the NGO Perspective

1. the NGO Perspective Sarah Fowler Shark Alliance Advisor European Parliament Hearing, 9 May 2012

2. BirdLife International Greenpeace IFAW North Sea Foundation Oceana Shark Trust Seas At Risk World Wildlife Fund Pew Environment Group NGOs SUPPORTING EU “FINS NATURALLY ATTACHED” (FNA) The Shark Alliance – over 100 member bodies

3. summary • Context • Problems and opportunities posed by the Regulation and this review (for the environment, industry, managers, decision-makers, and inspection/enforcement officers) • Science • Solutions

4. WHY ARE WE HERE? • The EU (ES, PT, FR, UK) dominates world shark fisheries and trade – over 13% of world catch – 32% of worldwide exports • EU (primarily Spain) among top exporters of shark fins to Hong Kong • Spain: 30% share of global fin trade

5. Why revise the regulation? There are major loopholes; • Enforcement is impossible – even with simultaneous landings – because the ratio is theoretical; • Finning can’t be proved or disproved, but infractions are numerous; • Other fleets continue finning because EU can’t support improved RFMO finning regulations; The solution – fins naturally attached

6. RFMO Finning bans • Most RFMOs (since ICCAT in 2004) have banned finning through 5% fin-to-carcass ratio (whole or dressed weight not specified); • US, Belize & Brazil have proposed banning at-sea shark fin removal at the last three ICCAT meetings; • EU support is crucial to improving RFMO finning bans, and global shark conservation & management policy The solution – fins naturally attached

7. Problems with ratios • Complicated: vary by fleet, by cut, and by species; • Contentious – scientific arguments to raise and reduce; • Spain reports and allows very high ratios, based on fishermen slicing deep & keeping entire tail; • The higher the ratio, the more opportunity there is for high-grading and finning; • Problem for low-ratio States (e.g. South Africa) accepting landings from EU vessels allowed high ratios. The solution – fins naturally attached

8. Sharks are a secondary target. Why keep shark carcasses if hold space can be used for tuna/swordfish? Shark fins are even more valuable than the target species Economic incentive to fin * Value at the Vigo fish market in February 2012

9. SPECIAL PERMITS–just exceptions? EU special permits allow at-sea shark fin removal: • Granted by MS without justification or reporting rules; • Intended to be an exception, but have become the rule for the main EU countries targeting pelagic sharks: Most of Spain’s surface longliners Virtually all of Portugal’s longline fleet • Process for justification & reporting is seriously lacking. The solution – fins naturally attached

10. Why do ngos support “fins naturally attached”? See Shark Alliance fact sheet for more information. Because the science supports it.

11. RFMO Scientists on ratios Cortes, E. & Neer, J. A. (2006). Preliminary reassessment of the validity of the 5% fin to carcass weight ratio for sharks. ICCAT Collective Volume of Scientific Papers 59, 1025–1036: “The only guaranteed method to avoid shark finning is to land sharks with all fins attached.” • Indian Ocean Tuna Commission Working Party on Ecosystems & Bycatch and Scientific Committee (IOTC WPEB, 2008, 2009) recommended that: “the fin to body weight ratio be replaced with a resolution that requires shark fins to be landed attached to the body”

12. Scientists on ratios, 2007 Hareide N. R., Carlson J., Clarke M., Clarke S., Ellis J., Fordham S., Fowler S., Pinho M., Raymakers C., Serena F., Seret B. & Polti S. (2007). European Shark Fisheries: a preliminary investigation into fisheries, conversion factors, trade products, markets and management measures. European Elasmobranch Association. “To ensure finning cannot take place, sharks should be landed with their fins attached.”

13. Scientists on fin bans, 2010 Fowler, S. & Seret, B. (2010). Shark Fins in Europe: Implications for Reforming the EU Finning Ban. European Elasmobranch Association & IUCN Species Survival Commission Shark Specialist Group. Prohibiting the removal of shark fins on board vessels is the “only fail-safe, most reliable, least expensive means to prevent finning and measure compliance.”

14. Experts on ratios, 2012 Santana-Garcon, J., Fordham, S. & Fowler, S. (2012). Blue shark Prionaceglaucafin-to-carcass-mass ratios in Spain and implications for finning ban enforcement Journal of Fish Biology. DOI:10.1111/j.1095-8649.2012.03233.x Landing all sharks with the fins still naturally attached “is the most reliable method for preventing undetected finning”

15. Experts on ratios, 2012 Biery, L. and Pauly, D. (2012). A global review of species-specific shark fin to body weight ratios and relevant legislation. Journal of Fish Biology. DOI: 10.1111/j.1095-8649.2011.03215.x “Species- and/or fleet-specific ratios are not a practical solution; “Requiring that all sharks be landed with fins attached is the best way to close loopholes in finning regulations”.

16. SCIENTISTS CONCLUDE: • Ratios vary –enormously– between and within fleets; • This limits the value of ratios to enforce finning bans and monitor compliance, and creates a dangerous loophole; • Removing fins on board hinders species identification; • Landing sharks with fins naturally attached is best. This: – prevents any finning, – improves species identification, data collection and reporting, and – improves the sustainability of fisheries

17. Why is fnaBest practice? Widespread support from scientists, conservationists, and fisheries monitoring and enforcement agencies because: • Straight-forward, simple, and reliable; • No need to set, calculate, review or revise ratios; • High-grading is impossible; • Low monitoring, enforcement & reporting burden/cost; • Facilitates collection of species-specific data on shark landings (much needed for assessment & management).

18. FNA Momentum is growing Fins “naturally” attached method is now accepted by many fishing countries and international bodies and has been promoted through: 2007 and subsequent United Nations General Assembly (UNGA) Sustainable Fisheries Resolutions 2008 IUCN World Conservation Congress Global Policy on Shark Finning 2010 Fish Stocks Agreement Review Conference on the Law of the Sea Scientific, Technical, and Economic Committee for Fisheries (STECF)

19. Domestic Finning Bans(fins remain attached mandated in at least some fisheries) Argentina Australia * Belize Brazil Canada Cape Verde Chile Cook Islands Colombia Costa Rica Dominican Republic Ecuador El Salvador Gambia Guatemala Guinea Honduras Japan * Mexico Namibia ? New Caledonia * New Zealand * Nicaragua Niue * Oman Panama Western Samoa Seychelles * Sierra Leone South Africa Sri Lanka Taiwan United States * UAE Vanuatu + European Union *exceptions apply

20. MOST Recent DEVELOPMENTS • Taiwan (whose fleet is often accused of finning) has banned the practice and is phasing in a fins-attached policy this year. • Eight member countries of the Central American Integration System (SICA) (Belize, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua & Panama) have adopted a common binding finning ban, requiring fins to remain naturally attached for vessels fishing in SICA countries, and those fishing in international waters flying SICA country flag.

21. Food quality and health Frozen sharks would have to be defrosted for gutting and removal of fins to take place Safety Frozen sharks are dangerous to handle because the rigid fins are so sharp Energy efficiency and storage Sharks with fins attached take up more space than carcasses and fins stored separately on board IBERIAN industry concerns

22. US fishermen use techniques pioneered by Costa Ricans for complying with fins-naturally-attached rule: • • partially cut/remove fins, and • • fold fins to be flush against carcass. • • Facilitates efficient storage & safe handling; • • Allows carcasses to be gutted and bled before freezing; • • Addresses key industry concerns; • • Applicable for both fresh and frozen sharks. A SOLUTION: THE partial cut

23. A SOLUTION: THE partial cut

24. Food quality and health Freshly caught sharks can be gutted, bled and beheaded while fins remain attached; they do not have to be defrosted for the fins to be removed Safety Frozen sharks are safe to handle if fins are folded back against the carcass Energy efficiency and storage Shark carcasses take up no more space than logs if fins are laid flat IBERIAN industry concerns

25. Short term costs On board processing practices changed Short term benefits No at-sea documentation of ratios; Reduced logbook reporting; less work for observers; National reporting and enforcement burden reduced Long term benefits Reduced shark mortality internationally (when RFMOs adopt FNA); improved yield & sustainability Implications for industry

26. • The drawbacks of using ratios for finning bans; • Most scientists support keeping fins naturally attached; • This does work for industry – immediate and long-term benefits outweigh the short-term cost of adopting FNA; • Many countries have adopted FNA rules; • RFMOs need the EU to adopt FNA too, to prevent finning in other fleets; • The EU should adopt the Commission’s proposal to ban the removal of fins at sea SUMMARY