We the under signed,
Would like to put the following submission to the Public Consultation into Alternative Sites for Shark Cage Diving Operators in South Australia.
As a group we categorically reject any plans for the shark cage dive industry to access any location out side of the currently permitted area at Neptune Islands, including all sites put forward for consultation, and furthermore call for reforms into the way the industry operates in that area in particular the act of chumming, which is illegal for the general public under fisheries act for safety reasons.
Our concerns are based on, but not limited to three main issues:
* Public Safety.
* Threats to two protected species, White Pointers listed as Vulnerable and Australian Sea Lions listed as threatened.
* Conflict of interest between DEWNR, Scientists & Shark Cage Operators.

Public safety being a primary concern, it is clear and apparent by the proposals put forward, safety of other water users was not a topic of concern judging by some of the locations.
Just to remind those considering this submission the Great White is an Apex Predator that grows to 6 meters plus and weighing more than 2 tonne, and at that size instinctively preys upon marine mammals, as big as Whales. They have a keen sense of smell and keen vision both of which they capably use under water and above the surface (spy-hoping). And have an adaptation which enables them to detect the electromagnetic field emitted by the movement of living animals, this includes a heartbeat.
Now considering this let’s look at the practice used by the Shark Cage Dive Industry to “entertain” their customers. Lure the shark to the area using a scent and or electromagnetic fields, placing a human being (inside a cage) into the sharks environment triggering instinctive reactions through sight and electromagnetic fields, at times amplified by the natural human response to fear generated by adrenalin altering the normal human heart rhythm. As well as being presented with the extra stimuli of a fish being cast and hauled toward the boat which mirrors the human food collection process of line fishing (just to put on a good show for the customers). While at the same time many other people on the boat Ooooh and Ahhh at the spectacle of seeing the Apex predator unsuccessfully using instinctive hunting techniques.
The risk that this “conditioning” of the sharks to associate humans as/with food creates to the general public is a legitimate concern and risk to all water users. For example the next encounter with humans these Apex Predators have, may result in tragic consequences. For example the lack of a protective cage, smaller boat or in some cases no boat at all.
Here is just a short list of people who face an increased risk due to conditioned sharks on a day to day basis:
Commercial Abalone Divers
Commercial Aquaculture Divers
Employees of/& Aquaculture Operators
Commercial Fishers (small boat)
Recreational Fishers (small boat)
Recreational Divers/Free Divers
Spear Fishers
Surfers (all aspects of surf riding)
Kayakers & Kayak fishers
Small boat sailors (including Dingy, Board & Kite)
General Swimmers and Water users.

Great White Sharks are a protected species listed as vulnerable, due to the time they take to reach sexual maturity. Therefore care should be taken to reduce risk of mortality of individual sharks. CSIRO published a study into the Shark Cage Diving operations at Neptune Islands which found that the operations had modified the behavior of the Sharks, more sharks were coming to the area and staying longer, and goes on to list threats to the sharks.
This DEWNR funded CSIRO summery on the practice has recently been removed from the CSIRO web site it was once found here. http://www.csiro.au/Outcomes/Oceans/CSIRO-shark-research-index/white-shark-cage-diving.aspx
Changes in predation of Sea Lions is listed in this CSIRO report, Sea Lions are classed as Protected and listed as Threatened. With Neptune Island documented on the DEWNR web site as supporting a population of these animals. So with more sharks coming to the area and staying longer as stated in the report, one can only assume that the chance of predation on this threatened species is increased by the conditioning of sharks, caused by shark cage diving operations.
Increased aggression between sharks was one of these threats, and was documented and publicized in an amateur video last year where a large shark was seen to attack a smaller shark.
Here https://www.youtube.com/watch?v=MkWTVwJEQ7c
Shark cage diving practices like chumming and teasing the sharks to the boat also increases the risk of conditioned animals to fall victim to interaction with fishing boats, elsewhere in their range.
Moves have been taken by the West Australian government to remove problem sharks to maintain safety of water users, the conditioning of Sharks at Neptune Island may not be proven to be the cause of attacks; however it has also not been disproved at the same time.
The recent event which has lead the industry to propose alternate sites was the mortality of a Shark with in viewing range of a working Shark Cage Dive Operation. This is no coincidence, the CSIRO report states Sharks have become attuned to visiting the area of operations at the same time on a daily basis even when operators are not present. The fact is the shark was in the area because of the operations, where a pod of Orca caused the mortality of the shark. Although this event may have been natural phenomena, the fact still remains that the risk on this protected species was increased at this site due to conditioning caused by Shark Cage Diving operations. So for the industry now shown multiple times to be increasing the threat levels to a protected species to propose somewhat of an extension of operations, justified on a mortality which they were in some way involved in causing is morally reprehensible.
We as a group demand that precautionary principle be invoked on the practice of Shark Cage diving, and that operations be suspended pending a full unbiased scientific review, sighting threats of serious and irreversible harm to populations of Australian Sea Lions and White Pointer Sharks.

We the undersigned call on politicians employed at the Parliament of South Australia to remove this consultation process from DEWNR due to their conflict of interest in relation to the shark cage diving industry. As we believe DEWNR incapable of providing an unpartisan public consultation process, especially under the hands of Mr Chris Thomas, Director of Marine Parks in SA, who oversaw the Marine Park Consultation Process. A process where a select committee enquiry heard countless reports of the consultation process being one of announce and defend and where the views of the community were cast aside if the view didn’t suit the DEWNR agenda.
South Australia is currently in a review process of the economic performance of Marine Parks. And the fact DEWNR retain a share of the revenue generated by Shark Cage Diving, un publicized amount judged to be in the millions. As well as using economic wealth generation from this so called eco friendly industry, to bolster figures on the performance of Marine Parks.
The haste of this consultation on Shark Cage Diving Operation Expansion, to be conducted and concluded before new “Long Term” licenses are issued on July 1st seems seem to be a knee jerk reaction to a one off incident. But judging by the short consultation, coinciding with the Easter break, should be seen for what it is, A mischievous plan to expand this dangerous and environmentally un-friendly form of entertainment.
Reportedly the disappearance of the shark population from the area happens on a regular annual basis. True unbiased science on the species on this issue is hard to come by because scientists to a large degree rely on the shark cage dive industry and conditioning of the sharks involved for the collection of data and field work on the species.
Those scientists and so called shark conservationists promoting shark cage diving as a good tool for public education about the species may in fact be encouraging a real life scenario of the cinematic blockbuster (JAWS) which they blame for the bad reputation of the species.

We would like to propose that, to reduce the financial impact to the shark cage dive industry, while the industry is independently reviewed on grounds of public safety and environmental impact, The Shark Cage Diving Industry consider, offsetting their loss of income with Whale Watching Tours.