August 7, 2022
U.S. Fish and Wildlife Service
5275 Leesburg Pike
Falls Church, VA 22041
Dear U.S. Fish and Wildlife Service
The undersigned organizations, which represent millions of America’s anglers, hunters, recreational shooters, wildlife conservationists, and the industries they support, write to express our appreciation for expanded hunting and fishing opportunities contained in the 2022 – 2023 Station- Specific Hunting and Sport Fishing Regulations (Docket Number: FWS-HQ-NWRS2022-0055). Additionally, we write to express our concerns with the lead ammunition and fishing tackle restrictions contained in the same proposed rule.
The undersigned are thankful for the U.S. Fish and Wildlife Service (Service) continuing to expand hunting and fishing opportunities within the National Wildlife Refuge System (NWRS). Specifically, we thank the Service for expanding hunting and fishing opportunities on 19 national wildlife refuges over nearly 54,000 acres of NWRS lands and water. The NWRS provides critical access opportunities for America’s sportsmen and women, and we appreciate the efforts of the Service to provide more access to these cherished lands and waters.
While our organizations appreciate the efforts of the Service to expand hunting and fishing access opportunities within the NWRS, we are exceedingly concerned about the Service’s efforts to arbitrarily limit and phase out the usage of lead ammunition and fishing tackle by the fall of 2026 across nine refuge units where expanded opportunities are identified as part of the proposed rule. Throughout the proposed rule, the Service states “…lead ammunition and tackle MAY (emphasis added by the signatories) have negative impacts on both wildlife and human health…”. We believe that this proposal is not rooted in a science-based decision process.
Science-based fish and wildlife conservation is the cornerstone of our organizations and is a fundamental component to how federal and state fish and wildlife agencies manage our natural resources. Importantly, with rare exceptions, terrestrial and aquatic animals are managed to objectives for the population, not each animal. Blanket regulations on lead products commonly used for decades or longer by sportsmen and women based on unsubstantiated assumptions threatens to undermine how we have successfully managed fish and wildlife for the last century. Blanket regulations also fail to acknowledge local authority and situational context in decision-making. Generally, efforts to ban lead ammunition and fishing tackle are based on concerns regarding mortality of individual animals due to incidental ingestion. However, in this instance, the Service provides no rationale whatsoever, other than blanket, unsubstantiated statements about the possible impacts of lead ammunition and fishing tackle on wildlife and human health. For example, the Service’s proposed rule lacks any specific justification whatsoever in terms of population objectives for terrestrial species, nor any evidence related to lead that impedes population management objectives. In addition, the proposed rule is not limited to certain categories of ammunition or fishing tackle that an individual animal might practically encounter, instead banning all types of lead ammunition and/or fishing tackle.
While supporters of lead ammunition and fishing tackle bans often claim that there are many comparable alternatives, this is simply not the case. Sportsmen and women provide the bulk of conservation funding across the nation through the “user pays – public benefits” American System of Conservation Funding (ASCF). It is important to recognize that non-lead ammunition and tackle options are often cost-prohibitive and not widely available, and as the markets have shown, supply is still struggling to meet demand. The resulting inability to locate non-lead options, especially those that are reasonably affordable, has the potential to stave-off participation. This in-turn may result in a loss of revenue for state fish and wildlife agencies through the ASCF, which just last year generated $1.5 billion in funding generated over the last year through the excise taxes of hunting, shooting, and fishing equipment.
Finally, on March 11, 2022, many of the undersigned organizations sent a letter to the Service regarding a lawsuit filed by an organization that is well-known as an anti-hunting and fishing entity. In the March letter, our organizations called on the Service to reject and cease settlement discussions with the plaintiff organization. Those discussions continued, however. Now “the parties are optimistic that they can settle this case, as they have reached a tentative agreement in principle on key terms and will now turn to drafting the written settlement agreement and seeking necessary approvals”, according to a joint motion with the federal court in Montana seeking an extension of time. The joint motion refers to the 2022 – 2023 Station-Specific Hunting and Sport Fishing Regulations and says the extension (which was granted) will give “Plaintiff time to determine if the Service’s final rule satisfies some of the Center’s goals of this litigation, which would further facilitate settlement of the case.” Unfortunately, given the recent proposed rule to phase out lead ammunition and tackle, the undersigned organizations are growing increasingly concerned that the voices of America’s sportsmen and women are being ignored at the whims of anti-hunting and fishing organizations.
With these reasons in mind, the undersigned organizations extend our appreciation to the Service for the expansion of hunting and fishing opportunities across 54,000 acres of NWRS lands and water. However, we urge the Service to strike the unfounded lead ammunition and tackle restrictions proposed in the recent 2022 – 2023 Station Specific Hunting and Sport Fishing Regulations.
American Catfishing Association
American Sportfishing Association
Bass Anglers Sportsman’s Society (B.A.S.S)
Boone and Crockett Club
Center for Sportfishing Policy
Coastal Conservation Association
Congressional Sportsmen’s Foundation
Dallas Safari Club
Houston Safari Club
International Game Fish Association
Major League Fishing
Marine Retailers Association of the Americas
National Deer Association
National Marine Manufacturers Association
National Professional Anglers Association
National Rifle Association
National Shooting Sports Foundation
Rocky Mountain Elk Foundation
Safari Club International
The Bass Federation
The Walleye Federation
Wild Sheep Foundation
CC: Deputy Secretary of the Interior Tommy Beaudreau
USFWS Director Martha Williams