Submitted on behalf of the undersigned organisatons, professionals, and community stakeholders.
To:
The Chief Executve, NSW Natonal Parks and Wildlife Service Cc: The Premier of NSW
Minister for the Environment
Shadow Minister for the Environment Members of the NSW Parliament
Request for Immediate Suspension and Independent Review of Proposed Aerial Shooting Operations in Kosciuszko National Park
Dear Sir/Madam
We write regarding serious concerns surrounding the proposed aerial shooting operations targeting wild horses in Kosciuszko National Park scheduled for next month.
This correspondence seeks the immediate suspension of the proposed operations pending independent review and greater public transparency regarding a number of unresolved issues.
These concerns include:
• Serious animal welfare and cruelty concerns associated with aerial shooting in mountain areas, including reports from local observers of wounded horses, prolonged suffering outcomes, and other evidence allegedly inconsistent with humane destruction standards;
• Continued reliance on extremely disputed survey methods and population modelling to justify ongoing aerial shooting operations, including the application of assumed detection rates resulting in up to 90% additional unseen horses being added to final population estimates;
• Lack of transparency regarding raw survey data, operational records, welfare monitoring outcomes, and related evidence despite repeated requests and GIPA processes, together with an ongoing failure by NPWS and Government representatives to respond to stakeholder correspondence and community concerns;
• Concerns regarding operational shooting procedures developed specifically for Kosciuszko behind closed doors, including procedures permitng multiple shots and prolonged suffering outcomes, which were not available for the public exhibition periods and remain unavailable for full public scrutiny today;
• Failure to implement independent welfare monitoring measures despite recommendations and concerns raised by the RSPCA regarding excessive chase times, pursuit stress, the chasing of horses away from waterways prior to shooting, and the refusal to install camera monitoring systems to independently assess animal welfare outcomes and compliance with humane destruction standards;
• Failure to properly assess, trial, or publicly justify non-lethal alternatives identified within the Plan of Management prior to using lethal control operations, including mustering methods which remain listed as approved management option despite never being trialled, while public statements have been made claiming all non-lethal methods had already been exhausted;
• Inconsistencies between current operations and NPWS own scientific committees’ advice stating that management actions should be based on demonstrated adverse environmental impacts rather than population numbers alone;
• Failure to properly consider the recognised heritage significance of wild horses previously acknowledged through government-commissioned heritage assessments, advisory processes, and earlier statutory protections under the former Kosciuszko Wild Horse Heritage Act 201ti.
Additional concern also arises from the failure to publicly disclose annual review processes that is a requirement under the current Plan of Management governing aerial shooting operations. These review requirements are important safeguards intended to assess animal welfare outcomes, operational risks, procedural effectiveness, and compliance standards.
Failure to properly address the serious animal welfare concerns previously identified during the Guy Fawkes River National Park aerial shooting program, where horses were reportedly found alive and suffering with multiple gunshot wounds, resulting in RSPCA prosecution action against NPWS and a permanent ban on aerial shooting by the then Minister for the Environment. Serious concern now arises that the new procedures developed specifically for Kosciuszko appear similar in protocol, while effectively legalising many of the same outcomes that previously occurred during the Guy Fawkes aerial shooting operations;
The continuation of aerial shooting operations while these matters remain unresolved and under active public and parliamentary scrutiny raises serious concerns regarding governance, accountability, and public confidence.
Accordingly, we respec1ully call on NSW National Parks and Wildlife Service to immediately:
1. Suspend all proposed aerial shooting operations pending independent review;
2. Provide a clear public explanation and independent review of the survey methodology and population modelling relied upon to justify continued lethal control operations, including how estimated horse numbers reportedly increased from approximately 4,000 to more than 10,300 within a single year;
3. Commission genuinely independent scientific and animal welfare oversight of future management activities;
4. Engage transparently with stakeholders regarding lawful, humane, and evidence-based alternatives.
This correspondence is provided in good faith and in the public interest.
Many people hold differing views regarding wild horse management. However, regardless of position, transparency, humane treatment, independent oversight, and evidence-based decision- making should be matters of concern to all members of the community.
We respectfully request that the concerns raised in this correspondence be properly considered and addressed in the interests of transparency, accountability, animal welfare, and public confidence.
This correspondence is supported by the undersigned individuals and organisations representing heritage, welfare, scientific, tourism, and community interests.
Yours faithfully,
Save the Brumbies Inc.
The Shadow Minister’s response to Leisa’s letter is as follows:
