Below is Andrew’s response to the proposal to allow aerial culling in the KNP.

The proposal is here.

You can respond in several ways:

  • complete the online survey
  • email to npws.submissions@environment.nsw.gov.au
  • post to The Project Team, Kosciuszko National Park Wild Horse Heritage Management Plan
    National Parks and Wildlife Service
    PO Box 472
    Tumut NSW 2720
  • via the online submission at the bottom of the proposal page, linked to above.


Amending the Kosciuszko National Park Wild Horse Heritage Management Plan:
Public Consultation

To Whom It May Concern

I wish to object in the strongest possible terms to the proposal to allow aerial culling of brumbies in the national park. I think this is nothing short of government-sanctioned cruelty, and it is completely unacceptable.

I find the proposal objectionable on several grounds:

  • It is a cruel way to kill. It is extremely difficult to get clean shots of moving horses from a moving helicopter. It does not matter how skilled your killers are, over the numbers of horses you are talking about killing, inevitably many will not be felled by a single shot. This means that they will suffer.It is unfathomable to me that this has been sanctioned by the RSPCA, an organisation that is supposed to represent the welfare of animals. There’s a reason that the Labor Government under Bob Carr put the restrictions in place. The nation watched in horror at what happened to the Guy Fawkes horses when they were cruelly killed from the air, and the government agreed with the public, “Never again.” Yet, here we are talking about it in 2023. It was unacceptable then, and it is unacceptable now.
  • The population numbers are faulty. My understanding from talking numerous sources, including MLA Emma Hurst (Animal Justice), is that the brumby count is nowhere close to the 18,814 cited by the proposal, nor the range of 14,000 and 23,000 cited in the media (example: https://www.news.com.au/technology/science/animals/nsw-environment-minister-proposes-aerial-shooting-to-cull-horses-in-kosciuszko-national-park/news-story/5f672f397a3b7734c381b681e86fdc5d)Ms. Hurst, and many brumby advocates who live down in the region have undertaken their own efforts to find the horses in question. The numbers they found were in the hundreds, maybe 1,000. But it was an order of magnitude fewer than what is cited by the proposal, and well below the 3,000 that are supposed to be allowed to live there under current guidelines.This has been exacerbated by the fact killing has already taken place, and that numbers were thinned during the bush fires.Therefore, the more appropriate step is to put a halt to the current killing, and undertake a revised survey with a methodology that doesn’t estimate, but actually counts the horses on the ground.
  • The impact claims are dubious. It would seem that the impact of humans on the KNP far exceeds the impact caused by the horses. Further, the proposal cites the “negative interactions with park visitors, including vehicle strikes and aggressive horses in and around campgrounds.” First of all, horses are prey animals, not predators. They run from people, not toward them. If they are being aggressive (and I doubt this), then it is because they are being provoked. Also, the assumption that the humans have a right to camp there, but the horses don’t have the right to live their lives is an arrogance.The proposal says, “Wild horses can cause direct or indirect damage to [Aboriginal cultural heritage] sites through trampling, grazing, and erosion.” Yes, they could, in theory. But no evidence is given that they actually do it. Have they? How many instances have there been of this? How does it compare to the human impact on those same sites?The proposal sites a 2018 study that “determined habitat degradation and loss by feral horses as a key threatening process, identifying more than 30 adversely” affected species. First of all, that is more than half a decade old now, so does not necessarily represent the current situation. Second, I again would ask that we consider the human impact by direct comparison. The fungus affecting the corroboree frog, for example, is not the fault of the horses. It is the fault of humans. It is humans who cause habitat degradation much more, and it is humans who have a far greater impact. From what i can see, the horses are being scapegoated for the acts of people.
  • The suffering is unwarranted. I believe that the government should take a more compassionate, animal-focussed approach. If there is horse management to be done, then let it be done in a way that does not cause such undo suffering. Horses killed in the way that this proposal suggests are subject to not just the pain of bad shooting and multiple shots, but the mares can abort from the stress, and foals are left to starve and die when their mothers are killed. This really is unconscionable.The proposal states that rehoming efforts are inadequate to the task. I question that deeply. This seems be a simple failure of will. How about the government asks the question, what would it take to encourage more people to take on brumbies? How about money? Take some of the thousands and thousands of dollars it plans to spend on helicopters, killers, and bullets, and it puts that money toward kindness and compassion. Support people financially who put their hands up to take on a horse or two or three. I bet you’d find that there’d be an uptick in interest from vetted individuals and sanctuaries.

With all of this in mind, I encourage the government to immediately stop considering this proposal, to implement the suggestions made above, and to focus on a more holistic, kind approach to the concerns about horses, not one centred on cruelty.

Please feel free to reach out if you have any questions.


Andrew Einspruch
Braidwood, NSW