Archived page, Submission Draft National Plan of Action for the Conservation of Sharks

Submitted to the Shark Advisory Group Secretariat Department of Agriculture, Fisheries and Forestry - Australia 13th August 2002

Recfishwest is widely recognised as the peak representative body for Western Australia's recreational fishers. As such we have a strong interest in ensuring the sustainability of marine resources, including shark species, and are pleased to respond to the above mentioned draft plan

Recfishwest considers that the draft plan represents a sound scoping paper. It thoroughly describes all the major issues affecting sustainability of sharks in Australian waters, as well as comprehensively outlining a series of desirable actions with timelines. However, whilst we broadly endorse the intent of the document we have significant concerns with respect to the capacity of Fisheries Agencies in Australia to resource and implement the recommended actions.

Recfishwest does not believe it possible or realistic to expect that the plan can be met with the timelines proposed. We base this view on the following:

Firstly, we have already observed, within several fisheries management forums, the difficulty in obtaining relevant catch data from Commonwealth managed fisheries. Given the variable movement and susceptibility of sharks between State and federal fisheries, the plan cannot be effectively implemented without a significant improvement in the performance of Commonwealth fisheries management agencies.

While the draft plan, together with the shark assessment report, may signal a welcome change in this regard, Recfishwest is not confident that the commitment to achieve a meaningful outcome has significantly changed.

Secondly, the plan makes no allowance for the competing priorities placed upon State fisheries agencies and managers. Unless the plan comes attached with significant additional federal funding, it is difficult to expect that stakeholder groups would support the unlikely prospect that State fishery agencies would tilt resources to this sector at the expense of other very valid concerns and without proper consultation.

Nevertheless, Recfishwest is currently very concerned that the sustainability of both whiskery and dusky sharks in WA is at risk.

Research advice has consistently shown that the whiskery shark stock is unlikely to meet its biomass targets without significant fishing effort reductions. In addition recent information has raised major concerns that dusky shark stocks are at significant risk of collapse due to the increasing and unmanaged take of adult sharks by State and, to a greater extent, Commonwealth fisheries.

In neither case do we consider that the current actions, in place or proposed by the Department of Fisheries WA or the Commonwealth are sufficient in satisfying the requirements of the 'precautionary principle'.

Therefore, whilst we endorse the scope and intent of the draft plan, we suggest that the plan be modified to facilitate a process to determine a list of up to five key management priorities for immediate action, with clearly identified costs and a commitment to meeting these costs. Stakeholder involvement in the development of these priorities must not be limited to commercial interests and fisheries managers. It must include a proper number of recreational and conservation representatives.

We would be very pleased to be able to assist at the national level, through our national body, Recfish Australia, in progressing such an outcome. Please do not hesitate to contact our office should further information or clarification be required.



This page last updated on 30 December 2003.