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The Hon. I. M. Macdonald, MLC. Minister for Natural Resources, Minister for Primary Industries, and Minister for Mineral Resources Level 30 Governor Macquarie Tower 1 Farrer Place Sydney NSW 2000
Worlds first test tube sharks to be bred in NSW
laboratories. (June 3, 2005) I am opposed to the proposed dive
fee to dive in Grey Nurse Shark (GNS) habitats. Since when did divers become the user group responsible for the protection of grey nurse sharks? This is taking the concept of user pays to ridiculous extremes! The dive fee is a fee to see GNS whilst diving in their habitats. That makes it a shark watching fee. There has been a lot of publicity lately about whale protection. The Federal Government has spent a lot of time, effort and money ensuring whales remain protected. Yet, this has not been funded solely by whale watchers! When someone walks along Dee Why Beach and sees an Osprey or when someone sees a Yellow Footed Rock Wallaby whilst driving at Camerons Corner will they be required to pay a fee? I think not. There is no difference between these categories of people and divers, they are all just observing nature. I am asking you to
declare 1500 metre no take zones around all known GNS habitats. Your scientific advisers and Dr John Stevens (whose report you personally commissioned several years ago), will confirm that no-take zones will eliminate at least 50 - 75% of the cause of GNS deaths; incidental hook injury. No-take zones will also benefit numerous other species, which reside in these habitats, including the wobbygong and black cod. No take zones must be implemented before any sharks produced in the breeding program are released; otherwise the whole program becomes an exercise in futility. There is little value in re-stocking with arguably the most expensive sharks in the world, only for them to die due to fish hook injury. The New Zealand experience of establishing no-take zones (Dr Bill Ballantine, world famous scientist and environmentalist) offers usable and supportable parallels. To have a successful fishing industry there must be a robust environment. A robust environment means taking a holistic view and ensuring we have enough fully complete areas to fall back on as part of our disaster recovery plan. One back up or one no-take zone does not make a disaster recovery plan. Immediate declaration of the 1500 metre no-take zones will significantly reduce the threat of fishing related injury and death to GNS, now. I am opposed to
restricting access to GNS habitats to commercial dive operators only. This condition seems to have been devised solely to facilitate a fee collection strategy. It in no way offers any increased protection to the GNS. Fisheries have estimated the number of dives done on GNS habitats by commercial operators. The number of dives done by individuals and independent dive clubs is insignificant by comparison. However, if the intention is to restrict diver numbers, please bear in mind that even allowing for the precautionary principle, all information to hand, to date, does not suggest that divers have contributed to a single GNS death. Many millions of dollars worth of assistance has been given to Fisheries by individuals, commercial operators and members of independent dive clubs to help in the collection of data for GNS research. If access to these sites is restricted, then so will be that assistance. How does the Government propose to
collect the proposed dive fee? Compliance by the public in perceived protection areas relies on either a highly visible deterrent presence (which is very costly to maintain), or self-compliance as the public understands and appreciates the values and aims of that protection area. Currently there is virtually universal condemnation of this proposal by all sections of the dive industry. Given the isolated nature of many of the aggregation sites there will need to be a significant physical compliance presence to administer this fee proposal or it will be ignored and not administered. Lack of administration of unworkable legislation is not new. There are many pieces of legislation in place, which are not enforced. It is a shame that such an important issue, as protection of the GNS, will be enmeshed in a piece of unworkable and moribund legislation. I am opposed to the
announcement of the GNS breeding program being used to side step the
real issues. It will be years before the breeding program will be up and running and deliver any viable numbers to the existing population. Programs like this are to be commended if they work. However, the need to introduce such a program indicates what a perilous position the GNS is really facing. Desperate times require desperate measures being the axiom. This is a desperate measure thought up at ten seconds to midnight in terms of this species. In the meantime 50 - 75% of all GNS deaths continue to be fishing related, while they are given no meaningful protection. The current fishing regulations allow hook and line fishing directly over GNS habitats, as long as the boat is not anchored! This seems a bit silly and reflects the view expressed by some that this proposal is not about meaningful protection. Whose responsibility
is it to look after the endangered GNS? Currently Fisheries have been spending modest sums (approx $300K pa) on GNS research and recovery work. To effectively run a recovery plan involves more than just injecting more funds into research. The GNS is close to being researched into extinction. Meaningful protection from known threats has to predicate any further research considering the mortality rate from these known threats. The proposal to charge divers to fund this research is novel. It is the first time that non-extractive users are being targeted to pay to fund activities, for which they are not the cause link! Also, this fee is based on site specific visitation. A site specific fee of this type leads me to believe that the way is now open for fee regimes at beaches and other aquatic sites where it is believed users are also gaining a perceived benefit! The sums involved are very paltry, in terms of the NSW budget. Based on simple biodiversity principles, it is in all NSW residents interests to have a diverse and healthy marine environment and in that environment I would like to think the GNS has an important place. Yours Sincerely, .
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