Submission 3

Dear Sir,

In regard to Department of Agriculture Fisheries, Forestry Shark-plan 2 draft, I wish to forward observations I have made, following the period of public consultation.

Whilst The Australian government claims to be committed to the conservation and management of Sharks and their long-term sustainability, consistent decline of shark populations as a result of fishing activities and beach netting programs continue to reinforce evidence that suggest sharks are not a sustainable species.

Well documented research indicates most Shark species cannot withstand the increasing pressures that modern fishing practices and technologies inflict. This is due to a slow growth rate, lateness of sexual maturity and few offspring. These characteristics make them especially vulnerable to overfishing and once depleted Sharks can take years, decades or more to recover. Some fisheries that collapsed in the first half of last century have yet to recover. Since implementation of Shark-plan 1 in 2004, the Northern reefs of Australia have all but depleted stocks of the Silvertip Whaler and Scalloped Hammerhead species.

Subsequent to a 3 year review of Shark-plan 1, many aspects of Shark-plan 2 have not been addressed effectively where shark protection is required. As this issue is of global concern and being that ALL shark populations are in decline, protection should be decisive and of high priority, with much needed transparent management recommendations that can help reverse the steep declines of many shark populations and begin rebuilding them. Further, The Australian Government should acknowledge that there is considerable lack of reliable data on which to base shark management, their inherent vulnerability to overfishing and that the prospects for achieving ecologically sustainable shark fisheries in the future are indeed very low.

Shark-plan2 is not indicative to achieving the targets of long-term sustainability, as some issues are noted as medium and low priority and therefore does not propose decisive actions.

Issue 13 raises immediate concern where a medium priority is set relative to that stated at action 28.
Where critical Shark numbers are known or assumed, such priority must be high in order to meet this very issue. The levels of protection for Grey Nurse Sharks should be strengthened so that all identified critical habitat sites are protected by a minimum 1500m radius no take marine reserve. In addition, critical habitats should be identified and protected as would be for all other shark species listed as threatened. Any and all Shark species identified as being critically endangered should be given national protection and a moratorium declared on the fishing of these species in accordance with Issue 13.

Medium should be removed leaving High priority for Issue 14, reduce or eliminate Shark bycatch.
Sharks are easily identifiable and non-target species should be released immediately once caught and identified. Issue 1 is suggestive to the use of identification guides, however priority should be given to all fishermen and these guides should be compulsory and rapidly accessible on all fishing vessels. In addition, where a species is not appropriate for targeted fishing due to poor or unknown conservation status then every effort should be made to avoid its capture. Allowing bycatch species to be sold commercially as by-product simply encourages their continued capture. Further research and development into new mitigation measures for shark bycatch are urgently required. Bycatch species should not be sold commercially (or marketed) as by-product.

Given the high pollutant content of shark, particularly mercury, careful consideration should be given to Issue 3, dealing with the full utilisation of dead sharks and the understanding of markets for trade in shark products. Since this is a public health issue, the public should be informed of the potential health risks that arise from shark consumption, especially during pregnancy. The use of shark in the fabrication of animal fodder is also pertinent as mercury is a toxin that accumulates in every organism that consumes it. No understanding of the trade in shark products is necessary- the Asian demand for shark fin has been the driving factor for increased shark fishing over the last 3 decades. In order to protect shark populations worldwide, there is a growing demand for this product to be banned. Australia could contribute to this by no longer exporting shark fin to Asia. Shark populations in Australian waters would rapidly recover- Issue 13.

Nowhere in this draft can mention be found in regard to quotas or even species specific quotas.
Having set quotas and species specific quotas is vital strategy to Issue 1, relevant to issues 5, 8, 11 & 15.
Quotas are essential to avoid over-exploitation of specified stocks where target fisheries are concerned.
Quotas should also be mandatory to marinas not participating in the Shark Free Marinas initiative.
Quotas for Indigenous shark fishing should also be set.

Minimum size catch is not at all mentioned in this draft either, yet it is biologically and scientifically known that Sharks sexually mature late. Size would be indicative of such maturity and differing sizes at maturity between species is also of valid point and should be founded via biologists, researchers and the like. Minimum sizes should be imposed on all sectors of shark fisheries and should comply with the rationale of issues 5, 8, 11 & 15 to meet that of Issue 13.

At Issue 12, there is already plenty of data available on shark biology, therefore assessments should be and concluded rapidly at action 24, where noted, shark stocks not yet assessed. Immediate priority should be given to these species and until so, numbers of those species should be assumed as low.

In accordance with Issue 2 and in prolongation of Issue 4, catch data should be compulsory for recreational and indigenous fishermen. This data would advance the risk assessment objectives of Issue 12 and reduce the necessity to assess the need for further assessments at action 26. Actions to improve the impact of recreational fishing at Issue 8 should be increased from medium to high priority.

Where shark bycatch or non-targeted species are caught, Issues 6, 8, 12 & 14, the use of circle hooks should be compulsory to reduce cryptic mortality upon the release of these sharks. The use of appropriate fishing gear should be implemented.

Vague mention of Bather protection at issue 15 finds no mention of action in this draft. Shark nets design is to keep Sharks from entering bathing zones, yet many sharks killed in these nets are caught shore-side trying to get back to the ocean. Many, many Shark sightings where nets are in use have proven harmless upon bathers. Since many species are harmless to humans consideration should be given for removal with regard to increasing fatalities of marine life, Sharks or otherwise. Nets should be of a more rigid material and of a much finer mesh.

Issues 16, 17 and 18 of Shark-Plan 1 have not been discussed in this draft. Whilst Issues 17 and18 have more relevance to the scientific community and shark research, the reduction of the impact of environmental degradation on sharks referred to in Issue 16 is an essential issue and should be addressed as per the FAO's recommendations in their International Plan of Action - Sharks, in 1999. Human impact on shark habitat is counterproductive to the recovery of species, Issue 13. Mangroves and other pupping sites are being destroyed to create marinas and other infrastructures prioritising human recreation. Offshore drilling also destroys shark habitat and in case of an accident, as happened recently in the Gulf of Mexico, the habitat of thousands of other marine species will be compromised. Environmental factors should be given as much consideration as commercial ones.

As it is known that sharks are essential to the health of all marine eco-systems and ultimately to the health of the world's oceans, their demise will be detrimental to the planet as a whole and not just individual nations.
The decline in shark populations can lead to unpredictable consequences, including the collapse of fisheries.

The fact that Australia has developed a "Shark-Plan" is to be applauded, but there is very little point in having any form of protection plan if its objectives are weak and ineffective, particularly since decisive shark protection must now be implemented rapidly. I hope my observations will be considered so that "Shark-Plan 2" becomes an effective and decisive plan to saving the sharks of Australia and the world.

The following letter was submitted by

Paul Garland [sswagman@tpg.com.au]
Paul Crooks [pdchtc@gmail.com]
tiomanjimi@gmail.com; on behalf of; Azimi Azmin [azimi@helpourpenyu.com]
archimedes favoured principal [negativebuoyancy@gmail.com]
Zaharah Mat Ali [dawusarah@yahoo.com]
nana bibi [tessuto_anna@hotmail.com]
KC Hau [kokcheong_no3@hotmail.com]
Aaina Karina M Senawi [aainakarina@gmail.com]
Justin Hill [beck_justin@bigpond.com]
noreha md jani [kawahi21@yahoo.co.uk]