Sierra Club Robert Lunz Group

 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