CCA MD Blue Crab Comment for April 10, 2008 Joint Commission Meeting

CCA MD joins with the Department of Natural Resources (Department, DNR) in calling for significant reductions in the harvest of female blue crabs in the Chesapeake Bay. It is intuitive that we need to afford more protection to the female of the species if we want a timely recovery of the population.

The blue crab started its recent decline in 1998 and we failed to adequately address its recovery until this current crisis. Crisis management has to be replaced by a long-term strategic plan to effectively address future crab management needs. CCA MD’s position statement on blue crab management adopted last month calls for such biologically based components for the Blue Crab Fishery Management Plan.

When the Department makes its final regulatory proposals designed to reduce the landings of female crabs by 20% – 40% they must be easily enforceable and provide a reasonable level of voluntary compliance by all crabbers or we will fail again in our effort to recover this resource. The commercial sector’s draft options for a maximum size limit on female crabs and a sliding bushel limit by month for only female crabs fail to meet these criteria. They are open to abuse by economically stressed crabbers. The rewards are too great and the risks are too small not to tempt deliberate violations that would undermine the effectiveness of the new regulations should either of these options be chosen.

CCA MD supports a closure on the taking of female crabs for both commercial and recreational crabbers at a conservative time certain date to return the blue crab fishery to the target removal rate of 46%. This would provide the greatest potential to protecting these biologically important spawners, be enforceable, increase the compliance level and be equitable. While this option differs from a recommendation in our letter of March 13th, it closely resembles our call for a closure of all crab fisheries when the fishing target is estimated to be reached and therefore we can support it.

The draft options for new recreational crabbing regulations are unacceptable. The proposal to prohibit citizen crabbers from taking any females is inequitable and reducing creel limits and imposing later start times on recreational crabbers fails to address reducing fishing mortality on females but instead reallocates the resource.

It is blatantly unfair to subject the citizen crabber to a total prohibition of taking female crabs when the commercial sector will be allowed to continue removing large numbers of these spawners. If protecting the female is critical to the blue crab recovery then we should consider a total moratorium on their harvest for all users. If a moratorium is deemed unnecessary CCA MD maintains that the only equitable solution is to apply the same regulatory restrictions for female crabs to both commercial and recreational crabbers.

Reducing the licensed recreational crab creel limit from 1 bushel to 5-6 dozen crabs is reallocation since any crabs conserved by this proposal would not be protected from commercial catch. Furthermore, while it would restrict the potential recreational catch by an estimated 25%, most of the reduction would not be females, the stated goal of new regulations. CCA MD opposes further reductions in creel limits for recreational crabbers absent similar reductions for commercial crabbers.

We recognize that recreational crabbers must do their share to support the blue crab recovery but we want the Department to recognize that regulatory changes enacted in 2001 to reduce fishing pressure by 15% have already significantly impacted the recreational crabber. Unlicensed recreational crabber’s creel limits were reduced from 1 bushel (7-10 dozen crabs) to 2 dozen crabs. Licensed recreational crabbers were restricted by 50% when their creel was reduced from 2 bushels to 1. The result of these restrictions was an estimated 36% reduction in the 2002 recreational crab catch, while the 2002 commercial catch of crabs increased.

CCA MD is also opposed to start time differences for commercial and recreational trotliners. This is not a conservation issue and will have little to no impact in protecting female crabs. This is an allocation and user conflict issue and should be dealt with as such in future deliberations. We find it unacceptable that an unfair advantage to this common property resource is given to a few privileged commercial crabbers to start their crabbing activity before the rest of the citizens of Maryland. In fact, the current start time difference should be eliminated, not widened. Why should commercial crabbers be afforded an advantage over the average citizen when those very citizens are already greatly restricted by creel limits and gear restrictions that are not similarly imposed on the commercial crabber?

Finally, latent effort and an over-capitalized commercial fishery need to be addressed. CCA MD agrees it is appropriate to freeze entry into the Limited Crab Catcher commercial license category now to avoid an expansion of fishing effort. Furthermore, the establishment of a control date of December 15, 2007 is a good first step towards the future reduction of latent effort in the commercial fishery.

We thank the Department for the opportunity to offer comment on these new suggested regulatory options for recovering the blue crab population in the Chesapeake Bay. We will provide more formal comment in the near future.

Sherman Baynard
Fisheries Committee Chairman
CCA MD