THE SHELL LEAKS FILES: 14 SEPTEMBER 2026
SLF-2007-057
The Sakhalin Papers XLVII: The Feeding Ground Was Losing Its Food — WGWAP’s 2019 Benthos Alarm
For fifteen years, oil companies operating off north-eastern Sakhalin financed a programme that measured the tiny bottom-dwelling animals on which gray whales depended. Then something changed. Amphipod biomass in the nearshore Piltun feeding ground began falling sharply in 2013 and reached the lowest level in the entire monitoring series in 2016. That same year, the industry-sponsored benthic programme ended. Three years later, the independent Western Gray Whale Advisory Panel issued an unusually stark public warning: the whales’ traditional nearshore feeding ground might be losing the capacity to support them.
1. The problem was beneath the whales
Much of the Sakhalin controversy had been visible above or within the water column.
Platforms.
Pipelines.
Ships.
Dredging.
Seismic airguns.
Fishing nets.
But the next warning came from the seabed.
Gray whales are benthic feeders. Off Sakhalin, they descend to the seafloor and consume large quantities of small invertebrates living in or immediately above the sediment.
In the shallow nearshore feeding area around Piltun Lagoon, one of the principal prey species was the amphipod Monoporeia affinis.
Farther offshore, another amphipod, Ampelisca eschrichtii, was particularly important.
The difference would eventually matter enormously because the nearshore and offshore feeding grounds were not interchangeable for every whale.
Young calves and dependent mother-calf pairs relied especially heavily upon the shallow Piltun habitat.
2. Fifteen years of industry-financed seabed monitoring
Between 2002 and 2016, Sakhalin Energy Investment Company and Exxon Neftegas Limited jointly supported an annual benthic sampling programme.
Its purpose was straightforward but scientifically important:
to measure the distribution, composition and biomass of gray-whale prey in both the nearshore and offshore feeding areas.
The Western Gray Whale Advisory Panel later acknowledged imperfections in the programme. Sampling locations and timing varied between years.
Nevertheless, WGWAP considered the resulting 15-year dataset to possess considerable scientific value. (IUCN Cetacean Specialist Group)
That point deserves emphasis.
The evidence underlying the later warning did not originate with environmental campaigners attempting to reconstruct conditions from outside the project.
Much of it came from research financed by the oil companies themselves.
3. The decline began in 2013
The long-term dataset began showing something troubling.
According to WGWAP’s formal Open Statement of Concern dated 11 July 2019, amphipod biomass in the nearshore feeding ground began declining in 2013.
By 2016, it had reached the lowest level recorded during the entire 15-year time series.
Offshore conditions were different.
Amphipod biomass there remained high through 2016. (IUCN Cetacean Specialist Group)
The distinction between the two habitats began to offer a possible explanation for another observation.
The whales themselves appeared to be redistributing.
Increasing numbers were using the richer offshore feeding ground.
Fewer were remaining in the traditional Piltun nearshore area.
4. Then the monitoring stopped
This is the central documentary fact in the present file.
After the 2016 season, the companies discontinued the benthic monitoring programme.
WGWAP stated in July 2019 that no new data had been collected under that programme since then.
The Panel also recorded that it had repeatedly expressed disappointment over the decision because the available evidence was already showing a sharp reduction in nearshore amphipod biomass.
The timing was therefore remarkable.
A monitoring programme had produced a warning signal.
The signal was worsening.
Then the monitoring ceased.
That sequence is established.
What it does not establish is that Sakhalin Energy stopped monitoring because it wished to conceal the decline.
The documents reviewed for this instalment do not demonstrate such a motive.
The evidentially safe conclusion is narrower:
the programme ended at precisely the time when the long-term dataset was showing its most concerning nearshore result.
5. The whales appeared to be moving too
The prey decline was accompanied by changes in whale distribution.
WGWAP’s July 2019 statement recorded two developments occurring in parallel with the loss of nearshore amphipod biomass:
a continued reduction in the number of whales using the nearshore feeding area;
and a noticeable southward shift in their distribution.
The Panel said the combined pattern raised the possibility that waters immediately outside Piltun Lagoon were gradually being abandoned and could cease to function as a viable feeding ground.
That was not presented as a proven prediction.
It was a scientific warning.
And WGWAP described the matter as urgent.
6. Why mothers and calves made the warning more serious
The offshore feeding area offered abundant prey.
So why not simply allow the whales to move?
Because the observations suggested that not all animals could use the deeper offshore habitat equally.
WGWAP reported that mothers were increasingly seen offshore after weaning their calves.
But calves and yearlings had not been observed there.
That suggested that the youngest animals might not yet be capable of feeding effectively in deeper offshore waters.
The nearshore Piltun habitat was therefore not simply one feeding patch among several.
At the time of the Panel’s statement, it was the only known Sakhalin feeding area where mothers accompanied by dependent calves regularly foraged.
If that habitat became nutritionally inadequate, the biological consequences could fall disproportionately on precisely the animals most important to future population growth.
7. The 2018 numbers intensified the concern
The 20th WGWAP meeting later examined whale-distribution data from 2018.
The figures were striking.
During synchronized nearshore surveys, the average number of whales counted was only six.
The maximum was eight.
WGWAP described eight as the lowest maximum count recorded since this component of the Joint Programme began.
In comparison, a nearly simultaneous September survey estimated 124 whales offshore and only five nearshore.
But the Panel identified an important methodological complication.
The vessel used for offshore surveys in 2018 had a much higher observer platform than the vessel used previously. Observers aboard the new vessel counted substantially more whales during comparative work.
WGWAP therefore warned that raw offshore counts from 2018 should not simply be compared with earlier years without correcting for observational differences.
This is an excellent example of why the source record must be handled carefully.
There was compelling evidence of reduced nearshore use.
But not every apparent numerical increase offshore could safely be treated as a biological increase.
8. WGWAP challenged the industry programme’s reassuring conclusion
The industry-supported 2018 monitoring report concluded that the overall Sakhalin foraging group was relatively stable and generally favourable.
WGWAP did not accept that conclusion.
At its November 2019 meeting, the Panel said the available data did not support such a broad characterization.
It pointed instead to:
the severe reduction in whale abundance in the Piltun nearshore area;
the contraction of whale distribution there;
the apparent correlation with declining prey biomass;
and unresolved methodological problems in the survey data.
The Panel repeated its concern that the declining benthic biomass could eventually produce population-level consequences.
This was therefore more than an argument over presentation.
The company-supported monitoring programme and its independent scientific advisers were drawing materially different conclusions from parts of the same evidence.
9. One scientist used the word “crisis”
The November 2019 WGWAP report records an unusually forceful intervention by Panel member David Weller.
Discussing the very low use of the nearshore feeding ground and the unusually early separation of some mother-calf pairs, he described the nearshore habitat as being, in his opinion, “in a state of crisis.”
His hypothesis was that lactating females might be exhausting their nutritional reserves and moving offshore earlier in the season to find better feeding, leaving newly independent calves behind in the shallower habitat.
If correct, such a process could affect calf survival and maternal reproductive intervals.
WGWAP did not present this hypothesis as established fact.
It explicitly treated follow-up survival and reproductive monitoring as necessary.
That distinction is vital.
A serious scientific hypothesis entered the record.
It was not a proven causal finding.
10. A peer-reviewed paper pointed strongly towards natural oceanographic drivers
There was another reason not to leap from declining prey biomass to an accusation against Shell.
In February 2019, researchers published a peer-reviewed analysis in Marine Environmental Research examining prey biomass around north-eastern Sakhalin between 2001 and 2015.
The study investigated relationships between benthic prey and water depth, year, climatic indices and oceanographic processes.
Its overall conclusion was that temporal changes in prey biomass appeared to reflect climatic and oceanographic factorsdriving broader ecosystem change across the Sea of Okhotsk and Pacific Arctic region. (PubMed)
That study is significant because it provides a credible natural explanation.
Indeed, WGWAP expressly cited it when discussing possible causes of the decline.
The scientists were not approaching the question from the premise that oil and gas activity must necessarily be responsible.
11. But WGWAP would not rule industrial disturbance out
The Panel’s position was deliberately more cautious.
In its July 2019 statement, WGWAP said the cause of the amphipod decline remained undetermined.
It explicitly acknowledged that natural changes in the ecosystem might be entirely responsible.
But it added that disturbance associated with more than two decades of exploration, infrastructure development and oil and gas production in the region could not yet be excluded as having played some role.
That wording is central to this instalment.
The Panel did not find:
Shell caused the prey decline.
Nor did it find:
oil and gas activity had nothing to do with it.
Its position was:
the cause had not been determined, several hypotheses remained plausible, and the missing monitoring data made the question harder to answer.
12. The solution proposed by the scientists was more data
WGWAP called for renewed investigation.
It said the nature and causes of the amphipod decline should be examined in much greater depth.
Multiple hypotheses should be tested.
And most importantly, regular benthic sampling should restart so scientists could determine whether the decline observed through 2016 had continued.
This was not a demand for an immediate finding of corporate liability.
It was a demand for evidence.
The distinction matters.
The scientific response to uncertainty was not to invent certainty.
It was to restore the measurement programme.
13. The public warning became contemporaneous news
IUCN issued a public report on 11 July 2019, the same day as WGWAP’s Statement of Concern.
Its headline was explicit:
“IUCN scientific panel calls for investigation of decline in prey of western gray whales.”
IUCN reported that the Panel feared waters immediately outside Piltun Lagoon might be losing their ability to support recovery of the endangered whales.
It noted the steep fall in amphipod biomass, the termination of the long-term monitoring programme in 2016 and the contemporaneous shift in whale distribution away from the nearshore feeding area. (IUCN)
The warning was therefore public at the time.
It is not a concern reconstructed retrospectively from private material.
14. Shell’s own 2019 Sustainability Report
There is an important authenticated Shell record from the same year.
Royal Dutch Shell plc’s Sustainability Report 2019 described IUCN as a long-standing environmental partner and specifically referred to the Western Gray Whale Advisory Panel.
Shell stated that in 2019 WGWAP had received a new three-year mandate to advise Sakhalin Energy on assessing and managing its impact on western gray whales.
The report identified Shell’s interest in Sakhalin Energy as 27.5% minus one share. (Shell)
That corporate statement confirms something important about responsibility for the advisory process.
WGWAP was not an external protest group attempting to impose itself on Shell.
It was part of an independent scientific mechanism that Sakhalin Energy had formally agreed to use.
Consequently, when WGWAP issued a public warning about the disappearing prey base, it was the company’s own independent scientific advisory structure speaking.
15. And yet benthic monitoring was still not scheduled to resume
At the November 2019 WGWAP meeting, Sakhalin Energy representatives discussed plans for 2020.
The company was seriously considering restarting annual acoustic monitoring.
But the representative confirmed that a resumption of the benthic component of the Joint Programme was not planned for 2020.
WGWAP again stressed the importance of benthic monitoring.
It was encouraged to learn that Exxon Neftegas and Gazpromneft-Sakhalin had collected environmental or benthic information independently and expressed hope that those data could extend the amphipod time series beyond the discontinued Joint Programme.
By that stage, therefore, the central problem was no longer merely that sampling had stopped.
It was that an independent scientific panel had publicly called for its resumption and regular benthic monitoring still had not been restored through the Joint Programme.
16. The High Court record remains background, not proof
As with earlier Sakhalin files, the English High Court litigation provides historical context.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), Mr Justice Mitting considered access to government environmental information relating to proposed British export-credit support for Sakhalin II.
The judgment records the scale of the project, the approximately US$650 million financing request and the environmental controversy surrounding western gray-whale habitat. (vLex)
But the limits of the judgment must remain explicit.
The High Court did not examine the 2013–2016 amphipod decline.
It did not consider the termination of the benthic programme.
It did not determine the cause of changing prey biomass.
It did not adjudicate the July 2019 WGWAP warning.
The case belongs here only because it establishes the longer history of governmental and judicial scrutiny surrounding environmental information about Sakhalin II.
Documentary Findings
The record establishes that Sakhalin Energy and Exxon Neftegas jointly supported annual benthic monitoring from 2002 through 2016 and that the resulting dataset was considered scientifically valuable by WGWAP. (IUCN Cetacean Specialist Group)
It establishes that nearshore amphipod biomass began declining in 2013 and reached its lowest recorded level in the 15-year series in 2016, while offshore amphipod biomass remained comparatively high.
It establishes that the industry-sponsored benthic programme was discontinued after 2016 and that WGWAP repeatedly objected to the loss of sampling.
It establishes that declining prey biomass coincided with reduced use and contraction of whale distribution in the Piltun nearshore feeding area. The documents describe that relationship as a correlation and concern; they do not establish a single proven causal chain.
It establishes that WGWAP regarded the loss of the nearshore habitat as especially concerning because mothers with dependent calves relied upon it and calves had not been observed feeding in the deeper offshore area.
It establishes that a 2019 peer-reviewed study found strong evidence that climatic and oceanographic processes influenced long-term prey variability. (PubMed)
And it establishes that WGWAP regarded the ultimate cause of the nearshore prey decline as unresolved: natural ecosystem processes might fully explain it, while some contribution from long-term industrial disturbance could not be excluded.
Commentary
The most striking feature of this episode is not that scientists discovered an environmental decline.
Monitoring programmes are supposed to discover changes.
The more troubling feature is what happened next.
For fifteen years, the oil companies financed the collection of evidence about what the whales were eating.
When that evidence showed the nearshore prey base falling sharply, the programme ended.
That does not prove bad faith.
There may have been contractual, scientific, regulatory, financial or programme-design reasons for ending it.
But from the perspective of environmental governance, the consequence was damaging.
The data series stopped at precisely the moment when continuity became most valuable.
Three years later, the independent scientific panel was effectively asking:
Is the decline continuing?
And because sampling had stopped, the answer was:
We do not know.
That is the larger lesson of the Sakhalin archive.
Monitoring is most useful when it produces unwelcome information.
If measurement stops when the trend becomes difficult, the entire rationale for long-term environmental monitoring is weakened.
There is also a second lesson.
This file does not establish that Shell destroyed the Piltun prey base.
The peer-reviewed evidence makes such a claim untenable.
Climate, ocean circulation and ecosystem processes offered credible explanations.
WGWAP itself acknowledged that natural change might be entirely responsible.
But precisely because multiple explanations were plausible, additional sampling was essential.
The scientific dispute was therefore not principally about whether Shell should be blamed.
It was about whether anyone was still collecting enough evidence to find out what was happening.
That question would become even sharper in 2020.
Source Record
The principal primary document is the Western Gray Whale Advisory Panel Open Statement of Concern on decline of the amphipod prey base in the nearshore feeding area near Piltun Lagoon, dated 11 July 2019. It records the 2002–2016 monitoring programme, the prey decline beginning in 2013, the 2016 low point, termination of the programme and the Panel’s call for renewed sampling. (IUCN Cetacean Specialist Group)
WGWAP Open Statement of Concern — 11 July 2019
The principal contemporaneous public report is IUCN’s “Scientific panel calls for investigation of decline in prey of western gray whales,” 11 July 2019. (IUCN)
The principal subsequent Panel record is the Report of the 20th Meeting of the Western Gray Whale Advisory Panel, Moscow, 6–8 November 2019. It records the exceptionally low nearshore counts, WGWAP’s rejection of overly reassuring interpretations, concern about benthic biomass and the absence of plans to restart Joint Programme benthic work in 2020. (IUCN Cetacean Specialist Group)
WGWAP 20th Meeting Report — November 2019
The peer-reviewed scientific record is Blanchard et al., “Prey biomass dynamics in gray whale feeding areas adjacent to northeastern Sakhalin (the Sea of Okhotsk), Russia, 2001–2015,” Marine Environmental Research 145 (2019), 123–136. (PubMed)
PubMed record for Blanchard et al. 2019
The authenticated Shell corporate record is Royal Dutch Shell plc Sustainability Report 2019, which confirms the renewed WGWAP mandate and Shell’s then 27.5%-minus-one-share interest in Sakhalin Energy. (Shell)
Royal Dutch Shell plc Sustainability Report 2019
The judicial background remains Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin) and is used solely for historical context concerning transparency and proposed UK financial support for Sakhalin II. (vLex)
Archive disclaimer: The decline in nearshore amphipod biomass is documented. Its cause is not established. WGWAP explicitly acknowledged that natural ecosystem change might be entirely responsible while stating that industrial effects could not be excluded. The termination of benthic monitoring after 2016 is documented; no motive for that decision is attributed without evidence. WGWAP recommendations were independent scientific advice rather than judicial or regulatory findings.
Site-wide disclaimer applies.
Next instalment
The Sakhalin Papers XLVIII: “A Philosophical Difference” — When Shell’s Scientists and Its Independent Advisers Disagreed About How Much Evidence Was Enough
By November 2020, the missing benthic data had become part of a broader dispute.
WGWAP said the disappearance of seabed monitoring was a major loss because scientists could no longer properly explain why whales were abandoning the nearshore feeding ground.
Sakhalin Energy took a different position.
The company maintained that it should not be responsible for collecting benthic information outside the area in which its operations could potentially affect the seabed.
During the meeting, Sakhalin Energy’s HSE leadership acknowledged what the minutes described as a “philosophical difference” between the objectives of conservation scientists and those of an oil company.
The next file examines that unusually candid exchange — and asks a fundamental question at the heart of independent corporate environmental oversight:
Is complying with regulatory requirements the same thing as knowing enough to protect an endangered species?(IUCN Cetacean Specialist Group)
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