Comment from Cassandra Brooks

Some of the threats listed in the petitions are wildly speculative, particularly those about the impacts of ocean acidification and the giant pacific garbage patch on the NEP Great White Sharks. Ocean acidification and plastic pollution are two of the greatest threats to our global oceans, but there is no evidence that Great White Sharks are particularly at risk. Moreover, suggesting that the main prey species of the adult NEP Great White Sharks are at risk or are in decline is unwarranted: NMFS surveys cited in the pending regulation demonstrate that Northern Elephant Seals and Harbor Seals have largely, if not fully, recovered to their carrying capacity. Further, a new study found that NEP Great White Sharks are widely opportunistic, with some individuals feeding exclusively on fish or squid rather than pinnipeds (Kim et al. 2012). Great White Sharks are currently protected to some extent in the US. Directed fisheries are prohibited. The recently passed California Shark Fin Ban prohibits the sale, trade or distribution of shark fins. Internationally, they are classified as near threatened by the IUCN and have been given CITES Appendix II status. Both of these listings afford some international regulation against taking or trading Great White Sharks and their biological components. In consideration of further protecting the NEP population of Great White Sharks under the ESA, the best available science should be weighed and considered. Growing evidence suggests that the NEP Great White Shark population is unique and distinct. Incidental catch seems to be the biggest potential risk to the population, but catch rates appear to be declining (as cited in the pending regulation). I hope that researchers actively engaged in NEP Great White Shark studies will weigh into the conversation and that their suggestions are heard and given weight. If the listing is warranted due to precautionary measures, then perhaps “threatened” would be a more a appropriate status.