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Tuesday, July 29, 2014

RMEF Joins Fight against Threat to Use of Traditional Ammunition

The Rocky Mountain Elk Foundation is one of 33 national sportsmen’s conservation organizations that sent a letter (see below) to the Department of the Interior in response to a petition from several anti-hunting organizations, including the Humane Society of the United States, seeking to ban the use of traditional ammunition on much of the nation’s public lands.

July 23, 2014

The Honorable Sally Jewell
Secretary of the Interior
1849 C Street, NW
Washington, DC 20240

RE: HSUS Petition to Ban the Use of Lead Ammunition

Dear Secretary Jewell:

The undersigned national sportsmen’s conservation, natural resource professional organizations and association for the hunting and shooting sports industry write to you in regard to a petition filed by the Humane Society of the United States (HSUS) along with 16 other organizations and individuals requesting that the Department of the Interior (DOI) promulgate a rule to ban the use of traditional ammunition made with lead components and require that only alternative ammunition made with metals be permitted for use on lands managed by the National Park Service (NPS) and the U.S. Fish and Wildlife Service (FWS).

Before addressing the merits - or lack thereof - of the petition, it is important to note that the principal petitioner, HSUS, is an avowed anti-hunting organization (as are a number of the co-petitioners), and one of its primary goals is to shut down all hunting. HSUS has said “We are going to use the ballot box and the democratic process to stop all hunting in the United States. We will take it species by species until all hunting is stopped in California. Then we will take it state by state.” HSUS has led numerous state and national initiatives in furtherance of achieving that goal, and this petition is simply another tactic unto that end. The petitioners suggest that hunting is acceptable as long as hunters use alternative ammunition, but the undersigned organizations reject this specious representation and encourage you to do likewise.

The issue at hand is not whether lead, when ingested in a sufficient quantity and metabolized by an animal can be injurious to that particular animal, but, instead, what is the population-based impact to a species at a local or regional level. Indeed, state fish and wildlife agencies have applied that very test in determining if, and when, special regulations regarding traditional ammunition are needed to address population-level impacts and taken management action as appropriate.

One of the seven tenets of the North American Model of Wildlife Conservation is that the best science available will be used as a basis for informed decision making in wildlife management rather than by opinion or conjecture, or as in this case, false inference. The body of scientific literature on the use of traditional ammunition does not support the petitioners' underlying conclusion that the past and continued use of traditional ammunition has resulted in negative wildlife population level effects. The 50-page petition is littered with pseudo-scientific statements that attempt, but fail, to link potential lead toxicity, from any number of possible sources, to federal statutory obligations to protect wildlife. In addition, this false line of reasoning is also true of the petitioners' claim regarding the threat to public health. There has never been a single documented case in the United States of a hunter having elevated blood lead levels, let alone blood lead poisoning, caused by consuming game harvested with traditional ammunition.

The signatories also note that if such a ban was instituted, additional petitions for Bureau of Land Management (BLM) lands and other federal holdings (e.g., National Forests) would likely follow. We also contend that additional bans, regarding traditional ammunition, will be sought for recreational target shooting on a broad suite of federal land holdings, including those noted in this letter. This is a traditional and historic use allowed on millions of acres of public lands. Alternative ammunition is more expensive for hunters - and there are not alternatives available for about half the hunting calibers. But, for target shooters, who consume far more ammunition in pursuit of their sport, the cost would be prohibitively expensive. The cost would effectively close public lands to shooters.

The importance of recreational shooting to the American System of Conservation Funding (see attachment) cannot be overstated. Approximately seventy percent of ammunition sold in the United States is for non-hunting purposes, much of it for target shooting. And traditional ammunition accounts for ninety five percent of all ammunition sold.

In addition, the signatories support the following principles that are relevant to this petition as agreed upon by the Association of Fish and Wildlife Agencies in a resolution adopted September 29, 2010:
  • Future regulation of lead ammunition and lead fishing tackle is best addressed by the individual states, rather than federal agencies.
  • Decisions related to future regulation of lead ammunition and lead fishing tackle should be based on the best available science related to wildlife population health.
  • State agencies should focus regulation efforts where population-level impacts to wildlife are substantiated.
  • State fish and wildlife agencies should lead efforts to develop the best science, and AFWA should provide this information to members for their use in bringing hunters, anglers and various interests together to determine the need for and nature of any needed management approaches to use of lead ammunition and lead fishing tackle.

In conclusion, there are no adverse wildlife population impacts or public health concerns on NPS and FWS lands that require such an unwarranted, national intervention as this petition seeks. It is quite simply an attempt to drive hunters, and subsequently recreational target shooters, off of Federal public lands. It is unnecessary, has no basis in sound science and should be rejected by the Department.


Archery Trade Association
Association of Fish and Wildlife Agencies
Boone and Crockett Club
Bowhunting Preservation Alliance
Catch-A-Dream Foundation
Congressional Sportsmen’s Foundation
Conservation Force
Dallas Safari Club
Delta Waterfowl Foundation
Ducks Unlimited
International Hunter Education Association-USA
Masters of Foxhounds Association
Mule Deer Foundation
National Rifle Association
National Shooting Sports Foundation
National Trappers Association
National Wild Turkey Federation
Pheasants Forever
Pope and Young Club
Public Lands Foundation
Quail Forever
Quality Deer Management Association
Rocky Mountain Elk Foundation
Ruffed Grouse Society
Safari Club International
Theodore Roosevelt Conservation Partnership
Tread Lightly!
U.S. Sportsmen’s Alliance
Whitetails Unlimited
Wild Sheep Foundation
Wildlife Forever
Wildlife Management Institute
Wildlife Mississippi

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