Keen scent appears to have pierced the change shape ability in half.
Damage reduction should probably be 10.
We should either give 'em the amphibious quality or water dependent ability of the sahuagins.
Speaking of sahuagins, do we want to borrow this ability?
Speak with Sharks (Ex): Sahuagin can communicate telepathically with sharks up to 150 feet away. The communication is limited to fairly simple concepts such as “food,” “danger,” and “enemy.” Sahuagin can use the Handle Animal skill to befriend and train sharks.
The nawidnehr (NAH-widd-near) is a great shark capable of assuming humanoid form. this powerful marine predator has an insatiable desire to kill. Also called the roaring shark, or sharkwere, the nawidnehr uses its shape-shifting abilities to pursue its prey onto land or insinuate itself into an unsuspecting party for a surprise attack.
Borrowing from other critters with change shape...
*When using its change shape ability, a nawidnehr gains a +10 circumstance bonus on Disguise checks.
All nawidnehrs speak the common tongue of humanity. Each individual sharkwere speaks several (1d4+1) other demihuman racial tongues as well.
Nawidnehrs speak Common. Most know two or more other languages, generally Dwarven, Elven, or Halfling, depending on which races are prevalent in the coastal regions near their feeding grounds.
Sometimes the creature decides not to roar when attacking in its natural form. Rather, it lunges at swimmers from below, imposing a -3 penalty to its opponents' surprise rolls.
Improved Init? Hide and Move Silently? Stealthy?
When nawidnehrs use their shape-shifting ability to fool humanoid victims, they try to lure the victim into the water before attacking. They usually leap into the sea, dragging paralyzed victims with them. However, sharkweres will grappled with an opponent and enter the water with a victim in their grasps. Nawidnehrs have effective Strength scores of 18/00 or 19 for this purpose.
Revise improved grab like crocodile?
Improved Grab (Ex): To use this ability, a nawidnehr must hit with its bite attack. It can then attempt to start a grapple as a free action without provoking an attack of opportunity. If it wins the grapple check, it establishes a hold on the oponent with its mouth and drags it into deep water, attempting to pin it to the bottom or can try to swallow the foe the following round.
Habitat/Society: Nawidnehrs hunt victims every waking moment; they can't stand to leave any other creature in peace. Even the sahuagin fear these powerful predators. Sharkweres swim the oceans, seeking prey as any natural predator. However, these craft beats often pose as fishermen, marooned sailors, or friendly natives to attract victims. When encountered under the sea, there is a 40% chance that 2d4+1 large sharks (7-8 HD) accompany a nawidnehr.
Further support for Disguise bonus and speak with sharks.