To whom it may concern,
Please accept this submission as our official response to the announcement that alternative sites are to be investigated for the redistribution of shark cage diving tourism. We understand that the proposed redistribution follows the absence of sharks from long established sites near the Neptune Islands, a phenomenon possibly caused by an orca attack, witnessed by tour operators.
While we acknowledge that this activity has economically benefited the state and raised the profile of Great white sharks and marine ecology in South Australia, we have concerns regarding the potential impacts of the redistribution of this activity. The orca attack itself is an indication of the need to better understand the industry’s impact on marine ecology.
- Operators should refer their undertakings to the EPBC Act
We believe that the industry should be subjected to a higher level of overall environmental impact assessment, and that EPBC Act referral is the most appropriate mechanism for this. These tours’ main attraction is the Great White Shark, a listed Vulnerable species under the Act. Any interaction with this species would be otherwise prohibited. Given that future tours may occur in the vicinity of endangered Australian sealion colonies or foraging habitats, in our opinion it would be appropriate for each vendor to submit a unique referral to the EPBC act, disclosing their proposed action, its location (or locations) and creating an opportunity for Federal environmental department consideration and formal public comment.
- Avoid colonies of endangered Australian sealions
The majority of proposed sites are located near offshore islands, many of which are home to resident colonies of New Zealand fur seals and Australian sealions. While the New Zealand fur seal has recovered well in recent years from the impacts of sealing in the 1800s, Australian sealion populations have struggled to recover, as evidence in their EPBC Act recovery plan, linked below.
As such, we believe that the assessment of possible islands should study and consider the size and status of nearby seal and sealion colonies, and should avoid visiting places where colonies of Australian sealions are established or foraging grounds are likely.
We understand that shark cage diving currently involves the use of chumming or loud acoustic signalling in order to attract sharks. If these actions provide an incentive for Great white sharks to increase the frequency of their visitation near Australian sealion colonies, it is possible that this could lead to increased risk of predation of Great white sharks upon Australian sealions, and thus potentially adversely impact the endangered species’ recovery.
We are also concerned that chumming and acoustic signalling may habituate some sharks to the sound of boat motors, which could learn to associate them with food. This possibility has also been raised with us by a number of recreational fishermen, and we believe it is a matter deserving of further investigation.
- Offset greenhouse gas emissions
Given the desire to present ecotourism in a favourable light as a low or no impact activity, it would pay for tour operators to calculate the greenhouse gas emissions generated by their operations, and offset these in a meaningful way (for example funding native revegetation projects). This would be in line with world’s best practise ecotourism operation, and would mitigate the industry’s contribution to climate change, which will in turn adversely impact marine ecosystems via carbon dioxide contributions to ocean acidification and the warming of the oceans.
The longer the distance travelled, the greater the cost to the operator in fuel purchased, travel time and carbon-offsets. While it would appear that travelling shorter distances would be the best response to this problem, the other users of the marine environment should also be considered.
- Avoid Spencer Gulf locations
Spencer Gulf represents multiple future opportunities in marine and nautical eco tourism, including diving and snorkeling opportunities. Fishing trips and cruises, for example, to the Sir Joseph Banks Group of islands have been popular since the age of sail, and interactions between fishermen, nautical tourists, snorkelers, divers and shark dive operators should be avoided in order to reduce the likelihood of other users’ interactions with sharks (including the possibility of shark attack).
In our opinion, shark dive tourism should be confined to remote waters, beyond the mouth of Spencer Gulf for this reason.
The Marine Life Society of SA wishes to remain a key stakeholder in this discussion and we request that we be included in any further opportunities for consideration and comment.
Steve Reynolds (President)
Dan Monceaux (Member and author of submission)