THE SHELL LEAKS FILES — 12 SEPTEMBER 2026
Archive reference: SLF-2007-055
The Sakhalin Papers XLV: From Critically Endangered to Endangered — What the Whale Recovery Did, and Did Not, Prove
By 2016, Shell could point to a genuinely encouraging development off Sakhalin: the western gray whales feeding near its giant oil and gas project were increasing in number. Shell’s own Sustainability Report recorded an estimated rise from 115 animals in 2004 to 174 in 2015. Independent conservation organisations reported the same trend. Two years later, the IUCN changed the western gray whale’s status from Critically Endangered to Endangered.
That was real progress. But the documentary record does not establish that Shell caused the recovery, that industrial disturbance had ceased to matter, or that the whales were safe. In fact, the independent scientific record becomes more complicated precisely at the point where the headline numbers begin to look most reassuring.
A recovery that deserves to be recorded
Previous instalments have followed the extraordinary concentration of industrial activity around the whales’ summer feeding grounds off north-eastern Sakhalin: pipelines, platforms, vessel traffic, construction, dredging and seismic surveys.
The most recent file examined the 2015 seismic season and the later scientific studies of its effects. Those studies found measurable short-term behavioural responses: whale density changed with accumulated seismic and vessel noise, and individual animals altered aspects of movement and breathing behaviour. Yet researchers did not establish consequent population-level damage.
That distinction becomes crucial in the next part of the record.
Because while scientists were measuring disturbance, the population itself was also increasing.
Shell’s Sustainability Report 2016 stated that the Western Gray Whale Advisory Panel had been advising Sakhalin Energy since 2004. Shell identified its own interest in Sakhalin Energy at the time as 27.5% minus one share. The company then recorded the central statistic:
the western gray whale population had grown by roughly 3% to 4% annually, from an estimated 115 animals in 2004 to 174 in 2015. (Shell)
That figure was not something invented by Shell’s public-relations department.
Independent organisations were reporting it too.
The independent assessment
At the IUCN World Conservation Congress in September 2016, the International Union for Conservation of Nature, WWF and the International Fund for Animal Welfare published an assessment of the work undertaken around Sakhalin.
Their conclusion deserves to be represented accurately.
They said Sakhalin Energy had made “important efforts” over the preceding 12 years to limit the impacts of its operations on the whales and their fragile environment. They also cited the same population increase — from approximately 115 whales in 2004 to 174 in 2015, equivalent to annual growth of around 3% to 4%. (IUCN)
For an archive that has documented serious environmental criticism of Sakhalin II, this favourable independent assessment cannot simply be passed over.
The mitigation programme mattered.
The scientific scrutiny mattered.
Changes to project planning mattered.
Monitoring mattered.
The creation of a permanent independent advisory mechanism mattered.
There is evidence that Sakhalin Energy responded to scientific advice and modified operations in ways intended to reduce risks to the whales.
That is part of the historical record.
But the same IUCN assessment contained an equally important warning: recovery remained vulnerable, and protection could not depend on one company acting alone. Other oil and gas operators, fisheries and other industries operating throughout the whales’ range also had to reduce cumulative pressures. (IUCN)
The good news therefore came with a large footnote.
The number “174” was not the whole population story
A simple progression from 115 to 174 is attractive because it is easy to understand.
The scientists themselves were dealing with something considerably harder.
The 17th meeting of the Western Gray Whale Advisory Panel, held in November 2016, examined updated population modelling. The Panel reported that the Sakhalin feeding aggregation continued to increase at about 4% per year.
But exactly how many whales belonged to the relevant population depended upon which animals and which geographical datasets were included.
For 2016, the Panel recorded an estimated 165–200 non-calf whales if only Sakhalin sightings were counted.
Include whales known from both Sakhalin and Kamchatka, and the estimate became 190–220.
Include all Kamchatka and Sakhalin whales and sightings, and the estimate could reach 300–400.
That range was not statistical carelessness.
It reflected a profound biological question.
What exactly was the “western” gray whale population?
Satellite tagging, photographs and identification work had revealed that some whales feeding off Sakhalin migrated all the way across the North Pacific to the eastern breeding grounds associated with the much larger eastern gray whale population.
The WGWAP report discussed an analysis estimating that approximately 67% of Sakhalin gray whales might migrate to the eastern North Pacific — but with extremely wide confidence limits of 30% to 100%. The data could neither prove nor rule out the existence of a smaller group breeding in the western North Pacific.
So even as the conservation news improved, the scientific definition of the population became less simple.
A success, but not a corporate causation claim
This point is important.
Neither the rise from 115 to 174 nor the later increase can scientifically be converted into the proposition:
Shell caused the recovery.
The whales had been devastated historically by commercial whaling long before Sakhalin II existed.
Their subsequent recovery took place under a combination of protections: cessation of commercial hunting, international conservation agreements, range-state cooperation, scientific monitoring, restrictions and mitigation around industrial activity, and the whales’ own reproductive success.
When IUCN later assessed why western gray whales were recovering, it said explicitly that the recovery was occurring largely because of commercial-whaling bans, international agreements and various protection measures. (IUCN)
Sakhalin Energy’s mitigation measures formed part of that protection environment.
They were not synonymous with it.
That is a much more defensible conclusion than either extreme.
It would be wrong to say Shell’s efforts made no difference.
It would be equally wrong to credit Shell with producing the population recovery.
The Panel was renewed, not retired
There is another useful test of how the scientists themselves viewed the improving numbers.
If recovery meant the problem had been solved, there would have been little reason to retain a costly independent scientific panel.
Instead, in March 2017, IUCN and Sakhalin Energy renewed their agreement for another five years.
The Western Gray Whale Advisory Panel was instructed to continue advising on future seismic-survey mitigation, implementation of International Finance Corporation environmental standards, joint whale-monitoring work, revision of Sakhalin Energy’s Marine Mammal Protection Plan and work connected with the International Whaling Commission. (IUCN)
IUCN described the population as showing a slow recovery, again citing the rise from 115 in 2004 to 174 in 2015.
But it simultaneously said that greater cooperation with other actors — including additional oil and gas operators and fisheries — remained critical for the whales’ long-term protection. (IUCN)
That continuation of the Panel is itself documentary evidence of how the recovery was understood.
Encouraging.
Real.
Incomplete.
Then came the Red List change
On 14 November 2018, IUCN announced a significant conservation milestone.
The western subpopulation of the gray whale was moved on the IUCN Red List from:
Critically Endangered
to:
Endangered.
This was not a semantic adjustment.
“Critically Endangered” is the highest threatened category before extinction in the wild.
Moving to “Endangered” represented a material improvement in assessed conservation status.
IUCN noted that western gray whales had been protected from commercial whaling in almost all range states since 1980 and that convincing evidence of increasing numbers had only comparatively recently become apparent, particularly among animals observed off Sakhalin. (IUCN)
Randall Reeves, chair of the IUCN Species Survival Commission’s Cetacean Specialist Group and a central figure in the Sakhalin scientific process, attributed the wider recovery largely to hunting bans, international agreements and protective measures.
At the same time, IUCN specifically identified oil and gas development and commercial fisheries as continuing potential threats. It also noted the role of the IUCN-led panel that had advised Sakhalin Energy since 2004. (IUCN)
The downlisting was therefore a conservation success.
It was not an all-clear.
The legal record explains why the scrutiny had become so intense
Long before the 2018 improvement in conservation status, Sakhalin II’s environmental consequences had already entered the British courts.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), the High Court dealt with a dispute over access to internal UK government environmental information concerning possible export-credit support for Sakhalin II.
The underlying project involved offshore oil and gas development off north-eastern Sakhalin. The judgment’s factual background records the environmental controversy surrounding the development, including concerns over the endangered western gray whale. Friends of the Earth sought disclosure of government communications, and the High Court ultimately dismissed ECGD’s appeal against an Information Tribunal decision requiring disclosure. (Casemine)
The significance of that judgment for this instalment must not be overstated.
The High Court did not determine whether Sakhalin II was safe for gray whales.
It did not rule on the effectiveness of the later WGWAP mitigation programme.
And it obviously could not determine anything about a population recovery documented years afterwards.
Its relevance is historical.
It records how politically and environmentally sensitive Sakhalin II already was, and how strongly questions of transparency and public scrutiny surrounded possible British government support for the project.
The later whale recovery should therefore be viewed against a background in which environmental performance was not merely a matter of voluntary corporate reporting. It had become the subject of international scientific scrutiny, NGO pressure, lender requirements, government deliberation and litigation.
What the documentary record establishes
The evidence reviewed in this instalment supports several findings. The western gray whales observed around Sakhalin were increasing in number during the period examined; Shell’s 2016 Sustainability Report accurately reflected the independently reported estimate of approximately 115 animals in 2004 and 174 in 2015; IUCN, WWF and IFAW credited Sakhalin Energy with important efforts to reduce operational impacts; WGWAP science nevertheless showed uncertainty about population boundaries and absolute abundance; the scientific advisory process continued after the encouraging population trend became apparent; and in November 2018 IUCN downlisted the western gray whale from Critically Endangered to Endangered. (Shell)
The same evidence does not establish that Shell caused the increase, that the 2015 seismic programme produced no behavioural effects, that oil and gas development ceased to present risk, that every whale observed off Sakhalin belonged to a genetically isolated western population, or that the 2018 downlisting meant the population had fully recovered.
Those distinctions are not pedantry.
They are the difference between a documentary record and advocacy.
Commentary
There is a temptation in environmental disputes to insist that the evidence must eventually vindicate one side completely.
Sakhalin does not cooperate with that expectation.
The record examined so far contains genuine evidence of industrial disturbance.
It also contains genuine evidence of successful mitigation.
The whales altered behaviour during periods of elevated acoustic exposure.
Yet the population continued to grow.
Sakhalin Energy operated an enormous oil and gas development beside feeding grounds used by an exceptionally vulnerable whale population.
Yet independent scientists also concluded that the company made important efforts to reduce its effects.
Environmental groups were right to insist on scrutiny.
Shell was entitled to point to measurable conservation progress.
Both statements can be true at the same time.
Perhaps the most important lesson is institutional.
The whale story improved not because scrutiny disappeared but while scrutiny intensified.
An independent panel challenged operational plans.
Scientists monitored individual whales.
Acoustic exposure was modelled.
Mitigation procedures were revised.
Population estimates were repeatedly reconsidered.
Data were exchanged across Russia and the wider North Pacific.
International organisations remained involved.
And the findings — including uncomfortable ones — were published.
That is a considerably stronger environmental-governance model than asking the operating company to assess its own performance and accepting the resulting sustainability statement at face value.
Shell’s 2016 report was entitled to record the improving population figures.
The independent scientific archive tells us what those figures actually meant.
The recovery created a new question
By late 2018, the conservation narrative had changed.
The immediate fear was no longer simply that this tiny population was heading inexorably towards extinction.
Numbers were rising.
The Red List classification had improved.
But recovery brought another problem into sharper focus.
A population can survive one pressure only to remain vulnerable to another.
And just one month before the IUCN announced the whales’ improved Red List status, an IUCN-backed scientific study issued an alarming finding from Sakhalin.
Researchers concluded that the whales were at “very high risk” of becoming entangled in coastal salmon nets.
Photographic evidence suggested that roughly one in five gray whales observed off Sakhalin bore signs of injury from fishing gear. (IUCN)
Oil and gas were no longer the only industrial activities demanding attention.
The conservation problem was becoming range-wide and cumulative.
Next instalment
The Sakhalin Papers XLVI: One in Five Bore the Scars — When Fishing Nets Became the Next Major Threat
The whales had survived commercial whaling. Their numbers were increasing. Sakhalin Energy’s operations were under unprecedented scientific scrutiny.
Yet along the same coast where mothers and calves came to feed, salmon nets extending kilometres offshore created another hazard.
The next file examines the evidence behind IUCN’s warning that approximately one in five Sakhalin gray whales showed signs of fishing-gear injury — and why the WGWAP concluded that protecting a recovering population required looking far beyond Shell’s platforms.
Principal documentary sources: Shell Sustainability Report 2016; IUCN/WWF/IFAW reporting on WGWAP, September 2016; Report of the 17th Meeting of the Western Gray Whale Advisory Panel, November 2016; IUCN/Sakhalin Energy renewal announcement, March 2017; IUCN Red List update, November 2018; Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). (Shell)
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