Tropical Tuna

Manager, Fisheries Policy and Environment
Department of Agriculture Fisheries and Forestry
GPO Box 858
Canberra ACT 2601

c/- 27 Saltair Street
Kings Beach
QLD 4551

Dear Sir/Madam

Eastern and Western Tuna and Billfish industry feedback on draft Shark-plan 2

Thank you for the opportunity to comment on the draft of Australia’s 2011 National Plan of Action for the Conservation and Management of Sharks (Shark-plan 2).

The East and West Coast tuna industry sectors mainly use pelagic longlines to target tuna and Swordfish and operations include some shark bycatch (mainly oceanic species). Both sectors already operate under a precautionary framework with respect to sharks notably trip limits (a basket 20 sharks per trip), bans on finning and on the use of wire traces. Both sectors have had substantial observer coverage over the last ten years and industry considers that the observer data on shark bycatch is robust with respect to shark species composition (identification), catch rates and condition upon release (most sharks are not retained).

Industry is supportive of measures to protect sharks that are vulnerable and/or characterised by low fecundity but also supports recognition in the Shark-Plan 2 that there is a sustainable position for more productive shark species across number of fisheries. Tuna operators do not wish, and are not entitled to target sharks however value their access right to retain limited quantities of some species as byproduct and have made efforts to develop markets for all species retained for human consumption.

Industry works with AFMA to embed Ecological Risk Management (ERM) practices in both fisheries. Operators recognize there is uncertainty in our understanding about some shark species taken as bycatch and can accept precautionary approaches are needed when risk assessments indicate information is poor and particularly where observer data indicates there may be higher rates of release mortality for less robust species.  In summary industry is prepared to work with government when management responses have been developed with reference to domestic assessments, legislation and policy (including the Fisheries Management Act 1991 and Environment Protection and Biodiversity and Conservation Act 1999).

By way of contrast industry has been forced to wear measures applying to Shortfin Mako and Thresher Sharks as a result of resolutions agreed at international conventions which to a large extent were based on overfishing in other oceans. The ban on retention of Thresher Sharks for our domestic fleet, for example,  is unlikely to save any more Thresher Sharks (they let them go anyway) but creates an ongoing compliance and inspection burden.  It is reasonable to assume however that the retention ban will just mean high seas fleets still using wire traces will just retrieve these sharks and then discard them with little regard for their survivorship.

We note the emphasis in Shark-plan 2 on regional capacity building and encourage DAFF to continue supporting meaningful management measures rather than blunt measures that usually create problems for states with decent management frameworks but have little impact on fleets operating without much restraint.

Industry accepts the Government is in a difficult position here (given it is a signatory to these agreements) but would urge DAFF to draw a line in the sand so that the translation of international obligations into domestic arrangements does not have to mean that all measures have to be replicated exactly.

At a more strategic level industry notes that the current Offshore Constitutional Settlement (tuna and tuna like species) currently cedes management responsibility for all sharks (including oceanic species) to the states. Industry would like to see some acknowledgment in Shark-Plan 2 that this needs to be addressed so that the responsibility for managing fishery – shark bycatch is better aligned with jurisdictional reality.  We accept that some species aren’t neat fits but note that there are a number of oceanic species that are virtually unknown in state waters and state managed fisheries but are fairly common offshore.
 
The East and West Tuna industry sectors appreciate the opportunity to provide feedback on draft Shark-plan 2.

Yours sincerely

[signed]
 
Industry Liaison Officer - Tropical Tuna MAC
15 July 2011