Go to the EPA website and submit your opinion on this proposal - the more opinions they get the better - here is what I sent them:
The proposed ban on lead ammunition is extreme and would result in no proven benefit while severely impacting the shooting sports and hunting communities. The negative impact on those communities would in turn significantly impact the funding of wildlife conservation efforts through the Pittman-Robertson Act and over the 10,000 clubs and organizations such as NRA, Ducks Unlimited, Safari Club International, shooters, and fishermen that fund nearly 75% of the annual income for all 50 state conservation agencies.
It is primarily from that funding and from the volunteer efforts of individuals in those communities that wildlife populations have made such dramatic resurgences in the last fifty years - the following have all increased in populations - most more than double - some ten times or more in the last fifty years -
18,000 wolves, 1 to 10 million coyotes, 30 million deer, 600,000 black bears, 32,500 brown bears, 30,000 mountain lions, 42 million ducks, 255,000 moose, 1,000,000 elk, 70,000 bald eagles, 5 million alligators, 530.000 bison (500,000 privately owned and 30,000 in conservation herds), over 1 million caribou, 40,000 to 100,000 mountain goats, 19,000 big horn sheep, 10 to 15 million beavers, the number of turkey vultures roughly doubled between 1980 and 2000, while black vulture populations increased more than fourfold. -Turkey vultures - 1,300,000 and Black vultures - 250,000, Red Tailed Hawks 2,000,000, Peregrine Falcons - 300,000, and the Wild Turkey - 1,200,000.
These continuing increases in wildlife populations have occurred despite allegations that the use of lead in ammunition poses a significant threat to them. Additionally the CDC’s (Center for Disease Control) own study
http://www.nssf.org/share/PDF/ND_report.pdf demonstrated that use of lead ammunition does not pose any significant health risk to hunters or those who consume game harvested with lead ammunition. Wildlife populations are demonstrably more impacted by roads, vehicles, and wind farms.
Additionally, there is no economically viable substitute for lead in ammunition - lead prices have increased to about two dollars a pound - but the most viable substitute - bismuth is seventeen dollars a pound and is not available commercially in the quantities that would be needed to substitute for lead. Practically speaking a ban on lead ammunition would effectively be an economic ban on many of the shooting sports, which would have the consequence of pricing many individuals out of them and thus result in a major loss of funding for wildlife preservation, ultimately to the detriment of the wildlife populations that this proposed rule is supposed to protect.
This proposed rule would destroy the reloading of ammunition - destroy the ability of those who hunt with traditional muzzle loaders to do so, as traditional muzzle loaders require the use of soft lead balls, and will create a political and legal firestorm.
Whether or not this proposal is even legal is questionable given that ammunition and fishing lures are taxed under - 26 U.S.C. § 4181 - and thus are covered by - statutory enactment, 15 U.S.C. § 2602(2)(B)(v) - which would exempt them from 15 U.S.C. § 2605(a)(2)(A)(i).
In summary, adoption of this proposal would violate federal statute, would negatively impact wildlife populations by de-funding through the loss of tax revenue and donations to private sportsman’s wildlife preservation organizations those programs that have contributed to the dramatic increases in wildlife populations in recent decades, and would do nothing to materially protect the health of hunters, fishermen, sportsmen, consumers of harvested wildlife, or wildlife populations.
This proposal is merely an attempt by the opponents of hunting, fishing, and sport shooting to ban those activities through the backdoor by attempting to use the EPA to enact their agenda. I would urge the EPA based on the facts of the matter to deny enactment of this proposal.
