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Dr. Anthony English's Report

  PARKS WORKERS SLAUGHTER
AUSTRALIAN BRUMBIES

Part Three

REPORT ON THE CULL OF FERAL HORSES IN GUY
FAWKES RIVER NATIONAL PARK IN OCTOBER 2000
DR A.W. ENGLISH HEAD OF THE DEPARTMENT VETERINARY CLINICAL SCIENCES FACULTY OF VETERINARY SCIENCE UNIVERSITY OF SYDNEY 15 NOVEMBER 2000 REPORT ON THE CULL OF FERAL HORSES IN GUY FAWKES RIVER NATIONAL PARK IN OCTOBER 2000 Introduction 1. This report deals with the culling by NSW National Parks and Wildlife Service (referred to from here as "the Service") of 606 feral horses in Guy Fawkes River National Park (GFRNP) between 22 and 24 October 2000. 2. The report looks at both why the culling of these horses was initiated by the Service and how it was planned and carried out. For the latter issue there will be emphases on an examination of the protocols currently agreed to by all relevant authorities for the aerial shooting of feral horses, in assessing what was actually done in this case. Background 3. GFRNP covers some 62,700 hectares of wilderness about 100 km north east of Armidale. The Guy Fawkes River runs north-south through a valley which rises on both sides to rugged escarpments and forested plateaus. The Park is dominated by open woodland vegetation of yellow box, cabbage gum, Blakely's red gum and broad -leafed stringybark. There are stands of dry rainforest on some of the upper slopes and in protected gullies along the river. Along the river itself there are grassy flats favoured by many species of native wildlife, as well as by the feral horses and wandering cattle that are found in the Park. Key species of wildlife in the Park include grey kangaroos, wallaroos, swamp wallabies and red-neck wallabies, with red kangaroos found in some upper areas. The endangered brush-tailed rock wallaby is also sometimes seen on the upper rocky slopes, while the rainforest harbours pademelons, potoroos and parma wallabies. Night spotlight walks often reveal greater gliders. The Park is also home to a great variety of birds, reptiles and amphibians, and is much favoured by campers and bushwalkers for it rugged beauty, The Bicentennial Horse Trail runs through the Park, which has about 20,000 visitors each year. 4. The Park is a part of the Service's Dorrigo Plateau Management Area, one of the 4 areas in the North Coast Region which has its headquarters in Grafton. The Dorrigo Plateau headquarters is located at the Dorrigo Rainforest Centre, and comes under the administration of the Regional Manager North Coast based in Grafton. 5. There are 32 Service staff who work from the Rainforest Centre, with 6 directly concerned with activities in GFRNP. There is a Pest Species Management Project Officer who has responsibility for the control of pests in the Dorrigo Plateau Management Area, including GFRNP. Dorrigo District Pest Species Management Plan 6. The current Pest Species Management Plan (PSMP) for the Dorrigo District was published in January 1998, and was prepared by the present Project Officer. The section on feral horses in the plan is attached a Annex A to the Report, with the following critical elements. 7. The PSMP identifies and prioritises the major pest species occurring within the Service's Dorrigo District. The term "pest species" refers to both pest animal species, and noxious and environmental weeds. It is pointed out that the plan outlines the Service's statutory requirements for pest species management, its pest species management philosophy and the major control programs currently running in the district. The Dorrigo District currently encompasses nine national parks, in ten nature reserves, two historic sites, two Aboriginal areas and one marine park. The District has recently acquired a number of new parks including Bongil Bongil National Park on the coast and the new Forest Reform reserves of Nymboi-Binderay, Chaelundi, Duggir and Bellinger River National Parks and major additions to New England and Guy Fawkes River Wilderness Areas. 8. Paragraph 1.1.1 of the PSMP deals with pest animal species. Those known to occur within and /or adjacent to Service estate in the Dorrigo District are separated into two broad groups: a. Animal pest declared noxious under the RLPB Act 1989 i.e. European rabbit, wild pig and wild dog; and b. Other domestic and introduced animals that have reached pest proportions or have the potential to be pest in Service areas. These include feral horses, feral deer, feral goats, feral cats and the red fox. 9. The Service has a number of statutory responsibilities concerning the management of this considerable array of ecosystems that comprise the protected areas of the Dorrigo District. Pest animals in Australia 10. Before returning to the management of pest animals in the Dorrigo District it is essential to highlight the significant impact that pest animals have had in Australia since European settlement. Olsen (1998) notes that despite ongoing improvements in established pest control methods and the development of new techniques, Australia has basically the same suite of pests now as at the turn of the century, and animals that were critical pest then continue to cause concern. Pest animals not only cause losses worth millions of dollars to Australia's agricultural production each year, but they also contribute to land degradation and pose a major threat to some endangered species of native animals and plants. Rabbits, foxes, feral cats, horses, goats, pigs, donkeys, camels, carp and even mice all damage our agricultural and ecological communities. 11. Only the most extreme Animal Rights groups maintain that feral animals should not be controlled in some way, which is totally at odds with all government and non-government conservation agencies. In contrast, the RSPCA "recognises that introduced animals which run wild adversely affect the natural Australian environmental systems, endanger native animal species, jeopardise rural production and may be carriers of pests and diseases. RSPCA accepts that from time to time it will be necessary to reduce or eradicate numbers of these animals. This must be humanely conducted by appropriately trained and experienced staff, under the direct supervision of the relevant government authorities" (RSPCA Policy Number 1.10-Animal welfare and the environment). 12. Much effort and expense, and considerable past and ongoing research have been committed to improving methods of pest management in Australia. Despite this, both protected area managers and private land holders are facing a huge task in minimising the effects of these pests in ways that are both cost-effective and acceptable to the community. While most effort is directed correctly to the control of widespread pests such as rabbits, feral pigs, goats and foxes, there are other species which can have equally severe impacts at a local level if their numbers build up, and feral horses are in this category. This Report will return later to the management of feral horses in Australia. NPWS legislative responsibilities 12. Paragraph 2.1 of the Dorrigo PSMP points out that the Service has a number of statutory responsibilities in relation to pest species management. The primary statutes are the NSW National Parks and Wildlife Act 1974, Threatened Species Conservation Act 1995, Rural Lands Reform Act 1989 and the Noxious Weeds Act 1993. a. The National Parks and Wildlife Act 1974 gives the Director-General of the NSW National Parks and Wildlife Service responsibility for the care, control and management of national parks, nature reserves, historic sites and Aboriginal areas. The key management objectives are listed as: conservation of these reserves, the provision of appropriate recreational and scientific opportunities, and the management of fire and pest species on these reserves. The management of protected areas is achieved through the production and implementation of Plans and Management, with two aspects of such plans having relevance to pest species: * Conservation of wildlife/protected flora and fauna, and * The protection of the special features of the reserve The central element of these Plans of Management is to identify key priority policies and actions for future management, including an examination of the occurrence and distribution of various pest species within the reserve, to investigate particular management strategies to control these pest species and to establish priorities for pest control programs based on the assessment of individual pest species occurrence, distribution and likelihood of effective control. b. The 'Threatened Species Conservation Act 1915' deals with developments or activities that may significantly affect threatened species, populations or ecological communities or their habitats. The Act lists "key threatening processes" which are identified as having significant impacts on the conservation of endangered (Schedule 1), populations and communities. There are a series of Service policies that flow from these legislative requirements. NPWS Field management policies 13. There is a policy on 'Introduced animals' that states that these "shall not be allowed to remain on Service estate, as these animals may pose a threat to the conservation of Service estate by preying on native fauna or through adverse impacts on native vegetation, soils and water quality. Stock are permitted to utilise travelling stock routes subject to the conditions between the NPWS and the relevant Rural Lands Protection Board, while domestic animals (excluding Seeing Eye Dogs or Hearing Dogs) are not permitted within Service estate without NPWS approval.. Pest management philosophy 13. Section 3 of the Dorrigo District Pest Species Management Plan (1998) notes that the aim of the Service's pest control program is to manage populations of weeds and pest animals to reduce their adverse impacts. The Service acknowledges that the eradication of pests is rarely in ever possible, with no pest species ever having been eradicated from mainland Australia since European settlement. Pest control programs "reflect a balance between the desire to use the most effective control techniques whilst minimising the non-target effects and potential for animals suffering. Where possible, integration control programs are adopted utilising a range of options, with the aim being to apply best practice, cost-effective and humane control methods". The Service employs a number of specialist staff to facilitate the effective planning and implementation of weed and pest animal control programs. These staff become very familiar with their area of responsibility, and are tasked with advising on and carrying out pest control activities on Service estate. The monitoring of pest control programs is a priority to ensure that programs are effective and that pest species impacts are reduced to an acceptable level. Objectives of pest control programs 14. Section 4 of the 1998 PSMP states that the objectives of the Service's pest control programs are to: a. Conserve biodiversity, b. Manage pest populations to minimise their movement out of and into Service areas, c. Satisfy legislative responsibilities, and d. Support a co-operative approach to pest management with other agencies and the community, and to foster community support for the Service's pest control programs. Feral horses in Australia 15. The authoritative reference to feral horses in Australia is Managing Vertebrate Pest: Feral Horses by Dobbie, Berman and Braysher (1993). This Bureau of Resource Sciences publication deals not only with the history, distribution and biology of feral horses, but also considers their impacts and use, and the options that are available for their management. There is said to be over 300,000 feral horses in Australia, mostly in the extensive cattle raising districts of the Northern Territory and Queensland but with many also in parts of Western Australia and South Australia, and in small scattered populations in New South Wales and Victoria. The authors note that feral horses pose a complex management problem in Australia, causing damage to the environment as well as being a pastoral pest. On the other hand they can be a source of meat for export and a significant animal welfare concern. As a result there are very diverse views about how best to manage Australia's feral horses, complicated further by the romantic image that wild horses have as a result of poetry and film. It is understandable that this image is in stark contrast to the reality of the adverse impacts that feral horses have in Australia, and of the need to do something about that. 16. Horses generally do very well in much of Australia, being well adapted to the sparsely distributed and unpredictable resources of arid and semi-arid regions. They can move up to 50km a day to food and water, and have few predators or diseases. Mortality is mainly associated with drought, which causes starvation, lack of water and consumption of usually avoided toxic plants. Thousands die slowly in times of drought. Mares produce , on average, one foal every two years and under good conditions the population can increase by 20% a year. 17. There is considerable evidence that horses cause significant environmental damage by fouling water holes, accelerating gully erosion along pads (tracks), trampling and consuming native vegetation, and possibly by excluding some native animals from preferred habitats. As will be shown below, all these impacts have been noted in GFRNP, with two of the every few studies done on feral horse impacts in Australia actually having been carried out in that Park (Taylor 1995, Andreoni 1998). 18. Dobbie et al (1993) further noted that feral horses and their management have developed a high public profile. Major concerns centre on mustering, transport to and slaughter at abattoirs and shooting from helicopters. There is pressure for the development of humane fertility control techniques that will lead to the eradication of feral horses, but no such techniques is currently available for use in large horse populations in remote areas. However, further research is certainly warranted. 19. It is further stated that reduction to and maintenance of feral horses at low densities is the best level of population control that is achievable. It is the options that are available for achieving this aim that require futher discussion in the context of the Report. It is noteworthy that the Service plan for the horses in GFRNP is to reduce their numbers and ultimately to achieve local eradication (PSMP para 8.13). This has been the approach since the early 1990's, with a number of attempts to reduce the number of horses in GFRNP by mustering and trapping. Details of these activities are given below. Senate inquiry into the welfare of feral horses 20. A senate inquiry in 1991 into the welfare of feral horses and other large feral animals concludes, reluctantly, that feral horses need to be controlled using techniques such as helicopter shooting. To minimise suffering, efficient control techniques need to be undertaken by trained operators. (Model Code of Practice for the destruction of capture, handling and marketing of feral livestock animals (Senate Standing Committee on Agriculture, SCA Technical Report Series-Number 34 (1991)). There is emphasis on the use of the most efficient control techniques to reduce the suffering that feral horses endure during repeated application of helicopter shooting and other potentially more inhumane techniques. Commercial use of feral horses 21. Commercial use of feral horses, at least in the initial stages of a control program, is considered to be essential. Without this incentive many land managers would not undertake control. However, the capture and long-distance transport of horses can cause unacceptable suffering if done poorly. More research is required to develop appropriate Codes of Practice. Current concerns are reflected in the grave disquiet expressed by the Australian Veterinary Association's policy on feral horse management in relation to the trapping of feral horses and their transport over long distances for slaughter at abattoirs. The same AVA policy (number 5.17) accepts that "strictly controlled helicopter shooting presents the most humane technique for large scale culling programs, provided that such programs are conducted only by skilled and trained shooters under a careful, controlled and planned government operation." Control techniques for feral horses 22. The control techniques for feral horses management are: a. Fertility control-as noted above, no large scale techniques is yet available, b. Immobilisation using drugs delivered by a dart rifle, c. Mustering and trapping, e. Shooting from the ground, f. Shooting from helicopters, The last four will be considered briefly here, and then dealt with again in the context of this Report on activities in GFRNP, it must be stressed that the adoption of any technique or suite of techniques must be based on the following elements, as for all species of pest animals. * defining the problem in terms of impact, * determining objectives and performance indicators, * identifying and evaluating management options, * implementing the control program, and * monitoring and evaluating the efficiency of the program and program objectives. Dobbie et al (1993) warn that no single method is likely to offer effective control of feral horses damage. Combinations of methods may be effective, depending upon local conditions. As will be details below, virtually all available options for reducing horse impacts have been tried in GFRNP since 1992. This approach should continue. Immobilisation using dart rifles 23. The use of dart rifles to immobilise horses for transport away from the capture site or for lethal injection at the site is seen by some as more humane than trapping, mustering, or shooting. While this technique may be appropriate for small numbers of horses that can be closely approached, it is in fact very labour intensive and costly, and requires closer veterinary supervision. The method itself is not without risk to the horses, as will be seen below when its use in GFRNP is discussed. Mustering and trapping 24. Feral horses can be caught by trapping in yards at water points or by using feed or lure mares as an enticement. They can also be mustered by helicopter, motor bike or on horsesback, with or without coacher horses. Trapping may cause very little stress than mustering, although skilled musterers can cause very little stress if the conditions are good. Captured feral horses can be sold as riding horses, relocated to reserves or humanely destroyed on the spot. The best financial returns can often be obtained by transporting captured horses to abattoirs where they are slaughtered for human consumption. However, as noted above careless operators can cause significant suffering to horses during long distance transport. There are also legitimate concerns about the welfare aspects of the slaughter of feral horses at abattoirs, with all the stresses and fears associated with that process. Shooting from the ground 25. Feral horses are commonly shot from the ground, especially in open country. The stallion is usually shot first, which confuses the remaining horses, slows their retreat and increases the chances of taking them. Ground shooting is often used alone, although it is sometimes used to remove horses that cannot be mustered or trapped. It is generally only effective on fairly flat ground and readily accessible country. It is impractical where water is abundant and in rugged country. It is not suitable for large scale control, and wounded animals are often difficult to pursue, especially in rough country. Shooting may also disperse remaining animals before they can be shot. It may be a useful technique during droughts, to reduce the number of horses that would otherwise die slowly of hunger or thirst. Horses are shot in this way in WA for the pet food industry. Shooting from helicopters 26. Helicopter shooting is considered to be the only practical method for quick, large-scale and humane culling of large animals in inaccessible locations (SCA Report 1991). This is so because: * Shooters can get close to the target animal, * Wounded animals can be followed-up quickly and killed. 27. Shooting from helicopters should be conducted by experienced government shooters or certified private individuals trained and operating under strict guidelines. In New South Wales this training takes the form of the Feral Animal Aerial Shooter Training Course (FAAST Course) conducted by teams of instructors drawn from the NSW Police Service, NSW Agriculture, Rural Lands Protection Board and the NSW NPWS. Not only is this technique highly successful in reducing pest animal numbers as a part of ongoing management, but it would be a vital tool in the control of exotic diseases should they be introduced to this country. FAAST course and similar programs in other states provide pool of trained and experienced shooters and pilots for such contingencies. Feral Animals Aerial Shooter Training Course (FAAST) 28. Training courses are conducted under the auspices of the FAAST Management Committee, with representatives from all the agencies listed above. The courses are conducted as required, with successful completion being a pre-requisite for accreditation as an aerial pest shooter in NSW. The FAAST course training program includes: * the aviation laws applicable to aerial shooting, * the relevant laws in NSW applicable to government agencies, \ * the use of the LIA1 SLR rifle, 12g shotguns and appropriate ammunition, * ability to use firearms safely and competently from helicopters, * ability to appreciate relevant animal welfare issues, * the organisation of group pest control programs. This is a rigorous and well-conducted 4-day training activity, with students being assessed by all instructors at the end of each session. All students must have prior experience with the use of firearms for feral animal control. Assessments are made using informal and formal oral, written and practical tests. The students must pass all sessions, including the range shooting, before being awarded the FAAST Certificate. Range shooting is done on the ground, from a cherry picker and from a helicopter at both static and moving targets. A high standard of marksmanship is required to pass. There have been five courses conducted since the first in 1994, with 61 Service and RLPB staff having been trained to date. Of these there are 37 who are currently accredited, including all three shooters used during the feral horse cull that is the subject of this Report. To maintain FAAST accreditation the personnel concerned must use a log book to record a minimum of 10 hours per year of both ground shooting and aerial shooting of pest animals, with the log book inspected each July by the FAAST Management Committee. This would generally mean that only individuals who are currently actively engaged in pest management would be able to maintain FAAST accreditation. All 3 shooters in this case were current under these terms. FAAST protocols for the shooting of feral horses 29. The FAAST course trains shooters in the use of a strict protocol for the pest species in question. Some key points are: * Shooters may fire at an animal only when they are sure of an effective shot into the killing zone, * Animals must be killed as quickly and humanely as possible, to satisfy the requirements of animal welfare. Additional shots should be fired to ensure that an animal is dead. * Shooters must ensure that, where practicable, wounded animals are killed as quickly and humanely as possible. If a line of animals is being shot and one is wounded, the the helicopter must fly back to allow the shooter to kill the animal, * Prescribed firearms and ammunition must be used for each pest species. For horses the FAAST course teaches the use of LIAI SLR in .308 calibre, with 150 grain soft point ammunition, or 130 or 150 grain hollow point bullets. The rifles are fitted with Aimpoint red dot sights or equivalent, * The brain is a small, mobile target well protected by bone; so the preferred killing shot is into the heart-lung area. Death due to massive intra-thoracic haemorrhage and tissue damage is rapid and humane when the appropriate rifle and ammunition are used, * Whenever possible shooting operations must use helicopter pilots who are experienced in aerial shooting and are able to place the shooter in a position that facilitates a humane kill. The application of these and other operational elements will be dealt with below when considering the protocols used by the Service's shooting teams during the horse cull in GFRNP. Feral horses and cattle in GFRNP 30. There is a long history of feral horses in the Park, with indications that they were well established before 1915. Estimates of numbers of horses vary quite widely thereafter with the area now incorporated into the Park having been used primarily for cattle grazing. When the Service took over the area in 1972 there is a record of Dalgetty's mustering over 4000 cattle, but there was no mention of horses. The Service estimated that there were still some 2000 cattle in the Park in 1975, with smaller numbers present for most of the time since then. The most recent Service estimate of cattle number in GFRNP was from an aerial survey 18 October 2000, with 181 cattle counted. 31. The Service has records of horse numbers in GFRNP which vary from 3 in 1978/79 to 400 in 1991, with the latter an estimate made by a local land owner (G. Everingham). There had been a significant increase in 1981 with 62 horses counted from a helicopter, with statement made by some local people that a large group of horses was purchases in Grafton and released in the Park. The number given in an estimate made in 1993 by another land owner (S. Jorganson) was also 400. The Service began making regular aerial inspections from 1992, with numbers counted given as 174 in 1996, 112 in 1998 and 180 in May 2000. 32. Although the exact number of horses can never be determined in the type of terrain found in the Park, the Service's recent estimates have been between 150 and 250 horses. It is worth emphasising that there is always a tendency to underestimate numbers in this type of survey, with the aerial count on Oct 18 producing a figure of 283 horses and 151 cattle, mainly along the Guy Fawkes River and Sara River valleys. It has been noted that the horses generally stay in established territories, but some mobs move seasonally between the river and the high plateau areas. The number of horses that stay in the rougher forested country, and are therefore less likely to be seen from the air, has not been determined. 33. The large number of horses encountered on 22 October was a surprise to all concerned, with the animals concentrated in the river valley by the prevailing conditions of drought followed by extensive fires over preceding weeks. This situation will be amplifies further below, when examining conditions that resulted in a decision to institute the culling operation in late October. Feral horse control techniques in GFRNP 34. It is accepted that environmental and other impacts of feral herbivores are density dependent, and horses are no exception. However, the relationship between density and impact needs to be quantified, with the development of simple, inexpensive techniques for assessing feral horse density and impact (Dobbie et el 1993). Very little research of this nature has been done anywhere in Australia, but a study in GFRNP by Andreoni (1998) found extensive erosion associated with horse movement. The majority of erosion occurred on steeper slopes in woodland areas. Horses appeared to use the area homogeneously, with a conclusion that feral horses have a obvious impact on the visual, auditory and olfactory nature of GFRNP. A study by Taylor (1995) showed that a number of weed species were being spread in horse manure. Observations by Service staff over the last 25 years have highlighted the effects that the horses have-horse pads trapping runoff and so causing erosion along the pads, slumping and washing of gullies due to lack of ground cover due to overgrazing, and the spread of weeds into areas frequented by horses. Riders on the Bicentennial trail are sometimes harassed by feral stallions. 35. There can be no argument that the impacts of horses which include erosion, soil compaction, changes in vegetation and overgrazing are in direct conflict with native fauna, with these effects becoming even more serious in times of drought. This was the case in the Park, compounded by the fires that had burnt out some 60% of the Park in the weeks before the cull. Australia's native fauna have evolved to cope with the harsh conditions that so often occur in this country, with a range of adaptions that enable populations to recover even after the most severe drought and fires. However, they have not evolved in the face of the significant competition for resources that occurs when hundreds of horses and cattle are also seeking to survive in the same area. This is the case in GFRNP as the native fauna compete for the grass that is now growing after rain that fell in the weeks after the horse cull in late October. Feral horse control techniques in GFRNP 36. A number of approaches have been taken by the Service since 1992, in attempts to reduce the number of horses in the Park. Initial attempts were made in that year to rope or dart horses, and to use ropes to lead them out. A stallion and foal were roped by private operators, and 12 were taken out by darting. However, six of the darted horses died. Five foals were caught later in the year, and there was a plan to put tranquilisers in feed-but this was never done. Thus, in the first year only 25 horses were removed, and 6 of these died as a result. 37. In 1993 there were further attempts to dart horses, which were even less successful than 1992. Teams of both private and Service personnel were involved, but only 10 horses were captured from the 67 that were hit by darts. No further use of this method has been contemplated. 38. Later in 1993 the first attempted muster of feral horses was carried out, using electric tape to guide the horses into temporary yards. None was caught. In June 1993, 28 animals were caught in three runs(18/19/1) at Rock Wall in temporary yards made from shade cloth. This remains the single most successful capture of horses in the Park, with 7 people involved. 39. In 1994 a set of steel yards were built and used to capture 27 horses which were mustered by local horseman. Some animals died from injuries received when they hit the steel yards. This was an expensive failure, and the yards were not used again for animal welfare reasons. 40. In 1995 the Service turned to light fishing nets to construct temporary yards in locations where mustered horses could be caught. In the first attempt private horseman were used, with 2 horses captured. However, both escaped by breaking through the light nets. This was tried again later in the year with heavier nets, with 7 horses caught. The blue nets were dyed to make them less visible for further attempts, which was and improvement, In three activities a total of 35 were caught in net enclosures, using horseman and a helicopter in two attempts in October 1995. This last episode involved not only the aircraft but 8 people (5 Service, 3 private) over 9 days, at an estimated cost of $74 000. Eleven horses were caught, but one mare close to foaling was injured and had to be shot. In December this was repeated using heavy net enclosures, with 12 horses caught over 5 days using only horseman. Two pregnant mares broke their necks, 4 were shot for dog meat and 6 were taken out. 41. In 1996 and 1997 there was no mustering, but in 1998 the heavy net enclosures were used again, with mustering by horseman and a helicopter. A small number were caught of which 4 were released with radio collars for a study on home ranges. This activity extended over 5 days and utilised 7 people (4 Service, 3 private), and was costed at $8869. A similar attempt at the Sara River junction in May 1999 resulted in 18 horses being caught, with 10 people involved over 5 days. 42. A total of 156 horses were removed from the Park by these measures, with 15 or more musters between 1992 and 1999. The cost-effectiveness of these activities must obviously be questioned in relation to the benefits derived from reducing the population by only this number, which is arguably less than the natural rate of increase of the herd. There were also significant animal welfare concerns in relation to the techniques that were used, despite the involvement of experienced local horsemen and experienced staff. Animal welfare concerns 43. Despite commitment over a number of years to utilise non-lethal means to reduce the horse herd in GFRNP, there were significant problems in the techniques that were used to catch and move the horses from the Park. These stemmed from the behaviour of the horses and the remoteness and nature of the terrain, and in particular from the difficulty encountered in getting trapped horses out of the valley and up to the escarpment. With an absence of roads over most of the area it was necessary to lead the horses up from the valley. This was done initially by the use of stock horseman behind which the halted feral horses were lead many kilometres. They were generally not inclined to travel readily in this way, and the whole process was very difficult and stressful for the stock horses, the newly caught feral horses and the people. In 1999 a trial was conducted whereby the haltered horses were tethered behind 4-wheel drive vehicles and virtually dragged up the escarpment. This was also a failure, in that the animals fought against the vehicles and became quite distressed. 44. In the time immediately after being trapped and even before the attempts to move the the horses up from the valley there was a very stressful 24 hours, in which the animals were roped in the enclosure, and then usually thrown to the ground and haltered. The practice was to tether them for the first night in the enclosure, drag them to the river for a drink and then begin the move up the escarpment. This whole process resulted in a number of horses being injured or killed, and all animals that were taken out were certainly very distressed by what was done to them. It was also extremely dangerous for the people concerned. Proposed feral horse mustering program 2000/2001 45. Given that the most successful technique had been the mustering into traps constructed from heavy netting, a decision was made by Service staff in 1999 to concentrate efforts on this techniques, but with the use of vehicles fitted with appropriate crates to transport trapped horses out of the Park rather than by leading them out. This was a plan that involved quite high costs, not only in the lease or purchase of vehicles and crates, but also in the work that was required to improve access at river crossings and elsewhere. A proposal dated 6 September 2000 was submitted by the Dorrigo office though the Service chain of command, for the implementation of large scale ground mustering operations in strategic locations throughout the Park. The plan involved the use of helicopter support, mustering into horse traps, local mustering specialists employed as casual Service labour to design and run the traps, Service ground crews to assist in trap set up and transportation of horses off the park. 46. The mustering program was to run for 15 months with completion of the mustering phase by November 2002. There was an intention to then look at ways of controlling horses in more remote locations where mustering could not be used, while also fostering appropriate concurrent horse control programs with other local groups to increase the overall effectiveness of horse control efforts. 47. A budget was submitted which included an additional $96,372 in the current financial year, and $75,000 in 2001/2002. 48. This submission was still being staffed through Service channel, when the conditions that resulted in a decision to use culling operation for the first time became the imperative. A combination of drought and bushfires resulted in a crisis developing in GFRNP, with large numbers of horses seeking the small amount of feed which was to be found on some unburnt river flats. These horses were grazing with at least 200 cattle that had come into the Park though burnt fences, in direct competition with the native fauna of the Park which were equally short of feed. The horses were in very poor condition and could only suffer more in such conditions, as would the native animals with which they shared the Park. At least 4 dead horses were seen near the river during an aerial survey on 18 October, with many others noted to be in very poor condition. 49. It became apparent that conditions were developing wereby an aerial cull of the horses was arguably the only way to achieve a significant reduction in their numbers in a reasonable time frame, thereby preventing the suffering and slow death of many of the due to starvation. The Service had an obligation to do something about the situation confronting both the horses and the native fauna that they shared the scarce feed with, with an opportunity to reduce the horse population in GFRNP to an extent that had not been possible in the past. This compiled with the Service's clear statutory obligations to conserve biodiversity and to control feral pest animals. Options considered 50. A detailed assessment began after the survey flight on 18 October, which resulted in a count of 283 horses and 151 cattle in the valleys of the Sara and Guy Fawkes Rivers. Even at that stage a number of management options were considered. The first was the possible helicopter mustering of large groups right out of the valley-the horses were congregated in mobs somewhat larger than the usual 5-7 in a group. The helicopter pilot concerned was experienced in mustering, and attempts were made to see if the horses could be moved as proposed. After a number of attempts it became apparent that the horses were reluctant to move any distance without breaking away, and the method was abandoned. 51. Consideration was given to the use of temporary netting traps as had been used before with some success. This was not taken any further because the fires had removed all vegetation around the trap sites, and the netting would have been far too visible for the horses to enter the traps. The plan to utilise helicopter shooting began to emerge as the most rational and effective way to deal with the situation confronting the Service in late October. Planning for the culling of horses in GFRNP 52. The Service was contemplating an approach to feral horse control that had not been used before in the Park, nor indeed in New South Wales. There is extensive aerial shooting of feral pigs and goats in the State, but not of horses. Shooting from helicopters has been used to control horses in other States, and is acknowledged by authorities including the NSW Pest Animal Control and the AVA as the only way to achieve effective large scale control. The SCA (1991) provisions are supported, providing that the shooting is done humanely by trained staff. If is also important to note that Dobbie et el (1993) state that during and coming out of drought are the times when feral horses cause most damage to pastoralism and to the environment, and when they are restricted to limited feeding and watering points. This was exactly the situation in GFRNP in late October 2000. 53. The preceding sections have detailed the situation leading up to the cull, and why it was considered to be the best approach to use in the time frame that prevailed. The Report will now examine how the culling operation was planned and carried out on 22/23/24 October 2000. Incident Control System 54. The incident Control System (ICS) is used by the Service in such situations, and an Incident Action Plan (IAP) is developed under this system. The Service has considerable experience over many years in the use of ICS for emergencies as diverse as bushfires, floods, land slides and marine mammal strandings. The ICS procedures require a detailed assessment of the nature and scale of the task, development of aims and objectives, and assessment of the resources likely to be required. The Service already had an ICS in place to deal with the fires that had been burning in the Park since 6 September, but the proposed cull of horses required a quite separate approach. The fires were no declared out until 28 October by which time some 43,000 hectares of the Park (60%) had been burnt out. This was considered to constitute 90% of the habitat that sustained the feral horse population. 55. At about the same time the Service was made aware that the RSPCA was concerned about the poor condition of horses and cattle on private properties adjacent to the Park. It was confirmed that some owners hod been approached by RSPCA about this, with acute concern for the condition of their animals at the time when the Service first began considering the use of aerial shooting of horses. 56. An experienced Incident Controller (IC) was appointed for the culling operation, and planning commenced in earnest after the 18 October flight. The the week or so prior to that date there had been reports from helicopters used for fire fighting that larger than usual number of horses were being seen near the river, and that they were generally in poor condition. Several dead horses were reported. 57. It should be stressed that the use of an ICS ensures that there is effective command and control throughout the activity, with comprehensive briefing and good coordination of all those who are involved. It ensures that adequate resources are made available for the task at hand, with the flexibility to scale up or down as the situation dictates. It also provides for a through de-briefing after the activity, to ensure that any difficulties or lessons learnt are recorded for future reference. Planning the culling operation 58. A memorandum was prepared in Dorrigo on 19 October, recommending that a horse culling operation be conducted in GFRNP. This was approved by the Service Executive after a number of telephone conversations on 20 October, with a belief locally that the NSW Agriculture Animal Welfare Unit was to be consulted. A member of the Executive did contact the NSW Pest Animal Council to inform that body that a cull of horses was being planned. There was advice given that if the cull were conducted under the State Emergency Plan on animal welfare grounds that the RSPCA would be made aware of the intention, given that the organisation has membership of the Council. A decision was made not to take this approach and the RSPCA was not informed of the plan to cull horses in the Park. The Service believed that there was no statutory requirement to do so, in the case of a control operation for a feral animal species of Service estate. 59. After the event it could be said that it would have been prudent to do so, with involvement of RSPCA in discussions about the acute animal welfare and environmental emergency that had developed in the Park as a result of drought and bushfires. Similarly, it would have been prudent to inform local landowners as well, outlining the background and methods to be used. Sequence of events 60. On Saturday 21 October an experienced local person was given the task of ensuring that no campers of horses riders were in the Park, before the culling began. This was done by helicopter, and despite the fact that the Park had been closed because of the bushfires and was still closed, two horse riders were found camping at Kitty's Creek. They were asked to leave the Park, and were given assistance by flying their camping gear out. A similar flight was conducted on the morning of Sunday 22 October to verify that they had left, and to ensure that nobody else had come in. 61. The Dorrigo Police were informed on 21 October that an aerial culling operation was to be carried out in the Park over the 2-3 days. 62. A detailed briefing of all personnel involved in the operation was carried out at the Rainforest Centre on the morning of 22 October. The briefing involved a detailed review of all elements of the IAP with emphasis on both human safety and animal welfare. The way in which the latter was dealt with should be emphasised. Animal welfare aspects of the briefing on 22 October 63. There was specific discussion about the protocol to be used by the shooters, with confirmation that heart-lung shots were to be taken, as taught in the FAAST Course. A FAAST Committee member was contacted by telephone , to verify this policy. This was followed by a study of diagrams of horse anatomy provided by one shooter, with agreement on the preferred location of the killing zone. A definite policy was confirmed, with shooters to fire one or more shot into the thorax, directed to hit the heart-lung area, followed by further shots into either the head or thorax to ensure that the horse was dead. 64. There was no ambiguity about the approach to be taken, with considerable emphasis placed on achieving a humane kill as quickly as possible. This was to be done using as many well-aimed shots as were needed. 65. There was then a detailed discussion about the way in which a group of horses was to be dealt with, shooting the last in the file first and confirming that this horse was dead before flying on to the next horse and so on. The fact that no wounded horse was to be allowed to remain alive for more than a few seconds was emphasised. 66. The "fly back rule" was confirmed, which ensured that not only was each horse confirmed as dead by both pilot and shooter before the next horse was targeted, but also that the group was flown over again and closely examined to ensure that all were dead, before a new group was sought. There was a specific instruction that no cattle were to be shot. 67. The briefing was thorough and comprehensive, as required by the ICS process. The shooting teams were well aware of what was expected of them, as professional pest control personnel. Extracts from the Situation Report Form and Incident Action Plan are shown at Annex B. Resources allotted to the cull 68. The major resources used in the operation were: * helicopters * shooters * navigators * support staff-communications, helicopter refuelling etc Helicopters 69. Three helicopters were used in total, with Service aircraft (Squirrel) and pilot flying on all 3 days. A private helicopter (Jet Ranger) and pilot was used on Sunday 22 October, replaced on 23 October by another private aircraft (also Jet Ranger) due to mechanical problems. All 3 pilots had extensive experience in aerial mustering and shooting, and all were very familiar with FAAST shooting protocols. The second private pilot is in fact one of the country's most experienced in aerial shooting, being an instructor of FAAST-type courses in the Northern Territory. 70. The pilot has a pivotal role in aerial shooting, with the following tasks; * to assist in the initial location of a group of horses, * to place the aircraft over the last horse in the file, in the best possible position to ensure that a shot into the killing zone is possible, * to confirm that the animal is down once the shot is taken, and to verify this with the shooter, * to hover over the animal so that additional shots can be taken, to ensure that the animal is dead, * only then to fly on to the next animal in the file, to repeat the process, * to fly back over the whole ground again to ensure that all the horses are dead, before looking for another group, * to verify the count and the GPS location with the navigator, who keeps the tally and plot of all horses shot. Shooters 71. A total of 3 shooters was used in shifts over the 3 days. all were Service employees and all current FAAST accreditation, having passed the training course conducted in May 1999. All of them are currently employed in pest control activities, and all had experience in the aerial shooting of pigs and goats. One had horses in Queensland, having passed and aerial shooter's training course in that State before joining the NSW Service. 72. All 3 had use of their own dedicated L1AI SLR, which they had used on the FAAST course. Each was therefore very familiar with his own firearm, a prerequisite for good marksmanship. Each rifle was fitted with an Aimpoint red dot scope, zeroed to hit the point of aim at 50 metres. Each shooter had at least 15 of the SLR's 20 round magazines, into which they each loaded their own 19 rounds of 150 grain soft point .308 calibre ammunition. It has been found by experience that magazines are more likely to malfunction if they are filled with the full 20 rounds. 73. During flight the shooters wear a safety harness attached to the helicopter, and headphones which enable them to talk to the pilot and the navigator. The shooter discusses with the pilot the position above the target animal that suits him best for each shot, and the 3 people in the aircraft work closely together as a team throughout the shooting process. Navigators 74. A total of 3 navigators was used over the 3 days. All were Service field staff with appropriate experience of Global Positioning System (GPS) navigation and the FAAST protocols. During a flight the navigator's main tasks are as follows: * to assist in the detection of a group of horses, * to check the GPS plot to ensure that no shots are ever taken within 500 metres of the Park boundary, using a digitised map, * to plot the locations of all groups of shot horses on the GPS, and to keep a tally of animals shot on each occasion, * during fly back over shot horses to assist when possible in verifying that every horse is dead. Shooting protocol 75. The following protocol was used throughout the operation, with minor variations due to topography, vegetation and the movement of horses: * When a group of horses was selected for shooting, the initial task was always to turn the group away from the river and up a spur line along an existing horse pad. The intention was to shoot no horses closer than 300 meters to the river, but when this was not possible the carcasses were later moved away by slinging under the helicopter. Some 40 were moved in this way, these generally being animals that were so poor and weak that they did not move away when the helicopter approached. * All personnel later confirmed that the horses invariably moved along the pad in single file, and mostly did not move in panic. It was apparent that they were not particularly concerned by the helicopters, probably because they had become accustomed to their regular presence during the fires. Even when an animal behind them was shot they tended not to increase pace, and some even stopped. * As described above, the rear horse was always shot first, and only after both shooter and pilot agreed that it was dead was the next in the file followed up and shot. It was confirmed that most groups consisted of 5-7 horses, with a few up to 12-15. * The FAAST fly back rule was rigidly used to ensure that all horses that had been shot were down and dead, using 2 or more additional shots if any doubt existed. Only then was a new group sought. * Foals were always shot before their dams, as required by FAAST protocol. * During the course of all 3 days most groups of dead horses were flown over at least 3 times during transit to and from the Park, and every opportunity was taken to check again that all were dead. Four wounded horses were located and shot from the helicopter on the third morning. The fact that one horse was shot twice but not killed, and not located by this process, was obviously at odds with this protocol. This was an exception to a system that had otherwise been very effective. Further details on this horse are given below and in Annex D. Policy on targeting 76. The recommended targeting protocol has been described in paragraph 29 and again in paragraph 63, but it is repeated again here as described by all 3 shooters. The target in a moving horse is the heart-lung area, including the large thoracic blood vessels. The helicopter is positioned between 40 and 60 metres above and behind the horse, as trees and the terrain allow. The shooter and pilot talk to each other until the helicopter is positioned well for a shot to be taken. FAAST training emphasises that no shot should ever be taken unless it can be directed confidently into the killing zone. 77. The target area on a moving horse is the middle of the back just behind the withers, or laterally on the thorax behind the elbow if shooting from the side. The first shot is directed there, with the intention of the bullet travelling down and forward into the thorax, hitting the heart, lungs or large vessels. In many cases the spinal column is fractured as well. Death is rapid, due to shock, haemorrhage and massive tissue damage, and is much less likely than a jacketed military round to pass right through an animal. 78. All shooters agreed that about 80% of horses dropped with one shot, but those that did not were shot a second time as close a possible to the first. With a self-loading rifle this second shot can be fired in a second or so. 79. All shooters stated that it was their policy to fire a third shot into each horse after it was down with the helicopter in hover, either into the head or into the thorax behind the elbow. The target for this third shot depended on how and where the horse was lying, and in some cases up to 5 rounds may have been fired to make absolutely certain that a horses was dead. It is estimated that the average time from first to last shot was invariably less than 20 seconds, with most horses dead within 5-10 seconds after 1 or 2 shots. Tally of horses shot 80. A total of 606 horses was shot over the 3 days with this count verified by careful checking of navigators' tally sheets and GPS plots. A map showing the GPS plot of each group of shot horses is attached as Annex C. 81. A total of 326 horses were shot on Sunday 22 October, 221 were shot on 23 October and 59 on 24 October. Results of the field investigation 82. To assist in the preparation of theirs Report a field investigation as carried out on Thursday 2 November. This was 10 days after the commencement of the cull on 22 October. A further visit to the Park was undertaken on Friday the 10 November, during which the carcasses of the 12 horses were closely examined for the location of gunshot wounds. 83. On 2 November a total of 7 hours was spent examining 27 dead horses at 4 separate locations within the Park. At the first site the horse which had been found alive by RSPCA inspectors and shot the previous day was examined. This animal (RSPCA # 139) was submitted to a necropsy by Dorrigo veterinarian Dr C. Shirley, acting for the RSPCA and myself, with RSPCA Inspectors Rose and Murdoch present. Also present were 3 Service personnel ( Alan Jeffrey, Brad Nesbitt and Carlo Zoppo). The results of the necropsy and conclusions are given at Annex D. 84. The horses that had been shot during the cull had been dead for 10 days, and were in an advanced state of decomposition. Despite this, it was possible on most to identify the location of bullet wounds and to make a judgment on how humanely or otherwise the shooting had been carried out. This judgement was based primarily on the number and the position of bullets wounds but also on the absence of evidence such as scuffing on the ground that would have suggested that the animal took some time to die, it was also possible to see from the location and spacing of each horse in the group how the shooting had been carried out, one after the other. 85. One adult horse had suffered a bullet wound to the upper left forearm, which had shattered the radius and ulna, and one foal had a fractured mandible (lower jaw). It was impossible to judge whether these wounds had been inflicted before or after the fatal shots to the thorax. On the basis of the shooting protocol that was used by the shooters, it was possible that these wounds were inflicted by follow-up shots in the seconds after the initial killing shots. 86. After examining all these 26 horses on 2 November I concluded that they had been shot humanely, with no evidence of indiscriminate targeting of the body away from the kill zone. In a discussion with Dr Shirley on Monday 5 November he confirmed that he had come to the same conclusion after examining 67 dead horses. I believe that this was the substance of his report to the RSPCA. 87. It would be naive to expect that every horse would be shot in exactly the same place in the thorax and killed with a single shot into the heart-lung area, even for expert marksman. The FAAST shooting protocol acknowledges this, by requiring follow-up shots to either the head or the thorax. This approach results in at least 2 and up to 5 shots being fired at each horse, all within 20 seconds or less. Most are killed by the first or second shot, and the additional shots are more often than not fired into a dead or unconscious animals. While this may result in a number of bullet wounds being visible on the carcass at later examination, it does not support a view that the shooting was not humane, and that the intention was not to kill the horse as quickly as possible. 88. The Service officer who was IC for the operation monitored the shooting from a separate helicopter, accompanied by the Regional Manager. They were able to watch the process very closely, and have verified that the approved protocols were followed by all teams. Conclusions 89. As a result of this inquiry I have come to the following conclusions: a. That the use of aerial shooting in Guy Fawkes River National Park was an appropriate technique under the circumstances. b. That the shooting was carried out in a humane way, under approved protocols designed to kill the horses as quickly as possible. c. That the culling operation was planned and carried out in a most professional manner on the part of all personnel involved. d. That all 3 shooters had been trained on a approved Feral Animals Aerial Shooters Training (FAAST) course, are currently accredited to act as aerial shooters, and have all had extensive experience in the shooting of feral animals from the ground and from the air. e. That all 3 pilots had extensive experience of aerial mustering and shooting, and were selected on that basis. f. That the conditions that prevailed in the Park by late October, as a result of severe drought and bushfires, had resulted in significant animal welfare problem for the feral horse herd. g. That the large number of horses in the Park, as well as the hundred of cattle, posed a significant threat to the native flora and fauna in the Park. h. That the adverse impacts of these horses are both long term (including erosion, overgrazing, pollution of the rivers and dispersal of weeds). but also short term in the competition with native animals for available feed after the drought and bushfires earlier this year. i. That the Service had used a number of management options since 1992 in attempts to reduce the number of feral horses in GFRNP, including roping, mustering, trapping and darting. j. That despite the use of local horseman and experienced Service staff, only 156 horses were removed by these methods, at significant risk to the people concerned and with major animal welfare problems as well. k. That there was a proposal in September 2000 to seek additional funds for a large scale mustering operation, using heavy netting enclosures and vehicles suitable for trucking horses out of the valley. l. That the large number of horses which began to congregate along the river valley in mid-October, in seeking the few remaining unburnt grassed areas, presented an opportunity to remove a large number by a concentrated aerial culling operation. m. That helicopter shooting by suitably qualified and experienced teams was the best method available to achieve this, and also to kill horses humanely before they starved to death. n. That it would have been prudent for the Service to have sought the involvement and cooperation of the RSPCA in planning and carrying out the operation, with emphasis on both the welfare for the horses and the significant ill-effects of the large horse herd on the native flora and fauna if nothing was done. o. That local land owners should also have been involved in some way from the outset, to ensure that they knew what was happening and why. Recommendations 90. As a result of this inquiry I have the following recommendations: a. That aerial shooting of pest animals, including feral horses, be retained as method of control under appropriate circumstances, providing that everything possible is done to ensure that it is carried out humanely. b. That the FAAST Management Committee be asked with a review of current aerial shooting protocols for all species, with a view to achieving improvements where required. c. That funding be made available for studies on improving the methods for assessing the impacts of feral horses in Australia, and on options for their management in a range of habitats. d. That a code of practice for the capture and transport of feral horses be developed and enforced. e. That the community continue to be made aware of the need for effective control of feral animals in Australia by all appropriate means, including aerial shooting. The recent stark images of shot horses, and the emotive language used by some commentators, must be countered by effective education concerning the threatening processes confronting our native fauna. A.W. English 14 November 2000 Annexes A. Extract from the Dorrigo District Pest Species Management Plan. Paragraph 8.1.3 Feral horses (Equus Caballus) B. Situation Report Form and Incident Action Plan (5 pages) dated 22 October 2000. C. Maps showing the GPS plots of groups of shot horses in GFRNP. D. Report on a necropsy performed on a wounded horse shot on 9 November. References Andreoni. F. (1998) Evaluating environmental consequences of feral horses in Guy Fawkes River National Park. Department of Ecosystem Management, University of New England, Armidale, NSW. Dobbie, W.R., Berman, D. McK. and Braysher, M.L. (1993) Managing Vertebrate Pests: Horses. Bureau of Resource Sciences, Department of Primary Industry and Energy. Olsen, P. (1998) Australia's Pest Animals. New Solutions to Old Problems. Bureau of resource Sciences, Department of Primary Industries and Energy. Taylor, U. (1995) Seed dispersal from feral horse manure at Guy Fawkes River National Park. Department of Ecosystem Management, University of New England, Armidale, NSW. Annex A - attached Annex B - attached Annex C - attached Annex D Report on a necropsy performed on wounded horse shot on 9 November 2000. Description The animal was a small adult mare, light brown in colour. There were two obvious bullets wounds to the withers area, and a fresh wound to the forehead where the RSPCA inspector had shot her. The mare was in poor condition. Findings The thorax area was dissected to determine the course of the 2 bullets that had caused the wounds visible on the withers. There was a quantity of dried blood running down the right hand side of the body from each wound, and both wounds were fly blown. The rear bullet wound was 2cm from the midline on the right hand side of the 11th thoracic vertebra, while the other one was 5cm on the RHS of the 4th thoracic vertibra. Upon reflection of the skin from the right hand side of the thorax, and of the forelimb including the scapula, it was possible to demonstrate that the projectile had tracked between the scapula and the rib cage down almost to the sternum, without penetrating the thorax. There was no exit wound, but the projectile was not found. The second projectile had hit above the 4th thoracic vertebra after penetrating the skin, and had apparently shattered on that bone. There was no penetration of the thoracic cavity by this bullet either, but there was a quantity of blood (approximately 2 litres) in the cavity. No bullet fragments were found. Interpretation While it was assumed that the 2 shots had been fired from a helicopter due to their position on the top of the body, in the absence of bullet fragments it was not possible to prove beyond doubt that this was so. The possibility of the shots being fired from high ground was discussed, but no firm conclusions were drawn. It was concluded that the horse would almost certainly have been knocked down initially by these 2 shots, but it was not possible to conclude how long it would remained recumbent. If it had been shot from a helicopter it may well have appeared to be dead, with no further shot fired. There was a final conclusion that the 2 projectiles had performed in a quite bizarre fashion in the horse, compared to all the others examined. It was remarkable that neither shot had penetrated the thoracic cavity, thereby hitting the heart-lung area, given that both were in the killing laid down by the shooting protocol. There was no reason to believe that the shooting team had not carried out their responsibilities for a humane kill. There is no doubt that if the horse had been seen on its feet after the initial shots that it would have been shot again. Recommendations This case places considerable emphasis on the FAAST protocol that every shot horse must be shot again at least once in the head or thorax, even it appears dead. This will ensure that there is no repeat of this most unfortunate incident. While this was the procedure used during this operation (with additional shots fired at either the head or the thorax), it is apparent tat this particular horse did not receive follow up shots for whatever reason. It is further recommended that the projectile currently used for horses be reviewed. A heavier bullet up to 180 grains may be more certain to penetrate the thorax in every case. It is appropriate to stress again that the situation with this horse was the exception in this operation, and should not be used to discredit aerial shooting as an option for large scale control of feral pest. To lose this valuable tool would be a setback to the control of pest animals in Australia. However, that is no to say that continuous review of shooting protocols should not occur, nor that research and development of alternative techniques should not be pursued.

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