Queensland Government - Deptartment of Employment, Economic Development and Innovation

Reference: 06176/11

Department of Employment, Economic Development and Innovation Sustainable Resource Management Division

Mr. Ian Thompson
Executive Manager
Department of Agriculture, Fisheries, and Forestry
GPO Box 858
Canberra ACT 2601

Dear Mr Thompson

Comments on the draft 2011 Shark-plan 2

I am writing in response to your advice of 12 May 2011 regarding the public ~~Iease of the draft 2011 National Plan of Action for the Conservation and Manag!Jment of Sharks (Shark-plan 2). Fisheries Queensland, a service of the Department of Employment, Economic Development and Innovation, appreciates the opportunity to contribute to this plan.

I support the national integration of measures to conserve sharks and effectively manage the sustainable use of more resilient species and I see significant benefit in a strategic plan that consolidates these measures. I also acknowledge the considerable work that has gone into the review.

As you are aware, the management of Queensland's fisheries that capture shark has undergone significant enhancement since Shark-plan 1 was introduced in 2004. The review has provided a timely opportunity to highlight the remaining gaps in fisheries management and marine biodiversity conservation regimes applying to sharks and to re-prioritise necessary future shark conservation and management actions.

Fisheries Queensland's comments on Shark-plan 2 centre primarily on the following recommendation of the review of Shark-plan 1:

REV-C1. Provide the Shark-plan with more authority, credibility, and enable improved management and research coordination through a range of mechanisms. The resourcing implications for implementation of actions and strategies, and performance monitoring for the Shark-plan need to be clearer.

The review of Shark-plan 1 was seen as a major opportunity to develop realistic, deliverable actions with a greater level of accountability. However, achieving this was acknowledged to be contingent on available resources and implementation mechanisms in both fisheries management agencies and biodiversity conservation agencies.

Shark-plan 2 states that 'As the plan does not have a dedicated budget for implementation the actions within the plan are expected to be achievable within the existing budgets of fisheries management and conservation agencies'. My major concern is that the resourcing and implementation mechanisms have not been assessed to the extent necessary to ensure the delivery of actions within Shark-plan 2 particularly within the specified timeframes.

Fisheries Queensland has committed significant resources in recent years to delivering actions from Shark-plan 1 but we consider the timeframes for completing 'high priority' actions in Shark-plan 2 (Le. 12 months from commencement) are unrealistic.

In light of the concerns raised above I strongly recommend that:

1. Resourcing and implementation mechanisms are fully assessed by fisheries management and biodiversity conservation agencies in all jurisdictions through the development of northern and southern Regional Operational Plans.
2. The timetable for delivery of actions based on their priority level is removed from Shark-plan 2 and addressed through Regional Operational Plans to ensure that actions can be meaningfully delivered within the overall lifespan of Shark-plan 2.

Also of concern is that habitat modification is absent from the issues identified in Table 1 as needing to be addressed in Shark-plan 2. There are several rarely encountered, vulnerable or threatened sharks, sawfish and ray species that occur in northern Australian inshore and coastal waters that have suffered from inshore habitat modification.

Their survival and possible recovery particularly on the northeast coast is dependent on appropriate fisheries and coastal management actions. This matter is within the capacity of national and jurisdictional conservation agencies to address and should be given greater prominence in the document generally.

Fisheries Queensland has made some additional specific comments within the draft document. I anticipate that consideration of those comments as well as the above matters will occur through the forum of the Shark Implementation Review Committee.

If you have any specific questions or require any further detailed information on the above comments, please do not hesitate to contact Ms Tara Smith on telephone 07 3405 6825 or email tara.smith@deedLqld.gov.au.

Yours sincerely

Maria Mohr
Managing Director
Fisheries Queensland