A Ban on Lead Ammunition is Unjustified

I oppose a petition filed August 3 by the Center for Biological Diversity (CBD) to ban traditional ammunition containing lead. This unjustified ban would apply to all ammunition including ammunition used by target shooters.

The petition erroneously claims that the use of traditional ammunition poses a danger to wildlife (in particular raptors such as bald eagles, that may feed on entrails or unrecovered game left in the field) and that there is a human health risk from consuming game harvested using traditional ammunition. Also falsely alleged in the petition is that the use of traditional ammunition by hunters is inconsistent with the Toxic Substance Control Act of 1976 -- Congress expressly exempted ammunition from being regulated as a "toxic substance."

There is no scientific evidence that the use of traditional ammunition has an adverse impact on wildlife populations that would require restricting or banning the use of traditional ammunition beyond current limitations, such as the scientifically based restriction on waterfowl hunting.

Recent statistics from the United States Fish and Wildlife Service showing that from 1981 to 2006 the number of breeding pairs of bald eagles in the United States increased 724 percent. And much like the bald eagle, raptor populations throughout the United States are soaring. Clearly, lead which is being returned to the soil by shooters is not adversely affecting these birds.

In fact, metallic lead as used in bullets and shot has not been shown to be toxic since it is not readily absorbed by living organisms. Only certain lead compounds (such as those used in the past in paint) have been shown to be toxic. In virtually all cases, lead which is returned to the soil from whence it came by shooters remains in its non-toxic metallic form since it does not result in the formation of meaningful levels of toxic lead compounds.

A ban on traditional ammunition would have a serious negative impact on wildlife conservation. The federal excise tax that manufacturers pay on the sale of the ammunition (11 percent) is a primary source of wildlife conservation funding. The bald eagle's recovery, considered to be a great conservation success story, was made possible and funded by hunters using traditional ammunition - the very ammunition organizations like the CBD are now demonizing.

In reality, the effort to ban lead ammunition is nothing more than another step in the long-term effort to eliminate the shooting sports altogether. I urge the rejection of any effort to ban traditional ammunition containing lead components. All such efforts are based on hysteria and on the distortion and misapplication of scientific evidence.