June 19, 2009
Ms. Cindy Gustafson, President
California Fish and Game Commission
1416 Ninth Street, 13th Floor
Sacramento, CA 95814
Dear Ms. Gustafson:
The National Rifle Association requests that this letter be included in the public comment record on the proposal before the Commission that would extend the ban on the use of lead ammunition in hunting to include all game species within the range of the California condor. The NRA strongly opposed the present ban and equally as strong, opposes its extension.
Proponents of the lead ammunition ban that was signed into law nearly a year ago (and which the Commission expanded upon in its regulations) attempted to make a scientific case that links the lead poisoning problem in free-ranging condors to the ingestion by condors of spent lead ammunition found in the carcasses and gut piles of animals killed by hunters. Two years ago, the NRA submitted to the Commission a report entitled “Summary of Science for Ammunition as the Source of Lead in Condors” prepared by two scientists eminently knowledgeable about lead ammunition in the environment. In reviewing all of the research conducted on lead poisoning in condors that was submitted as a summary report to the Commission by the California Fish and Game Department, their conclusion was that the scientific data was not conclusive and only presented hypotheses linking lead ammunition to high blood lead levels in condors. There was no proof of that linkage and, therefore, no expectation that banning the use of lead ammunition will reduce health risks to condors.
In spite of this report, the California legislature banned the use of lead ammunition in hunting big game in the areas inhabited by condors and the Commission followed by expanding the areas affected and extending the ban to .22 caliber ammunition. These actions set the stage for extending the ban statewide, because science is not driving the decisions. Politics are driving the decisions; the politics of lead ammunition bans. The proponents of the current ban have had their sights on banning metallic bullet lead throughout the state of California. They can achieve their goal piecemeal, and the proposal before the Commission takes their goal that much further to the borders of the state.
Since the ban went into effect last year, no research has come to light that gives scientific support to the ban, nor has any research surfaced that gives scientific support to extending the ban to small game and upland birds. The only reason this proposal is on the table is because of a lawsuit that was settled between the state and the lead ban proponents that requires the Commission to consider amending the hunting regulations to extend the ban to all game species within the condor’s range. This isn’t about good science; it is about good litigation.
The Commission states that its objective is to follow the path of sound and enlightened resource management. NRA believes that to mean that California’s resource management decisions are supposed to be based on sound science. But, there is no scientific justification to extend the ban to other game species any more than there was justification for the existing ban. If this proposal is adopted, we can only assume that the real objective is to eliminate lead ammunition and that objective is being concealed behind a concern for the condor.
It is the hunter and shooter who provide funding to the state’s Fish and Game Department through license fees, game tags, and excess taxes that fuel wildlife conservation projects for game, non-game, and threatened and endangered species. There is no other group of people in the United States, including those behind the lead ammunition ban, who have provided such an enormous and sustaining contribution to wildlife conservation. They deserve to have decisions made by the Commission and the Department based on scientific data that supports the actions taken, especially when those decisions add restrictions to hunting regulations that impose hardships. In the case of the current lead ban, no such courtesy was accorded the hunter. The ban was put into effect in response to proponents whose interests are motivated not by the health of the California condor, but by what a ban can do to the hunters and shooters by eliminating the most cost effective, balistically superior, and readily available ammunition on the market.
No data has been presented to suggest that the health of condors has been improved since the lead ban went into effect nor is there scientific data to suggest that extending the ban will provide any greater positive results for the condor. Such data cannot be provided because there is no proof that high blood lead levels in condors are associated with their ingestion of spent lead ammunition by hunters.
In conclusion, we strongly urge that the Commission table this ill-conceived proposal.
Sincerely,
Susan Recce
Director
Conservation, Wildlife and Natural Resources
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