Question 1

Misrepresentation of facts in letter tabled in Queensland Parliament on 25 September 2025

Accepted Answer

I am writing to complain about the gross misrepresentation of facts presented by Minister Perrett in a letter tabled in Queensland Parliament on 25 September 2025.

Many of the claims within the letter about whale releases, shark control efficacy, and “scientifically proven” safety measures are contradicted by independent research, court rulings, and even the government’s own reports.

Below I have cited claims made in the letter, and outlined why these claims are misrepresentations of fact. 
“Prioritising Queenslanders’ safety also protects our international tourism reputation, with our beaches the envy of the world and the centrepiece of our $33 billion tourism industry.”
 • Queensland’s $33 billion tourism industry depends on healthy marine ecosystems, not shark nets or lethal drumlines. Tourists come for the Great Barrier Reef and vibrant biodiversity, not outdated culling gear.
 • The 2019 Federal Court case Humane Society International v DAF confirmed that lethal shark controls do not reduce the risk of unprovoked shark bites. The science was described as “overwhelming.”
 • Despite this, the government continues to use harmful methods that kill non-target species, including whales, and threaten marine biodiversity. This not only damages ecosystems but risks Queensland’s reputation as a world-class ecotourism destination.
“The Plan and increased investment into the Program are being delivered following the Government’s consideration of recommendations from the KPMG Shark Control Program Evaluation Report, as well as feedback from Queenslanders, scientific experts, Surf Life Saving Queensland, and Local Government. Any recommendation or measure that prioritises human safety first, above all other factors, has been adopted in line with the Crisafulli Government’s priority.”
 • The KPMG report did not endorse shark nets and drumlines as effective mitigation tools. Instead, it found them ineffective and recommended non-lethal alternatives, including a trial removal of nets during whale migration (Recommendation 3.2) to reduce entanglements.
 • By selectively using the report’s findings while dismissing key recommendations, the government undermines its credibility, risks breaching legal obligations, and endangers both marine life and public safety.
“The Plan sets a clear and strong direction for the future management of the Program, with human safety central to its operation. Until alternatives are proven effective at reducing the risk of shark attacks, the Program will continue to use mesh nets and traditional drumlines.”
 • Minister Tony Perrett recently claimed that nets and drumlines are “scientifically proven” to protect swimmers. This is not supported by the evidence.
 • The 2024 KPMG evaluation, citing the government’s own Scientific Working Group, recommended removing nets during whale migration and did not endorse them as effective. The 2024 Huveneers review found no evidence that shark nets reduce negative interactions, while non-lethal methods like drones and Catch-Alert Drumlines showed far better results.
 • The 2019 Federal Court ruled that lethal shark controls do not reduce risk, calling the scientific evidence “overwhelming.” Similarly, the 2017 Senate Inquiry found these methods ineffective and recommended modern non-lethal alternatives.
“...the location and configuration of shark control equipment will be optimised which will include expansion to new locations.”
 • Section 43B(3) of the EPBC Act 1999 makes clear that any significant expansion of existing programs may be deemed unlawful without federal approval. To expand such a lethal program risks contravening national law and exposing the State to legal challenge. 
“Research and trials into other mitigation devices or strategies will continue. Approximately 60 per cent of the additional funding announced for the Program is for research, trials of new technology, education, and the SharkSmart drone program, which the Crisafulli Government has not only made permanent, but doubled it from 10 beaches to 20.”
 • While expanding drone surveillance is a positive move, key questions remain. The SharkSmart Drone Trial shows drones are more effective than lethal nets and drumlines—so why are they used at only 20 beaches? Claims about water turbidity don’t justify such limited coverage.
 • Of the $88.2 million program, around 40% (~$35 million) appears directed to traditional, lethal methods. Despite evidence favouring non-lethal tools, significant taxpayer funds continue to support outdated approaches.
 • This raises a clear concern: if safety is the goal, why does the government still rely on less effective, more harmful methods across most of the coast?

In essence, much of the content provided in the tabled letter is misleading or selectively framed, and it ultimately underscores the central issue - the Queensland Department of Primary Industries continues to ignore widely available scientific evidence. This is a political letter justifying policy decisions, not genuine stakeholder engagement.

Lethal shark culling methods, including nets and drumlines, do not prevent negative shark interactions or enhance swimmer safety, and they cause demonstrable harm to marine life and the broader ocean ecosystem. Continuing to assert they do is both dangerous, and shows while interest in human safety may be a good talking point, it is not genuine. Until the Department genuinely aligns its policies with this science and prioritises non-lethal, evidence-based solutions, both human safety and the health of our oceans will remain compromised.

Question 2

Misrepresentation of KPMG Report

Accepted Answer

I am writing to lodge a formal and serious complaint regarding the Queensland Government’s recent media release titled “Shark control program strengthened to protect beachgoers” and associated public communications issued in late May 2025 (Ref: CTS 08930/25).

These communications misrepresent the findings of the KPMG Shark Control Program Evaluation Report (November 2024), while omitting, contradicting, or sanitising key facts that are central to the program’s legal, scientific, and ethical legitimacy. The result is a misleading justification for a policy expansion that warrants urgent scrutiny.

This complaint outlines the most significant issues, supported by direct references to the KPMG report and binding legal findings, namely the 2019 Administrative Appeals Tribunal (AAT) decision regarding the Shark Control Program (SCP) in the Great Barrier Reef Marine Park.

1. False Framing of KPMG Endorsement
The government’s statement implies that the expansion of lethal methods is grounded in KPMG’s recommendations. However, KPMG does not recommend such expansion. On the contrary, it highlights a lack of evidence for effectiveness in shark bite prevention and increasing harm to the marine ecosystem:

“Research is effective across all three outcome areas; however, none of the initiatives primarily focus on the Program’s ecosystem impact or shark bite prevention.”

There is no empirical or evaluative basis within the report to justify claims that the new measures are evidence-based or endorsed by KPMG.

2.  Cherry-Picked Sentences to Create False Legitimacy
A single sentence referencing third-party literature is used to suggest scientific endorsement of lethal methods:

“The literature indicates that Operations have likely had some effect in reducing shark bites…”

This quote is:
 • Taken from literature, not from KPMG’s own research,
 • Presented without noting that no inferential statistical analysis was conducted,
 • Stripped of surrounding context, which includes contradictory findings and methodological limitations.

The selective use of this isolated phrase distorts the broader findings of the report.

3.  Omission of AAT Findings and Legal Precedent
The communications fail to acknowledge the 2019 AAT ruling (HSI v DAF (Qld)), which concluded:

“The lethal component of the SCP does not reduce the risk of unprovoked shark interactions. The scientific evidence before us is overwhelming in this regard.”

This omission is indefensible, given the ruling’s direct relevance to the current SCP and its legally binding nature within the Great Barrier Reef Marine Park.

4. Failure to Disclose Increased Bycatch Mortality
KPMG explicitly reports worsening ecosystem outcomes:

“Operations resulted in the mortality of 1,200 non-target species, with the total average annual bycatch mortality increasing…”

This increase contradicts the claimed “strengthening” of the program and reflects a clear failure to reduce ecological harm. Yet this critical information is absent from public-facing materials.

5. Disregard for Non-Lethal Alternatives
KPMG reports dramatically better animal survivability using Catch-Alert Drumlines (CADs):

“Catch-Alert Drumlines show an improved survivability of catch (80%) compared to Modified Traditional Drumlines (35%).”

Despite this, the new plan does not invest in CADs, favouring traditional lethal drumlines, contrary to the evaluation’s findings.

6. Omission of Legal Constraints Under the EPBC Act
KPMG notes that the SCP’s exemption from EPBC Act assessment does not permit expansion:

“Subsection 43B(3) does not allow for the enlargement, expansion, or intensification of the exempted uses.”

The new plan clearly intensifies effort — more drumlines, more frequent servicing — raising serious legal risks. No mention of this risk appears in the government’s announcement.

7. Neglect of KPMG’s Whale Migration Recommendations
KPMG recommends the temporary removal of shark nets during whale migration to minimise risk to protected species. This recommendation is ignored in both the plan and the announcement, despite the risk to humpback whales being well-documented and preventable.

8. Misrepresentation of SharkSmart Campaign Outcomes
Public statements claim that SharkSmart “effectively reached a wide audience,” yet KPMG’s evaluation reveals a decline in performance, with metrics stagnating or worsening in 2024.

The communications also include nonsensical language, such as claiming the campaign “effectively reached a wide audience, including Meta,” which undermines public confidence in the rigour and professionalism of the campaign’s evaluation.

9. Sanitisation of Language and Public Misleading
The announcement avoids the terms “lethal,” “cull,” or “death,” instead referring to “strengthening” and “improvement.” This is deliberate sanitisation, aimed at downplaying the program’s core function: the routine killing of wildlife. Such euphemistic language denies the public their right to transparent and accurate information.

Relief Sought
I formally request that the Department:
1. Launch an independent investigation into the preparation and approval process for these public communications.
2. Issue a formal correction to clarify:
   1. The KPMG report does not endorse lethal expansion.
   2. The report finds increased ecosystem harm and limited research outcomes.
   3. Key legal risks under the EPBC Act were not disclosed.
   4. The AAT has ruled that lethal methods are ineffective.
   5. Several of KPMG’s core recommendations were disregarded.

1. Refer this matter to the Queensland Integrity Commissioner for review of potential breaches of public communication standards and ethical obligations.
2. Implement a new transparency protocol for all future references to independent evaluations, including:
   1. Full-source quotation and referencing,
   2. Publication of a concordance table mapping claims to report findings,
   3. Mandatory disclosure of omitted findings that contradict policy actions.

In a democratic society, governments must not weaponise independent reports to support politically convenient narratives, especially when these narratives lead to the large-scale killing of wildlife. Public trust, policy legitimacy, and the ethical obligations of government demand accuracy, transparency, and accountability.

Question 3

Lethal Shark Take in the Great Barrier Reef Marine Park

Accepted Answer

Please tell us in a few words what your feedback relates to: Non-compliance with the requirement to minimise lethal shark take in the Great Barrier Reef Marine Park.
Tell us what happened: As per the case ‘Humane Society International (Australia) Inc and Department of Agriculture & Fisheries (Qld) [2019] AATA 617,’ the Department of Agriculture & Fisheries (Qld) is legally required to conduct the Shark Control Program in a way that avoids, as much as possible, the lethal take of sharks within the Great Barrier Reef Marine Park (GBRMP). Unfortunately, this is not happening, and there remains a significant kill rate of sharks in this area, as evidenced by recent reports. Attempts to raise this issue with QDAF result in responses that appear politically driven rather than focused on adherence to the law. It is critical that the department operates independently of political influence and follows its legal obligations to protect marine life in the GBRMP.
Where did the matter take place?:
Not applicable If you've raised this with us before, please provide your reference number and/or name of the person you dealt with:
Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 4

Restricted Access to Shark Control Exclusion Zones

Accepted Answer

Please tell us in a few words what your feedback relates to: Lack of a process for applying for authorisation to enter Shark Control Program exclusion zones.

Tell us what happened: There is currently no process for applying for authorisation to enter Shark Control Program (SCP) exclusion zones under the Fisheries Act 1994. This decision raises several concerns:

Legal Rights and Transparency: Without a process to apply for authorisation, the relevant provision in the Fisheries Act 1994 becomes meaningless, undermining principles of fairness and transparency.

Impact on Marine Rescue Efforts: Marine rescue and community organisations, which play a critical role in public and marine life safety, are excluded from applying for authorisation. This exclusion limits their ability to respond effectively to emergencies, including shark net and drumline entanglements, where government response times are often insufficient.

Ethical and Fair Access: Denying access based on non-affiliation with the department appears discriminatory and prevents organisations from contributing meaningfully to marine conservation and rescue efforts.
I urge you to reconsider this stance and establish a clear and fair application process for authorisations to access SCP exclusion zones. This change would enhance marine conservation, improve public safety, and ensure transparency and equality in managing these areas.

Where did the matter take place?:
Not applicable If you've raised this with us before, please provide your reference number and/or name of the person you dealt with:
Not applicable
What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 5

Ineffectiveness of Shark Net Pingers

Accepted Answer

Please tell us in a few words what your feedback relates to:Lack of evidence supporting the effectiveness of pingers on shark nets.
Tell us what happened:The department has confirmed that it holds no records of scientific evidence proving the effectiveness of the “pingers” used on shark nets to reduce dolphin and whale entanglements. The department uses Future Oceans pingers but relies on technical data from the manufacturer’s website, with no independent validation of their effectiveness. Research, such as “A whale alarm fails to deter migrating humpback whales: an empirical test (2014),” has shown that 3khz Whale pingers are ineffective in Australian conditions.

Despite this, the department continues to publicly claim that these devices deter whales and dolphins from shark nets and drumlines, misleading the public about their impact. This approach raises concerns about transparency and accountability in the Shark Control Program, and I urge the department to review its practices and provide evidence-backed solutions to reduce entanglements.
Where did the matter take place?:
Not applicable If you've raised this with us before, please provide your reference number and/or name of the person you dealt with:
Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 6

Misleading and Outdated QFish Data

Accepted Answer

Please tell us in a few words what your feedback relates to: Concerns about inaccuracies and transparency in QFish data on the Shark Control Program.
Tell us what happened: QFish contains misleading and incomplete information about the Queensland Shark Control Program (QSCP). For example, the “fate” filter categorises animals as either alive or dead, but this only reflects their condition when found in equipment—not their ultimate outcome. Target sharks found alive are routinely killed, meaning the reported figures misrepresent the true number of animals killed. In 2023, an additional 230 sharks (194 target and 36 miscategorised as target sharks) were found alive and then killed, raising the total to 867 animals killed, not the 637 shown in the dataset.

Additionally, 286 non-target sharks were wrongly classified as target species, highlighting a lack of oversight in the program’s data management. This discrepancy was discovered by a third-party NGO, not the department, which raises serious concerns about the program’s monitoring and transparency. Compounding the issue, QFish data remained outdated for six months in 2023, only being updated in December. This delay is unacceptable and undermines public confidence in the accuracy and reliability of QSCP data.
Where did the matter take place?:
Not applicableIf you've raised this with us before, please provide your reference number and/or name of the person you dealt with:
Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 7

Use of Dolphin Semen in Shark Control Program

Accepted Answer

Please tell us in a few words what your feedback relates to: Ethical concerns about the use of dolphin semen from dolphins killed in shark nets.
Tell us what happened: The treatment of marine wildlife is a sensitive and deeply important responsibility, especially when it involves programs that operate under legal exemptions to kill protected species.

Public trust in these programs depends on their transparency, ethical standards, and commitment to minimising harm to marine life. Any practice that undermines these principles warrants careful scrutiny and open dialogue.
It has come to light, based on entries in the department’s catch and kill spreadsheet (DR3184.xlsx), that sperm from male dolphins killed in shark nets may have been collected and provided to Sea World for use at Dolphin Cove. If true, this practice raises serious ethical and moral concerns about the Shark Control Program (SCP) and its associated partners.
Dolphins, as protected marine species, deserve to be treated with dignity and respect, even in the unfortunate event of their deaths. The idea that biological materials, such as sperm, could be harvested from these animals and repurposed without public disclosure or a clear ethical framework raises significant questions about the values guiding the SCP.

This practice—if substantiated—goes far beyond the program’s stated objectives and highlights a troubling lack of transparency.
The public has entrusted the SCP with significant taxpayer funding to manage marine life responsibly and in a manner consistent with ethical and legal standards. Practices such as this, if they have occurred, undermine public trust and cast doubt on the accountability of the program and its partners. Furthermore, they risk overshadowing the program’s core mission by introducing elements of exploitation and profiteering at the expense of marine wildlife.

It is essential for the department to address this issue openly and to provide clarity on whether this practice has occurred, and if so, under what circumstances and justifications.

A full and transparent investigation is necessary to determine the facts, disclose any arrangements or agreements between the SCP and external entities like Sea World, and assure the public that such actions are not condoned.
This situation highlights the urgent need for strengthened oversight and stricter ethical guidelines within the SCP. The public must be assured that all aspects of the program align with its intended purpose.

By addressing these concerns, the department has an opportunity to rebuild public trust and demonstrate its commitment to ethical practices that prioritise the welfare of marine life and the expectations of the communities it serves.
Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable
What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 8

Misleading Messaging on Shark Control Program

Accepted Answer

Please tell us in a few words what your feedback relates to: Concerns about deceptive public messaging regarding the Shark Control Program (QSCP).

Tell us what happened: The Queensland Government continues to mislead the public about the Shark Control Program (QSCP) through its messaging:

Contractor Checks on Equipment: QSCP claims that contractors “regularly check nets and drumlines for captured animals” to release non-target species alive. In reality, contractors are only required to check equipment 182 days a year with no maximum interval specified. Nets and drumlines often remain unchecked for days, making the release of live animals highly unlikely and rendering the claim deceptive.
Use of Drumlines Instead of Nets: QSCP states drumlines are used “where possible” to reduce marine mammal entanglements. However, replacing nets with drumlines is technically feasible across all existing sites. A Cardno report (2020) found this approach could maintain target shark catches while reducing bycatch by 97%. This change is not implemented due to bureaucratic and political resistance.
Electronic Warning Devices (Pingers): QSCP claims pingers deter whales and dolphins. Despite nearly two decades of use, there is no scientific evidence supporting their effectiveness, and catch rates remain unchanged, disproving the claim.
Alternative Baits and Configurations: QSCP asserts the use of alternative bait and apparatus to reduce dolphin and turtle catches. However, catch data shows no measurable improvement, making this claim misleading.
Hook Trials: QSCP references comparative trials of circle and J hooks, which is globally established and well understood. Conducting such trials is unnecessary and appears to be a superficial effort rather than a meaningful step toward reducing bycatch.

These deceptive claims undermine public trust and accountability in the QSCP. Immediate action is needed to ensure transparency, accuracy, and effective measures to protect marine life.

Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days.

How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 9

Concerns About Predation on Hooked Animals

Accepted Answer

Please tell us in a few words what your feedback relates to: The potential risk to water users from predation and shark habituation caused by QSCP drumlines.
Tell us what happened: I have observed a troubling pattern of predation on hooked or entangled animals on QSCP drumlines, with bite marks and jaw sizes suggesting that large, so-called “dangerous” sharks are responsible. This predation raises serious concerns about the safety of water users and the potential for drumlines to alter shark behaviour, such as habituation to human activity or increased shark presence near popular beaches.

The department has failed to provide any studies or data to assess the risks posed by this predation. The lack of transparency is particularly concerning, as the evidence suggests that baited drumlines and hooked animals could be attracting large sharks closer to swimming areas. This scenario increases the likelihood of shark interactions, potentially undermining the very safety measures the QSCP claims to provide.
One specific incident further highlights the urgency of this issue. A shark bite was reported at Bargara, a heavily drumlined beach. While I cannot confirm a direct link, it is reasonable to consider that the drumlines and their baited hooks may have played a role by drawing sharks into the area. This incident, along with others at beaches with drumline protection, calls for an immediate review of how drumlines influence shark behaviour and increase risks for beachgoers.
The broader implications of this issue extend beyond safety. Predation on hooked animals could disrupt local ecosystems and contribute to stress on marine populations. If QSCP equipment is inadvertently altering shark movements and behaviours, it may have far-reaching consequences for marine life and public safety.
I urge the department to investigate these concerns thoroughly and provide clear, evidence-based responses. It is critical to evaluate whether the QSCP is truly delivering on its promise of safety or whether it is inadvertently increasing risks through predation and behavioural changes among sharks. Greater transparency, research, and proactive measures are needed to address these pressing

Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days.

How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 10

Contractor Compliance with WHS Standards

Accepted Answer

Please tell us in a few words what your feedback relates to: Concerns about the standards required of contractors engaged in the Shark Control Program (SCP).

Tell us what happened: I am seeking clarification regarding the quality, safety, and environmental standards required of contractors engaged in the Shark Control Program (SCP). Specifically, I would like to know if contractors are required to adhere to the following internationally recognised standards: ISO 9001 (Quality Management), ISO 14001 (Environmental Management), and ISO 45001 (Occupational Health and Safety Management). If so, are contractors required to obtain third-party certification for compliance with these standards?
If these standards are not mandated, what contractual requirements are in place to ensure quality, safety, and environmental outcomes? Additionally, how does the department monitor compliance with these contractual obligations?
Recently, I have been advised of various WHS breaches by the Sunshine Coast contractor to Workplace Health and Safety Queensland (WHSQ). It is unclear whether these WHS breaches also constitute contract violations, or if the contracts impose limited or no safety, quality, and environmental requirements on contractors.
I trust that the Queensland Government places significant importance on ensuring high-quality, safe, and environmentally responsible practices. It is imperative that stringent standards and monitoring mechanisms are in place for all contractors engaged with state funds to protect public safety and the environment.
Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 11

Misleading Statements and Lack of Transparency in QSCP

Accepted Answer

Please tell us in a few words what your feedback relates to: Misleading claims and failure to implement evidence-based improvements in shark control practices.
Tell us what happened: I am submitting a formal complaint regarding misleading statements made by the Queensland Shark Control Program (QSCP) and the apparent lack of transparency and accountability in their practices.
The QSCP has publicly claimed that “drumlines are used instead of nets where possible, as marine mammals are less likely to be entangled in drumlines.” However, there is clear evidence that this process has not been fully implemented across all regions, despite the availability of assessments that demonstrate the benefits of replacing nets with drumlines.

For example, the report “Selectivity of nets and drumlines used in the Queensland Shark Control Program” highlights specific cases where the replacement of nets with drumlines would result in significantly reduced bycatch without compromising target shark captures. One notable case involves the Noosa region on the Sunshine Coast, where replacing two nets with two additional drumlines could potentially reduce captures of other sharks and bycatch by approximately 97% while maintaining catches of the three most dangerous target shark species (bull, tiger, and white sharks).

Despite these findings, there is little evidence that the department has comprehensively assessed or acted upon similar opportunities in other regions. If this process has not been conducted statewide, it reflects a failure to act on readily available data and advice and it makes the claim that “drumlines are used instead of nets where possible, as marine mammals are less likely to be entangled in drumlines” fraudulent. If it has been conducted, the lack of transparency surrounding the outcomes raises serious concerns about the department’s commitment to evidence-based decision-making.
The department’s public statement about using drumlines instead of nets where possible lacks transparency and is misleading given the clear recommendations provided in their own research. This undermines public trust and raises questions about the prioritization of non-lethal and more effective strategies.

I request an investigation into why the recommendations from the Selectivity of nets and drumlines report have not been implemented comprehensively across all QSCP regions and to cease claims that “drumlines are used instead of nets where possible, as marine mammals are less likely to be entangled in drumlines.”
Additionally, I urge the department to clarify the criteria for determining where drumlines can replace nets and to provide transparent updates on actions taken to reduce bycatch and modernise shark mitigation strategies.
Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 12

Disregard for Scientific Advice in the QSCP

Accepted Answer

Please tell us in a few words what your feedback relates to: Failure to follow recommendations from the QSCP Scientific Working Group.

Tell us what happened: I am raising a formal complaint regarding the repeated and ongoing disregard for scientific advice in the Queensland Shark Control Program (QSCP). The QSCP Scientific Working Group (SWG) was established in 2017 to provide independent scientific advice on the operation of the QSCP, initially focusing on marine parks and later expanding its scope statewide. However, there are multiple instances where QDAF has ignored, contradicted, or overruled the SWG’s recommendations.
One concerning example is from the October 2022 meeting, where the SWG expressed concerns about the delayed implementation of recommendations from A Review of the Shark Control Program Target Shark Species List 2021. This review advised reducing the target shark list from 19 species to only three—bull, white, and tiger sharks. Instead, QDAF decided on a phased reduction to a seven-species target list, delaying full implementation of the review’s recommendations until at least 2025, subject to further review. This decision contradicts scientific evidence and undermines efforts to modernize shark mitigation strategies.

Another critical issue involves the SWG’s repeated recommendations, starting from March 2020, to replace shark nets with drumlines during whale migration seasons to reduce entanglements. Despite consistent support from the SWG in subsequent meetings, including September 2020, February 2021, and October 2022, QDAF has failed to act on these recommendations. Feedback on draft SWG communiqués prepared by QDAF reveals that the department has deliberately downplayed the SWG’s opposition to inaction, further highlighting a disconnect between scientific advice and departmental decisions.

It is alarming that QDAF continues to deploy shark nets year-round, disregarding the risks posed to migrating whales. I request that QDAF provide evidence that lost equipment was not caused by humpback entanglement and confirm that self-release mortality has not occurred. 
Furthermore, I urge an immediate review of QSCP practices to align with the SWG’s recommendations and modernise shark bite mitigation strategies to non-lethal methods.

Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable

What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days.

How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 13

Concerns About Humane Practices in Shark Handling

Accepted Answer

Please tell us in a few words what your feedback relates to: Inhumane treatment of a shark by QSCP contractors.
Tell us what happened: I have seen images online of an incident involving the Queensland Shark Control Program contractors where a shark was killed in a manner that does not align with the department’s stated standard operating procedures, which are claimed to be humane. These procedures typically involve methods such as ‘pithing’ or ‘brain spiking’, but in this case, it appears the shark’s spinal cord was severed while it was still alive using a knife.
This method is neither humane, as the shark would have experienced significant suffering during this process, nor does it comply with the department’s own guidelines or legal exemptions. While certain actions by Shark Control Program contractors are exempt from the Animal Care and Protection Act, this incident does not appear to meet the exemption criteria, as the method used—a knife—is not classified as “fishing apparatus” under the Fisheries Act.

This raises serious concerns about adherence to regulations, contractor oversight, and the program’s claims of humane practices.
Where did the matter take place?: Not applicable

If you've raised this with us before, please provide your reference number and/or name of the person you dealt with: Not applicable
What outcome are you expecting?:
Please provide a formal commitment that you will be addressing my concerns and rectifying the situation within 14 days. How would you like to be contacted? Choose between email, phone and do not contact me - we suggest choosing email so that everything is in writing.

Question 14

Lack of Onboard Surveillance for Contractors

Accepted Answer

I am writing to make a formal complaint regarding a critical oversight in the Queensland government’s shark control program: the lack of a requirement for onboard surveillance cameras for contractors.

Given that this program involves the killing of wildlife using taxpayer funds, it is imperative to uphold the highest standards of accountability, transparency, and quality assurance. 
The absence of surveillance cameras onboard vessels involved in this program raises several serious issues: 
1. Accountability: Without proper surveillance, it is impossible to verify that contractors are adhering to the program’s guidelines and regulations. This lack of oversight undermines the integrity of the entire operation. Surveillance footage would provide an essential layer of transparency, allowing for public scrutiny and trust. 
2. Quality Assurance: Ensuring that contractors meet quality assurance standards is crucial for any government program. The absence of surveillance means there is no way to confirm that contractors are performing their duties ethically and effectively, which is a breach of quality assurance standards. 
3. Ethics and Compliance: The lack of surveillance is not only an ethical issue but also a potential breach of contract conditions. Contractors should be held to strict compliance standards, and surveillance cameras are a straightforward and effective way to ensure this.

While I firmly believe that the shark control program should not exist in its current form, it is essential to implement surveillance measures to mitigate some of its negative impacts. Requiring onboard surveillance cameras would be a significant step toward ensuring that the program operates with the necessary level of oversight and ethical responsibility. 
I urge the Queensland government to take immediate action to mandate the installation of surveillance cameras on all vessels involved in the shark control program. This will help ensure that the program is conducted in a transparent, accountable, and ethically responsible manner.

I request a formal response to this complaint following complaint management procedures. Simply “noting” my response is not acceptable me.

Question 15

Misuse of Tragedy to Justify Shark Control Exclusion Zone

Accepted Answer

I write to lodge a formal complaint regarding the Queensland Government’s justification for the 20-metre exclusion zone introduced under Section 31 of the Fisheries Act 1994, as outlined in the Fisheries (Sustainable Fisheries Strategy) Amendment Bill and associated explanatory notes.

The government has publicly cited the tragic 1992 drowning of a nine-year-old boy at Nobby Beach, an event that occurred over 25 years prior to the law’s introduction, as a core justification for this offence. To use this decades-old incident as the emotional centrepiece of a policy aimed at criminalising proximity to controversial shark control gear is, frankly, abhorrent and unconscionable.

If the true purpose of the law was public safety, particularly in response to this drowning, the government would not have waited a quarter of a century to act. The glaring delay undermines any claim of urgency or sincerity in protecting human life. It instead exposes the law for what it truly is: a targeted response to growing public opposition and activism, particularly by individuals attempting to document and expose the environmental cruelty and scientific redundancy of the Shark Control Program.
Let's be clear, this law was introduced not after a drowning, but after increased scrutiny and public awareness around shark nets and drumlines. The government’s own statements acknowledge that people have interfered with the apparatus “on quite a regular basis.” The clear intent of the exclusion zone is to shield the program from public accountability, not to protect lives.

It is deeply unethical for the government to co-opt the memory of a child’s death to lend moral weight to legislation that serves an entirely different function. The attempt to emotionally legitimise an anti-scrutiny measure by invoking a tragedy from 1992, particularly one resulting from poorly secured and storm-displaced gear, not deliberate interference, is a gross misuse of legislative reasoning.

Furthermore, the maximum penalty of 200 penalty units ($26,110) is wildly disproportionate and appears designed to intimidate, silence and criminalise concerned citizens rather than to reasonably mitigate any proven risk to public safety.
I call on the government to:
 • Immediately review and repeal or amend the exclusion zone offence under Section 31;
 • Acknowledge the improper use of a historic fatality in promoting this law;
 • Commit to a public inquiry into the real motives and enforcement practices behind the exclusion zone;
 • Re-focus shark bite mitigation efforts on scientifically supported, non-lethal methods rather than expanding laws to protect ineffective and damaging lethal gear.

Public trust cannot be maintained when emotionally manipulative tactics are used to justify legislation that obstructs transparency and shields outdated programs from scrutiny.

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