Colin Simpfendorfer

I make these comments based on the following experience:

1. 24 years of experience working with sharks, shark fisheries and shark conservation
2. Experience working in academia (10 years), WA state fisheries research lab (6 years), and an international research laboratory (Mote Marine Laboratory's Center for Shark Research),
3. Research focused on sharks that has generated 80 peer reviewed scientific papers as well as numerous reports.
4. Experience in providing scientific advice on the management of shark fisheries (including Western Australian shark fisheries, the Southern Shark Fishery, Queensland shark fisheries, US Atlantic shark longline fishery, and international pelagic longline fisheries) and shark conservation (including as the leader of the US Smalltooth Sawfish Recovery Team, as an advisor to SEWPAC on the conservation of sawfishes and river sharks, and as the Regional Chair (Oceania) for the IUCNs Shark Specialist Group).

Please note that these are my personal comments, and do not represent the views of the organisation that employs me, or any of the groups that I belong to or represent.

Colin Simpfendorfer PhD
Centre for Fishing and Fisheries Research
School of Earth and Environmental Sciences
JamesCook University

Comments

1. Research coordination
   Shark Plan 1 failed to deliver on the issue of improved research coordination, and it is not clear how Shark Plan 2 will deliver an improvement on this. The new plan identifies the FRDC's Shark Futures as an initiative that will help in this regard; however the reality is that FRDC funds only relatively small portion of Australia's shark research. While in the past this may have been true, Australian universities now provide the largest amount of
   research on sharks. Shark Plan 2 does not offer any mechanism by which to engage the university sector in coordination of research, this needs to be addressed with some urgency. Under Shark Plan 1 the group with the responsibility for this coordination was presumably the Shark Implementation Review Committee (SIRC). However, this committee did not have a representative of from the university sector, nor am I aware (because the SIRC never communicated with the majority of the research community) of any attempt for it to gather information about the extent of research being undertaken outside of those agencies that sat on the committee. As such I would recommend that the implementation group be specifically tasked and resourced with truly playing a coordinating role for research, as well as include representation from the university sector. To fulfil a coordinating role the implementation group will also need to identify research needs for the implementation Shark Plan 2, communicate these to researchers and
   research funders, and preferably provide resources (including funds) to this research.

   Recommendations:

   • The implementation group contain at least one member of the university sector in recognition of the importance of this sector in the provision of research on sharks, and this member(s) be tasked with broadly representing this sector on research coordination.
   • That the implementation group be tasked with maintaining a list of current research on sharks that is relevant to Shark Plan 2.
   • That the implementation group be tasked with developing a list of research priorities to support the implementation of Shark Plan 2.
   • That the implementation group be provided with the resources to allow for effective research coordination.
     
2. The requirement for funding to support Shark Plan 2
   One of the main reasons that there was limited achievements from Shark Plan 1 is that there was no specific funding support for the plan. It is unusual that the review of Shark Plan 1 did not recognise this situation nor make any recommendation to this effect. The review did identify that Shark Plan 2 should "The resourcing implications for implementation of actions and strategies, and performance monitoring for the Shark-plan
   need to be clearer." In fact, the reality is that Shark Plan 2 will fail to achieve the desired outcomes unless a clear plan for funding the plan is provided, including the commitment by the Federal and state governments to funds to support it's implementation. The current model suggests that government does not consider that sharks represent a value to the Australian community or to Australian ecosystems. While this attitude persists, the aspirations of Shark Plan 2 will fail to be met.

   The plan identifies FRDC as the funding body from which funding should be mostly sourced for research relevant to the implementation of the plan. While FRDC can provide significant funding, this does not recognise the diversity of research that is required. Give the resources of FRDC it cannot come close to funding the majority of research required for effective implementation, and there is research required that is beyond the remit of FRDC. I have identified above that government needs to provide specific funding at levels substantially above those currently provided to ensure effective implementation of Shark Plan 2. It will not be sufficient for FRDC to provide the only funding for this research. In addition, the government should consider funding shark research in a similar way that it does for marine mammals through it's Australian Marine Mammal Centre. This would provide shark-specific funding that could be targeted at research required for Shark Plan 2 implementation.

   Recommendations:

   • That government provide specific funding for the implementation of Shark Plan 2, including for research, management evaluation, reporting, etc.
   • That government fund an "Australian Shark Centre" to provide core expertise and research funding for sharks in the same way that it does for marine mammals.
     
3. Lack of economic and social considerations
   There is a distinct lack of consideration of economic and social issues related to sharks, shark management and shark conservation. These two factors are major drivers in the fishing for sharks, compliance with shark fishing regulations, sustainability of shark fisheries, etc. Only Issue 3 deals with economic factors, and then only through issues related to markets. There is a complete lack of consideration of the value of sharks to Australia in terms of fishery production, tourism, ecosystem services, etc. On the social side of things, there is no consideration of attitude of people to sharks, the importance of sharks to individuals, communities, different fishing sectors, etc. Given the importance of these factors the plan needs to be revised to consider these aspects. This also points to the heavy reliance of biologists in the development of Shark Plan 2. I recommend that there is a directed involvement of a greater number of people with experience in economic and social aspects of sharks, shark fisheries, etc.

   Recommendations

   • Economic and social considerations be added to the issues dealt with under Shark Plan 2.
   • That expertise on economic and social aspects of sharks be included in the implementation group.
     
4. Over reliance on the use of risk
   The Shark Plan 2 document spends a lot of time talking about risk, risk assessment, and using risk to manage sharks. While risk is an important in he management of sharks, the lack of other approaches in the document provides a very one dimensional approach to shark management in Australia. There needs to be a recognition of a range of approaches to managing Australia's sharks, including the broader use of stock assessments, marine protected areas, etc.

   Recommendations:

   • That the reliance on risk be reduced, and an increase in other approaches to assessment and management be developed.
     
5. Monitoring and reporting on the progress or Shark Plan 2
   One mechanism to help improve the outcomes of Shark Plan 2 over that of the previous plan is to ensure there is a significant improvement in the monitoring and reporting of implementation. The SIRC (or other body responsible for overseeing implementation should be required to report on an annual basis on the success of implementation of each of the issues, and ensure the wide distribution of this report. Where implementation has not met the timelines outlined in Shark Plan then they should develop a plan for how these will be met. The reporting on the progress of implementation each year should also be accompanied by an annual stakeholders meeting. As far as I am aware only one such meeting was held during Shark Plan 1. This meeting provided a forum that many stakeholders found useful to understand the progress of the plan, what was being done unerring the plan, and to present issues for the SIRC to consider. Unfortunately this meeting was only held when the plan was coming up for review, and came to late foray stakeholders to have any meaningful input to the process. The engagement of a broader range of stakeholders with the implementation of Shark Plan 2 will also be important to improving outcomes.

   Recommendations:

   • Annual reporting of progress on all issues identified in Shark Plan 2, and broad distribution of this report to all stakeholders.
   • An annual stakeholder meeting be held each year.
   • That the implementation group contain a broader range of stakeholders than under Shark Plan 1.
     
6. Issues removed from Shark Plan 1
   Three issues were removed from Shark Plan 1. In my opinion one of these (Issue 16 - Reduce the impact of environmental degradation on sharks) should not have been removed. This issue is a serious one confronting sharks, and deserves to be treated as a separate issue. Current shark management and conservation plans contain very little consideration of habitat, despite there being significant data to show that this is important for many species. Given the focus on climate change within government, and the knowledge that it will affect sharks, it will be important that assessments, management and conservation take account of habitat issues.

   Recommendations:

   • That "Reduce the impact of environmental degradation on sharks" be included as an issue in Shark Plan 2.