Testimony regarding Correction to the Shark Conservation Act

RE: Implementation of the Shark Conservation Act; Correction

To Whom It May Concern,

The Shark Conservation Act, as currently proposed, undermines the very basis of state legislation aimed at protecting shark populations.   Instead of “conserving” shark populations, the Shark Conservation Act seeks to loosen state laws and boost the shark fin trade within the U.S.  In light of the importance of sharks as apex, marine predators, combined with their severe decline worldwide, Pacific Whale Foundation thus asks NMFS to reconsider the Shark Conservation Act and to amend the Act so as not to allow the Act to supersede stricter state laws that regulate shark finning. 

Shark fin bans have met with overwhelming support in states and territories where implemented.  In the case of sustainably caught shark species (e.g. dogfish), it is reasonable to assume that states would be aware of species status and thus grant exemptions as necessary.  Managing the dogfish on the same level as species such as great whites, however, is short-sighted and ill advised.   

Despite some protests, state shark fin bans do not threaten global economies or trade.  Furthermore, it should be within the right of states to determine how species are managed and landed once inside state waters. 

For over 450 million years, sharks have inhabited the ocean as apex predators. Healthy shark populations are a key component to maintaining marine food webs, healthy prey populations and vital marine habitats (e.g. coral reefs and sea grass beds).  The elimination of shark populations thereby threatens the collapse of entire ocean ecosystems.  The idea of an ocean without sharks is not farfetched, as over 90 million sharks are killed each year for their fins alone.  In addition, millions of sharks are annually killed as fisheries bycatch.  These two factors alone should be enough to prompt NMFS to implement stringent regulations designed to promote shark conservation.

Frustrated with the continued decline of sharks, as well as the lack of substantive regulations controlling the import and trade of shark fins, several states have enacted their own legislation banning the possession, sale and distribution of shark fins.  These measures have represented a tremendous step forward for shark (and ocean) conservation, with negligible economic repercussions. 

While Pacific Whale Foundation applauds NMFS for taking steps to implement the Shark Conservation Act, we are frustrated that the federal government could so easily overturn the very laws designed to promote marine conservation and ensure a sustainable ocean ecosystem for the future.  Current state laws banning the shark fin trade should be held in high regard and set the standard by which the federal government also manages sharks.


Lauren Campbell
Conservation Manager
Pacific Whale Foundation
300 Ma’alaea Rd., Suite 211
Wailuku, HI 96793


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