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Early in 2011, Pew produced a 32 page report entitled 'Sharks in Trouble' on the global status of sharks.

You can download this as a PDF file by entering 'Pew Sharks in Trouble' into your search engine

This was my response to that document, and their reply:


Pew Environment Group
901 E St. NW
DC 20004-2008
United States of America

Re - Sharks in Trouble

Dear Sir,

I've read your recent report with interest. Some points come to mind.

Page IV

The report states that up to 73 million sharks are killed each year. This is the top end figure from Dr. Shelley Clarke, but her research states a range from 26-73 million, with a median of 38 million.

Therefore simply stating 73 million does not give a true perspective of the situation, and is therefore somewhat misleading.

The next line states. "Further, scientists estimate that at least 100 million sharks are killed annually, including sharks caught for other products, such as their meat."

This begs the questions;

Which scientists estimate that at least 100 million sharks are killed annually?

Which year does their estimate refer to?*

Where is the scientific paper to support this claim?

*If they've carried out the research for annual catch, it would be fair to assume they carried this research out over a specific 12 month period.

As I understand, the 100 million so-called 'Magic Number' was first cited in 1997. Therefore it is reasonable to say that there were most likely 100 million sharks killed in the previous year, 1996, for the figure to be evaluated and published in 1997.

Your report claims that there are 100 million sharks killed every year, which in turn suggests there have been 100 million sharks killed every year for the last 14 years.

Even although sharks mature late in life, and produce few young, it can be implied, (from your use of the 100 million figure), that this number is in fact a sustainable catch. Your report fails to take the apparent sustainability of 100 million, enforced by the report itself, into consideration.

It would also indicate, given this number was initially used in 1997, that the annual shark catch has remained constant over this period of time.

It could also be argued, from your report and your use of the 100 million figure, that over those 14 years, all the efforts of shark conservation, legislation, shark sanctuaries, MPA's, petitions, donations, not to mention scientific research, have counted for nothing, because the catch total you are citing in 'Sharks in Trouble' is exactly the same as in 1997.

So if I were a shark fishing nation, looking at this paper, with the knowledge of the 1997 figure, I would be justified in claiming;

a) the 100 million figure is sustainable - even in the face of advanced fishing techniques,

b) the catch has remained incredibly stable, year in year out, regardless of any advances in fishing techniques,

c) the increase of demand for shark fin products, which you cover on Page XVIII has had no impact on the annual catch,

d) shark conservation has had no discernible effect over the past 14 years.

Given these points, it could be argued based entirely on your use of the 100 million figure that there is no problem at all.

Now obviously I'm sure you'll suggest there is a problem, that conservation has made inroads, and that fishing techniques have improved. All this may be so, but it appears you've undermined your own cause before being able to present any evidence to the contrary.

Based purely on your report, a shark fishing nation could easily undermine your credibility, and that of shark conservation in general by pointing out that the shark catch is the same as it was in 1997, and has remained stable over the last 14 years. Therefore they have no case to answer.

Page X

"As a Data Deficient listing simply indicates a lack of data, it does not mean that a species is not at risk of extinction."

By the same token, it doesn't indicate that a species is at risk of extinction. Because there's no data, any statement pertaining to the possible threat, or possible non-threat to a species, is pure conjecture.

IUCN (International Union for Conservation of Nature) may well consider Great White Shark as Threatened, however according to my correspondence with Dr. Ronald O'Dor, senior scientist for the Census of Marine Life at the Consortium for Oceanographic Research and Education in 2010, he stated;

"It turns out we really do not know how many great white sharks there are in the world, but we do know that the many breeding populations are small."

So with regards to great white populations, it seems there's no conclusive data to detail exactly how endangered they are. Certainly if I chose to do so, I would expect to see a great white within 3-4 days of leaving London. I wouldn't expect to see a tiger in the wild within 3-4 months of leaving London. I cite the tiger as an example, because that was the species Dr. O'Dor used to illustrate the status of great whites.

Incidentally my correspondence with Dr. O'Dor was because he'd contradicted himself at the AAAS in San Diego last year with regards to the estimate of how many great whites there actually are.

With regards to the Blue shark, on the IUCN Near Threatened list; you've cited Dr. Boris Worm's work in your report.

However in Dr. Worm's paper, 'Patterns and Ecosystem Consequences of Shark Declines in the Ocean', he cites that Blue sharks have in fact increased by 20% in the North Pacific, relative to their 1970's levels.

This isn't mentioned in 'Sharks in Trouble', although you obviously feel Dr. Worm's research is credible enough for your report.

You will also note from this paper that Dr. Worm states that of the species evaluated globally, 4.1% are endangered, with 2.4% critically endangered, and that shark decline is not universal across all species. Effectively you've cherry picked what suits you from his research whilst ignoring that which would show the shark status in a more positive light.

Page XI

Whilst studies have been carried out to reveal severe declines in many shark species, it's of some interest to note 2 of the 3 examples you quote in the boxed section of text; Decline from Unexploited Levels, namely the Sandbar and Dusky sharks.

Both species have been subject to questionable research. You will no doubt be aware of Steve Pavon's film, 'The Shark Con'. He told me;

"I have paperwork with doctored catch totals. One of many examples was a scientist doing sandbar shark research in Florida, on board shark boats. For a fortnight these boats met their quota, but the paperwork showed zero sandbar sharks caught. This scientist was working on grant money to show that sandbar sharks were overfished."

"Another example that blew me out of the water was a scientist who got a grant to research dusky shark migration from Louisiana into Mexican waters. This research went on for 4 years. When it was time to turn his work in, he'd lost all his data! 'Don't worry' he was told, 'We'll reuse some numbers from the 1980's".

As you can see, if either the scientists or their figures from this flawed research of these 2 specific species were included in the Decline from Unexploited Levels statistics, then perhaps there's a possibility that the conclusions in your boxed text might be open to question.

Perhaps you could see if PEW funded any of this research, or perhaps if these scientists were involved in the conclusions you've used in your report?

Perhaps you could contact Steve Pavon for clarification, or their names?

I'm sure he'd be interested to hear from you, although I can't say I'd be surprised if he didn't reply. He also told me that during the making of his film shark conservationists weren't exactly forthcoming;

"Oddly not one of these conservation groups would return my phone calls or answer emails. I even offered to send the questions I wanted to ask beforehand, and sign a document stating I wouldn't stray from them. Not one single group or organisation agreed."

I don't know if he tried to speak to you.


"45% The percentage of all reported shark landings in 2008 coming from Indonesia; India; Spain; Argentina; and Taiwan, Province of China."

Whilst I am unaware of the percentage of landings from the first 4 countries listed, I have had correspondence with the Taiwanese on a shark related matter.

In a letter sent to me, dated 11th March 2011, the Taipei Representative Office in the U.K. stated;

1) Whilst Taiwan doubtless does* consume shark's fin and is involved in the fishing of the animal, Hong Kong and mainland China are the major markets for these products, and the consumption of shark fin in Taiwan is in fact decreasing*.

(*their italics)

2) According to 2009 statistics from the Fisheries Agency of the Council of Agriculture, most of the Taiwanese fishing industry is in fact based around Bonito (16.43%)

Shark accounted for only 1.33% of the total catch of Taiwanese fishermen.

3) Taiwan complies with common international regulations on shark fishing.

4) Taiwan has moved to protect certain species of shark, notably enacting legislation to ban the fishing, selling, importing and exporting of whale shark in 2008.

Obviously your 45% statistic is open to individual interpretation, but by listing Taiwan at the end of the text it might infer, unintentionally or otherwise, that the Taiwanese accounted for the lion's share of the 45% figure quoted.

So I've sent a link to your report to the Taipei Representative Office here in London, together with a copy of this letter, and if they feel the need I'm sure they'll clarify their position to you.

Obviously to maintain parity, I've duplicated this process across the relevant desks for Indonesia, India, Spain and Argentina.

Page XIV

With regards to Shark Bycatch Fisheries;

"In essence, it is unregulated and often unreported and is considered to be a major source of mortality for many shark species worldwide."

You'll note within your report you have quoted IUCN figures, and the work of Dr. Boris Worm.

I think you'll find in his paper, 'Patterns and Ecosystem Consequences of Shark Decline in the Ocean' that he lists IUCN figures for the breakdown of the annual catch as follows;

Direct commercial - 31.7%
Bycatch - 57.9%
Recreational fishing - 0.7%
Subsistence fishing - 5.8%
Habitat destruction - 2.9%
Pollution - 0.4%

So according to Dr. Worm, there is in fact a reported percentage for bycatch out of the annual shark catch. Interestingly, should these figures withstand scrutiny, it appears bycatch is the biggest threat to sharks, yet obviously within your report you have preceded this with Commercial shark fishing.

The 57.9% bycatch figure would give a much clearer indication of the threat to sharks as a result of bycatch than the five examples subsequently listed on Page XV

Again, if these quoted IUCN figures stand up, it illustrates that direct commercial shark fishing would account for less than one third of shark mortality. I mention this as you will be aware that the target of the majority of shark conservation is aimed squarely at the Asian market, as illustrated in your opening paragraph on Page XVIII, whereas bycatch would implicate all fish consuming markets.


This section deals with the rise in imports and trade of shark fins between 1985 and 1998, and between 1991 to 2000.

"In the Chinese market, trade in shark fins grew by 6 percent a year from 1991 to 2000."

However I have seen items on shark conservation social networking sites in the past twelve months that suggests the trade is currently rising at 6% per year. It appears, in light of your report, that these recent claims on social networking sites are in fact old data, and are not substantiated by current data.

It may well be that the trade is rising 6% per annum even now, but it appears that some shark conservation groups are in fact rehashing data that is a decade old and passing it off as current, when, as the Taiwanese have stated, their consumption is in fact decreasing.

So whilst your report may be accurate in regard to the rise in trade within the stated period, current shark fin trade increases, as portrayed to those supporters signed up to various shark conservation social network sites, may well be misleading.





The trophic cascade from Boris Worm's 'Patterns and Ecosystem Consequences of Shark Decline in the Ocean.'

Whilst your report focuses on the potential impact of the loss of sharks, it's become apparent that for those areas where sharks are effectively protected, (Palau), there have been no studies or models to synthesis the impact of an increase in the shark population.

It would be reasonable to assume that if there is a detrimental consequence to the ecosystem with the depletion of sharks, there would be an impact of some sort if shark populations were to explode.

This would be of particular relevance in Palau, because although they have a protected EEZ, with a stable shark population, they have no resident shark scientist. They also have several endangered species below sharks in the food chain, and any substantial increase in certain shark species would, as Dr. Worm confirmed to me in correspondence, potentially have an impact on the behaviour of these endangered species (turtles and dugongs).

I spoke with both Dermot Keane of the Palau Shark Sanctuary and Tova Harel-Bornovski of the Micronesian Shark Foundation on this very matter earlier this year.

It was evident that neither had considered the possibility of the impact an increase of sharks might have on the ecosystem as well as increased interaction between sharks and the local Palauans - there was anecdotal evidence of a local receiving a shark bite whilst spear fishing, (January), and naturally an increase of sharks will lead to an increase in negative interactions between sharks and humans. Tova herself considered that the increase in the salt water crocodile population in Palau - a protected species like the shark - may now have exceeded 'safe' limits.

You've called, in your recommendations, Page XXVIII, for high quality scientific research to inform decision making that is precautionary and ecosystem-based, and for the establishment of shark sanctuaries.

It is important that you pay attention to the potential increase of shark populations within established sanctuaries and what effects any increase has on the ecosystem with the same diligence as is given to the decline in shark populations and the subsequent cascade.

Tova is carrying out the collection of invaluable scientific data, but this is purely orientated for the benefit of sharks, not other endemic endangered marine species.

Dermot implied that once shark conservation had got the necessary attention it would then focus on highlighting problems with other endangered species lower down the chain. I hold Dermot in some regard, but I got the distinct impression that he wasn't totally convinced this would be the case, because he'd had to stagger his answer to the question.

I certainly remain unconvinced that shark conservation would switch tack en masse to support other endangered marine species.

Shark conservation works on the principal that if you fix sharks, everything else will somehow magically sort itself out. I don't subscribe to this view and would point to the number of shark conservation groups worldwide. There are more shark groups than there are countries in the world. Now compare that with the number of dedicated groups focusing on more endangered marine animals, certain species of turtle, or dugongs for example.

Compare your work on sharks with your work on these rarer species of marine life. Feel free to send me your most recent thirty page report dedicated to endangered turtles or dugongs for that matter. You've operated in Palau - how much money, time, effort and lobbying have you invested there, specifically to help those species in comparison to what you've invested in sharks?

Shark conservation operates in a bubble of isolation, using detrimental effects on the ecosystem purely and solely to support the shark cause.


The value of live sharks for recreational diving and eco-tourism.

This was a very interesting section.

Conspicuous by its absence was the Bahamas, especially given PEW's recent high profile work there in the face of Chinese expansion in the region.

Taking a closer look at the selective examples you have cited with regard to shark eco-tourism they all have one thing in common; they do not include any operators who provision sharks.

"Indeed researchers document more than 200 shark dive tourism operations around the world."

These include shark feeding dive tourism. This is obviously a controversial subject in it's own right.

In the recent research by Dr. Eric Clua, 'Behavioural response of sicklefin lemon sharks to underwater feeding for ecotourism purposes', he strongly recommends, "An annual cessation of the feeding activity for several months, preferably encompassing the mating period, is an obvious solution."

Given this is to negate the potential negative effect on the gene flow within shark species, will you now be recommending to Stuart Cove and other operators who provision that they tailor their current year round operations for the benefit of the sharks they feed? This would naturally reduce the amount of revenue their brand of ecotourism generates, but looking at Dr. Clua's research it would mean the shark wasn't exploited to the detriment of it's gene pool, solely for the benefit of eco-tourism and the finance year round interaction brings.

In closing I would add that I am totally independent. I am not in the employ of any agency or Government, neither am I affiliated to any conservation group, or fishing interest of any kind, nor have I received any payment for this document.

My interest in shark conservation started in January of 2010 with the 100 million figure, because common sense told me that anything with a 'Magic Number' moniker was extremely suspect.

During the course of my subsequent eighteen months of part time research I have noted the following;

Shark conservation is conducting a PR campaign. The problem with this is that many non-stories are being fed into the media who have regurgitated them, clearly without questioning or checking the facts fed to them.

Consequently well meaning members of the public who support shark conservation receive a daily drip feed of shark 'stories' and misinformation, where such 'churnalism' leads them to the conclusion that the Asian market is solely responsible for the perceived plight of sharks. It is as if shark conservation paints Asian countries as some sort of pantomime villain.

Whilst shark conservationists consider claims of cultural bias against them preposterous, invariably the 'churnalism' rarely mentions the involvement of the EU, UK and US in readily supplying the Asian market.

There is also little mention of bycatch as a major contribution towards shark mortality in comparison to shark fin soup and those who consume it.

Environmental news services advertise their ability to place stories with writers who can then put the desired message into print.

One environmental wire service used by shark conservation states;

"Enhancing your company brand with expert news stories creates the invaluable impression that you are an expert source of crucial information in your field."

Most popular shark conservation appears not to be run by scientists, but from people with a marketing background. They're experts in selling Coca-Cola and Apple and seem to be applying the same methods to selling the shark message. They also appear not to have read the science they probably should have.

Championing sharks by telling the general public more people are killed by toasters, falling coconuts, vending machines and lightning strikes proves nothing, other than the fact that shark conservationists don't have a rudimentary grasp of probability.

Shark conservation appears to be striving to exaggerate the problem, most notably with the 100 million figure, this in spite of Dr. Shelley Clarke's figures which I found within the first week of my research.

I understand that PEW are currently helping to finance research into a new annual catch figure. Having looked at shark conservation over the past eighteen months I would suggest that this new research is not primarily intended to succeed Dr. Clarke's research but to supplant it.

It is inevitable that whatever the subsequent new figures are, they will be in well in excess of 73 million, and the top end figure will again be the one that's cited, rather than a range, or median, as has been the case with Dr. Clarke's work.

The danger of this will be that it will reflect, as the 100 million figure has done, on how ineffective and theatrical current shark conservation has become.

The single biggest threat to sharks may well be the lack of credibility within shark conservation, which I believe your report in part reinforces.

Consider what someone with the mind, the will, the time, and the financial incentive to discredit shark conservation could do?

With one exception, every scientist has replied to my enquires. Many have sent me scientific papers or pointed me in the right direction. All have corresponded with courtesy, even when I was vigourously challenging their assertions, notably Sarah Fowler.

When I contacted Dr. Worm I knew full well that he was a leader in his field. What impressed me is that his reply to my initial questions was a frank and honest assessment that scientists didn't know the answer.

In stark contrast, when I have challenged shark conservationists about their claims they cannot substantiate, they ignore me, with the notable exception of Dermot Keane and Tova Harel-Bornovski, who I spoke to personally, and Suzanne Pleydell of Project AWARE.

It was of no great surprise that even my email request to PEW for the names of the authors of 'Sharks in Trouble' went unanswered.

If you won't talk to an independent, what possible hope is there that the body of shark conservation will talk to their opposition?

Surely the way forward is sensible round table discussion, initially between conservation groups, and then with shark fishing nations and shark markets, rather than engage in the current propaganda news feed, where the only outcome is a sense of self righteousness and disappointment at CITES?

Sadly from my experience, it appears that the mission to 'raise awareness' only goes one way.

Ironically it's self awareness shark conservation lacks.

H E Sawyer

PS: Good photographs


2005 Market Street, Suite 1700
Philadelphia, PA 19103 7077

August 9, 2011

Dear Mr. Sawyer:

Thank you for your interest in our report, Sharks in Trouble, I apologize for a late response to your enquiry, our campaign has been very busy over the past few months. As part of the Pew Environment Group's mission to work globally to establish pragmatic, science-based policies that protect our oceans, Pew initiated a global effort aimed at reversing the decline of shark populations in 2009. Since that time, we have worked internationally with our coalition allies to influence the fishing nations and treaty organizations that regulate high sea fisheries. In addition, we have begun work with countries interested in developing domestic shark conservation measures and advocating for international measures.

Sharks are virtually unmanaged in all of the world's oceans and the vast majority of shark fishing is believed to be illegal, unreported or unregulated, which leads to a great paucity of data. Pew did not provide funding for Dr. Shelley Clarke's 2006 paper; however we have found her study to be the best available published research on the scale of the shark fin trade. Regrettably there are not more recent estimates of the number of sharks killed globally and while this study is a bit dated the total numbers of sharks killed for all uses is probably much greater. The "100 million" number is an informal estimate that has been put forward by some experts in the past, but both people and sharks would be better served by an estimate supported by more detailed scientific analysis.

You correctly point out that the fact that 47 percent of all globally assessed sharks and rays are categorized as "Data Deficient" does not in itself indicate that a species is at risk. Rather this deficiency highlights the need for more accurate, species-specific data so that assessments can be made. However, just as the precautionary principle holds and given the life history characteristics of many shark species (i.e. relatively late sexual maturation and low reproduction rates), a lack of species-specific stock assessments should not be a reason for inaction in implementing conservation (sic) measures.

You inquired about Pew's funding of several different pieces of research. Bycatch is a significant part of the global problem, and we plan on focusing more on this issue moving forward. The marine science program of the Pew Environment Group is supporting university researchers to improve and update global estimates of illegal, unreported and unregulated fisheries catches, which should lead to better estimates of total fisheries catches, including for sharks. Pew values transparency with its research funding, and therefore asks that researchers acknowledge their funding source in all publications. The stock assessments cited for the decline in sandbar and dusky sharks were conducted by scientists with the National Marine Fisheries Service, a U.S. government agency.

We have had the opportunity to meet with reprenstatives from the Taipei Economic and Cultural Representative Office in the U.S, and are pleased that the Taiwanese fisheries agency recently announced that Taiwan will strengthen its shark management measure and implement "fins-naturally-attached" policy beginning next year. We would welcome further discussions with the other countries you mentioned, Indonesia, India, Spain and Argentina, as well as any government that would like to discuss shark protection measures.

Lastly, thank you for referring us to Dr. Eric Clua. We have recently been in communication with Dr. Clua and look forward to learning more about his research on shark ecotourism.


Matt Rand
Director, Global Shark Conservation
Pew Environment Group