The Wilderness Society Australia Inc

The Wilderness Society Australia Inc
ABN 21147806133
0439 657 645
www.wilderness.org.au
roberta.dixon@wilderness.org.au

Ian Thompson
Executive Manager
Sustainable Resource Management Division
Department of Agriculture Fisheries and Forestry
GPO Box 858
Canberra ACT 2601 600

7 July, 2011

Dear Mr Thompson,

RE: Australia’s draft 2011 National Plan of Action for the Conservation and Management of Sharks (Shark-plan 2).

The Wilderness Society would like to would like to thank you for this opportunity to comment on the draft of Australia’s 2011 National Plan of Action for the Conservation and Management of Sharks (Shark-plan 2), hereafter referred to as ‘Shark-plan 2’. The Wilderness Society has had a long standing interest in the management of our marine environment and considers Shark-plan 2 an opportunity to redress some of the ongoing impacts on shark species.

The cumulative impacts of Australian fisheries on individual shark species remains the key threat to Australian sharks. This impact is predominantly from the commercial sector however the recreational fishing sector does have a significant impact on shark species. In NSW recreational fishing is directly impeding the recovery of the east coast Grey Nurse Shark (Carcharias taurus) population. The NSW Department of Primary Industries has identified hook and line fishing as ‘the major threat to the species survival’ and acknowledges ‘significant progress has been made in the commercial fishing sector however similar changes have not occurred in the recreational sector’¹.

As a case in point, The Wilderness Society is concerned that Shark-plan 2 does not propose any action or tool which would assist in addressing the long-standing decline in the east coast Grey Nurse Shark population. Issue 8, Table 2 of Shark-plan 2 simply calls for further review of management actions pertaining to recreational and game fishing. This is a species that will be reviewed to extinction at this rate.

Critical habitats should be determined and protected for all shark species listed under Federal/State legislation, and Recovery Plans integrated (where species are crossjurisdictional), implemented and progressed. The Federal Government should be proactive in working with the State/Territory governments on implementing effective measurable management outcomes, including timeframes and budgets. The Federal government needs to direct the State Government in terms of management arrangements where there are obvious and ongoing signs of failure in terms of shark species management at the State level (i.e. State Government not addressing key threats and no sign of species recovery).

Shark-plan 2 should involve the abolishment of the Bather Protection Programmes (Action 12, Table 2). There are two programmes by the NSW and Qld Governments that fund the killing of listed endangered species. These programmes are designed not to exclude sharks, but to reduce their numbers significantly.

Other issues with Shark-plan 2 include:

• Shark-plan 2 lacks significant actions, in particular it has less specific actions than the previous 2004 Shark-plan 1.
• Shark-plan 2 lacks an implementation strategy.
• The Shark Implementation Review Committee (SIRC) needs to include stakeholders not just government. The SIRC oversee and implement the Shark-plan, but committee members are comprised of representatives from fisheries agencies (state/territory and Commonwealth), GBRMPA and AFMA. Significantly, there are no NGO stakeholders on the committee.
• The benchmark for precautionary principle risk assessment should be the CSIRO/AFMA Ecological Risk Assessment approach.

Yours sincerely,

[signed]

Roberta Dixon
Marine Working Group Convenor

^{1 NSW Department of Primary Industries, 2011. Discussion paper for Grey Nurse Shark Protection.}