Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Planning Evaluation and Assessment
PO Box 95
Parramatta NSW 2124


Dear Sir/Madam

Horse riding in wilderness: proposed amendments to plans of management

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and has many members in surrounding New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

The primary function of Kosciuszko National Park is for conservation of Australia’s unique natural heritage and for the many ecosystem services it provides to the broader Australian community. Many of its values are already under threat. It is ironic that the current proposal should be out for public comment at much the same time as the NSW Threatened Species Scientific Committee released final determinations on Snowpatch Feldmark and Snowpatch Herbfield in the Australian Alps Bioregion as critically endangered ecological communities, and also a preliminary determination of Habitat degradation and loss by feral horses (Equus caballus) as a key threatening process.

Shortness of trial

We would argue that a short trial of a couple of years is not long enough to assess adequately some impacts. In particular, it is not sufficient time to assess whether or not there is an increased spread of weeds from horse riding or, with the accumulation of dung, an alteration in or loss of native species due to increased nutrient loads. As time goes on, the horse riding traffic will almost certainly increase, which will worsen any impacts that occur.


We recognise that areas of particular environmental sensitivity will be avoided with the horse riding proposals. However, another issue is the level of compliance with the proposed management plan requirements once the trial is over. FOG is concerned that, once horse riding is allowed along some trails, some riders will start to go off the trails or into other areas where horse riding is prohibited. This will be impossible to police, or even determine that it is happening, particularly with the resourcing levels within NPWS and the plethora of other more urgent management tasks. An analogy might be drawn to dogs in Canberra Nature Park (CNP). Dogs are allowed on-lead in a number of sections of CNP, and many dog owners comply with this. However, there is always a minority who take liberties and allow their dogs to roam freely off-lead in CNP, with consequential disturbance to wildlife. Our concern is that, over time, a similar situation will evolve in wilderness areas if horse riding is permitted at all. Kosciusko National Park is of particular concern because of the fragility of its ecosystems, the number of endangered species, and other impacts from wild horses.


In conclusion, FOG is opposed to horse riding in any designated national park. To maintain the environmental values of these areas, impacts from human and exotic animal activities should always be minimised, not expanded.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

2 August 2018