Lead Shot Commentary ending

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Lead Shot Commentary ending

Postby crbutler on Mon Nov 30, 2015 9:21 pm

The DNR has a public commentary time ending on the proposal to end the use of lead shot on Minnesota's WMA's. I think that this has been mentioned before here, but in the hopes that more folks can say something...

From the DNR web page:


Input sought on proposed hunting rule changes, including non-toxic shot on WMAs

(Released October 12, 2015)

Small-game hunters and others can give input starting Tuesday, Oct. 13, on proposed rules that include requiring the use of non-toxic shot on wildlife management areas (WMAs) in Minnesota’s farmland zone.
“The non-toxic shot rule would apply to hunters using shotguns with shot, not to hunters using single-projectile ammunition, such as rifles or shotguns with slugs,” said Jason Abraham, furbearer and regulations specialist with the Minnesota Department of Natural Resources. “We’re trying to reduce the amount of lead deposited on public land, especially wetlands.”

The non-toxic shot proposal is one of several proposed rule changes, which also include hunting game on certain refuges, use of non-toxic shot for rails and snipe statewide, and adjustments to small game possession limits.

The non-toxic shot requirement would affect hunters using shotguns to hunt wild turkey, pheasants and other small game species on WMAs in the farmland zone. Hunters currently need to use non-toxic shot for hunting waterfowl. It would not affect private land, state forest and county forest land. The farmland zone includes the far western and southern portion of the state. The forest zone makes up the northeastern part of the state and would not be affected by this proposed rule change.

“Requiring non-toxic shot on farmland zone WMAs will reduce the amount of lead deposited in or near wetlands on public lands. These are places with heavy hunting pressure,” Abraham said. “Also, federal lands already have this requirement, so our proposal makes the regulations simpler for hunters in WMAs, which are often bordered by federal land.”

The proposal would allow steel or other alternatives to lead that are approved by the U.S. Fish and Wildlife Service.

Other proposals
“Many of the rule changes included in this package have been discussed and supported at past public input meetings and are currently in effect as temporary rules,” Abraham said. “Other proposals have not been in effect and we’re encouraging hunters to learn more about the rule proposals and provide input.”
Specifically, provisions being proposed in this rule package include:

Require non-toxic shot on wildlife management areas in the farmland zone, beginning in 2018.
Make minimum archery draw weight requirements for hunting big game and wild turkey consistent with statute by no longer requiring a draw weight of 40 pounds or more.
During the youth deer season, allow youth to harvest a deer of either sex.
Clarify requirements for registering and identifying bear bait stations.
Make the possession limit for migratory waterfowl, coots, gallinules, rails and snipe consistent with federal regulations for migratory game bird species by making the possession limit three times the daily limit instead of two times the limit.
Increase the ruffed and spruce grouse possession limit from 10 to 15.
Increase the sharp-tailed grouse possession limit from six to nine.
Increase the gray partridge possession limit from 10 to 15.
Increase the cottontail rabbit and snowshoe hare possession limit from 20 to 30.
Decrease the jack rabbit possession limit from 20 to three, with not more than one jack rabbit taken per day.
Increase the combined gray and fox squirrel possession limit from 14 to 21.
Modify the prairie chicken season to improve hunting opportunity by making the season nine days instead of five and moving the season to the last Saturday in September.
Modify the opening-day shooting hours for waterfowl hunting by removing the requirement that shooting hours begin at 9 a.m. Instead, shooting hours will be one-half hour before sunrise, to sunset.
Allow open water hunting for migratory waterfowl, coots, gallinules, rails and snipe in limited areas in the state.
Require non-toxic shot when hunting snipe or rails.
Increase the dove season by 10 days for consistency with federal regulations.
Standardize common crow hunting dates by making the dates March1-31; Sept. 1 to Oct. 31, and Dec. 15 to Jan. 15.

More information about specific rules proposed and the rules process is available online on the wildlife rules input page. The DNR will accept written comments about the proposed rule changes for at least 60 days beginning Oct. 13. Comments may be submitted to DNR Wildlife, Box 20 Minnesota Department of Natural Resources, 500 Lafayette Road, St. Paul, MN 55155-4020 or by email at jason.abraham@dnr.state.mn.us.


This is what I sent them. I did address all of their items, but as far as a unified voice, we need to be pretty clear that we don't want more regulations, especially ones that they admit have no impact.

Mr. Abraham:

I am entering the following for the public comment portion of the DNR request regarding the proposed hunting and rule changes.

As someone who has a college degree with wildlife management classwork and having a professional degree in medicine, I am grateful that the DNR makes this opportunity available; unfortunately, I wish that I could be more uniformly positive on the proposed changes. Unfortunately, some of the proposals seem rather poorly thought through, mainly due to a lack of evidence available at this time.

Requiring the use of nontoxic shot while hunting Rails and Snipe: This is a very minimal portion of the hunting that goes on. I would venture to say that most rail and snipe shot are shot as an add on activity to other upland bird hunting. Anything that would add regulation would tend to reduce opportunity to hunters. I don't think the number of shells fired at Snipe and Rails could have any noticeable impact on our environment.

Now for the major concern, Nontoxic shot rules:

This has been a personal gripe of mine for quite some time. The DNR admitted that there is no evidence that this change would make a positive impact with regards to wildlife and that the lead shot from upland game hunters was not s significant issue as far as health and the environment. As a physician, I am pretty well versed in the toxicology of lead. In general, lead is a quite inert metal, unless it is attached in some manner to an organic compound. In general, metallic lead is quite inert even in the body, with people with bullets in them not typically showing any increase in blood lead levels. While there is evidence that birds will increase lead levels and may have toxicity from feeding on lead pellets as grit, the studies that have shown this are much more theoretical than practical. The original Pautuxtent studies done at Milo Farms had very large adjustments made to show significance, requiring a large assumption of birds with lead abnormalities not being found. The use of nontoxic shot on waterfowl was something that was foisted on the hunting community without solid evidence. Even now, the studies are set up in ways that are rather impractical. As an example, the amount of lead used to determine shot concentrations for a study on doves was over that what would be expected in a small field used for organized clay bird shooting (and at which level is economically justifiable to reclaim that shot.) Further, it has been my experience that steel shot (which is the majority of the nontoxic shot used) results in substantially increased numbers of wounded and lost birds, and this is worsened by less experienced shooters. The only issue with lead is that the uneducated community hears lead and thinks of the scares caused by lead paint and the contamination from leaded gasoline (the anti knock compound was an organic lead compound.) Now I hear comments about wanting to end the use of fishing tackle with lead (such as sinkers and jig heads) in addition to hunting shot and bullets. California has gone down this road repeatedly regarding the no lead bullets due to the condor, and they have thus banned the use of almost all .22 rimfires in the state.

As such, it seems that the DNR keeps bringing this issue up, and keeps hoping at some point in time that the hunters will not contest it as vigorously, and they will be able to go to press it through and thus claim we are doing something meaningful for the environment.

While hunters and fishermen are at the forefront of caring about our environment, there are certainly much bigger environmental issues than the miniscule (relatively speaking) amounts of material that sporting use puts in the environment. Aviation gasoline is probably a bigger biologic load than all of the ammunition fired in the US in a similar time frame, yet we are not trying to ban private civil aviation. We need to be reasonable here.

The down side of going to nontoxic alternatives is price. Steel shells cost much more than lead ones of comparable use. One can buy a box of upland use lead shells for around $0.20 a piece. Steel shells are at least twice that, and the good hunting loads are about $1/shell. The other nontoxics are even more than that (more than $2/shell for hevishot or Bismuth- when you can find them.)

The DNR will see gradually decreasing numbers of participants in hunting and sport shooting as the middle class gets priced out of being able to participate. Given that hunting and fishing have been enshrined in the Minnesota State Constitution, we are obligated to avoid that. I feel that until we have good quality published evidence that leaves no doubt that there is a clear threat to our environment by using these traditional materials I would respectfully request that we not place any more restrictions on the sportsmen and sportswomen of Minnesota.
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Re: Lead Shot Commentary ending

Postby CROSBYK2 on Wed Dec 02, 2015 7:50 am

Great letter! Thanks for sending it to them and also for posting it.

I find it amazing how the MN DNR is so adept at coming up with solutions in search of a problem. Perhaps its a money thing, and I believe they have too much of it. This organization in its infinite wisdom collapsed the walleye population in one of our finest fisheries, think Mille Lacs, and no one got fired. That little wisp of smoke is their credibility going up in smoke. :o Why anyone would listen to these stoops is beyond me. I will admit that I'm a big fan of the conservation officer program and believe they need more money and more officers. Another good idea would be to move this part of the DNR to the Department of Justice so the their credibility isn't negatively impacted by the rest of the DNR disaster. My 2 cents.
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