Western Australian Naturalists Club

14 July 2011

I write to you on behalf of the Western Australian Naturalists’ Club to lodge a formal submission on Australia’s 2011 National Plan of Action for the Conservation and Management of Sharks: “Shark-plan 2”

The Western Australian Naturalists’ Club is a well-established organisation, founded in 1924,with currently more than 600 members who are actively involved with education, research, publications and submissions in the field of natural history and nature conservation. We host over 120 activities each year including public lectures, meetings and excursions. Amongst
our regular publications is the widely-distributed scientific journal “The Western Australian Naturalist”.

Our club has reviewed the draft document known as Shark-plan 2 and found it lacking. While we commend the Government for undertaking a review of Shark-plan 1 and for providing an opportunity for public comment on the proposed new Shark-plan 2, the new document is weak in that it backs down from tackling some of the tough but important issues of shark conservation. Many of the proposed actions are passive in nature, requiring jurisdictions to “consider” various measures, and “assess” the potential of other measures.

These types of actions are difficult to audit and are unlikely to lead to real environmental change or improved management of shark populations. Specific issues of concern for our club are as follows:

• Shark-plan 2 should ban the import of shark products derived from unsustainable fisheries. Importers of shark products should be required to demonstrate that their products are source sustainably. This would simultaneously act to put pressure on other countries to manage their shark fisheries sustainably and would also act to educate Australian consumers about the threats faced by shark populations world wide. Such an action would be a direct implementation of one of the stated aims of the draft Shark-plan 2 document which states: Australia’s approach to the conservation and management of shark resources should be guided by the principles of Ecologically Sustainable Development, with particular attention given to the
  application of a precautionary approach in the absence of more comprehensive information (page 3). Action no.7 is noted but it only requires an assessment of trade issues – assessing issues is not taking action.
• Greater emphasis should be given to ecosystem based management measures and research, this does not get sufficient attention in the draft Shark-plan 2 even though it is highlighted in the review of Shark-plan 1. As part of this, CSIRO/AFMA Ecological Risk Assessments should be used to assess and determine risks to sharks from fishing. Action no.35 is noted, but it only requires the consideration of ecosystem structure and function. The requirement to consider something is a very weak stance, this should be revised to require real action and improvement.
• Improve transparency and accountability by including representatives from environmental NGOs in the Shark Implementation Review Committee.
• Include a resourcing plan and funding commitments to ensure the actions of the plan are delivered.

Thanks again for the opportunity to comment on the draft Shark-plan 2. Our members are looking forward to reviewing a finalised and strengthened policy document in due course.

Yours sincerely

[signed]

for Roz Hart
President, Western Australian Naturalists’ Club