CSIRO - comments on draft Shark Plan

20 July 2011

The Manager
Fisheries Policy and Environment
GPO Box 858
Canberra ACT 2601

Comments on Shark Plan-2

I have enclosed a synthesis of comments on the draft Shark Plan 2 from Scientific staff at CMAR.

Yours sincerley

[signed]

Barry Bruce
Senior Research Scientist

CSIRO comments on Australia’s draft National Plan of Action for the conservation and Management of Sharks (Shark Plan-2)

Shark Plan 2 (SP2) provides a series of actions for the on-going conservation and management of chondricthyans (herein ‘sharks’) in Australian waters. Its development has been based on a review of progress against listed actions in Shark Plan 1 (SP1 -2004) and an updated assessment of current conservation and management issues. In general, the plan articulates the primary issues surrounding conservation and management of Australian sharks and the actions required to address these issues. However, of key importance is not only the articulation of actions but establishing a process of effective implementation and most importantly, establishing a transparent and consistent framework to assess progress against these actions across jurisdictions. This was one of the clear limitations to SP1 and this point is well discussed in the available review document (Review of Australia’s 2004 National
Plan of Action for the Conservation and Management of Sharks - Shark Plan 1: Final Report). Achieving this will require clearly specified and consistent performance measures and reporting templates from which to effectively evaluate evidence of progress against these performance measures. In general, it is not clear how SP2 will improve on these implementation, evaluation and reporting issues. This is a significant area to be addressed, although it may need doing so in the context of the Shark-Plan Implementation and Review Committee.

Specific comments on issues raised or not addressed in SP2 are provided below.

Issue 1: Improved identification of shark species
Issue 1 identifies the important ongoing need for improving species identification and the role that identification guides and effective log book designs play in both improving the identification of species and enable efficient reporting of catch. A key sub-heading under Issue 1 is:

“ensure the best available guides have been provided to relevant user groups, including fishers, processors, compliance officers, observers and scientists”.

It is vital that such guides are accurate and up-to-date, particularly given the high degree of endemism of Australian sharks and the challenges involved in some species’ identification. While regional identification guides provide local relevance, it is crucial that identification guides follow a national standard and be subject to a level of quality control. Taxonomists active in the field should be consulted when guides are being produced as reliance on previously published information, particularly older literature, can be misleading. It will be important to review guides over time to ensure they are up to date. Initiatives such as the Atlas of Living Australia will provide a useful link for guides as this will have images for all species, their distribution and will be searchable for species in given geographic areas.

Given the importance of species specific identification, an assessment of the effectiveness of identification guides in improving the skill of fishers, observers,
scientists and the public in general is a vital prerequisite to forming a useful national standard. While is it important for all jurisdictions to take this action on-board, unless this is coordination at a national level, the result will continue to be a mix of different styles, quality and accuracy of guides that may not always achieve the best outcome. Consistency in guides produced for different areas or fisheries would also facilitate a common approach to species identification across jurisdictions and reduce costs in production.

Issue 2: Secure accessible and validated data sets that record all catch data
Although presumably covered by the intent of Issues 1 and 2, the lack in documenting catch at species level remains a key factor for some target shark fisheries in Australian waters. All target shark fisheries should have a minimum reporting standard for species level data and this needs to be a clear statement in the plan. There are similar concerns regarding fisheries that take sharks as by-product or bycatch.

Issue 6: Reliable assessments for shark by-catch/by-product
Also related to Issues 5, 2 and 1. Listed actions remain poorly articulated in this area of the plan. It is unlikely that catch and effort data will provide sufficient information on bycatch species to enable useful assessments of status in the short and medium term, even if accurate reporting is achieved. The lack of historical time-series in data sets will preclude such assessments. There is a need for research into alternative methods of estimating abundance with priority application to species or species groups determined to be of high vulnerability. Most methods of estimating abundance/status are also likely to require an understanding movement patterns. Thus further research in that area is also required.

In species-diverse fisheries there is an ongoing need to obtain observer-collected data to obtain accurate species composition. Incomplete observer coverage can lead to biased assessment of catch. Observer coverage is expensive and unless other objectives such as collection of biological data, tagging etc need to be collected, an alternative for some jurisdictions may be to at least monitor catch when it landed at the first point of sale. This could be done through identification of whole sharks, trunks or alternatively using morphometric identification of fins and or genetic methods (or a combination of these). This latter monitoring tool naturally precludes assessments of bycatch composition.

The cost-effectiveness of available monitoring methods requires evaluating to determine the most cost-effective and appropriate means of identifying and
quantifying elasmobranch catch from multispecies fisheries.

Issue 7: Assessment of the adequacy of management for all shark species..
Recurrent stock assessments are available for relatively few targeted shark species in Australian waters and thus the means to evaluate the efficacy of introduced management measures by robust iterative process are few. Application of the precautionary principle has seen the introduction of management measures such as size limits, trip catch limits, reduced total allowable catches and spatial closures in some regions. While these measures are a positive step, there is often no means of evaluating the effectiveness of these management initiatives. In multi-species shark fisheries where gear selectivity precludes species-specific targeting, management measures should be directed towards the most vulnerable (high risk) species within catches and quantitative data are required to assess whether implemented management initiatives are having the desired effect.

Issues 9 and 10: Reduce cryptic mortality and improved handling practices
Cryptic mortality remains an important issue and is addressed within the plan. However, the definition of cryptic mortality needs to be further addressed. In most cases cryptic mortality refers to the death of a captured animal after its release, the latter in ‘good faith’ believing that it will survive. ‘Reproductive mortality or ‘interruption’ may be a significant issue for some species. For example the stingarees (Urolophidae) are considered relatively hardy and will generally survive trawl capture, landing and release. However, they can have a long gestation period (11 months) and a large percentage of pregnant females abort their young prematurely when caught. Thus, although females are surviving, they have they may lose an entire annual reproductive effort. Populations of such species may decline as a result, but this would go unrecorded since the animals are not retained and are considered to survive release. Several species of rays are vulnerable to this effect. Such issues may be too detailed to include in SP2 but require some consideration when setting future
research priorities.

Issue 12: Risk assessments for all shark species from all impacts on those species.
The importance of risk assessment approaches, their refinement and application to shark fisheries is well acknowledged in the document. Although stated in the document, we reiterate that refinement of risk assessment approaches without a concomitant improvement in data will not achieve the most beneficial conservation or management outcomes. There needs to be a balance between reactive species-specific responses to issues and proactive coordination of data collection which in some cases might best be achieved across ecological groups.

Issue 13: Develop strategies for the recovery of shark species and populations.
Recovery plans for threatened and endangered shark species require clearly defined performance measures from which to evaluate the efficacy of actions and ways of monitoring the impact of these actions.

Issues not addressed

Regional (Australasian) cross-jurisdictional issues
Although cross-jurisdictional issues are raised in data sharing, research partnerships and management strategies, these are primarily raised in the context of State and National boundaries. Several shark stocks are shared between Australia and it’s regional neighbours (in particular, some pelagic and tropical species). An improved understanding of shark catches in the Australasian region and developing capacity in Australia’s regional neighbours to improve their data collection and management capacity is key to determining the full impact of harvesting on Australia’s shared shark stocks.

IUU Fishing
Illegal, unreported and unregulated shark catches in the Australasian region remain a significant issue and is not raised in SP2. There is an ongoing need to evaluate and quantify the catch and effort of IUU in, particularly, northern Australia both in the context of cumulative impacts on Australian shark stocks as well as from an ecosystem perspective.