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Submission to the Review of the National Environmental Biosecurity Response Agreement (NEBRA)

A submission to the independent review of Australia’s National Environmental Biosecurity Response Agreement (NEBRA) in response to a call for comments on a discussion paper in January 2017. The submission was submitted in March 2017 and endorsed by 21 state and national conservation, industry and natural resource management organisations.

The submission identifies as the highest priorities for reform the process for decision-making under NEBRA to optimise the public interest. These include automatic triggering of NEBRA for priority organisms, majority instead of consensus decision-making, an emergency response fund, and meaningful involvement of environmental stakeholders and environment departments. Outbreaks of national environmental significance should always be considered under NEBRA (rather than the Emergency Animal Disease Response Agreement (EADRA) and the Plant Pest Response Deed (EPPRD) ) and no industry body should have a right under any agreement to veto an eradication. The proposed Environment Health Australia or equivalent is needed to undertake the preparatory work for effective responses to outbreaks, and an environmental body or committee with ecological expertise is needed to inform decision-making under NEBRA.

Mechanisms to foster transparency and accountability, such as a requirement to publish all decisions and information relied on, are vital for decision-making in the public interest. The NEBRA criteria (as well as those under EADRA and EPPRD) should be revised to reflect Australia’s environmental obligations and the characteristics of environmental invasions, including application of the precautionary principle, removal of the requirement for eradications to be cost beneficial and extension of NEBRA to outbreaks where existing outbreaks are contained and have a low risk of spread.

Attached to the submission was our proposal for Environmental Health Australia.

The submission was endorsed by Arid Lands Environment Centre, Australian Marine Conservation Society, Australian Network for Plant Conservation, Bush Heritage Australia, Conservation Council ACT Region, Conservation Council SA, Environment Centre Northern Territory, Gene Ethics, Humane Society International, Island Conservation, Kuranda Envirocare, National Parks Association of NSW, National Parks Association Queensland, National Parks Australia Council, Nature Conservation Society of SA, Northern Gulf Regional Management Group, Queensland Conservation Council, Vertebrate Pest Managers Association Australia, Victorian National Parks Association, Wildlife Queensland and WWF-Australia.

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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]