Environment Tasmania

Ian Thompson
Executive Manager
Sustainable Resource Management Division
Department of Agriculture Fisheries and Forestry
GPO Box 858
Canberra ACT 2601 600

20 July 2011

Dear Mr Thomson,

Thank you for providing the opportunity to provide comment on the Draft Plan of Action for Sharks (Shark Plan-2), and sincere apologies for the delay in sending our submission. We hope that you can consider it in the review of submissions.

Environment Tasmania has 25 member conservation organisations with a collective membership of over 5000 Tasmanians from across our island state. The principle purpose of Environment Tasmania and our member groups is the protection, conservation, or rehabilitation of the natural environment. Our work covers issues such as marine and coastal protection and management" forest and water conservation, climate change and pollution.

We highly support proactive and planned action on shark. protection and management. However, the NPOA-21acks action and has even less specific a~tions than NPOA-1, which itself has been critiqued for its failure for actior:J. .

The NPOA-2 lacks an implementation strategy. This is particularly necessary if any of the state departments are meant to be engaged to take action. .

The Shark Implementation Review Committee (SIRC) currently does not include NGO stakeholders. This is a severe shortcoming of the Committee, as it should have a range of stakeholders, including NGOs represented to ensure it can fulfill its role in overseeing and implementing the Shark-plan effectively.

The finning ban - where sharks landed with fins naturally attached - should be explicitly adopted across all states and territories, consistent with that adopted by the Commonwealth.

The introduction of comprehensive trade codes for import and export should be developed. The codes are currently not specific enough to enable monitoring of Australian trade in shark products. In line with this, there should be an official process for assessment and restriction of imports of shark products derived from non-sustainable sources.

To work on decreasing shark by-catch, Environment Tasmania support trials of the suggested mitigation actions from Patterson, H.M. and Tudman, M.J. 2009. Chondrichthyan guide for fisheries managers: A practical guide to mitigating chondrichthyan bycatch (Bureau of Rural Sciences and Australian Fisheries Management Authority, Canberra)

It is well known that protection of critical habitats for all species listed under Federal and State legislation is a must-do for any management and protection plans deaiing with threatened species. Likewise for all species of sharks listed under State and Federal legislation, critical habitat should be determined and protected. This information should be communicated and actioned through an ImplementatiCm Plan to all States and Territories.

Rebecca Hubbard
Marine Coordinator
Environment Tasmania Inc.