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Dear Hon. Minister for the Environment Greg Hunt MP,

 

I strongly encourage you to reject the Government of Western Australia’s proposal for a 3 year, lethal drum line program as part of its broader shark hazard mitigation policy. There is insufficient scientific evidence to justify the continued destruction of wildlife that are listed nationally and internationally as of conservation concern, both in terms of ocean user safety, and with respect to potential impacts on these shark populations.

  

You should reject the proposal on the following grounds:

  

(1) The proposal presents no evidence to suggest that the lethal drum line program, as implemented, will make ocean users safer. The document justifies safety outcomes on the back of netting or mixed netting / drum line programs despite netting having been rejected in WA on the grounds of their excessive impacts on ocean wildlife. The proposal ignores relevant hook-only examples from Hawaii (that showed no improved safety outcomes despite a 16 year long line program that captured nearly 300 tiger sharks a year (comparable to the expected take of tiger sharks in the WA program)) and Queensland beaches where only drum lines are used (Wetherbee et al., 1994).

  

(2) The proposal does not adequately assess non-lethal alternatives such as the South African shark spotter program and Brazilian tagging program as viable options for Western Australia (Hazin and Afonso, 2013). We are particularly interested in the shark spotter program as it has directly provided surfers with increased knowledge about the timing and location of white sharks at popular surf breaks so in addition to direct warnings, surfers have better information to evaluate risk.

  

(3) White sharks are globally threatened and as such we should be supporting recovery rather than adding additional pressure. Estimates of white shark population numbers are uncertain and the Department’s ability to predict how many they will catch is also uncertain. Thus a more appropriate approach in assessing potential risk should be applied. A recent report from South Africa, based on genetics and mark-recapture analyses, suggests that the South African population of white sharks, once considered to be the largest in the world, is an order of magnitude smaller than previously estimated(Andreotti et al. 2014) and the best peer-reviewed estimate to date suggests approximately 700 breeding white sharks in south western Australia (Blower et al. 2012). As the targets are also all large individuals that are mature or nearly mature, significant caution should be applied in evaluating population risks and that is not the case in this proposal.

  

(4) The proposal considers that there will be a “negligible” effect of capturing an estimated 900 tiger sharks over the period because the tiger shark population is in reasonable condition, tiger sharks are relatively resilient to exploitation and the proposed catch is about 50% of historical catch levels in fisheries that are now closed. No estimates of population size are presented, the assessment ignores the sex ratio of large (>3m) females to males in the trial (4:1; equating to 720 females over the proposal period) and the comparison to historical catch does not consider whether there is ongoing IUU fishing of this population in northern Australia (and elsewhere) nor whether that historical catch level was ever actually sustainable.

  

(5) Broad scale ecological impacts are assessed as negligible on the grounds that there was no evidence that there were ecological impacts on the ecosystem associated with shark removal during the height of the shark fishery in the region. Evidence of the effects on marine ecosystems as a result of the removal of apex predators are increasingly being identified but require targeted research to do so (with appropriate controls). It is not clear that there was ever a proper study of trophic cascades associated with the commercial fishery in this region and thus the posited lack of this in the past is not grounds for dismissing them now.

  

(6) The proposal frames potential impacts on the two regional World Heritage Areas (Shark Bay and Ningaloo) only in terms of direct impacts of drum line deployment in these areas. It ignores the connectivity of these systems with the south west in terms of tiger shark movements and thus the potential impacts on these region as a result of the removal of upwards of 40 tonnes of tiger shark a year.

 

THIS IS OUR CHANCE TO STOP THE CULL -

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