Lynn's submission to the EPA: Western Australian Shark Hazard Mitigation Drum Line Program 2014-2017

Greens MLC Lynn MacLaren has completed her submission to the Environmental Protection Authority regarding the State Government's referral to extend the WA Shark Hazard Mitigation Drum Line Program for three years. Lynn would like to urge members of the public to make their own submissions, and invites the public to use her submission as a recommendation on what to include.

Despite receiving over 20,000 submissions last month, the EPA chose not to assess the policy because the limited time frame of the policy (ending April 30 of this year) was deemed not to have an environmental impact.

With plans to extend the program to 2017, we must now send a clear message to the EPA that this policy is environmentally unacceptable and should conduct full assessment of the environmental impact.

You can make a 500 word submission here. A 500 word submission will be available on Lynn's website later this afternoon.

Alternatively, you can send a more comprehensive submission to EPA Chairman, Dr Paul Vogel, who's address is listed below. The deadline for submissions is Wednesday 16 April 2014.

Please see also attached the PDF version of Lynn's submission.

Dr Paul Vogel, Chairman
Environmental Protection Authority
Locked Bag 10
East Perth Western Australia 6892

Dear Dr Vogel

Level of assessment – Western Australian Shark Hazard Mitigation Drum Line Program 2014-2017

I submit that this proposal should be deemed ‘API Category B (environmentally unacceptable)’. I provide the following notes to show that this proposal is inconsistent with established environmental policies, guidelines and standards; is likely to have a significant detrimental impact on marine environmental values; does not meet the EPA’s environmental objective for marine fauna and, because its purpose is to kill marine fauna including a protected species (great white shark/ Carcharodon carcharias), it cannot be reasonably modified or mitigated.

The relevant EPA environmental objective for this proposal is “marine fauna – to maintain the diversity, geographic distribution and viability of fauna at the species and population levels”. 
A factor is termed a Key Environmental Factor if the EPA considers that there is currently a lack of confidence that the proposal is likely to meet the environmental objective for that factor. The evidence presented in this referral – namely ‘Advice on the Proposed Shark Mitigation Strategy using drum lines for the period November 2014 - April 2017’ (Attachment 30 to the referral) does not provide confidence that the proposal will allow the diversity, geographic distribution and viability of marine fauna at the species and population levels to be maintained. This is the case in relation to Carcharodon carcharias (hereafter referred to as ‘white sharks’), tiger sharks and other marine fauna populations as a result of removing these apex predators.

1. Key Environmental Factor – white sharks
There are several reasons why the EPA should consider environmental objectives for this factor (white sharks) would be compromised by this proposal.

1.1 Status of the ‘western Australian’ white shark population
White sharks are listed under the Federal EPBC Act as vulnerable and migratory; as vulnerable under the WA Wildlife Conservation Act and protected under the WA Fish Resources Management Act.

The WA Department of Fisheries was a contributing agency to the latest version of the national ‘Recovery Plan for the White Shark (Carcharodon carcharias)’  , released in 2013, and to the South-west Marine Bioregional Plan, released in 2012.  In the later, white sharks are listed one of 18 ‘conservation values’ and a ‘regional priority’ for the South-west Marine Bioregion.

The following extracts from the 2013 national Recovery Plan are relevant (my emphasis added):

P6 (‘Summary’):
A review of the 2002 White Shark (Carcharodon carcharias) Recovery Plan, finalised in November 2008, concluded that it was not possible to determine if the white shark population in Australian waters has shown any sign of recovery (DEWHA, 2008). Considering the lack of evidence supporting a recovery of white shark numbers—together with historical evidence of a greater decline in white shark numbers over the last 60 years as compared to other shark species — the review supports the white shark’s current status as vulnerable under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The review concluded that a new recovery plan should be developed to remove the completed actions and include new conservation priorities.

P8 (‘Population trends’):
Determining trends in the Australian white shark population is difficult because the species is a widely dispersed, low density, highly mobile apex predator. In addition, it is not targeted by fishers in Australian waters, limiting catch reports as an index of population status. Recent evidence from the New South Wales Shark Meshing (Bather Protection) Program suggests that white shark numbers may have stabilised over the last 30 years in that state. There is, however, historical evidence of a greater decline in white shark numbers Australia-wide over the last 60 years, and no evidence to suggest that white shark numbers have recovered substantially since receiving protection (Reid et al., 2011). However, it is difficult to distinguish population change from the high rates of inter-annual variability in the numbers observed within any one site or region (Cliff et al., 1996). This high level of inter-annual variability means that what may be seen as a decline or increase in numbers over a stretch of a few years may actually be the result of changes in the distribution of white sharks from one place to another (Bruce, 2008). In addition to this variability caused by movements of white sharks, any rate of increase in the population size of white sharks will be inherently low because of their life history characteristics and will therefore be difficult to detect.

The above extracts concur with other up-to-date Government analyses of Australian white shark populations, including the western Australian white shark population, being white sharks found west of Bass Strait. Similar commentaries on the status of white shark populations are available on the Federal Department of Environment website. 

I therefore find the following claims by the WA Department of Fisheries in its document titled ‘Advice on the Proposed Shark Mitigation Strategy using drum lines for the period November 2014 - April 2017’ (Attachment 30 to the referral) extraordinary. It appears that the Department is claiming new knowledge about the status of the western Australian white shark population – without providing evidence for what would in normal circumstances to be regarded as a major scientific breakthrough.

The Department states (attachment 30, P10):

Estimating the current status and size of the western white shark population size (west of Bass Strait) has been difficult due to the lack of long term monitoring information. Recent research has focused on reconstructing the likely historical catch levels generated from all sources (including commercial and recreational fishing plus whaling) in combination with different life history scenarios and initial population sizes to generate potential fishing mortalities for the western white shark population based on available lines of evidence. These include the catch rates of white sharks by commercial fishers across periods before, during and after the highest levels of white shark captures occurred, trends in the rate of attacks per head of population over the past 20 years and encounter (observed) rates by abalone divers. 
The most plausible scenarios of current compared to unexploited population size, fishing mortalities and life history characteristics suggest that the western Australian white shark population either did not decline significantly or if it did, it has “recovered” to at least stable levels since the reduction in fishing effort and mortality and their listing as protected species nearly two decades ago. The results of these analyses suggest that the size of this western population is therefore likely to be in the order of at least a few to several thousand individuals. As such, the expected very low level of annual and therefore cumulative mortality from drum lines over the next three years is highly likely to only have a negligible impact on the total size of the western Australian population of white sharks.

The only evidence the Department puts forward to supports its extraordinary finding that “that the western Australian white shark population either did not decline significantly or if it did, it has “recovered” to at least stable levels” is the following footnote:

A report that outlines the plausible scenarios for the western white shark population will be available online in April/May 2014, followed by a more extensive report of the biology and potential impacts of fisheries on the white shark population.

There is no mention what level of scientific review this report will have. The study is central to the EPA’s decision as to whether the proposal will meet the environmental objective for white sharks, and whether to assess this proposal – however the study is not yet available for either public or scientific scrutiny.  This means that the EPA cannot have confidence in this Key Environmental Factor: the data is simply not in. The “available lines of evidence” cited above by the Department of Fisheries seem likely to be problematic at best. For example, “trends in the rate of attacks per head of population over the past 20 years” seems a poor substitute for ‘trends in rates of attacks per water users’, which would still be a tenuous approach to gauging a white shark population off half a continent but a minor improvement. I presume that it is because the “available lines of evidence” are not good indicators of the western Australian white shark population that they haven’t been used before.

1.2 Impacts on white sharks of drum lining for three years
The Department of Fisheries also claims in Attachment 30 that:
“fewer than 10 white sharks in the target size range (>3m) are expected to be caught each year. This would lead to a likely cumulative catch of less than 25 white sharks (>3m) over the three year period.
The level of annual catch would be consistent with the low annual catches of white sharks that have been sustained for decades through the drum line and netting programs off
Queensland and NSW and much lower than the numbers (estimated to be > 50) previously
caught each year as bycatch by commercial fishing prior to the major reductions in effort that occurred in the mid 1990’s.”

This description of annual catches of Queensland and NSW from netting and drumlining should be contrasted with the national Recovery Plan which highlights the eastern seaboard lethal shark control measures as a principal threat:

P14 (‘Threats’):
The principal threats to the white shark in Australia are outlined in the 2013 Issues Paper for the White Shark (Carcharodon carcharias) (DSEWPaC, 2013). These threats are similar to those identified in the 2002 White Shark (Carcharodon carcharias) Recovery Plan (EA, 2002) and can be summarised as:
•    Mortality related to being caught accidentally (bycatch) or illegally (targeted) by commercial and recreational fisheries, including issues of post release mortality.
•    Mortality related to shark control activities such as beach meshing or drumlining (east coast population).
Other potential threats to the species include the impacts of illegal trade in white shark products; ecosystem effects as a result of habitat modification and climate change (including changes in sea temperature, ocean currents and acidification); and ecotourism, including cage diving. The life history characteristics and habitat use of the white shark requires that actions to manage these threats are focused on minimising impacts on survivorship and protecting critical habitat.

The Recovery Plan goes to on to describe how Queensland and New South Wales lethal shark control measures appear to have damaged the eastern Australian white shark population:

P29 (‘Current management practices’):
Evidence from both the Queensland and New South Wales shark control programs indicates a long-term decline in the capture of white sharks, at least during the period since the identification of shark species was recorded.

In other words, rather than catches of white sharks being “sustained for decades” during drumlining and netting on the eastern seaboard, as the WA Department of Fisheries states above, in reality, the National Recovery plan finds that these activities have been harmful to the eastern seaboard white shark population, and are one of two principal threats to it. The fact that lethal shark control measures have been used for decades in Queensland and NSW does not make these measures sustainable. I am astonished to read a document ostensibly produced by the WA Department of Fisheries Research Division play such semantic games.

1.3 Impacts on undersized / juvenile white sharks are not addressed
Despite its own acknowledgement that mortality rates for juvenile tiger sharks released from drum lines currently are probably higher than the official ‘released alive’ figures indicates, Fisheries does not acknowledge the likelihood of juvenile white sharks also dying under a three-year drum lining proposal. It does not even raise this issue as a question, yet it must be obvious to its staff that this is a concern, based on the evidence of the damage being done to undersized tiger sharks (see 2.2 and 2.3 below) and the Department’s own experiences in tagging and releasing white sharks for scientific purposes.

It is my understanding that when tagging and releasing white sharks for scientific tracking devices using transmitter-type tags such as acoustic tags, the Department of Fisheries uses much lighter and less destructive fishing gear to catch the sharks than is currently being used on the drum lines; it checks the drumlines hourly rather than leaving them for hours including overnight (which risks captured sharks asphyxiated); and as much as possible the white sharks are tagged and processed in the water, rather than being dragged up a ramp at the back of a boat where irrigation of their gills may not be sufficiently effective and they are more likely to go into a shock. It is also my understanding that due to their various metabolic rates, some sharks survive capture and release better than others but white sharks are the sharks most inclined to die from asphyxiation and this sort of processing. It is concerning that the Department of Fisheries advice in Attachment 30 makes no mention of these issues.

1.4 Department’s role as source of scientific advice on drumlining impacts is compromised
In terms of judging potential environmental impact, the Department of Fisheries’ advice contained in Attachment 30 may be the only source of advice that the EPA has received on the potential environmental impacts of the three-year drumlining proposal.

However, the EPA should regard the advice with caution because the Department of Fisheries’ position as a source of independent advice on the environmental impacts of drum lining is compromised by the fact that it has been the operator of the drum lines off the metropolitan area.  The Department’s Minister has also been the chief Government enthusiast, in conjunction with the Premier, for drum lining and held joint press conferences with the Premier announcing drum lines will be used. While only the Department of Premier and Cabinet is listed as the proponent in the referral, at many stages the lines have been blurred with the Fisheries Minister acting as jointly responsible with the Premier for the drumlining strategy.

2. Key Environmental Factor – tiger sharks
There is a range of reasons why the WA Department of Fisheries’ (DoF’s) document titled ‘Advice on the Proposed Shark Mitigation Strategy using drum lines for the period November 2014 - April 2017’ does not provide confidence that proposal will allow the diversity, geographic distribution and viability of tiger sharks at the species and population levels to be maintained in WA waters.

2.1 No stock status assessment done
As the document acknowledges, there has never been a formal stock status assessment of tiger sharks in WA. It is unacceptable to embark on a three year program of killing tiger sharks for a period of five-and-half-months-a-year for three years without such an assessment. To do so raises concerns about local tiger shark populations because it is embarking on a significant environmental action against the local population of a marine species with no knowledge of that population and what the impacts will be.

2.2 Department of Fisheries estimates unreliable
The Department has already been proven wildly inaccurate in its estimate of how many tiger sharks would be caught and killed on drum lines in the current program. In its ‘Research Advice on the Proposed Shark Mitigation Strategy using drum lines for January to April 2014’, released in January 2014 (see Attachment 29 to the referral) the Department predicted that “the number of tiger sharks expected to be killed in this program may only be in the order of 10-20”. In fact, as of 16 March 2014, only halfway through the program and with another six-and-a-half weeks to go, the number of tiger sharks captured was 105, of which 11 were retrieved already dead and 33 were euthanised. The 44 dead tiger sharks represent twice the number of tiger shark deaths the Department had predicted in January, and in half the timeframe. If tiger shark mortalities continue at a similar rate until 30 April, the Department’s prediction will be proven inaccurate by a factor of around four.

In fact there is every reason to believe the Department’s January estimate was even more inaccurate than the above official shark ‘releases’ figure indicate. It is highly likely that at least half of the 61 under-sized tiger sharks supposedly released alive between January and 16 March 2014 are actually dead. Detailed observations and logs by members of the public acting as independent observers, including underwater video and photographs, show that at least half of undersized tiger sharks released have been badly injured, immobile or unable move and breathe unaided (see 3 below). In response to my questions in Parliament, the Fisheries Minister said that one of three tiger sharks fitted with acoustic tags before its release from the drumlines is now suspected dead (and since those three sharks, no more sharks released from shark hazard mitigation drum lines have been fitted with acoustic tags). 

As the Department advises: “total mortality is likely to be higher” than the total number of released sharks, although the Department has not provided any more accuracy in its predictions than that. In response to the above criticisms, the Department may claim that its advice on the extended drum lining program to occur between 15 November and 30 April over the next three summers will be more accurate, because it has the experience of the current drum lining program to go on.  However, I strongly contend that the evidence of two-and-a-half months of drum lining over one summer is not a good indicator of what annual drum line catches over three, five-and-a-half month periods for the next three years will be. This is especially the case given there has never been a stock status assessment of tiger sharks in western Australian waters.

2.3 Government’s ‘released alive’ statistics are wrong
My interviews with independent observers and observation of their footage and records are that the three common ways in which undersized sharks released in poor condition are:
-    Large holes in their head from the 25/0 ‘closed gape or ‘C’ shaped circle hooks penetrating, and then being required to be hacked out by the drumline operators to release the shark (the south-west contractor uses a blade attached to a broom handle and leans over the side of the boat to do this). These sharks are returned to the water with heavy blood loss occurring from the holes, making them an obvious prey item for a larger shark if the injury itself doesn’t kill them.
-    Sharks floating at the surface belly up and not righting themselves.
-    Sharks sinking immobile to the seabed and not moving during period of 15 minutes or more while being filmed.

These injury types are relevant to the issue of whether impacts on non-target shark captures can be mitigated. The Department’s advice states that customised ‘closed gape’ or C-shaped hooks have been used in order to reduce by catch of non-shark species on the drum lines. Very large hooks, instead of the smaller hooks and lighter gear typically used for shark tag and release scientific exercises, have been used for the same reason. It appears therefore that mitigating damage done to non-target and juvenile sharks is not an option without risking catching other non-target species on the hooks.  

Even if one chooses to agree with the unsubstantiated claim that even if all tiger sharks caught on the drum lines died the impacts on the WA tiger shark population is negligible, the above documented concerns about serious and fatal injuries done to released tiger sharks is relevant to the potential for similar harm done to any other released non-target sharks including juvenile white sharks, dusky sharks, grey nurse sharks, et cetera.

Figure 1. A small sample of records made by independent observers of the condition of undersized tiger sharks recorded as ‘alive/released’ by drumline operators. 
Date    Time    Location    Shark size (metres)    Shark gender
(male/female)    Independent observers comment on its condition
13/2/2014    09:07    Mullaloo    2.2    M    Bleeding heavily
15/2/2014    07:35    Scarborough    2.8    M    Close to death
19/2/2014    07:41    Trigg    2.71    F    Sank dead (video)
24/2/2014    07:48    Mullaloo    2.56    ?    Sank (video)
26/2/2014    14:10    Port Beach    2.99    F    Suspected nearly dead

2.4 High number of juvenile tiger sharks killed
Figure 4 on page 6 of the Department’s advice shows that the vast majority of tiger sharks captured between January 26 and March 16 2014 were less than 3 metres in length, especially off the metropolitan coast. However, poor practice by the drum line operators especially the South-West contractor, has meant that many tiger sharks (at least 17, according to Attachment 30) were not measured. Research elsewhere in the world indicates that tiger sharks reach maturity at 2.3-2.9 metres for males and 2.5-3.5 for females . It seems likely that many tiger sharks being killed on the drum lines or released fatally injured have not reached sexual maturity. The impacts of this on WA tiger shark populations should not be guessed and requires further research.

3. Key environmental factor – Dusky sharks
While only one dusky shark has been captured to date in the two-and-half-months since current drum lining operations began, and it was reportedly released alive, it cannot be predicted how many will be killed over a five-a-half-month period repeated for five years and including other season of the year. Therefore it cannot be said with any confidence that this species, the WA population of which is still recovering from past over-fishing, will be unaffected by the proposal.

4. Key Environmental Factor – Biodiversity / Impacts on other marine fauna
As stated in 1.1, the white shark has been chosen as one of 18 conservation values in the South-west Marine Bioregional Plan and a regional priority for the region. This is in part because of its role as an apex predator, a status within a marine ecosystem that tiger sharks also share. There is no mention made in Attachment 30 of what risks drum lining poses to other marine fauna in WA waters that may be indirectly resulted by the removal of white and tiger sharks from the ecosystem.

The national Recovery Plan for white shark states:

P12 (‘Biodiversity benefits’):
The white shark is an ecologically important apex predator that is recorded in low numbers in comparison with other large sharks, even in its known centres of abundance.
The South-west and Temperate East marine bioregional plans have identified the white shark as a regional priority on the basis of their unique association within the regions and their habitats.
Although the white shark is a wide-ranging species that is found in all seas, the South-west Marine Region appears to be an important area for the species. Available records of incidental catches of white sharks in Australian waters are higher in the South-west Marine Region than in any other region, and are not well correlated with fishing effort. Fishing activities along the west coast of Western Australia (Shark Bay to Bunbury) and in the Great Australian Bight appear to have significantly higher interactions with white sharks than in other areas, which indicates that these areas may be particularly important for the species.
Given this recovery plan focuses on removing threats from white shark habitats, it is also likely to have positive implications for a diversity of non-target native species that occur within the same habitats as this species.

The National Plan indicates that not only may white sharks depend on the south-west marine region as an important habitat for their population success and survival, but also that this could have flow-on effects in the ecosystem.

The EPA must satisfy itself that these concerns are investigated and addressed. Clearly, much more needs to be known about white sharks in this region to understand the implication of removing a few individuals.

Examples given by the EPA in its guidelines of issues or aspects of proposals which are potential sources of impact to the environment objective for marine fauna are: noise, light and vessels movements. These are impacts that seem comparatively benign against a proposal that proposes to kill marine fauna over three years, including a species – the white shark – that is protected as vulnerable.

The WA Department of Fisheries has provided in its referral documents, including its Risk Assessment document dated April 2014, a series of arguments claiming that impacts on marine fauna species and population will be negligible. However, the evidence for its arguments is sparse and in several cases deeply flawed. One of the most crucial claims that it makes about the status of western Australian great white shark populations is based on a study that is yet to be published; and yet to be subject to any public or scientific scrutiny, despite it making an extraordinary new claim about the status of great white shark populations which contradicts every mainstream and government science finding on this subject that has been made before, including national great white shark documents released as recently as within the past year to which the Department of Fisheries itself contributed.

Further, the Department has already been proven inaccurate in terms of the impacts of drumlining  on tiger sharks with its Risk Assessment issued in January 2014 of how many would be killed in the January-April 2014 drumlining program proven wildly wrong by a factor of four or more – this is based on the Government’s own ‘release’ statistics which copious video and photographic evidence provided by independent observers shows are not accurate statistics; the number of tiger shark deaths, including undersized individuals, is undoubtedly much higher than the Government’s figures indicate. Further, the Department admits there has never been a formal stock status assessment of tiger sharks in WA.

The Department of Fisheries advice is further problematic in that the Department has been one of the operators of the current drum lining program and the Minister for Fisheries has acted as a joint proponent for drumlining with the Premier and his staff. While it is acknowledged that only the Department of Premier and Cabinet is listed as the proponent for this proposal, the Department of Fisheries’ advice on the impacts on marine fauna from the proposal can no longer be regarded as independent or uncompromised. There is therefore no independent scientific advice attached to this proposal to support the argument that impacts on marine fauna will be negligible.

This is an important consideration given the Department of Fisheries’ claims in regard to the great white shark population in western Australian run counter to all available evidence from reputable sources including the Recovery Plan for the White Shark (Carcharodon carcharias), released in 2013 by the Federal Government, and the Issues Paper to the Recovery Plan. The WA Fisheries Department was a contributor to both the Recovery Plan and Issues Paper, and yet now is making new claims about the western Australian great white shark population that have no precedence in any other research.

On the basis of what I have concluded above, it is clear to me that the EPA cannot feel confident that the environmental objective of maintaining the diversity, geographic distribution and viability of marine fauna at the species and population levels can be achieved in this proposal, and subsequently, the only tenable response to this referral can be for the EPA to deem this proposal either API category B (environmentally unacceptable) or at second best, Public Environmental Review (PER).

Final comment - the overwhelming need for the EPA to prepare Strategic Advice on this issue
I recently wrote to the WA Environment Minister and the EPA urging that the EPA prepare Strategic Advice under Section 16 of the EP Act on drum lining and/or shark hazard mitigation in general. It doesn’t take much scrutiny to observe that little-to-no strategic thinking has gone into the drumlining proposal. I again urge the EPA to consider taking this as an action, and list the following reasons:

1.    As a measure of shark hazard mitigation, drumlining to date has been proven as illogical, or even more so, as those of us who opposed it from the start had predicted. White sharks are the only species of shark confirmed as responsible for fatal attacks on humans in WA going back several decades. A number of fatal attacks that have been popularly attributed to tiger sharks have, under cold case review, appeared more likely to be incidents of tiger sharks scavenging on the body following death by other causes, or simple misidentification of a great white shark. To date, not a single white shark has been caught on the drumlines. Even if one is eventually caught, while it might gratify the Government, it cannot be argued to make a significant improvement to human safety. White sharks are highly migratory, able to travel 100 kilometres in 24 hours: there has been no evidence presented so far to indicate that killing one, or even 25 white sharks over three years, will necessarily reduce the threat of a fatal attack. 

2.    There are numerous other measures of non-lethal shark hazard mitigation that have not been considered. The Department of Premier and Cabinet claims in its referral documents that it consulted a wide range of individuals and organisations before deciding to go ahead with drumlining as its shark hazard mitigation strategy (see Attachment 26). However, my questions in Parliament have revealed that this consultation, to selected individuals or organizations only, lasted no more than four days between 2 and 6 December 2013.  I am aware of one large Perth dive shop owner who was informed of the consultation process by PADI Australasia and began preparing documents only to hear, less than 24 hours later that the consultation had been formally cancelled by the Department of Premier and Cabinet. The same dive shop owner found via the media at about the same time that drumlining had been announced.

3.    A popular forum organized by opponents of drumlining on 30 March 2014, held at the Alexander Library, showcased a sample of alternative, non-lethal measures for shark hazard mitigation, including:
a)    non-lethal shark proof enclosures, such as developed and trialled at Coogee this summer with apparent great success by local business Eco Shark Barrier;
b)    shark shield personal deterrent devices, such as a device built into surfboards by local business Surfsafe.
c)    Smart phone ‘app’s so people planning surfing and diving trips can find out from others if a shark has been sighted in the area, such as developed by local business ‘iKoast’.
d)    A ‘Sharkspotters’ program as already done with great success in Cape Town, South Africa with spotters employed to watch surfing or bathing areas from a high vantage point and use an appropriate signalling system to inform the public of sightings or risks.
e)    Public education about local sharks risks and behaviour, perhaps combined with shark eco-tourism based around explaining WA’s existing world class shark tracking and acoustic array monitoring system.
I am concerned that none of the above measures that seem more likely to save lives while having no obvious negative impact on the environmental values have been explored.

4.    The Department of Fisheries own research, published in 2012, on the time of year and conditions in which fatal sharks have occurred have occurred din WA since 1995, seems to have been ignored. The Department’s ‘Correlation study of the potential risk factors associated with white shark attacks in Western Australian waters’, dated November 2012, identified the key risk factors, including time of year. The report states that most attacks occur in winter and spring, when drumlins are not proposed to be deployed. I include this figure from the report.

Kind regards



14 April 2014

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2014-04 14 Submission EPA level of assessment Extended Drumlining Program v3.pdf 532.16 KB