Groups Ask EPA to Get the Lead out of Hunting Ammunition
One hundred organizations in 35 states on March 13 formally petitioned the U.S. Environmental Protection Agency (EPA) to regulate toxic lead in hunting ammunition to protect public health and prevent the widespread poisoning of eagles, California condors and other wildlife. Up to 20 million birds die each year from lead poisoning after consuming spent lead shot and bullet fragments left in the wild from hunting.
“The unnecessary poisoning of eagles, condors and other wildlife is a national tragedy that the EPA can easily put an end to,” said Jeff Miller with the Center for Biological Diversity. “There are safe, available alternatives to lead ammo for all hunting and shooting sports, so there’s no reason for this poisoning to go on. Getting the lead out for wildlife is in line with traditional American conservation, hunting and fishing values.”
The petition follows the EPA’s refusal in 2010 to review a petition asking for a ban on lead bullets, shotgun pellets and fishing tackle under the Toxic Substances Control Act, and seeks federal rules requiring use of nontoxic bullets and shot for hunting and shooting sports. It was filed by groups representing conservationists, birders, hunters, zoologists, scientists, American Indians, wildlife rehabilitators and veterinarians.
In the U.S., 3,000 tons of lead are shot into the environment by hunters every year, while another 80,000 tons are released at shooting ranges. Birds and animals are poisoned when they scavenge on carcasses containing lead-bullet fragments or ingest spent lead-shot pellets, which can cover popular hunting grounds at high densities.
Spent lead from hunting is a widespread killer of bald and golden eagles, trumpeter swans, endangered California condors and more than 75 other species. Nearly 500 scientific papers have documented the dangers to wildlife from lead exposure.
“It’s encouraging to see so many groups unite to end lead poisoning of wildlife,” said Miller. “This isn’t about hunting—it’s about switching to nontoxic materials to stop preventable lead poisoning. Getting the lead out of hunting ammunition will reduce hunters’ lead exposure too, as well as the health risks to anyone eating shot game.”
There are many commercially available alternatives to lead rifle bullets, shotgun pellets, fishing weights and lures. More than a dozen manufacturers market hundreds of varieties and calibers of nonlead bullets and shot made of steel, copper and alloys of other metals, with satisfactory to superior ballistics. Nonlead bullets and fishing tackle are readily available in all 50 states. Hunters and anglers in states and areas that have lead restrictions or have already banned lead have made successful transitions to hunting with nontoxic bullets and fishing with nontoxic tackle.
“We wisely removed lead from gasoline and paint because of the dangers of lead poisoning, and now it’s time to do the same for hunting ammunition. Future generations will thank us,” Miller said.
Lead has been known to be highly toxic for more than 2,000 years. Its use in water pipes, cosmetics, pottery and food is suspected to have been a contributing factor in the collapse of the Roman Empire. It is dangerous even at low levels; exposure can cause death or severe health effects, from acute, paralytic poisoning and seizures to subtle, long-term mental impairment, miscarriage, neurological damage, impotence or impaired reproduction, and growth inhibition. There may be no safe level of lead for fetuses and the young. In recent decades the federal government has implemented regulations to reduce human lead exposure in drinking water, batteries, paint, gasoline, toys, toxic dumps, wheel balancing weights and shooting ranges.
At least 75 wild bird species are poisoned by spent lead ammunition, including bald eagles, golden eagles, ravens and California condors. Despite being banned in 1992 for hunting waterfowl, spent lead shotgun pellets continue to be frequently ingested by swans, cranes, ducks, geese, loons and other waterfowl. Many birds also consume lead-based fishing tackle lost in lakes and rivers, often with deadly consequences.
Lead ammunition also poses health risks to people when bullets fragment in shot game and spread throughout the meat that humans eat. Studies using radiographs show that numerous imperceptible, dust-sized particles of lead can infect meat up to a foot and a half away from the bullet wound, causing a greater health risk to humans who consume lead-shot game than previously thought. State health agencies have had to recall venison donated to feed the hungry because of lead contamination. Nearly 10 million hunters, their families and low-income beneficiaries of venison donations may be at risk.
In denying the 2010 lead ban petition, the EPA claimed it lacks authority to regulate toxic lead bullets and shot under the Toxic Substances Control Act, which controls manufacture, processing and distribution of dangerous chemicals in the U.S., including lead. Yet congressional documents and the language of the act explicitly contradict the agency’s claim. The House report on the history and intent of the act states it “does not exclude from regulation under the bill chemical components of ammunition which could be hazardous because of their chemical properties.” Petitioning organizations sued the EPA over the improper petition denial, but hit a procedural snag and the lawsuit was dismissed in September 2011. The EPA never evaluated lead ammunition risks to wildlife and human health, and the court never ruled on the merits of the petition or lawsuit.
- Frequently Asked Questions
- Timeline of lead hazard reduction for wildlife and people
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One of nature's epic events is underway: Monarch butterflies' fall migration. Departing from all across the United States and Canada, the butterflies travel up to 2,500 miles to cluster at the same locations in Mexico or along the Pacific Coast where their great-grandparents spent the previous winter.
Millions of People Care About Monarchs<p>I will never forget the sights and sounds the first time I visited monarchs' overwintering sites in Mexico. Our guide pointed in the distance to what looked like hanging branches covered with dead leaves. But then I saw the leaves flash orange every so often, revealing what were actually thousands of tightly packed butterflies. The monarchs made their most striking sounds in the Sun, when they burst from the trees in massive fluttering plumes or landed on the ground in the tussle of mating.</p><p>Decades of educational outreach by teachers, researchers and hobbyists has cultivated a generation of monarch admirers who want to help preserve this phenomenon. This global network has helped restore not only monarchs' summer breeding habitat by planting milkweed, but also general pollinator habitat by planting nectaring flowers across North America.</p><p>Scientists have calculated that restoring the monarch population to a stable level of about 120 million butterflies will require <a href="https://doi.org/10.1111/icad.12198" target="_blank">planting 1.6 billion new milkweed stems</a>. And they need them fast. This is too large a target to achieve through grassroots efforts alone. A <a href="https://www.fws.gov/savethemonarch/CCAA.html" target="_blank" rel="noopener noreferrer">new plan</a>, announced in the spring of 2020, is designed to help fill the gap.</p>
Pros and Cons of Regulation<p>The top-down strategy for saving monarchs gained energy in 2014, when the U.S. Fish and Wildlife Service <a href="https://www.fws.gov/southeast/pdf/petition/monarch.pdf" target="_blank">proposed</a> listing them as threatened under the Endangered Species Act. A decision is expected in December 2020.</p><p>Listing a species as endangered or threatened <a href="https://www.fws.gov/endangered/esa-library/pdf/listing.pdf" target="_blank">triggers restrictions</a> on "taking" (hunting, collecting or killing), transporting or selling it, and on activities that negatively affect its habitat. Listing monarchs would impose restrictions on landowners in areas where monarchs are found, over vast swaths of land in the U.S.</p><p>In my opinion, this is not a reason to avoid a listing. However, a "threatened" listing might inadvertently threaten one of the best conservation tools that we have: public education.</p><p>It would severely restrict common practices, such as rearing monarchs in classrooms and back yards, as well as scientific research. Anyone who wants to take monarchs and milkweed for these purposes would have to apply for special permits. But these efforts have had a multigenerational educational impact, and they should be protected. Few public campaigns have been more successful at raising awareness of conservation issues.</p>
<span style="display:block;position:relative;padding-top:56.25%;" class="rm-shortcode" data-rm-shortcode-id="91165203d4ec0efc30e4632a00fdf57d"><iframe lazy-loadable="true" src="https://www.youtube.com/embed/KilPRvjbMrA?rel=0" width="100%" height="auto" frameborder="0" scrolling="no" style="position:absolute;top:0;left:0;width:100%;height:100%;"></iframe></span>
The Rescue Attempt<p>To preempt the need for this kind of regulation, the U.S. Fish and Wildlife Service approved a <a href="https://www.fws.gov/savethemonarch/pdfs/Monarch%20CCAA-CCA%20Public%20Comment%20Documents/Monarch-Nationwide_CCAA-CCA_Draft.pdf" target="_blank">Nationwide Candidate Conservation Agreement for Monarch Butterflies</a>. Under this plan, "rights-of-way" landowners – energy and transportation companies and private owners – commit to restoring and creating millions of acres of pollinator habitat that have been decimated by land development and herbicide use in the past half-century.</p><p>The agreement was spearheaded by the <a href="http://rightofway.erc.uic.edu/" target="_blank">Rights-of-Way Habitat Working Group</a>, a collaboration between the University of Illinois Chicago's <a href="https://erc.uic.edu/" target="_blank" rel="noopener noreferrer">Energy Resources Center</a>, the Fish and Wildlife Service and over 40 organizations from the energy and transportation sectors. These sectors control "rights-of-way" corridors such as lands near power lines, oil pipelines, railroad tracks and interstates, all valuable to monarch habitat restoration.</p><p>Under the plan, partners voluntarily agree to commit a percentage of their land to host protected monarch habitat. In exchange, general operations on their land that might directly harm monarchs or destroy milkweed will not be subject to the enhanced regulation of the Endangered Species Act – protection that would last for 25 years if monarchs are listed as threatened. The agreement is expected to create up to 2.3 million acres of new protected habitat, which ideally would avoid the need for a "threatened" listing.</p>
A Model for Collaboration<p>This agreement could be one of the few specific interventions that is big enough to allow researchers to quantify its impact on the size of the monarch population. Even if the agreement produces only 20% of its 2.3 million acre goal, this would still yield nearly half a million acres of new protected habitat. This would provide a powerful test of the role of declining breeding and nectaring habitat compared to other challenges to monarchs, such as climate change or pollution.</p><p>Scientists hope that data from this agreement will be made publicly available, like projects in the <a href="https://www.fws.gov/savethemonarch/MCD.html" target="_blank">Monarch Conservation Database</a>, which has tracked smaller on-the-ground conservation efforts since 2014. With this information we can continue to develop powerful new models with better accuracy for determining how different habitat factors, such as the number of milkweed stems or nectaring flowers on a landscape scale, affect the monarch population.</p><p>North America's monarch butterfly migration is one of the most awe-inspiring feats in the natural world. If this rescue plan succeeds, it could become a model for bridging different interests to achieve a common conservation goal.</p>
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