Submission to the EPA’s call for comment on Shark Cull

Hey folks

The EPA are asking for public comment on the shark cull / drum line policy. Submissions are open until the 20th of February; based on the comments they will decide whether or not to conduct an environmental impact assessment. Head over there and put in a submission. It’ll take five minutes and a public environmental impact assessment could go a long way to ending this policy.

Below is my submission. Please don’t just copy & paste it – doing so diminishes its impact. However, feel free to use it as a source of inspiration and ideas for your submission :-)

The species of shark targeted by the drum line deployment are subject to federal protection as vulnerable species. Actions against that protection are inconsistent with existing environmental policies and should be subject to public review.

There has been enormous public concern about the drum line deployment, popularly described as (and in practical effect) a shark cull. Many thousands of people attended protests around the state, notably the large protests on two occasions at Cottesloe Beach. Significant discussion of the policy has occurred in regional, national and international press, with potential ramifications for tourism. This level of public concern justifies a public review period.

The shark cull is being conducted both in the Perth metropolitan region and in the South West. It is of state wide significance.

Insufficient evidence exists that:
a) the deployment of drum lines and the killing of sharks will reduce attacks upon humans
b) that the drum lines will not attract by-catch (including such endangered species as the Grey Nurse shark, or sharks of target species under 3m in length)
c) that personnel inspecting caught sharks are sufficiently trained to identify species and make a correct decision to release or kill under the policy

The long term impact on targeted species of the killing of individuals over 3m in length is complex to understand and the ramifications have not been considered in detail. There has been no opportunity for scientific inquiry and debate. Substantial, expert examination of the proposal is required to ensure these impacts can be managed.

Large individuals may be carrying pups and entering shallow waters to give birth. The low reproductive rate of these species necessitates review of the policy by the EPA to ensure long-term damage to the viability of these species does not occur.

Sharks are apex predators and are vital to healthy fisheries. The sustainability of Western Australian fisheries is a strategic issue. The EPA must assess the impact of the deployment of drum lines on these key species in order to ensure that a major industry remains viable.

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