dying, and Victoria is doing nothing about it.
Feral horses are not only destroying the Alps fragile ecology, plant and animal communities, but the ability to provide a reliable source of water via the slow release of clear, pure water.
[The Australian Alps produce 29% of the Murray Darling’s water, worth about $9.6 billion p.a. As well, since the Snowy River’s diversion as part of the Snowy Scheme, the south eastern slopes of the Eastern Alps are the principle source of its water.]
In a time of climate change, can we afford to ignore this degradation of our major water resource?
Dear Ministers
This is an open letter to you, written with the approval and support of the Gippsland Environment Group, the Australian Native Orchid Society, and the Friends of the Cobberas.
Roger Bilney’s letter to Lisa Neville of 11 January 2016, and Bill Kosky’s letter of 23 April 2008 to Gavin Jennings, both requesting action to deal with feral horses that are destroying the values of the Alpine National Park (Eastern, Cobberas/Snowy, Regions) were referred to Parks Victoria.
The similar, standard, departmental responses 8 years apart advised that a Management Plan to deal with the acknowledged feral horse problem was being prepared, and its adoption was imminent. Eight years later there is no sign of any such plan.
Our regular visits to the eastern parts of the Alpine National Park go back 35 years. We both noticed a rapid increase in feral horse numbers after the 2003 fires. This increase was accompanied by the steady destruction of the National Park values that the Secretary (DELWP) is required by the National Parks Act to protect and conserve, and for which, you as the relevant Ministers have ultimate responsibility.
We both served on the Victorian Alps Wild Horse Management Plan Round Table Group a diverse group whose well-considered advice provided to Parks Victoria in 2013, has not been acted upon.
The objectives of the National Parks Act are to inter alia preserve protect and manage the natural environment and the indigenous flora and fauna of our National Parks.
Section 17 (2) The Secretary shall, subject to this Act—
(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;
As early as 2006, significant damage was being observed by visitors to the park, and Bill raised this issue with Parks Victoria, and personally with the then Minister John Thwaites (who retired soon after). And it is not just us. The Victorian National Parks Association (VNPA), a host of concerned groups, scientists, and other individuals, have complained about Parks Vic and its Political Master’s lack of action on this issue.
The 2010 the report of the Auditor General found that:
Several reports, ……. have made it clear that Victoria’s biodiversity is in poor condition and declining in most areas. Invasive plants and animals are a major contributor to that decline, and can have substantial economic, environmental and social impacts on parks.
Governance arrangements for the control of invasive species across the state are complicated and not well coordinated. There is no single point of focus for oversight or for the responsibility of success or failure. How well Parks Victoria manages the invasive plant and animal threat in national and state parks is generally unclear. Its planning is not robust,……. its park management plans are also outdated and lack sufficient detail. ………..
Given the scale of the problem, if these organisational issues and resource constraints are not addressed, invasive species will continue to pose a major and likely growing threat to Victorian parks.
The Auditor General’s recommendation 5 stated [our underlining]:
Parks Victoria should improve its park-level planning so that:
• all national and state parks have current park management plans …
• specific actions to manage the threats, including targets, performance indicators, monitoring standards and responsibilities for implementing these activities are clearly documented.
The 2010 response by the Secretary to this recommendation was;
DSE is commencing the development of a forest and parks planning ……… The plans will align with the aspirations of government invasive species policy, and will address priorities for early intervention and asset protection at scales appropriate to the desired outcome.
Now 6 years later Parks Victoria’s promised “early intervention” to deal with feral horses, is yet to see the light of day. And when it does, can one expect it will be followed by another round of the endless consultation and review that has been conducted since 2008?
In preparing successive versions of proposed Park and Horse Management Plans, Parks has assembled a massive body of scientific evidence as to the damage being done to these once pristine and delicate alpine ecosystems. Such as the 2015 Feral Horse Impacts Report. Parks has developed detailed options for actioning effective control measures. But this evidence is not acted on, and no effective control activities, undertaken.
As a result, the feral horse has become the dominant species to the detriment of all native plants and animals and ecological function. The Secretary’s and Parks Victoria’s procrastination on this issue is appalling given that: Alpine Sphagnum Bogs and Associated Fens are listed as endangered under the Environment Protection and Biodiversity Conservation Act; and protected under the Flora and Fauna Guarantee Act; as are many of the plants and animals they support; and, that the FFG Act lists habitat degradation by Feral Horses as a potentially threating processes.
As stated in Roger’s recent letter, the damage this animal has done in the past 12 months is astounding. We have noticed a significant decline in the condition of the mares during last winter and expect there will be a population crash in the Cobberas and Snowy River Box Woodland areas of the Eastern Alps, either this winter, or certainly by the winter of 2017, with the corresponding environmental damage probably being beyond recovery. This will also create a major issue of how to manage emaciated animals, and efforts by horse sympathisers to feed them, and the public relations disaster that will follow. This prediction is not without precedence, as this is what occurred in the Snowy Valley at the end of the drought from 1979 to 1983, where all the horses died of starvation.
Sadly, feral horses have moved beyond being a threat to the values of the Alpine National Park. The large, unsustainable, populations in the Eastern Alps are now destroying those values. There is heavy grazing, trampling, compacting and horse dung. The once pristine snow plains, fens, marshes, sphagnum bogs, forests, and the plant and native animal communities they support, are now suffering from severe, and perhaps irretrievable, horse damage. The place has the appearance, and smell, of a heavily grazed horse paddock.
When in good condition, the Alpine fens, bogs and meadows, together with aquifers and springs, act like a giant sponge to retain rain and snowmelt which is slowly released to provide a year round reliable source of pure water to the Murray-Darling and depleted Snowy River systems. Horses negatively impact the very source of this water by destroying and draining the Alpine fens and bogs, damaging stream edges, altering stream flow, and creating erosion, turbidly, wash out, and pollution.
And it is all happening on Labour’s watch!
Leaving the currently large population of horses there is not humane, as they will suffer greatly each winter, and it is also extremely damaging to alpine and sub-alpine ecosystems.
Please put the values of these precious alpine places first, by ensuring effective action to deal with the terrible feral horse problem.
Yours faithfully
Roger Bilney
And on behalf of
Gippsland Environment Group
PO Box 988 Bairnsdale 3875
Bill Kosky
And on behalf of
Australian Native Orchid Society; and
Friends of the Cobberas
22 Harold Street, Middle Park 3206