The Shark Proposals (Whale Shark: Prop. 11.47; White Shark: Prop. 11.48; Basking Shark: Prop. 11.49) will set a precedent for CITES, namely, the inclusion of commercially fished marine species under CITES Appendices.

The UN Food & Agriculture Organization (FAO) is the proper forum for conservation and management of commercially fished marine species. Implementation and enforcement of CITES’ controls will be too complex to be effective.

The strongest argument for including sharks under Appendix II (none fit Appendix I criteria) is for collection of data and monitoring of trade. FAO’s International Plan of Action (IPOA) for Sharks does exactly that, albeit in a voluntary fashion which respects sovereign rights of fishing nations. The FAO measure will be broader than CITES as there are more member nations of FAO than CITES.

The following organizations are currently compiling data on sharks: American Tropical Tuna Commission (IATTC), the International Council for the Exploration of the Sea, the International Commission for the Conservation of Atlantic Tunas (ICCAT), the Northwest Atlantic Fisheries Organization, the Sub-regional Fisheries Commission of West Africa, the Latin American Organization for Fishery Development, the Indian Ocean Tuna Commission, the Commission for the Conservation of Southern Bluefin Tuna (CCSBT), and the Oceanic Fisheries Programme of the Pacific Community.

Unscrupulous NGOs are seeking to manipulate public opinion by suggesting that "shark finning" is widespread and affecting all shark species. It is not. Wasteful finning is largely confined to incidents involving outlaw vessels and some incidental catches of blue sharks. None of the species being considered at COP 11 are shown to be involved.

Cooperation by CITES with FAO, not competition, is the most beneficial approach to the conservation of commercially fished marine species. Controversy based on emotion, and ignoring science will only undermine CITES’ credulity and ultimately will harm efforts to conserve natural resources and promote sustainable, environmentally compatible trade.