The scientific facts behind shark nets to be deployed at Tinley Manor by Club Med

OPEN LETTER IN REGARD TO THE DEVELOPMENT AT TINLEY MANOR BY CLUB MED

We would like to provide comments on the many statements made during the Public Participation Process (PPP) related to the proposal for the installation of lethal shark control gear at Tinley Manor by Club Med. The statements below (in italic) were made during both the online public meeting and the in-person evening meeting, dated 6th November 2025.

We believe those statements to be biased as made by interested parties with a vested interest in the project's approval.

Following our clarifications, we would also like to ask some relevant questions to both DFFE and Club Med.

Statements made by the developer of Tinley Manor: 

“the beach will be a busier public beach. The resort itself is looking at about 900 guests who can be accommodated in the resort at any given time. Being an international resort we expect about 24,000 visitors international and about 12,000 visitors domestic”.

·        Question: is there really any scientific evidence that an increase in the number of water users at a single beach/location (and not over a large area) will increase the risk of encountering a shark at that location?

o   Comment: we believe that the risk of an encounter between a person and a potentially dangerous shark hinges on both the number of people and of sharks. While there might be a slight increase of an individual encounter, if more people were in the water along a specific stretch of coast, the population declines of most of the shark species in the area should also be considered.

·        Question: would the introduction of a single installation reduce the risk of a shark encounter or unprovoked bite?

o   Comment: as nets and drumlines are not barriers, they are fishing devices aimed at lowering the population of potentially dangerous species over their distributions by removing/killing them, we don’t believe there would be a reduction in risk for water users because those proposed nets will be removed from another area nearby. White sharks, tiger sharks and bull sharks, thanks to the last decades of telemetry and population genetic studies, are known to be highly migratory species. For instance, among the three potentially dangerous shark species targeted by nets and drumlines, the species considered most “resident” is the bull shark. Bull sharks however, travel annual distances between 450 and 3760 km (Daly et al., 2014). Therefore, moving nets and drumlines from one location to another would not reduce the risk of an encounter but would only provide a perception of extra safety in an area where no shark bites have occurred, and since 1994, when the nets were removed from that area. Therefore, the alleged urgency in applying a lethal approach to mitigate the potential risk of human-shark conflict, promoted in the Public Participation Process by the KZNSB, appears unfounded.

The PPP repeatedly claims that relocated nets at Tinley Manor will “reduce the local risk” by lowering the presence of “resident” sharks. This is not supported by current shark-movement data or by KZNSB’s own catch records. A lethal shark control gear (net or drumlines) hinges on the combined effect of the whole system and not in isolation at a local level, as there are no resident populations confined to Tinley Manor, for instance. Installing a single net/drumline configuration does not control the local presence of migratory sharks (like the main three target species of the KZNSB gear), nor does relocating gear alter risk at a fine spatial scale. If risk were genuinely reduced at Tinley by installing this gear, the PPP would have to acknowledge a corresponding increase at the site it is removed from — which it does not. The claimed benefit is therefore perceptual rather than operational.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“Club Med had looked at numerous alternatives and they considered the only viable alternative right now for the high-energy environmental conditions and species of concern was the use of nets and drums and hence we were approached.”

“KDM was concerned about job creation, economic growth in the region, almost zero environmental impact, and cost, as nets and drumlines are cheap, so the decision was made by KDM to approach the Sharks Board”.

·        Question: those are contrasting statements on who requested the KZNSB services. As neither Club Med or KDM, or the environmental consultants, have any expertise on shark risk mitigation, and considering that the KZNSB should not be considered impartial in relation to its decisions toward appropriate shark mitigation measures and impacts (see also further discussions below), and considering the large investment made by Club Med, has Club Med been provided with information by experts outside the KZNSB?

·        Comments:

o   The contradictory statements point to a deeper procedural concern: the PPP does not disclose any record of how the decision pathway unfolded, nor whether independent technical advice was ever sought before concluding that lethal gear was the “only viable” option. A process involving multimillion-Rand tourism infrastructure should demonstrate a transparent, traceable decision trail — not conflicting verbal accounts. Without documented evidence of independent expert consultation, the conclusion that nets and drumlines are the sole viable option cannot be considered procedurally sound.

o   Declaring “almost zero environmental impact” before any independent specialist study has been completed pre-empts the outcome of the impact assessment and undermines procedural integrity. Under environmental law, the conclusion must follow the assessment — not precede it. Presenting the impact as negligible in advance suggests a predetermined outcome rather than an objective evaluation, and the PPP provides no evidence to support such a claim.

o   Furthermore, the statement “almost zero environmental impact” is highly questionable, as that would require an independent assessment on the impacts on the habitat and ecosystems, on the target species and the bycatch, and the ecological effects, especially on threatened and protected species. Please see the official position of the IUCN on lethal shark control programs: https://iucn.org/sites/default/files/2023-10/2023-commission-statement-on-shark-control-programs-and-shark-culls.pdf

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“In the last 73 years the deployment of nets and drums has reduced the incidence of fatal shark attacks by 100%.”

·        Comment: the metric of encounters/ unprovoked bites at “protected beaches” is not scientifically correct, considering that the aim of this fishery (shark control program) is to lower the number of entire populations, thus across the whole distribution of each species. At a minimum, the entire geographical extent where the whole lethal shark control program is deployed (i.e., from the first net/drumline in the South to the last net/drumline North) should be considered, or even more correctly, the entire distribution of each shark population in question should be considered. In fact, 40% of the sharks are caught on the inside of the shark nets, indicating that they can swim around and below the net. The nets and drumlines have never been designed to prevent the sharks from reaching a beach, but were designed to reduce their populations.

o   Question: if the definition of shark incidents was to be expanded to the entire area serviced by the lethal shark control program (i.e., from the first net/drumline in the South to the last net/drumline North), how many more negative interactions should be included since the 60s?

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“Since the mid 1990s, Sharks Board reduced the length of nets by 84% and it reduced the capture of animals by 80%. In the last 5 years, the average number 564 animals per year have been caught, of which 150 are released alive. So we catch on average 416 animals and that equates to about 1.1 animals per day.”

·        Comment: the reduction in capture (80%) should be considered in parallel with the decline in shark populations. For instance, since the 1970s, the global abundance of oceanic sharks and rays has declined by 71% (Pacoureau et al., 2021). Those numbers must be unpacked between target and non-target species, as well as for threatened and protected species. The ratio between target and non-target species is actually 1 to 7.6 (Atkins 2023), showing that the majority of catches are non-target species. According to the Parliamentary Enquiry RNW1409 of the 29th October 2024, the data provided by the Department of Forestry Fisheries and the Environment (DFFE) shows that over the course of four non-consecutive years (2016, 2019, 2020 and 2021 were the only data DFFE provided) the captures by the KZNSB can be summarised as:

o   Target species (tiger, white and bull sharks): 58 per year, which were 13.2% of total catches

o   Non-target species: 381 per year, which were 86.8% of the total catches. Specifically:

• marine mammals: 21 per year, which were 4.7% of total catches

• turtles: 8 per year, which were 1.9% of total catches

•  other non-dangerous sharks: 305 per year, which were 69.5% of total catches

• rays: 42 per year, which were 9.6% of total catches

•  bony fishes: 3 per year, which were 0.8% of total catches

•  birds: 1 per year which was 0.3% of total catches

When the same data provided during the Parliamentary interrogation is looked at in terms of threatened species (Vulnerable, Endangered or Critically Endangered categories by the IUCN), 79.1% of the animals removed by the KZNSB lethal shark control program are species considered to be facing between a high to extreme risk of extinction in the wild. Of the target species, 2 out of 3 species (67%) are protected. If one adds the three hammerhead shark species, the ragged tooth sharks, together with all the turtles and marine mammals, a minimum estimate reflects that, out of the average total annual catch, 46% of the time, KZNSB catches species which are either protected or prohibited (TOPS).

The removal of 416 animals per year is not a trivial figure when shark and ray populations are already severely depleted, and when the majority of those removals involve non-target and often threatened species. Furthermore, reporting “1.1 animals per day” obscures the cumulative effect of hundreds of removals annually over the past six decades and does not align with the claim of “almost zero environmental impact”. A valid assessment must evaluate ecological significance, not raw daily averages.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“So if we look at the shore fishery (just the anglers fishing from the shore) and we look at just the competitive fishery, a paper in 2007 looked at the average catch between 1977 and 2000. Those are old figures but I'm not aware of any more recent ones. The competitive shore fishery core averages at ~8,800 fish per year with an average of 64% elasmobranchs so that equates to roughly 5,643 elasmobranchs”.

·        Comment:  this information provided is biased, as most, if not all, those elasmobranchs are caught and released alive, which makes the comparison irrelevant.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“If we look at the non-competitive fishery, a study in 2012, with data of 2009, estimated that the recreational shore fishery catches between 600 and 700,000 fish per year. Now I could only have the abstract of that paper but, if we assume that just 1% of those 650,000 fish are elasmobranchs, that equates to 6,500 per year”.

·        Comments:

o   An expert statement should not be made using only an abstract and further guess relevant estimates. In fact, those estimates are incorrect. Only 0.26% of the total catch was elasmobranch species that were kept/killed, which equates to ~1690 animals/year, most being milk sharks and lesser sandsharks (non-target species of the KZNSB).

o   Recreational fisheries—competitive or non-competitive—are overwhelmingly catch-and-release nowadays, and although post-release mortality and poor handling can cause harm, and that impact is not yet quantified, it is obviously biologically different from the guaranteed removals (i.e., mortality) caused by nets and drumlines. Because recreational fisheries primarily release their catch, while the shark-control program intentionally removes the larger, slow-growing species, the two activities do not produce comparable ecological effects. Using recreational catch numbers to evaluate or justify lethal shark-control operations, therefore, does not provide a valid basis for comparison.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“There is another paper by Dunlop and Mann in 2013, where they looked at what the recreational commercial and charter skiboats (between 2 and 3000 boats fishing). And again, I don't have the figures but let's conservatively say elasmobranchs are caught per year by 2-3,000 boats”.

·        Comment: once again, an expert opinion should be based on correct data and not just guesses. In fact, the data show that only 0.03% of the total boat catches (all sectors combined) consist of elasmobranchs that are kept/killed (~433 animals/year, once again mostly milk sharks or blacktip sharks). It is worth noting that in some years, when there is a lucrative market, commercials will target juvenile dusky sharks for sale to Australia for their “flake and chips” market.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“If we look at the KZN crustacean trawl fishery, the primary targets are prawns and crabs. However, it does catch hammerheads in 65% of trawls and dusky sharks in 3% of trawls. Thus it's a high percentage of elasmobranchs. Now the totals, including discards, is about x000 tons per month [unfortunately we could not hear well this specific number provided] so if we conservatively estimate 10% of the catch being some form of elasmobranchs, that's 100 tons of elasmobranchs per year. And if we assume that each elasmobranch is maybe 20 kilos, that equates to around 5,000 elasmobranchs per year”.

·        Comment: once again, partial information may lead to wrong and misleading statements, which are insufficient for informed decision-making. For instance, it is true that in the inshore trawl fishery on the Thukela Bank, 65% of all trawls caught at least a hammerhead and 3% a dusky shark, but it failed to mention that the same inshore prawn-trawl fishery came to an end in 2019 after the declaration of the uThukela MPA where trawling is nowadays completely banned (even though the offshore fishery still trawls close to the offshore MPA boundaries). Elasmobranchs are still caught in the deep-water prawn-trawl fishery (even though completely different species compared to the inshore trawl fishery), but because the inshore trawl fishery has ceased, these data should not be used to look at the impact of current fisheries. Furthermore, a study done between 1989 and 1992 estimated for the inshore trawl fishery that for every retained caught animal (target), 4.25 were discarded (non-target), while the ratio between target vs non-target species for the KZNSB lethal shark control program is 7.6 to 1 (Atkins 2023), thus higher than the inshore trawl fishery.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“If we add those all up we get approximately (and it is just an order of magnitude 18,143 elasmobranchs per year, and that's just what we know of. Of course not all of those elasmobranchs die. Many are going to be released. The release rate is going to differ between fisheries”.

·        Comment: not a small caveat, as the majority of sharks and rays caught are released alive as described above, and the figures from the inshore trawl fishery are not relevant any longer, as it is not an active fishery in KZN.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“But if we assume that 70% survive, well, that conservatively estimates that approximately 5,000 elasmobranchs are killed by those fisheries each year while only 418 are killed in the Sharks Board nets”.

·        Comment: these are instead the correct figures quoted from that paper cited (Fennessy et al, 1994): “Of the estimated 44 600 elasmobranchs caught by trawlers from 1989 to 1992, about 57% (25 600 fish) were returned to the water alive (based on mortality rates recorded onboard). Mortality subsequent to this study was not estimated. During the same period, the Natal Sharks Board caught 9 276 elasmobranchs, of which 3 350 (36%) were released alive (Natal Sharks Board unpublished data). Catches at Natal angling competitions, from ski boats and by shore-anglers, amounted to 37 566 sharks and rays (National Marine Linefish System feedback analyses 1989-1992). Increasing numbers of elasmobranchs are being released by competition anglers, with some estimates being as high as 90% (R. Roux, Natal Coastal Anglers Union, pers. comm.). Estimates of recreational catches of elasmobranchs are imprecise, because they rely on the voluntary completion of catch cards by anglers. Total catches recorded by recreational skiboat- and shore-anglers for the period 1989-1992 amounted to 5 590 fish (National Marine Linefish System feedback analyses 1989-1992), a figure which could be underestimated by as much as 90%”.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“So this puts into context that the environmental impact of the protection gear compared to other fisheries is very, very minimal. In fact, when you look at the 11 fisheries that currently catch elasmobranchs in South Africa, KZNSB catches the least number of elasmobranchs so certainly from a conservation point of view the Sharks Board has the least environmental impact”.

·        Comment: to really judge the impact of a fishery (including the lethal shark control program run by KZNSB), it is important to discriminate target vs non-target catches, as well as quantify the numbers of protected and threatened species, as well as the ecological role each species plays in the ocean.  As already stated above, 86.8% of the total catches by the KZNSB are non-target species, and 46% of the total catches fall under the protected and/or prohibited categories (TOPS). In fact, Da Silva et al. (2015) clearly indicated the impact of the KZNSB gear is actually significant compared to other fisheries because the “bather safety” gear is responsible for more than 50 to 75% of South Africa’s catches for five of the six Endangered and Critically Endangered shark species, namely the raggedtooth shark, scalloped hammerhead, great hammerhead, sandbar shark and the dusky shark.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“It's very difficult with accuracy to say what the deployment at Tinley Manor would capture, as that area hasn't been fished for a good 20 or 30 years. We looked at what was captured at Tinley Manor when it had nets between 1973 and 1994 and what was caught at Blythedale (which is adjacent to Tinley Manor) over the same time period. In those days Tinley Manor has three double nets with similar captures to what is caught now at Blythedale: on average we expect around 15 animals”.

·        Comment: the details of those 15 forecasted animals killed per year are not clear in relation to the management of the Club Med’s Tinley Manor resort.

o   Questions: How many target shark species are expected to be killed? But also, how many dolphins? How many turtles? How many of those animals are threatened or protected species?

·        Comment: a credible impact forecast must reflect current species vulnerability to extinction and modern abundance, not data that pre-dates TOPS listings and the documented collapse of several shark populations. Without updated, contemporary baseline data, the projected figure of 15 animals per year has little scientific validity in terms of impact assessment.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“Drones, cameras, shark spotters, they're all types of surveillance technology and they're based on the ability that you can see the animal of concern. Shark spotters are currently used in False Bay and Plett. It goes without saying those are bays. They're calm, they're sheltered. And the species of concern is the white shark. Unlike the bull shark and the tiger shark which are a concern or possible concern for men, the white shark spends a considerable time at the surface so you have an ability to spot it. The chances of spotting bull sharks and tiger sharks at Tinley Manor with those environmental conditions are minimal, if not existent. So surveillance technologies at Tinley Manor it's not a suitable shark mitigation technology”

·        Comment: surely one of the main target species is indeed the white shark (1 out of 3 bites relate to white sharks in KZN: Cliff 1991). Using the statistics about bites above, this approach could reduce the risk for people by one-third. Of course, calm conditions to allow a drone to spot a white shark might not be frequent, but a study in Australia (link) showed that drones were estimated to be more than twice as effective compared to shark nets. From the summary report of that study (link) “this was despite drones operating for only approximately 2.9% of the time that nets were deployed and 5.1% of the time drumlines were actively fishing”. Of particular interest, that study also showed that “Across all drone trial beaches, a similar number of bull sharks were detected by drones (23) and caught in gear (26), yet 64 tiger sharks were caught in gear with none being seen by drones”, showing that drones under certain situations could also be used to detect bull sharks.

o   Questions: of course, the water clarity in Australia might be better than in KZN, but because of the low cost of drones, and the fact that life-guards will already be employed on the beach by Club Med, would it not be worth using drones, even if to spot just white sharks every now and then? Would that not already significantly reduce the risk for water users? Why not add that method to detect large sharks?

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

 “Then we have another barrier device called the SharkSafe barrier. I'm aware of being installed commercially in the Bahamas. Again very different surf conditions to that at Tinley Manor. There have been 5 published studies on the shark safe barrier. Four of those were in 2014, one is in 2017. And the conclusions were it might have applicability, but it hasn't been tested in a real world scenario. Thus it needs more testing”.

·        Comment: the SharkSafe barriers have actually been successfully tested since 2012, with several publications on their efficacy to deter white sharks and bull sharks available online (link). They have been commercially installed at two resort locations in the Bahamas, with already very positive results for the clients. Furthermore, the SharkSafe barriers have been tested by coastal engineers at two very high-energy locations in South Africa (Granger Bay over rocks and Mackerel Beach on sand) since 2024 (news feed 1 and news feed 2). Differently from shark nets and drumlines, this barrier aims to keep large sharks efficiently separated from bathers, without killing other marine animals.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

 “The first question regarded the Sharks Board represent the biggest captures of white sharks in South Africa. That is not true. We know reliably that there are unreported captures in the longline fishery and the longline fishery alone can catch 2 to 3 tons of white sharks”.

·        Comment: the latest official catch statistics from the KZNSB talk about an annual average of 22 white sharks caught by the KZNSB. As most will be juveniles and the average weight (based on data from dissections performed at KZNSB) would be conservatively around 150 kg, this would mean an average for the KZNSB of 3.3 tons of white sharks caught per year. This would still make the KZNSB the primary source of mortality for white sharks in South Africa. This information is confirmed by a published study (Kock et al 2022): “White sharks overlapped with longline and gillnet fisheries within 25% of South Africa’s Exclusive Economic Zone and spent 15% of their time exposed to these fisheries during the study period. The demersal shark longline fishery had the highest relative spatial and temporal overlap, followed by the pelagic longline fishery and the KwaZulu-Natal (KZN) shark nets and drumlines. However, the KZN shark nets and drumlines reported the highest white shark catches, emphasizing the need to combine shark movement and fishing effort with reliable catch records to assess risks to shark populations accurately”.

·        Questions: What reliable data source was referred to?

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“A study by Sheldon Dudley and Colin Simpferdorfer in 2006 showed that the potential impact of captures in the KZNSB gear was minimal to zero for all but two species, the dusky shark and the ragged tooth shark. Now since 2003 we've reduced the capture of dusky sharks by 50% and ragged tooth sharks by 73%. So in all we are now having zero impact on any shark populations in the country”.

·        Comment: the cited article actually says “Catch rates of four species (bull sharks, blacktip sharks, scalloped hammerhead sharks and the great hammerhead sharks) showed a significant decline, as did the mean or median length of three species (pigeye sharks, blacktip sharks and female white sharks). For three species that showed declining catch rates or length, the potential effect of the shark nets was assessed to be low, suggesting that other sources of catch were responsible for the declining status. The potential effect of the shark nets was assessed to be high for two species (dusky sharks and ragged tooth sharks, neither of which showed declines in catch rate or length), because of very low intrinsic rates of population increase… The KZN program was assessed to have a medium potential effect on three species (white sharks, scalloped hammerheads and bull sharks). All these species showed some indication of population declines between 1978 and 2003… for bull sharks the effect may be more pronounced”.  Yet there was no mention by the KZNSB that at the time of that study, only 2 out of the 14 assessed shark species were considered threatened (i.e. Vulnerable). Nowadays, 13 out of those 14 species are now threatened (3 Critically Endangered, 3 Endangered and 7 Vulnerable) with the remaining 14th (the tiger shark) considered Near Threatened.

o   Question: as the referred paper actually evaluated that the KZNSB nets indeed have an effect on two of the three target species, especially for bull sharks. Why were those target species not included in the public statement?

·        Comment: to properly establish whether the shark nets and drumlines have an ecological impact, and to reliably quantify their impact, an independent expert review would be needed.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“MPA (nearby) is multiuse. Recreational fishermen both from the shore as well as on boats, will catch and kill more sharks in the MPA than the proposed deployment of shark nets and drumlines just outside the MPA”

·        Comment: there is no data supporting this statement. Actually, there is evidence of the complete opposite as the uThukela MPA regulations say that all captured sharks and rays must be released alive and unharmed, whether caught from the shore or from a boat, in the controlled area. 

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“We look at alternatives all the time. We sit on various advisory shark mitigation committees globally. We're in contact with experts around the world. In different countries they use different technologies and we would be the first organisation to consider the replacement of nets and drums with alternatives… It's just a fact that there are no technologies that are currently as effective to replace nets and drums. So this in no way makes the Sharks Board being reluctant to change his ways. The technology just doesn't exist… If they did and there was a realistic expectation of success, we would be the first organization to implement them”.

·        Comment: this is a fantastic official promise by the KZNSB where, if an alternative could provide evidence of being successfully tested with the main target species and could sustain high-energy environments, the KZNSB will implement it, or at least test its use, to replace nets and drumlines.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“It was shark attacks that caused the decimation of the tourism industry and the loss of thousands of jobs and millions of Rand back in the 50s and 60s. That's why shark protection was implemented… Why do we need to protect against shark attacks even if the risk is low? When we look back what happened in KZN in the 50s and 60s when there were lots of attacks, the economy was decimated, no tourism would come to KZN. Around the world when there is a shark attack, the local economy, the coffee shops, the surf stores, the service industry, the hotels loose hundreds of millions of Rand with job losses: that is also in Reunion and Australia, so shark attacks will cost jobs and will cost the economy. While the risk of a shark attack is extremely low, it only takes one shark attack to impact the economy. Lots of people die on the road, lots of people die drowning, but do not affect the economy, people still come on holiday, despites crime, drowning or protests but it takes only one shark attack, in all likelihood, will reduce numbers of visitors at the new Club Med hotel which will mean less jobs for the local community”

·        Comments:

o   The use of the term shark attack appears 11 times in the Public Participation Process website, and again, 11 times is mentioned by the Acting Director of Research of the KZNSB in this document. There is plenty of scientific literature (e.g. Neff and Hueter, 2013) which provides evidence for not using such terminology but to rather talk about encounters, bites and fatal bites. This is not a minor detail, as the terminology used by the KZNSB is the result of a strategy aimed at perpetuating fear, forcing the public to remain anachronistically focused on conflict rather than promoting safe coexistence for all species.

o   There is no evidence that a single shark bite would collapse an entire tourism industry. It is possible that a series of bites could (not necessarily will) create a tipping point, which could impact the economy negatively. However, the data referred to by the KZNSB refers to the events that happened in the 1950s, more than 70 years ago, when both our society and the abundance of shark populations were profoundly different. So, it would be quite naïve to expect a similar outcome nowadays. In fact, Plettenberg Bay is a great case study to debunk the catastrophic narrative. In general, shark bites have indeed caused short‑term declines in visitor confidence and local revenue, but in the case of Plettenberg Bay, where two fatal shark incidents occurred in 2022, the local municipality and other partners rapidly formed the Plett Shark Action Group, and through transparent risk management, targeted public communication, and nature‑positive economic strategies, their tourism recovered rapidly. Combining proven safety measures, clear communication, and investment in sustainable, community‑linked marine tourism turned damaging incidents into a catalyst for resilient economic recovery and stronger conservation outcomes.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“The very fact that people are looking for alternatives to be used must suggest that everyone does realize that there's a risk of attack otherwise no one would ask for alternatives. So I think, in itself even the lobby groups here suggests that even they believe that there is some level of risk”.

·        Comment: while some alternatives are mentioned, it is important to clarify that they are not proposed because the vast majority of scientists believe shark-human interactions pose a significant risk requiring intervention, especially when extractive. Rather, their inclusion reflects the entrenched legacy of the KZNSB, which has historically shaped public perception through fear-based messaging and political influence. Additionally, any operational shift away from lethal methods has implications for staff livelihoods, and without viable alternatives, job losses may occur. Therefore, alternatives are referenced not as a necessity for public safety, but as a pragmatic response to the institutional and socio-economic realities surrounding KZNSB’s continued operations.

Statements made by the KZN Sharks Board (hereafter KZNSB) official representative (acting Head of Research, Dr Matt Dicken):

“Certainly the risk of a humpback dolphin capture should gear be deployed at Tinley Manor is almost zero or very very minimal” 

·        Comment: catches are generally relatively rare indeed. During the 1980-2009 period, around 6 humpback dolphins per year were killed by the KZNSB nets. Tinley Manor had the 3rd highest catch rate of humpback dolphins (after Richards Bay and Zinkwazi) with an average of 0.5 humpback dolphins per km of net per year. Yet as the remaining population of humpback dolphins (the most endangered dolphin species in the Western Indian Ocean) is already estimated to be below 500 individuals, each individual counts.

CONCLUDING REMARKS:

Ultimately, as the KZNSB lethal shark control program is based on the removal of potentially dangerous species, its alleged high success rate and effectiveness in preventing human interactions with potentially dangerous sharks can only happen because of the high impact on the populations of these target species. What about the catches of non-target species (which represent 86.8% of the total catches by the KZNSB)? The KZNSB cannot claim zero or minimal impact and high success at the same time. This is an oxymoron.

Maybe the most important detail, and a possible point of reflection for the Department of Forestry Fisheries and the Environment, during its evaluation of the request to install new nets and drumlines at Tinley Manor, and more in general in the continuation of providing permits to the KZNSB to use and operate only lethal shark control gear, is that the KZNSB is the only permitted fishery (recreational or commercial) in South Africa allowed to target and catch an unlimited (no quota) number of prohibited species (as listed in the Marine Living Resources Act) and that regularly catch Threatened Or Protected Species (TOPS listed species). Furthermore, the same KZNSB gear impacts many species which have little to no interaction with the majority of other fisheries mentioned, yet they are regularly caught in shark nets and drum lines (i.e. all the Mobula spp, turtles, cetaceans etc…).

We would like to reiterate that we are not against development in KZN, nor against job creation. We are against unsustainable, extractive and wasteful practices, with short-term gains, that are no longer relevant or acceptable in todays’ ecological era. We are also against practices which go against the core ethos of South Africa’s constitution (as well as many other national laws) to secure sustainable development for present and future generations. Data show that, by protecting the environment and the ecosystem services it provides, South Africa’s national, provincial and local government will indeed support the economic development and job creation through tourism, which, if sustainable, will have long-term benefits.

As Club Med is endorsed by the Green Globe certification, it will benefit from having an alternative approach to the proposed lethal methods, aimed at reducing potentially dangerous shark populations to reduce the likelihood (already low) of encounters with bathers. Simple techniques like banning bathing at night and at dawn and dusk, and not allowing bathing when the sea is rough and turbid, will already greatly reduce the risk of a shark encounter or bathers/swimmers getting into trouble (the risk of drowning in reality is a far bigger threat than the million-to-one chance of a shark bite). This, together with the implementation of tested technology (e.g. SharkSafe barrier), along with the use of vigilant lifeguards (maybe further empowered by drones) who can assess risk and quickly get people out of the water if a shark is detected, will help to reduce the perception of risk and improve the overall safety for water users at Tinley Manor.

Contributing Researchers:

• Dr Enrico Gennari, Oceans Research Institute

• Dr Ryan Daly, Oceanographic Research Institute

• Dr Bruce Mann, Oceanographic Research Institute

• Dr Jennifer Olbers, marine conservation professional

• Mr. Grant Smith – Sharklife Conservation Group

• Dr Sara Andreotti, Stellenbosch University

• Dr Judy Mann-Lang, Rhodes University

• Dr Serena Lucrezi, North-West University

• Prof. Conrad Matthee, Stellenbosch University

• Dr Alejandra Vargas-Fonseca, Nelson Mandela University

• Dr Sasha Dines, Seasearch Research and Conservation

• Prof. Amanda T. Lombard, Nelson Mandela University

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