Connecticut Audubon’s horseshoe crab testimony, February 2020

Horseshoe crabs at Griswold Point, Old Lyme.

February 12, 2020

Testimony of Patrick Comins, executive director of the Connecticut Audubon Society, regarding Horseshoe Crab Restoration in Connecticut and the 2019 Stock Assessment. Prepared for a public informational meeting to discuss regulatory actions the Connecticut Department of Energy and Environmental Protection should take in response to the request from the ASMFC Horseshoe Crab Management Board.

You can read the DEEP’s informational bulletin here.

The Atlantic States Marine Fisheries Commission (ASMFC) manages the horseshoe crab stock from Maine to eastern Florida. In 2009, the conservation community joined with the ASMFC to better manage the harvest of horseshoe crabs (ASMFC 2009). The resultant Adaptive Resource Management (ARM) framework represented a useful new tool in our efforts to restore horseshoe crab populations after the devastating overfishing of the 1990s. Ten years later, and more than 20 years after ASMFC management began, restoration remains a distant goal, particularly in our “New York” region (Connecticut, New York, and northern New Jersey) where stocks of horseshoe crabs have been determined to be in poor condition.

The lack of progress was made abundantly clear in the 2019 benchmark stock assessment for the horseshoe crab on the Atlantic Coast (ASMFC 2019). The assessment confirms our view that current management has at best stemmed the decline of the horseshoe crab population in some areas and that stocks in our region remain in poor condition. Restoration to habitat carrying capacity was the main goal set in 1998. Restoration is essential for horseshoe crabs to resume a functional role in ecosystems, provide for recovery and maintenance of Red Knot (Federal Threatened) and other shorebirds whose populations crashed from overharvest and loss of egg resources, and provide for other fish and wildlife that depend a recovered and healthy horseshoe crab population.

The ASMFC’s explicit intent of the horseshoe crab management plan is to ensure sustainably harvested populations and allowing horseshoe crabs to have a “continued role in the ecology of coastal ecosystems” (AMFSC 1998). The stock assessment does not consider whether the horseshoe crab population, at its current size, is providing “the necessary quantities of adults and eggs for fish and wildlife resources.” The 1998 fisheries management plan recognized ecosystem service as a prerequisite to “appropriate coastwide management of the horseshoe crab population.”

Under the provisions of section 26-159a of the General Statutes, the Connecticut Department of Energy and Environmental Protection is authorized to regulate marine arthropods such as horseshoe crabs. We recommend that Connecticut play an appropriate role to focus on rapid restoration of the population to carrying capacity so horseshoe crabs can quickly resume a functional role in ecosystems. Increasing horseshoe crabs to carrying capacity is critical to the viability of the federally listed Red Knot (Calidris canutus rufa), other migratory shorebirds, sportfish, and forage fish.

Horseshoe crabs are primarily harvested commercially as bait for the commercial American eel and whelk/conch fisheries along the Atlantic Coast. Connecticut has so far changed the harvest rules to close hand-harvest on Milford Point, Sandy Point in West Haven, and Menunketesuck Island in Westbrook, and recently the Town of Stratford included their beaches as a closed area. According to data from Sacred Heart University, the number of females coming up to the beaches without a mate has been increasing, so a male-only harvest, as has been implemented in some areas, may cause an increase in females unable to lay fertilized eggs. We strongly feel that because of the poor stock levels of horseshoe crabs in our region, the only remaining course of action is to invoke a moratorium on the harvest of horseshoe crabs in Connecticut.

Thank you for the opportunity to provide comments on this important issue.

Literature Cited

ASFMC 1998. Interstate Fishery Management Plan for Horseshoe Crab. Fishery Management Report No. 32 of the Atlantic States Marine Fisheries Commission. December 1998. 57 pgs. http://www.asmfc.org/uploads/file/hscFMP.pdf

ASMFC 2009. Stock Assessment Report No. 09-02 (Supplement B) of the Atlantic States Marine Fisheries Commission. A Framework for Adaptive Management of Horseshoe Crab Harvest in the Delaware Bay Constrained by Red Knot. 46 pages. http://www.asmfc.org/uploads/file/2009DelawareBayARMReport.pdf

ASMFC. 2019. 2019 Horseshoe Crab Benchmark Stock Assessment and Peer Review Report. ASMFC, Arlington, VA. 316 pp.