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Fire regimes that cause biodiversity decline

This submission responds to the draft proposal to list adverse fire regimes as a key threatening process under the national EPBC Act. 

The Invasive Species Council and Bush Heritage Australia welcome the advice by the Threatened Species Scientific Committee (TSSC) to finally list ‘Fire regimes that cause biodiversity decline’ (adverse fire regimes) as a key threatening process (KTP). We commend the TSSC on the quality and comprehensiveness of the KTP assessment. 

We strongly endorse the listing of this KTP – not only because it clearly meets the criteria under the EPBC Act and is one of Australia’s major environmental threats, but because it interacts strongly with other threats, including invasive species such as invasive pasture grasses, predators and ungulates and climate change. Our organisations also have a strong interest in strengthening the threat abatement system, including through comprehensive listing of KTPs. As the first potential listing of a KTP for many years, the adverse fire regimes KTP provides an opportunity to implement an exemplary planning process, and to potentially link with regional planning processes proposed in the Samuel review of the EPBC Act. 

In this submission, we address the question of whether there should be a national threat abatement plan (TAP) to address the threat of adverse fire regimes. 

Given the national significance and complexities of this threat, there can surely be no doubt that some national plan or strategy to abate this KTP is warranted, noting: 

● The scale of the threat is vast, impacting most terrestrial ecosystems. 

● The intensity of the threat is extremely high, impacting hundreds of threatened species and ecological communities. 

● The needs and opportunities for national coordination and leadership are also very high given the evident gaps in current abatement efforts and the shared challenges across jurisdictions. 

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Save the Snowies

The NSW government is one step away from allowing aerial control of feral horses in Kosciuszko National Park. This is huge news and a crucial step for our threatened native wildlife and the fragile alpine ecosystems they call home.

Dear Project Team,

[YOUR PERSONALISED MESSAGE WILL APPEAR HERE.] 

I support the amendment to the Kosciuszko National Park Wild Horse Heritage Management Plan to allow our incredible National Parks staff to use aerial shooting as one method to rapidly reduce feral horse numbers. I want to see feral horse numbers urgently reduced in order to save the national park and our native wildlife that live there.

The current approach is not solving the problem. Feral horse numbers have rapidly increased in Kosciuszko National Park to around 18,000, a 30% jump in just the past 2 years. With the population so high, thousands of feral horses need to be removed annually to reduce numbers and stop our National Park becoming a horse paddock. Aerial shooting, undertaken humanely and safely by professionals using standard protocols, is the only way this can happen.

The government’s own management plan for feral horses states that ‘if undertaken in accordance with best practice, aerial shooting can have the lowest negative animal welfare impacts of all lethal control methods’.

This humane and effective practice is already used across Australia to manage hundreds of thousands of feral animals like horses, deer, pigs, and goats.

Trapping and rehoming of feral horses has been used in Kosciuszko National Park for well over a decade but has consistently failed to reduce the population, has delayed meaningful action and is expensive. There are too many feral horses in the Alps and not enough demand for rehoming for it to be relied upon for the reduction of the population.

Fertility control as a management tool is only effective for a small, geographically isolated, and accessible 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 large and growing feral horse population in the vast and rugged terrain of Kosciuszko National Park.

Feral horses are trashing and trampling our sensitive alpine ecosystems and streams, causing the decline and extinction of native animals. The federal government’s Threatened Species Scientific Committee has stated that feral horses ‘may be the crucial factor that causes final extinction’ for 12 alpine species.

I recognise the sad reality that urgent and humane measures are necessary to urgently remove the horses or they will destroy the Snowies and the native wildlife that call the mountains home. I support a healthy national park where native species like the Corroboree Frog and Mountain Pygmy Possum can thrive.

Kind regards,
[Your name]
[Your email address]
[Your postcode]


Dear Project Team,

[YOUR PERSONALISED MESSAGE WILL APPEAR HERE.] 

I support the amendment to the Kosciuszko National Park Wild Horse Heritage Management Plan to allow our incredible National Parks staff to use aerial shooting as one method to rapidly reduce feral horse numbers. I want to see feral horse numbers urgently reduced in order to save the national park and our native wildlife that live there.

The current approach is not solving the problem. Feral horse numbers have rapidly increased in Kosciuszko National Park to around 18,000, a 30% jump in just the past 2 years. With the population so high, thousands of feral horses need to be removed annually to reduce numbers and stop our National Park becoming a horse paddock. Aerial shooting, undertaken humanely and safely by professionals using standard protocols, is the only way this can happen.

The government’s own management plan for feral horses states that ‘if undertaken in accordance with best practice, aerial shooting can have the lowest negative animal welfare impacts of all lethal control methods’.

This humane and effective practice is already used across Australia to manage hundreds of thousands of feral animals like horses, deer, pigs, and goats.

Trapping and rehoming of feral horses has been used in Kosciuszko National Park for well over a decade but has consistently failed to reduce the population, has delayed meaningful action and is expensive. There are too many feral horses in the Alps and not enough demand for rehoming for it to be relied upon for the reduction of the population.

Fertility control as a management tool is only effective for a small, geographically isolated, and accessible 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 large and growing feral horse population in the vast and rugged terrain of Kosciuszko National Park.

Feral horses are trashing and trampling our sensitive alpine ecosystems and streams, causing the decline and extinction of native animals. The federal government’s Threatened Species Scientific Committee has stated that feral horses ‘may be the crucial factor that causes final extinction’ for 12 alpine species.

I recognise the sad reality that urgent and humane measures are necessary to urgently remove the horses or they will destroy the Snowies and the native wildlife that call the mountains home. I support a healthy national park where native species like the Corroboree Frog and Mountain Pygmy Possum can thrive.

Kind regards,
[Your name]
[Your email address]
[Your postcode]