Among the many threatened marine species in the world, shark populations exhibit some of the most worrying trends. According to the International Union for Conservation of Nature’s latest assessment, 139 of the approximately 482 species of sharks found across the planet are threatened by over-fishing. The marine research initiative Sea Around Us suggests that over one million tonnes of sharks are caught annually across the globe.
As most shark species are slow-growing and give birth to very few offspring in their lifetimes, scientists fear over-exploitation could lead to a collapse of some populations.
To deal with this problem, the Food and Agricultural Organisation (FAO) came up with an International Plan of Action (IPOA) in 1999. The goal was to “ensure the conservation and management of sharks and their long-term sustainable use.” The IPOA set out guidelines for 26 shark-fishing nations, including India, to create their own National Plan of Action for managing shark fisheries.
Yet, nearly 20 years after the FAO’s IPOA, India is yet to implement a national plan of action. Meanwhile, estimates from government research agencies show that shark populations have been steadily declining in most coastal states in the country and may have even been depleted in Tamil Nadu and Maharashtra.
A draft of India’s first National Plan of Action for Conservation and Management of Shark fisheries (NPOA) was submitted to the government of India in December 2015, but the plan hasn’t been approved for four years.
Although not specifically targeted, sharks are routinely caught as part of almost every type of marine fishery, from small traditional crafts to large industrial trawlers in India. So much so, that until 2018, the country ranked second in the volume of sharks caught annually and contributes about nine percent to the global shark catch. In 2019, India slipped to the third position.
Demand for shark products varies: the meat is consumed primarily in the coastal state of Kerala and shark liver oil is used for boat building. Until a ban was implemented in 2015, fins were exported to Southeast Asia and China. Smaller coastal sharks and juveniles are much sought after in local markets in states like Tamil Nadu.
Twenty years in the making
When the FAO announced its International Plan of Action two decades ago, it optimistically stated that shark fishing nations should create a national action plan by 2001. But for eight years no plan of action emerged from India. Then in 2008, India’s Department of Fisheries tasked the intergovernmental organisation the Bay of Bengal Programme (BoBP) with the job.
The BoBP’s four member countries are Bangladesh, Sri Lanka, the Maldives and India. Its stated mission is to “enhance cooperation among these member states, as well as with other countries and organisations in the region, and to provide technical and managerial support for the development and management of sustainable coastal fisheries in the Bay of Bengal region.”
Several shark species – especially large, open ocean ones – are highly migratory, moving between national borders and international waters. Fishing vessels that catch these species also operate in both these areas. So after each BoBP member country came up with its own plan, they were to create a joint Regional Plan of Action to regulate shark fisheries among them.
Sri Lanka came up with and formally ratified a plan in 2013. The Maldives, which completely banned shark fishing in its territorial waters in 2010 after reef and oceanic sharks had become nearly extinct, came up with an NPOA meant to monitor shark populations and aid shark fishers affected by the ban. Bangladesh and India have only come up with drafts, the former in 2014 and the latter in December 2015.
Yugaraj Yadava, the director of the BoBP submitted this draft plan to the Department of Fisheries (which was then under the Ministry of Agriculture) for approval on December 11, 2015. In February 2019, the central government announced the formation of a separate Ministry of Fisheries, Animal Husbandry and Dairy. In July 2019, Yugaraj Yadava, confirmed to Mongabay-India that the draft plan was now with this new ministry, but it had not yet been approved or commented on.
“We are waiting for a date on which we can convene the final national meeting and have the National Plan of Action approved and then release it,” he said.
Why has it taken nearly two decades to create a plan and approve it?
According to the timeline in India’s draft NPOA, the years 2008-2009 were spent in consultation with other BoBP members, while 2009 to 2015 was spent in consultation with shark traders, fishing communities and government research agencies like the Central Marine Fisheries Research Institute (CMFRI) and the Fisheries Survey of India.
Meanwhile, another related FAO initiative called the Bay of Bengal-Large Marine Ecosystem project agreed to provide a portion of the funding for the national action plans with the remainder meant to come from each respective country’s governments in 2012. Yet, Yadava pointed out, India’s NPOA had been held up due to funding bottlenecks from the government.
“BoBP is also saddled with many commitments from other countries so we can’t devote all our time to India,” he said.
Shekhar Kumar Niraj, an Indian Forest Service officer who is currently the director of the Advanced Institute of Wildlife Studies in Chennai, participated in consultations for the plan between 2008 and 2015. Niraj, who has seen the draft version, suggested that disagreements between various government agencies and a lack of co-ordination were responsible for the delay.
As an example, he pointed to repetitive work done by the BoBP and the Central Marine Fisheries Research Institute (CMFRI), a government research agency. In June 2015, just six months before the BoBP’s draft NPOA was published, CMFRI came up with a document called Guidance on National Plan of Action for Sharks in India.
Shobha Joe Kizhakudan, a principal scientist at the CMFRI, said that the document was prepared as part of the institution’s mandate to provide background information on shark fisheries for the plan of action to be developed. “This guidance document was then handed over to the Ministry of Agriculture [which was in charge of fisheries in 2015],” she said. But Yadava said that the draft NPOA was already prepared and ready to be submitted by the time CMFRI came up with its guidance document and had no role to play in shaping the NPOA.
“They did it on their own. We never requested it,” Yadava said during a phone conversation with Mongabay-India in August. “I don’t think it has any relevance because unless and until the National Plan of Action is approved by the concerned authorities and the government, we cannot take the things forward,” he added. “The only guidance required is that the government should look at the document quickly and, you know, approve it so that we can start with the implementation process.” Khizhakudan declined to comment on the draft NPOA.
“If you are not working together right in the beginning, then it becomes difficult to come together,” Niraj pointed out.
No progress without approval
Despite this apparent lack of coordination, BoBP officials did manage to complete a draft action plan in December 2015 that was then circulated to both the Fisheries and Environment ministries, along with 18 government agencies, independent researchers, fishing unions and civil society organisations. (This list has been provided to Mongabay-India.)
“We received comments from a few of them, and those comments have been incorporated into the revised version,” Yadava said.
Among those who responded to the draft were the Association for Deep Sea Going Artisanal Fishermen, a collective of India’s only specialised shark fishers from the Thoothoor region in Kanyakumari; research agencies like the CMFRI; and international organisations closely associated with shark conservation, including the FAO and the IUCN.
But in the four years since the draft was circulated, the BoBP has not received a single written or verbal comment from either the Ministry of Fisheries or the Ministry of Environment, Forests and Climate Change.
This silence seems all the more surprising because representatives from both ministries have been present at various points in the draft NPOA’s preparation. Yadava explained that the BoBP’s own governing council is made up of representatives from fisheries departments or ministries of all four member countries. In addition, officials from India’s environment ministry participated in consultation meetings held for the NPOA.
In November 2014, the then-Deputy Inspector General of Wildlife in India, M.L. Shrivastava from the Environment Ministry, attended a consultation meeting as the chief guest and spoke about India’s obligations to implement international regulations for shark conservation.
The involvement of these two ministries is important not just to improve the plan but to actually implement any measures it outlines. According to Yadava, the draft outlines “a plan of action as to what needs to be done by India to prevent over-exploitation,” of shark populations and a timeline for implementing it, he added.
According to this timeline, approval from both ministries was supposed to happen within six months of the draft being submitted to them. If things had gone according to this timeline, BoBP would have received feedback and approvals by June 2016. By then, a coordinating committee comprising the Joint Secretary of Marine Fisheries responsible for fishery policy and the Inspector General of Wildlife responsible for wildlife protection, would have been formed to oversee all the other activities. If the timeline in the draft NPOA had been followed, suggested measures would have been implemented at least partially by December 2018.
These measures include directives to all fisheries departments to not promote direct shark fishing and to regulate or control fishing beyond 12 nautical miles, where mechanised boats are allowed to fish in India and most shark fishing – both accidental and targeted – occur. Most of these measures, such as the regulation of fisheries, require active participation from the Ministry of Fisheries.
The draft NPOA also advocates for the use of circle hooks for tuna fishing. That’s because sharks are also often caught as bycatch by fishers after bluefin tuna, a high-value export fish. Tuna fishing is largely done with long lines that have hooks that attach to sharks’ gills and can kill them. Circle hooks have been found to cause less injury to gills and could ensure that sharks are alive and released when caught by tuna fishers.
At present, government agencies like the National Fisheries Development Board (NFDB) and Marine Products Export Development Authority (MPEDA) – both of which are managed by the Ministry of Fisheries – promote deep sea tuna fisheries. The NFDB, for instance, offers schemes for fishers to convert their trawlers into tuna longlining boats. Promoting the right gear to avoid shark bycatch in tuna fisheries would require them to modify these policies, but the directive to do so would have to come from the Fisheries Ministry.
The NPOA also suggests improving data collection and creating research collaborations with other member countries to study migratory shark species and implementing wildlife protection laws related to shark species in India. The responsibility for implementing both these actions lie with the Ministry of Environment, Forests and Climate. To implement such measures, both ministries would have to first read, comment and otherwise adopt the draft NPOA.
Is it possible that the ministries were unaware that the plan would not be implemented without their approval? Yadava dismissed this suggestion. “They are aware,” he said explaining that both ministries were vital stakeholders in this issue and knew that the plan could only be implemented by them.
Nine of 26 nations, including India, yet to finalise plan of action for shark fisheries
The longer India delays passage of the plan the further it gets left behind. Out of 26 shark-fishing nations, India is currently one of only nine that have not yet formalised a national plan of action. The others include Bangladesh, Pakistan, Honduras, Myanmar, Thailand and Kenya. Meanwhile, Indonesia and recently Spain the only other countries to land more sharks than India have already completed its first plan of action and implemented a second updated version.
“It is a matter of concern that the NPOA is still not ready,” said N.G. Jayasimha, the former director of the Humane Society of India, an animal welfare organisation that has campaigned for various shark conservation measures and participated in some consultation meetings over the draft NPOA in March and November 2014. “I cannot comment on why there is a delay; however, I can make a guess that it is due to apathy,” Jayasimha said over email.
Yadava however is more charitable and suggested that the delay from the Ministry of Fisheries was because they were going through the draft closely and making many changes. He declined to comment on delays from the Ministry of Environment.