Stop Australia's Shark-Fin Export Trade

Dear Mr. Burke

The Australian shark fishing industry is a smoke screen for what should actually be called the Australian shark fin export industry. Of the 94t of shark fins collected in Australian waters (between 1998-1999) 92t were exported to foreign markets (Rose and McLoughlin 2001) and the remaining shark meat sold in Australia and abroad under such disguises as „flake‟. This is because the Australian shark fishing industry is well aware that shark is not desired by the Australian people and so they must be fooled into consuming it. Ten years later, shark fin exports have doubled, with reported figures of around 206 tonnes of shark fin exported between January 2007 and February 2008 (AQIS 2008). Without an international trade in fins the Australian shark fishing industry would end very quickly as shark meat (1-6 A$/Kg) is almost worthless in comparison to the fins (100-300 A$/Kg) (Larcombe and Begg 2008).

Around one quarter (322 species) of all known species of Chondricthyes (Sharks, Skates, Rays and Chimaeras) are found in Australian waters. Of these, over half are found nowhere else in the world (Last and Stevens 2009). Given this diversity there is national and international interest in conserving and managing Australian sharks. The Australian government claims to be committed to the conservation and management of sharks and their long-term sustainable use; however, consistent declines in shark populations as a result of fishing activities and beach netting programs continue to reinforce the evidence that suggest sharks are not a sustainable species for collection by the commercial fishing industry and yet this industry still prevails.

Shark populations are in distress, not only in Australian waters but around the world. IUCN states that of the 1,046 species of sharks and their relatives (class Chondricthyes) approximately 17% are in threatened categories (critically endangered, endangered and vulnerable), and 13% are considered „near threatened and may reach the thresholds for a threatened category in the near future if current pressures are not reduced (Polidoro et al. 2008). The IUCN has further found that 11 of the 21 species of oceanic pelagic sharks and rays that have been studied are threatened with extinction (Dulvy et al. 2008), with 32% of the 64 known species of pelagic sharks being threatened globally, a further 24% Near Threatened, 19% of Least Concern and 25% being Data Deficient (Camhi et al. 2009). Myers and Worm (2008) estimated that large predatory fish biomass (including sharks) is only about 10% of pre-industrial levels, and scientists from the Future of Marine Animal Populations (FMAP) project of the Census of Marine Life program concur that up to 90% of all large predatory fish have been depleted (Census of Marine Life 2008).

The current legislation is far from close to providing the level of protection required for sharks in Australian waters. Australia's approach to shark conservation risks falling well behind the rest of the world. Many nations have now opted for a complete ban on shark fishing and/or the trade of shark products.

We urge the Australian Government to protect all sharks in Australian waters.

Recommendations for Shark Conservation in Australia

Point 1. End targeted shark fishing in Australia

The Australian Government needs to acknowledge that there is a considerable lack of reliable data on which to base shark management, their inherent vulnerability to overfishing and that the prospects for achieving ecologically sustainable shark fisheries in the future are very low (Robbins et al. 2006).

Point 2. End the trade of shark products in Australia (emphasis on fins)

Australia made a big step forward when the „fins attached‟ policy was introduced, rendering it illegal to remove shark fins at sea and then dispose of the carcass (Shark Advisory Group and Lack 2004). However, given that there is still a trade for shark fins in Australia this illegal practice still continues (Senate Rural and Regional Affairs and Transport Committee 2005). Once fins reach the market place their origin can no longer be confirmed and so they are sold along with legally obtained fins. Protection of sharks therefore, must go beyond shark-finning bans, as this would lead only to an increase in the use of whole shark, not a decrease in mortality (Clarke et al. 2007).

Point 3. End the export of shark products

Between 1998-1999 Australia exported 92 tonnes of dried shark fin, valued at more than A$5.5 million, with around a third of this figure derived from unrecorded illegal shark catch (Rose and McLoughlin 2001). Ten years later, shark fin exports have doubled, with reported figures of around 206 tonnes of shark fin exported between January 2007 and February 2008 (AQIS 2008). Using a standard conversion of 2% of wet fin weight to 98% whole shark (Rose and McLoughlin 2001), these export figures represent 10,329 tonnes of whole shark. This is far more than the numbers reported by FAO figures of 7,269 tonnes for Australia's shark production for the year 2007 (FAO 2007). Australia should recognise the urgency to put a stop to the future export of all shark products (fins, meat, cartilage, liver oil) as this exploitation is not ecologically sustainable and risks causing detrimental impacts to the survival and conservation status of many species.

Point 4. End the importation of shark products

Currently there are very limited regulations on imported sharks and, as such, shark catches from fisheries that go unregulated in other countries, and could be illegal or unsustainable, may be exported to Australia. Australia should therefore stop the importation of shark products.

Point 5. Stop the sale of bycatch by ending commercial by- product

Bring an end to the treatment of bycatch species as by-product. If a species is not appropriate for targeted fishing because it has a poor or unknown conservation status then every effort should be made to avoid its capture. Allowing bycatch species to be sold commercially as by-product encourages their continued capture. Further research and development into new mitigation measures for shark bycatch are urgently required. Bycatch species should not be sold commercially as “by- product”.

Point 6. Identify and protect critical habitats

The levels of protection for grey nurse sharks should be strengthened so that all identified critical habitat sites are protected by 1500m radius no take marine reserves. In addition, critical habitats should be identified and protected for all other shark species listed as threatened. This protection should include listing of critical habitats for all listed shark species on the EPBC (environmental protection and biodiversity conservation) Register of Critical Habitat (or state equivalent) and the establishment of marine reserves to remove threats where they exist.

Point 7. Be a world leader in the international law and policy making for sharks

The Australian Government should support the listing of any Chondrichthyan species nominated for inclusion on CITES Appendices by other Parties. The Australian Government should also review the current listing of the Freshwater sawfish, Pristis microdon, on Appendix II. P. microdon’s listing on Appendix II was an attempt to facilitate aquarium breeding programs in the U.S., as Australia does not have facilities in place for such a program. However, given the lack of success and the potential damage that their removal may have on the original population, are these programs really effective? If not then the Australian Government should propose the uplisting of P. microdon to Appendix I of CITES to afford this species the same protection as all other members of the Family Pristidae. Equally, the Australian Government should propose the uplisting of the great white Carcharodon carcharias, the basking shark Cetorhinus maximus and the whale shark Rhincodon typus from Appendix II to Appendix I. Australia should also continue to encourage the adoption of binding international resolutions prohibiting shark finning and minimise shark bycatch.

Summary

The shark fin trade creates many issues for the management of sharks, both in Australia and globally. The high price of shark fins has resulted in an increased take of sharks, while also increasing the incentive for illegal activity such as under-reporting of catch, finning at sea and foreign fishing. Australia needs to join other forward thinking nations like Palau and the Bahamas, plus cities and states in Canada and America such as Hawaii, by implementing a complete ban on the sale, trade and distribution of shark products.

Sincerely,