THE SHELL LEAKS FILES: 13 SEPTEMBER 2026
SLF-2007-056
The Sakhalin Papers XLVI: One in Five Bore the Scars — When Fishing Nets Became the Next Major Threat
The western gray whales feeding off Sakhalin were recovering. Their IUCN status would soon improve. But another danger was becoming impossible to ignore. In 2013, Sakhalin Energy personnel photographed mothers and calves within 100 metres of newly deployed salmon nets near Piltun Lagoon. By 2018, peer-reviewed research found evidence of fishing-gear injury on 28 of 150 photographed whales — 18.7 per cent. The same research classified coastal salmon set nets near Piltun as presenting a “very high” entanglement risk. The documentary record also contains an important complication: this was not an impact caused by Shell’s oil and gas operations. Sakhalin Energy helped identify and report the threat.
1. The recovery did not remove the danger
The previous instalment ended with an apparently contradictory picture.
The whales feeding off north-eastern Sakhalin were increasing in number. By 2018 the IUCN would move the western subpopulation from Critically Endangered to Endangered.
Yet recovery did not mean security.
A small population recovering from historical commercial whaling remained vulnerable to relatively few avoidable deaths — particularly deaths of reproductive females and calves.
And one of the next dangers to emerge was not an oil platform, seismic airgun or tanker.
It was a fishing net.
The significance of this episode lies partly in that fact. The Sakhalin record cannot responsibly be reduced to a narrative in which every environmental hazard originated with Shell or Sakhalin Energy.
In this case, the immediate threat came from commercial salmon fishing.
More strikingly, it was Sakhalin Energy personnel who supplied some of the evidence that triggered the alarm.
2. Shell had already acknowledged the fishing-net danger in 2005
The danger was not new.
Royal Dutch Shell plc’s authenticated Sustainability Report 2005 discussed Sakhalin Energy’s work with IUCN and the independent whale scientists. It said the developing advisory arrangement should encourage wider research into the whales’ activities, including ways of reducing risks along their migration route.
Shell then gave a specific reason why such wider protection was necessary: the need had been underlined by the deaths in 2005 of three gray whales caught in fishing nets in Japanese waters. (Shell)
That Shell statement matters in retrospect.
Years before the Piltun salmon-net controversy, the company publicly recognised that conservation of these whales could not be confined to managing the direct effects of Sakhalin II.
The animals migrated across jurisdictional boundaries.
So did the risks.
3. August 2013: Sakhalin Energy reports nets in the core feeding area
The documentary trail becomes unusually precise on 6 August 2013.
According to the Western Gray Whale Advisory Panel’s formal Statement of Concern, Sakhalin Energy informed the Panel that salmon fishing nets were operating close to the mouth of Piltun Lagoon, inside an area intensively used by gray whales during summer and autumn.
The information was not second-hand.
The WGWAP letter states that Sakhalin Energy personnel had directly observed and photographed the situation.
At least two nets, each approximately 1.5 kilometres long, had been positioned perpendicular to the coastline. During the first days of August, company personnel observed gray whales — including mother-calf pairs — within 100 metres of the nets.
The Panel regarded the situation as serious enough to write directly to Russian authorities on 7 August 2013.
Its conclusion was unequivocal: the risk from salmon fishing within this core feeding area was considered extremely high, and WGWAP urged that commercial salmon fishing in the Piltun area be stopped immediately pending official investigation and assessment.
This was independent scientific advice, not a regulatory order.
But the language left little ambiguity about the scientists’ assessment of the risk.
4. Contemporary IUCN reporting made the issue public
IUCN publicised the dispute on 16 August 2013.
Its contemporaneous account reported that large-scale commercial salmon fishing had begun near Piltun Lagoon and that whales had been seen extremely close to the nets. IUCN said five gray whales, including females and a calf, had been killed in fishing gear in Japan and China in preceding years.
At the time, the Sakhalin-associated population was estimated at about 150 animals, including only around 35 mature females.
WGWAP chair Randall Reeves called for an immediate halt to salmon fishing at Piltun and an official investigation before such operations were permitted to resume. (IUCN)
This contemporaneous account is important because it fixes the issue in real time.
The later 2018 research did not manufacture a new concern from old photographs.
Scientists were already warning about the danger while the nets were actually in the water.
5. The authorities did respond — at least temporarily
The Russian administrative response should also be recorded.
A subsequent communication from the Sakhalin Oblast Ministry of Natural Resources and Environment stated that the regional fisheries commission had considered the issue and, by a decision dated 21 August 2013, closed the pink-salmon catch in the relevant area from 24 August.
The ministry told WGWAP that the immediate potential threat from fishing enterprises had therefore been eliminated for that season.
It also said fisheries authorities had been asked to take potential gray-whale impacts into account when developing future recommendations for placement of set nets along north-eastern Sakhalin.
That was a substantive response.
But it was not a permanent prohibition.
And the problem returned.
6. A whale was found with rope around its tail
The 2018 peer-reviewed study later reconstructed a disturbing sequence.
A western gray whale photographed off north-eastern Sakhalin on 22 August 2013 had rope wrapped around its caudal peduncle — the narrow part of the body immediately before the tail flukes.
The rope was described as similar in colour and type to material used by the nearby salmon set-net fishery. A rope-related wound appeared comparatively fresh.
The same animal was photographed the following year without the rope and without apparent evidence of serious continuing injury.
The scientists were careful not to claim more than the evidence allowed.
But they noted that the incident coincided with the first known deployment of salmon set nets directly in the Piltun feeding area since systematic annual whale research had begun there in 1995. (IUCN Cetacean Specialist Group)
That distinction is essential.
The photographs evidenced an entanglement.
They did not scientifically prove which particular net had caused it.
7. The nets multiplied
The fishing activity did not end with the 2013 intervention.
A later WGWAP technical report recorded that only one trap net was deployed in the area in 2014, but that at least sevenwere reported close to Piltun Lagoon in 2015.
The same report noted why this location was especially sensitive.
Mother-calf pairs use the nearshore feeding area, with many observed less than one kilometre from shore. The nets ran outward across precisely that habitat. (IUCN Cetacean Specialist Group)
This geographical overlap was the central problem.
The whales were not merely passing an isolated fishing operation far offshore.
The fishing structures were being placed through waters that mothers and calves repeatedly used for feeding.
8. These were not ordinary small nets
The later scientific paper explains the physical scale.
Coastal salmon set nets on Sakhalin can include meshed fence-lines extending one to three kilometres or more offshore, positioned perpendicular to the beach and supported by ropes, cables, anchors and floats.
The fence guides salmon towards large traps.
For a gray whale travelling parallel to the coast or feeding close to shore, such structures can become barriers extending directly across its path. (IUCN Cetacean Specialist Group)
The researchers estimated that the Sakhalin government permitted companies to deploy approximately 550–650 coastal salmon set nets annually.
During 2011–2015, more than 400 were normally installed around Sakhalin each year, although fishing effort was lower on the north-east coast than elsewhere on the island.
There was another disturbing finding.
Satellite-image monitoring conducted by Sakhalin Environment Watch found some fence-lines extending as much as 5.7 kilometres offshore, contrary to fisheries regulations. (IUCN Cetacean Specialist Group)
Again, this did not mean hundreds of nets were deployed in the Piltun whale feeding ground.
Most were elsewhere around Sakhalin.
But it demonstrated the scale of the regional fishing industry with which migrating whales potentially had to coexist.
9. Then came the figure: 28 out of 150
The headline statistic emerged from photographic evidence.
Earlier researchers had examined photographs of 150 living western gray whales identified near Sakhalin.
Twenty-eight showed signs consistent with having suffered injury from fishing gear at least once.
That is 18.7 per cent.
Approximately one whale in five. (IUCN Cetacean Specialist Group)
It is an arresting number.
It is also easy to misuse.
The scientific paper explicitly warned that this type of scar analysis could not determine where the animals encountered the fishing gear or which particular fishery was responsible. (IUCN Cetacean Specialist Group)
Therefore the defensible statement is:
28 of 150 photographed whales showed evidence of previous fishing-gear interaction.
It is not:
one in five whales was injured by Piltun salmon nets.
The latter proposition is not established by the evidence.
Some injuries could have occurred elsewhere across the enormous North Pacific range used by these animals.
10. The 2018 study nevertheless rated Piltun’s set-net risk “very high”
That evidential limitation did not remove the local concern.
The peer-reviewed paper — “Entanglement risk to western gray whales from commercial fisheries in the Russian Far East”, published in Endangered Species Research on 11 October 2018 — assessed risk using several factors: known ability of particular fishing gear to entangle whales, fishing intensity, and geographical and seasonal overlap between fisheries and whale distribution.
Its conclusion concerning coastal salmon set nets near Piltun Lagoon was severe.
The authors assessed the entanglement risk as “very high.”
The reason was ecological as much as mechanical.
More than 100 whales can be present off north-eastern Sakhalin during summer, including mothers, calves and newly weaned animals. The nearshore feeding grounds immediately north and south of Piltun Lagoon are especially important while females are recovering from pregnancy and lactation and calves are learning to feed independently. (IUCN Cetacean Specialist Group)
The researchers concluded that when set nets are installed across these areas, they create risks of entanglement or entrapment capable of causing injury or death.
They recommended mitigation rather than treating the danger as hypothetical.
11. A calf with 25 fishing floats
The November 2018 meeting of WGWAP added a particularly troubling case.
Participants reported that in September 2016, a young gray whale identified as KOGW272 was seen near Piltun showing signs of recent entanglement.
A rope remained attached to the animal with approximately 25 fishing floats.
It was about 500 metres offshore and travelling rapidly south.
Monitoring teams obtained photographs and video.
The whale was not seen again during that season and had not been identified in either 2017 or 2018. One participant therefore said its survival after the entanglement was in doubt.
The record does not establish that the whale died.
Absence from later photographs is not proof of death.
But neither could the Panel establish that it survived.
That unresolved outcome illustrates a recurring problem in whale-entanglement research: many events are never witnessed, and many animals disappear before their fate can be determined.
12. The regulatory paradox
The same WGWAP report records a striking exchange about regulation.
Sakhalin Environment Watch had asked the Sakhalin government to ban salmon set nets near Piltun.
According to the meeting record, regulators responded that they could not impose such a ban because there was insufficient evidence of entanglement in that particular area, although the request could be reconsidered if stronger evidence emerged.
By then, however, scientists possessed several different forms of warning evidence:
the physical overlap between nets and feeding habitat;
whales photographed extremely close to the gear;
known fatalities from similar gear elsewhere;
individual Sakhalin whales photographed with ropes and floats;
and population-level scar evidence demonstrating previous interactions with fishing gear.
The dispute was therefore partly about the evidential threshold required before preventive regulation could be justified.
That is a familiar environmental-policy problem.
Waiting for incontrovertible proof can mean waiting until the harm has already occurred.
13. No nets in 2018 — but apparently not because of stronger whale protection
There was one superficially encouraging development.
WGWAP heard that salmon nets were absent from the Piltun area in 2018.
But the reason appears not to have been a new conservation prohibition.
A participant told the Panel that the lack of nets was attributable to forecasts of poor salmon runs rather than regulatory action. He judged the immediate prospects for stronger entanglement-protection measures to be low.
That distinction matters.
A whale is protected equally well from a net that is absent because of conservation law and one that is absent because fishermen do not expect enough salmon.
But only the first provides durable protection when fishing conditions improve.
14. Sakhalin Energy also helped fund the response capability
Another part of the record deserves explicit recognition.
In June 2017, the International Whaling Commission reported the completion of specialist entanglement and stranding-response training in Yuzhno-Sakhalinsk.
The IWC described fishing-gear entanglement as the highest-priority threat to the critically endangered western gray whale population in the region.
The training was supported by IFAW, local organisations — and Sakhalin Energy Investment Company. (International Whaling Commission)
This is important because it prevents the historical record from becoming distorted.
Sakhalin Energy was itself an industrial operator whose activities created environmental risks requiring extensive mitigation and monitoring.
But on fishing-net entanglement, the company was also part of the conservation response.
Those propositions are not contradictory.
15. The independent Panel had moved beyond policing its sponsor
There is a deeper institutional point.
WGWAP had been established principally because of concerns over oil and gas development around the whale feeding grounds.
Sakhalin Energy funded the advisory mechanism.
Yet by 2013–2018 the Panel was issuing warnings about an entirely different industry and lobbying government authorities over fisheries management.
That is significant evidence about the character of the Panel.
A body functioning merely as a corporate public-relations mechanism might reasonably have been expected to confine itself to assuring observers that Sakhalin Energy was behaving responsibly.
Instead, WGWAP increasingly considered cumulative threats from the entire environment in which the whales lived.
Its recovered archive records more than 600 formal recommendations over its lifetime, addressed primarily to oil and gas companies but also to Russian regulators and other actors. (IUCN Cetacean Specialist Group)
The salmon-net episode is a useful example of why that broader mandate mattered.
Whales do not distinguish between corporate sectors.
An animal injured by fishing gear before encountering seismic noise is still the same animal.
16. The court record remains relevant — but only as background
The English High Court litigation considered earlier in this series predates the Piltun salmon-net controversy.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), Mr Justice Mitting dealt with access to environmental information concerning proposed UK export-credit support for Sakhalin II.
The case demonstrates how deeply questions concerning Sakhalin II, environmental assessment and public transparency had already entered British governmental and judicial scrutiny. (vLex)
But its limits must again be explicit.
The High Court did not consider salmon fishing at Piltun.
It did not determine fisheries policy.
It did not make findings concerning the 2013 nets, the 2016 entangled calf or the 2018 scientific study.
The judgment is historical context, not evidence establishing the fisheries findings described here.
Documentary Findings
The evidence establishes that Shell had publicly acknowledged fishing-net deaths as a threat to western gray whales as early as 2005. It establishes that on 6 August 2013 Sakhalin Energy informed WGWAP of salmon nets near Piltun Lagoon and supplied direct observations and photographs showing whales, including mother-calf pairs, within 100 metres of those nets. It establishes that WGWAP considered the resulting risk extremely high and called for an immediate halt to fishing there. (Shell)
The evidence also establishes that the Sakhalin authorities closed the relevant pink-salmon fishery later that month and directed officials to consider whale impacts in future net-placement recommendations. It does not establish that this created a permanent exclusion zone.
Peer-reviewed research published in October 2018 found evidence of fishing-gear injury on 28 of 150 photographed whales — 18.7 per cent. The same researchers assessed coastal salmon set-net fishing near Piltun Lagoon as creating a very high entanglement risk. (IUCN Cetacean Specialist Group)
The evidence does not establish that all 28 scarred whales were injured at Piltun, that all were injured by Sakhalin salmon fisheries, or that every entanglement was fatal. The researchers explicitly stated that the location and fishery responsible for individual scars could not generally be determined. (IUCN Cetacean Specialist Group)
The WGWAP record further establishes that a young gray whale was photographed near Piltun in 2016 with a rope and approximately 25 floats attached. Its later survival was uncertain because it was not subsequently identified in the 2017 or 2018 monitoring seasons. Absence from later sightings is not treated here as proof of death.
Commentary
This is one of the Sakhalin files in which the documentary evidence points away from a simplistic anti-Shell conclusion.
Commercial fishing created the immediate hazard examined here.
Sakhalin Energy did not install the nets.
Its personnel helped expose them.
The company notified the independent scientists, documented mothers and calves near the gear, had already informed Russian authorities of its concern and later helped fund entanglement-response training.
That deserves to be recorded.
But the episode also demonstrates why the independent scientific structure surrounding Sakhalin II became more valuable than ordinary corporate environmental reporting.
The whales existed inside an ecosystem of overlapping risks.
Oil and gas development.
Shipping.
Fishing.
Noise.
Potential oil spills.
Habitat change.
Migration through several national jurisdictions.
No one corporate environmental department could control all of those threats.
The independent Panel gradually became something broader: a scientific mechanism capable of looking beyond the company that funded it and asking what was threatening the whales regardless of whose activity created the risk.
The “one in five” statistic is therefore important, but not because it supplies another allegation against Shell.
Its importance is evidential.
Photographs showed that fishing-gear encounters were not merely theoretical.
They had left marks on living animals.
And even while the population was recovering, the whales were carrying those marks with them.
Source Record
The principal primary record for the beginning of this instalment is the Western Gray Whale Advisory Panel Statement of Concern on the Risks of Salmon Fishing near Piltun Lagoon, dated 7 August 2013. It records that Sakhalin Energy notified the Panel one day earlier, identifies two approximately 1.5-kilometre nets and records company personnel observing mother-calf pairs within 100 metres of the gear.
WGWAP Statement of Concern — 7 August 2013
The principal scientific record is Lowry, Burkanov, Altukhov, Weller and Reeves, “Entanglement risk to western gray whales from commercial fisheries in the Russian Far East,” Endangered Species Research 37, 133–148, published 11 October 2018. It documents the 28-of-150 scar result, the physical configuration of the salmon set nets, the geographic overlap with whale habitat and the authors’ assessment of very high risk near Piltun.
Lowry et al. 2018 — full paper
The Report of the 19th Meeting of WGWAP, Moscow, 14–16 November 2018, records the 2016 calf observed with approximately 25 fishing floats, the subsequent uncertainty over its survival, the discussion with Sakhalin regulators and the Panel’s request for updated analysis of anthropogenic scarring.
WGWAP Report of the 19th Meeting — November 2018
The authenticated Shell corporate record is Royal Dutch Shell plc Sustainability Report 2005, which recorded the need to understand and reduce migration-route risks and specifically referred to three whales killed in Japanese fishing nets during 2005. (Shell)
Royal Dutch Shell plc Sustainability Report 2005
Contemporaneous reporting is supplied by IUCN’s 16 August 2013 account of the Piltun salmon-fishing controversy and its 11 October 2018 report accompanying publication of the peer-reviewed study. (IUCN)
IUCN — Salmon fishing clashes with endangered gray whales, 16 August 2013
IUCN — Western gray whales at great risk from salmon nets, 11 October 2018
The judicial background remains Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). It is used solely to document earlier British legal scrutiny of environmental information concerning Sakhalin II and does not establish any of the fisheries findings in this instalment. (vLex)
Archive disclaimer: References to fishing-gear injury are based on photographic analysis and reported observations. The 18.7 per cent figure does not identify the location or particular fishery responsible for every injury. WGWAP recommendations were independent scientific advice rather than regulatory commands. Sakhalin Energy’s role in identifying and responding to the fishing threat is recorded where supported by the documents. No fishing-related mortality is attributed to Shell without evidence.
Site-wide disclaimer applies.
Next instalment
The Sakhalin Papers XLVII: The Feeding Ground Was Losing Its Food — WGWAP’s 2019 Benthos Alarm
The whales had survived whaling.
Their numbers were increasing.
The fishing-net threat was finally being quantified.
Then the scientists noticed something disturbing beneath the water itself.
The tiny bottom-dwelling amphipods on which gray whales fed near Piltun had undergone a steep decline. The fall had begun in 2013 and reached its lowest recorded level in 2016.
There was another complication.
In 2016, the oil and gas companies ended the dedicated long-term benthic monitoring programme.
By July 2019, WGWAP had become concerned enough to issue an Open Statement of Concern, warning that the nearshore waters around Piltun Lagoon might be losing their capacity to support the recovering whales.
The next file examines what disappeared from the seabed — and why the scientists were alarmed that the monitoring disappeared too. (IUCN)
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