REQUEST FOR ACTIONS TO STOP THE DECLINE OF THE              
                     HORSESHOE CRAB (LIMULUS POLYPHEMUS)
                             
The American Bird Conservancy and the National Audubon Society urge the ASMFC to impose a
moratorium on Horseshoe Crab harvests in the fishery from New Jersey to Virginia and to 
require restrictions on the remaining fisheries.  The moratorium is necessary until: 

1) BETTER STOCK ASSESSMENTS ARE COMPLETED, INCLUDING THE
   ASCERTAINMENT OF SUSTAINABLE HARVEST RATES (HARVEST MORTALITY
   RATES) AND MALE/FEMALE RATIOS; 
2) HARVEST PRESSURE IS BETTER UNDERSTOOD, INCLUDING CATCH PER UNIT
   EFFORT AND THE NUMBER OF HARVESTERS, THE METHODS USED, AND END USE
   OF THE HARVEST; 
3) MEASURES ARE ADOPTED TO PROTECT THE REMAINING SANDY BEACHES AND
   OTHER CRITICAL BUT DWINDLING SPAWNING AREAS OF THE HORSESHOE CRAB; 
4) REGULATIONS ARE ADOPTED REQUIRING THE LICENSURE
   OF HARVESTERS AND ENFORCEABLE PROVISIONS FOR REPORTING CATCH;  
5) COMPREHENSIVE REGULATIONS ARE DEVELOPED BY THE OTHER STATES TO
   BETTER REGULATE AND TO REDUCE HARVEST PRESSURE ON THE HORSESHOE
   CRAB; 
6) ECONOMIC ANALYSIS ARE CONDUCTED TO DETERMINE THE VALUE OF THE
   FISHERY AND THE VALUE OF ECO-TOURISM RELATED TO THE HORSESHOE
   CRAB-SHOREBIRD LINK, AND NON-CONSUMPTIVE  MEDICAL USE FOR LIMULUS
   AMOEBOCYTE LYSATE; AND  
7) ALTERNATIVES ARE RESEARCHED AND DEVELOPED TO THE USE OF
   HORSESHOE CRABS FOR EEL BAIT.

Once the above conditions are met and the moratorium is lifted, 
we suggest at a minimum that items 1) through 7) above be required 
as part of a fishery management plan that would also include: 

A) A PROHIBITION ON THE HARVEST OF HORSESHOE CRABS FROM SPAWNING
   BEACHES DURING SPAWNING SEASON; 
B) A PROHIBITION OR SIGNIFICANT RESTRICTION ON DREDGING OR TRAWLING
   FOR HORSESHOE CRABS IN THE STATES' THREE MILE OFFSHORE WATERS AND IN
   THE DELAWARE BAY; 
C) A PROHIBITION ON THE CRABS' HARVEST BY TRAWL, DREDGE, SCRAPES, AND
   OTHER MECHANICAL DEVICES DURING SPAWNING SEASON; 
D) LIMITS ON THE NUMBERS HARVESTED AND TYPES OF GEAR USED; 
E) A SURVEY OF HORSESHOE CRAB BYCATCH IN OTHER FISHERIES SUCH AS
   CONCH, SURF CLAM, AND MONKFISH AND THE ADOPTION OF MEASURES TO
   RESTRICT THIS BYCATCH; AND 
F) A SURVEY AND ANALYSES ON THE IMPACT OF MEDICAL "BLEEDING" OF THE
   CRABS TO ADEQUATELY ASSESS THE IMPACT ON POPULATIONS OF THE CRAB, 
   INCLUDING AN ASSESSMENT OF MORTALITY.