Victoria's new draft feral horse management plan, released on the last working day before Christmas, will be open for comment until February 2. But will it protect the Alpine National Park? The answers are yes on the Bogong High Plains, and no in the eastern Alps.
The government deserves congratulations for planning to remove all horses from the most sensitive alpine areas around Falls Creek by 2020. These areas of the Bogong High Plains have fewer than 100 horses, but also rare snow-patch and bog communities that are extremely vulnerable.
But elsewhere, the goal of removing 400 horses a year from the eastern Alps doesn't seem to go far enough. And by refusing to countenance the idea of culling, the state government is passing up the only realistic chance of getting feral horse numbers under control.
The bulk of the plan provides grounds for cautious optimism. It acknowledges that feral horses threaten a range of native mammals, frogs and lizards, as well as displacing kangaroos and wallabies. Horses have enormous impacts on vegetation in alpine bogs and streams, and in many other ecosystems too.
The plan also makes clear that reducing horse numbers is a legal requirement. Victoria's Flora and Fauna Guarantee Act 1988 lists "degradation and loss of habitats caused by feral horses" as a threatening process. The Victorian National Parks Act 1975 calls for "exotic species" such as horses to be exterminated or controlled within national parks.
The plan also sets a realistic time frame for review (annual reviews and major review after three years), and suggests that management plans will be altered if adequate environmental protection is not achieved. All of this is extremely promising, suggesting the state government is genuinely interested in delivering tangible environmental benefits.
But while the aspirations are good, the details present some problems. The draft plan promises to "explore all possible control options" to deliver a low horse population in the eastern Alps.
But the proposed reliance on trapping and removal, rather than culling, suggests the government is reluctant to enter what would be a tough debate against the often vocal pro-brumby lobby groups. This reluctance is to the detriment of our native species and apparently at odds with legislation.
The problem is that the New South Wales government has already tried trapping and removing horses in Kosciuszko National Park, and it hasn't worked. Horses have continued to spread northward onto the main range, where environmentally sensitive alpine tarn and snow-patch communities occur.
It is unclear whether Victoria's "aspirational goal" of removing 400 horses each year over three years will actually be enough to reduce horse numbers, or even to stabilise them. The report mentions modelling showing that the population can be stabilised by taking 200 horses per year, and that it would start to decline if 400 were taken per year.
But none of this modelling is published, so it can't be evaluated in detail. And simple calculations suggest that these figures are incredibly optimistic.
The report says there were 2,350 horses in the eastern Victorian Alps in 2014. Horse populations can increase at up to 20% per year, so by now there could be more than 4,000 feral horses.
This means that even if the government does manage to remove the full quota of 400 horses each year, it would only take a 10% population growth rate for the numbers to keep rising. At a rate of 20%, there could be well over 5,000 horses by 2020, even with trapping and removal.
Based on this rough calculation, the plan needs to eradicate many more horses. The draft plan claims that feral horses in the eastern Alps are "well established and are considered beyond eradication using currently available control tools". Yet this claim ignores aerial culling, which is the cheapest, most effective, and most ethical way to reduce feral horse numbers.
Highly trained sharp-shooters and helicopter pilot teams can destroy more than 50 horses per day (based on previous culls in NSW, in which three teams of three people destroyed 606 horses over three days). Three teams could solve the feral horse problem in the Victorian alpine country in a month, and at lower cost.
It cost taxpayers more than A$1,000 for each horse trapped and removed from Kosciuszko National Park. Using the NSW cull as a guide to the resources required, and assuming A$300 per day per person, and A$10,000 per day per helicopter, it might have cost around A$150 per horse using aerial culling. That's roughly 15% of the cost of trapping and removal.
Despite the risks to wildlife canvassed in the draft plan, and similar reports from NSW, there is no peer-reviewed research that defines the threats to native animals. A revised plan must include research to understand both the impacts of feral horses on native animal populations and their welfare.
The debate over culling horses typically ignores the unseen suffering that horses cause to native animals. Quantifying that suffering will be crucial for making informed decisions around feral horse management.
It is great that we have a plan for managing horses in the Victorian Alpine National Park – albeit one that seems unlikely to work in the eastern Alps. But the Victorian government needs to show courage and leadership on the issue of culling feral horses. Our alpine natural heritage will continue to decline until horses are taken out of our national parks, and that will only happen when managers can include culling among their suite of management tools.
In NSW, the feral horses in Kosciuszko National Park are growing in number, and doing real damage to Australia's highest mountains. Hopefully both states can take back the reins of feral horse management from single-issue lobby groups and exercise some real control over their feral horses.
Explore further: Humane effective feral horse control essential for Kosciuszko