Commonwealth Fisheries Association

18 July 2011

Manager, Fisheries Policy and Environment
Department of Agriculture Fisheries and Forestry
GPO Box 858
Canberra ACT 2601

Submission – Australia’s 2011 National Plan of Action for the Conservation and Management of Sharks – Shark-plan 2

The Commonwealth Fisheries Association (CFA) welcomes the opportunity to contribute to the development of Sharkplan. We also welcome the recognition of progress in shark conservation as a result of Shark Plan 1, including by the fishing industry. It is noted that the ongoing management of shark fisheries and conservation are currently addressed in Commonwealth fisheries management arrangements.

CFA in-principle supports the issues for shark conservation and management identified for Sharkplan 2.

CFA believes that Issue 16, Reduce the impact of environmental degradation on sharks should be relevant to Sharkplan 2. We note that this issue was identified in Sharkplan 1 with little/no progress made during the life of that plan. CFA recommends that this issue must be addressed in Sharkplan
2 particularly as habitat degradation is widely identified as both real and potentially significant impacts on some shark species.

CFA considers that Sharkplan 2 is ambitious in the priorities that it proposes. We note that resourcing for implementation of actions has been identified as key to the effectiveness of this plan but question the ability of existing management strategies to accommodate the resourcing required, particularly within a 1224 month period as allocated for most of the identified issues and actions. We believe there is potential for raising unrealistic expectations of key stakeholders eg governments, fisheries managers and the fishing industry, about what will be achieved, and, in not meeting the priority targets, leave the Department and fisheries management open to attract potential unwarranted criticism when realistic progress may nevertheless have been achieved within the timeframes. CFA considers that additional resourcing, for fishery managers and research in particular, will be required to meet the objectives as proposed.

Yours sincerely

[signed]

Trixi Madon
CEO