Nature Conservation Council of NSW (NCC)

Friday, 15 July 2011

Dear Sir/Madam

Thank you for the opportunity to comment on the Australian National Plan of Action for the Conservation and Assessment of Sharks (Shark-Plan 2).

The Nature Conservation Council of NSW (NCC) has a long history of involvement with the conservation of sharks in NSW waters, including participation with consultation on Shark-Plan 1, representation on many State-level fisheries management advisory committees, and active campaigning for improved management for the endangered grey nurse shark.

The conservation of grey nurse sharks has suffered a recent setback in NSW as the result of the rollback of protection of key aggregation sites by the NSW Minister for Primary Industries Katrina Hodgkinson. Greater leadership is currently needed from the Federal Government in the protection of critical shark habitat to ensure a nationally consistent approach that is reflective of current international best practice.

The lack of additional resourcing to the implementation of Shark-Plan 2 shows a lack of commitment on the part of the Federal government to achieving its aims. The goals of Shark-Plan 2 cover both State and Federal waters and the NSW government needs strong encouragement from the Federal government to implement best practice management and ensure the conservation of sharks.

Adequate resourcing forms a critical component of making Shark-Plan 2 achievable on the ground.Similarly the lack of a detailed implementation strategy suggests a lack of commitment on the part of the Federal government to achieving the aims of Shark-Plan 2. There should be much clearer focus within the Plan on the measurement of progress, and statement of consequences resulting if actions are not achieved.

As a peak environmental representative body under the NSW Fisheries Management Act 1994, NCC strongly encourages representation of conservation stakeholders in aquatic resource management processes. I note that the Shark Implementation Review Committee (SIRC) does not include such stakeholders, despite the significance of shark conservation within the national and international arena. NCC would strongly support the inclusion of a stakeholder representative from the conservation sector within the SIRC as a result of this review process.

NCC calls upon the Federal government to exercise leadership in the area of shark finning bans by implementing the Commonwealth requirement for sharks to be landed with fins naturally attached.

Action 6 in Table 2 should be specific about the nature of the shark finning ban which should be implemented as a result. Shark-Plan 2 should also specify that the CSIRO/AFMA ecological risk assessment approach is used to assess the risk to sharks in Australian waters.

The AFMA Chondrichthyan technical working group progressed discussions on mitigation of the catches of sharks that are at risk. The actions under issue 12 of table 2 should explicitly refer to the implementation and trials of the findings in 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

NCC encourages fisheries management that considers the harvest effects of all fishing sectors. There are a large number of recreational fishers who also exploit shark stocks, and in many cases the recreational fishing harvest is far in excess of the commercial harvest. NCC is concerned at the implications of this unmonitored harvest on shark species, which should be given higher management priority through Shark-Plan 2 at both the State and Federal levels.

Yours sincerely

[signed]

Pepe Clarke
Chief Executive Officer
Nature Conservation Council of N.S.W.