April 2, 2022
Robert Boyles, Director
SC Department of Natural Resources
P.O. Box 167
Columbia, SC 29202-0167
Re: Concern Regarding Harvesting of Horseshoe Crabs
Dear Mr. Boyles:
Thank you for your work to promote the SCDNR mission of advocacy and
stewardship of South Carolina’s natural resources. I am writing on behalf of Sierra
Club Robert Lunz Group to express concern about the management of Horseshoe
Crabs (Limulus polyphemus) resources.
Sierra Club Robert Lunz Group comprises a 4-county area around Charleston and
represents over 1,300 members who are dedicated to our mission:
 To explore, enjoy, and protect the wild places of the Earth;
 To practice and promote the responsible use of the earth's ecosystems and
resources; and
 To educate and enlist humanity to protect and restore the quality of the
natural and human environment.
I believe aspects of our mission statement resonate with those of SC Department
of Natural Resources. We ask that you reconsider SCDNR policies regarding
horseshoe crabs in alignment with your stated Mission, Core Values and Guiding
Principles.

Sierra Club Robert Lunz Group supports recommendations proposed by
Defenders of Wildlife and other regional conservation groups, including the
following:
Harvest Practices: We ask that regulations for harvesting Horseshoe Crabs
(Limulus polyphemus), address protection of spawning Horseshoe Crabs and
prohibit the of harvesting such crabs in all known Red Knot (Calidris canutus)
foraging locations.
1. Permitting and Closures: We ask that permitting rules list all areas closed
to harvesters, require use of refrigerated trucks, impose a 24-hour window
for harvest/bleed/return of crabs to water and mandate marking of bled
crabs.
2. Data Collection: We ask that SCDNR implement regular, comprehensive
surveys for horseshoe crab population to provide reliable data upon which
to base policies regarding harvesting.
3. Containment Ponds: Use of containment ponds interrupts breeding cycle
which is critical to both Horseshoe Crab and Red Knot populations. This
practice has been abused by biomedical operators and we ask that it be
terminated.
4. Conflict of Interest: We are concerned that SCDNR’s ability to manage the
horseshoe crab fishery with integrity, open communications and in the
public interest is jeopardized by the financial arrangement with Charles
River Laboratories.

The SC Lowcountry natural resources are imperiled by growth, development and
climate change. Effective management of these resources by our public entities is
essential for their and our survival.
Thank you for consideration of this letter. If you have questions, or require
additional information, please do not hesitate to contact me.
Sincerely,

Christine von Kolnitz, Chair

 

April 13, 2022

 

Lewis White, Jr., Chairman

Town of Awendaw Planning Commission

6971 Doar Road

P.O. Box 520

Awendaw, SC 29429

 

Re:      Concern Regarding Proposed Residential Development in Awendaw

 

The South Carolina Sierra Club strongly counsels against the development of 204 homes on the White Tract and 249 homes on the Romain Bay Preserve Tract in the Town of Awendaw.

 

These large residential developments are inconsistent with the conservation of the Cape Romain Wildlife Refuge, the Francis Marion National Forest and the quality of life of the citizens in the Town of Awendaw. 

 

Due to the lack of a piped sewer system, hundreds of septic systems would be needed for the houses. There is plenty of local evidence that septic systems lead to polluted bodies of water and groundwater.  That pollution could lead to incredibly expensive clean-up efforts as seen throughout Charleston County.  Humans and wildlife stand to suffer in known ways.  We have experience, we do not need to learn any lessons here.   

 

Controlled burning taking place on the edges of neighborhoods is very likely.  This method of controlling forest growth must continue,  especially with the increases in summer heat and drought we've seen in recent years with predictions of worsening heat and drought in the future.  We've seen the out of control forest fires out west.  We do not need to learn lessons here.

 

There are not enough jobs locally to keep the proposed population from having to drive long distances to find work. That feeds the need for more fossil fuels, which feeds climate change.  More habitat will be lost for needed upgrades to handle the increase in traffic. 

 

The homes themselves if not built high above the flood waters will surely be swamped in future storms. Thus relegating more Lowcountry homeowners to years of fighting the tide.   We know how this story ends as well.  Again, we do not need to learn lessons here.  

 

Lowcountry residents, natural environment and infrastructure are critically vulnerable to sea level rise.  It is imperative that proposed development projects consider current AND future climate conditions to protect humans and wildlife.  We urge you to act to ensure the safety of these existing communities.

 

Sincerely,

 

 

 

Christine von Kolnitz, Chair

Sierra Club Robert Lunz Group