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Thank-you for considering my submission, and not listing Brumbies and Walers as a cause of habitat destruction, which they are clearly not. The evidence provided in the Preliminary Determination is weak, incorrect, biased and unfounded. 1. (1) I totally refute the use of the word “Feral” when discussing the impact of the species of animal with the recognised scientific name of Equus caballus, commonly known as Horses. I recognise that the Preliminary Determination is referring to Horses that live in the wild in publicly owned and managed areas of land within NSW. The colloquial term used in Australia for these Horses is Brumby or Brumbies, and Waler or Walers. The use of the term “Feral” to describe these wild-living horses in Australia is offensive, and racist towards the many Australians descended from Early Settlers who brought with them, the ancestors of the surviving wild horse populations in Australia. 1. (2) Wild horses in Australia including the Brumbies and Walers are protected through the International legislation to which Australia is a signatory, the Convention on Biological Diversity, United Nations, 1992. The following points from the Convention on Biological Diversity support this. Principles underpinning the Strategy • We share the Earth with many other life forms that have intrinsic value and warrant our respect, whether or not they are of benefit to us. "Biological diversity" means the variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part: this includes diversity within species, between species and of ecosystems. "Country providing genetic resources' means the country supplying genetic resources collected from in~situ sources, including populations of both wild and domesticated species, or taken from ex-si tu sources, which may or may not have originated in that country. "In-situ conservation' means the conservation of ecosystems and natural habitats and the maintenance and recovery of viable populations of species in their natural surroundings and, in the case of domesticated or cultivated species, in the surroundings where they have developed their distinctive properties. Noting that, ultimately, the conservation and sustainable use of biological diversity will strengthen friendly relations among States and contribute to peace for humankind, and Determined to conserve and sustainably use biological diversity for the benefit of present and future generations The Australian Brumby is a recognizable population of a species that have evolved over the past 200 years at various specific locations within Australia including in the Australian Alps of NSW. They are distinct and recognisable populations and sub-populations. The natural environment areas in which the Brumbies live have also continued evolving over the past 200 years, including the Brumby as an important component of the ecosystem. 1. (3) The listing of the Horse Equus caballus as being responsible for habitat destruction will lead to wholesale slaughter of these animals, for the satisfaction of a minor current section of the Australian community, but to the detriment of the majority of Australian people, who would be very grief- 1 stricken with the loss of these Horses. Their loss will affect future generations of Australians, who deserve the opportunity to appreciate the ongoing future existence of these Horses in the wild. In response to the 15 points listed in the Preliminary Determination: 2. (1) Horses have been a part of the Australian environment since 1788, when horses from Great Britain arrived on the First Fleet with the first European inhabitants of Australia. Wild Horses in Australia are descended from and related to domesticated breeds and are known as Brumbies. They live in a variety of public land tenures across Australia. This response is regarding the Preliminary Determination associated with Brumbies located in NSW. 2. (2) Brumbies are descended from a variety of domesticated breeds including Draught Horses, Arabian and Thoroughbred stock. Brumbies are resilient animals and have adapted to the environmental conditions in which they live in NSW. They are attractive animals, particularly in the wild. Due to the dispersed locations of public land where they are found, they have formed distinct and recognisable populations and sub-populations. 2. (3) Wild Horses, known as Brumbies are located in various locations within NSW. Recent data indicates that there are 10,000 wild horses across NSW. NSW has an area of 809,444 square kilometres, which means there are about 1 Brumby per 80,000 square km. 2. (4) Brumbies are herbivores, and graze along-side the native fauna of Australia including kangaroos and wallabies. Brumbies form social groups. 2. (5) Brumbies breed in sync with environmental conditions, and are less likely to bear offspring in times of drought. 2. (6) Brumbies and most horses prefer flat open grassy areas. The main ranging lands of Brumbies within the Alps of NSW are the Alpine Herbfields and Grasslands which are neither Threatened, Endangered or Vulnerable. These vegetation communities are abundant and resilient, in very good condition considering Brumbies have been a part of the Alpine environment since the 1830’s. 2. (7) Brumbies exist in the NSW Alpine areas at a very low stocking rate. Their impact as grazing animals in the High country is negligible. The most abundant water sources horses access are easily accessible open streams, man-made water channels and water bodies. They do not seek out boggy and puggy country, preferring to avoid those areas as any horse-rider knows. Where there is abundant grass to eat, they do not ring-bark trees, particularly the abundant, unpalatable Snow Gums of the High Country. 2. (8) The Anemone Buttercup is under most threat from Ski Slope Development. The Ginini Flats known habitat of the Northern Corrobboree Frog are in the ACT and so are not relevant to this PD. As stated in point 7, horses prefer to drink from open streams, not the swampy boggy habitat of the species listed. 2 2. (9) The two lovely furry species, the Mountain Pygmy Possum and the Broad Toothed Rat, are both found within the ski resort areas of NSW, which are not the grazing rangelands of the Brumbies. Although climate change is a very worrying occurrence for the Alpine environments, it is not caused by Brumbies. Any animals that are being negatively impacted or caused to become extinct by climate change, are going to be effected regardless of Brumbies. 2. (10) Brumbies have been a part of the Australian environment for over 200 years and have become a naturalised part of the environment in which they live. They were brought into this country just as the Dingo was brought to Australia around 4000 years ago and has become naturalised and is considered a native species. Horses are herbivores and their impact on Australian biodiversity is negligible compared to the carnivore Dingo which caused important species of Australian mammals into extinction, in particular both the Tasmanian Tiger and the Tasmanian Devil on mainland Australia, and countless unknown smaller mammals. 2. (11) This Preliminary Determination is regarding horses in NSW, not Victoria. 2. (12) Refer to Table 1 Analysis of claims of the effect of Horses on Endangered Ecological communities. The listing of these 5 communities as under threat from Horses is wrong. The majority of these communities are not favoured habitat by horses and are not commonly accessed. This is particularly so with the Windswept Feldmark a rocky and sparsely vegetated area. As horses generally prefer flat open grassy areas, the Bogs, Peatlands and Swamps mentioned are not favoured preferential habitat of horses. The Tablelands Woodland community is mostly located on private property and State Forest, and therefore not highly or exclusively effected by wild horses. NSW State forests are working forests and must accommodate a range of recreational activities, primary production such as grazing and apiary, and timber harvesting. The Forestry Corporation of NSW (FCNSW) carefully balances community access and environmental management with operations to supply timber to the NSW economy, and recreational hunting is a mutually beneficial part of this balance. Paling Yards - On the edge of the Paddy River, lush green open flat in the high country plains is very popular with horse riders, mountain bike riders, fishermen, families and general campers. Very high usage in summer months. (Bago State Forest). 2. (13) The Preliminary Determination lists 23 species of Flora which it is claimed are adversely affected by horse grazing. 22 of these 23 species are orchids, daisies and , grasses and sedges. There is one woody shrub within the list. Of the 22 ground flora mentioned, one is not located in NSW, 3 are not relevant as they are in the Data Defficient Stream with insufficient knowledge, two burr daisies are in fact spread by grazing animals, the Carex species are in bogs not conducive to horses grazing, the Feldmark grass is under most threat from bushwalkers, the Greenhood and Leek Orchids (7) are under most threat from rooting pigs. Wallabies, not horses love to eat minute orchid flower stems amongst leaf litter. Of the 23 flora species listed, not a single species is under dire threat from the exclusive grazing of horses. To generalise as has been done in this PD is unscientific and biased. Refer to Table 2 “Analysis of claims of the effect of Horses on Plant Species”. 3 2. (14) The Preliminary Determination lists 7 species of Fauna which it is claimed are adversely affected by horse grazing. Of these (2) are not listed or located as being in NSW, the Spiny Crayfish and Latham’s Snipe. The 2 furry mammals are mostly located within the ski run areas, not the Brumby grazing lands. The 2 Corrobboree Frogs are under most threat from the Chytrid Fungus, which is most unfortunate but is not related to horse grazing.

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