To the Editor:
This letter was sent to David Pierce, director of the Massachusetts Division of Marine Fisheries.
On behalf of Mass Audubon, I submit the following comments on the proposed amendments to regulations governing the catch of horseshoe crabs. This proposed amendment would: a. Increase the horseshoe crab mobile gear trip limits from 300 crabs to 600 crabs effective no later than July 1; and b. Exempt mobile gear fishermen from all or some of the springtime lunar closures.
Mass Audubon Wellfleet Bay Sanctuary has conducted standardized regional horseshoe crab spawning surveys and tagging studies since 1999, and has worked with the Division of Marine Fisheries (DMF) on two horseshoe crab sonic telemetry studies of crab movement, as well as on juvenile horseshoe crab surveys. Our spawning survey data is submitted to DMF each year for inclusion in the annual compliance reports to the Atlantic States Marine Fisheries Commission (ASMFC).
Despite lunar closures implemented in 2010, along with reducing the daily catch limit to 400 crabs for hand harvesters in 2008, there is no sign of a population increase based on our spawning survey data for three embayments on the Outer Cape. More broadly, according to the ASMFC’s most recent stock assessment for horseshoe crabs, “the New York and New England regions continue to see a decrease in abundance … the status of horseshoe crabs in the New England region appears worse than what it was during the 2009 stock assessment, with more indices now likely less than their Q25 and 1998 reference points.”
Mass Audubon opposes the proposed regulations because the best available data indicates that horseshoe crab populations are low and likely still declining, especially in areas subject to bait harvest. We oppose the elimination of lunar closures for draggers because, while the crabs harvested by draggers are not actively spawning, they are likely to spawn in the future. Also, the state’s annual trawl surveys have shown no sign of an increase in crabs for the Southern New England region, which includes Nantucket Sound, the area most affected by the proposed regulations.
While we appreciate the need for a steady supply of crabs for the biomedical industry, given the lack of evidence for recovery of the horseshoe crab population in areas subject to bait harvest in Massachusetts, we feel there is no justification for increasing harvest in any form.
We continue to recommend a bait harvest moratorium in Wellfleet, where the spawning indices have been very low relative to other embayments. Rolling embayment closures will allow stocks to recover for several years before harvest is allowed again.
Thank you for considering these comments.
John J. Clarke, director
Public Policy & Government Relations, Mass Audubon
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