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Lead Ban Chronicles – New Lead-Free Gear Preview

February 8, 2016

Lead Ban ChroncilesA few weeks back, at SHOT, one of the new products I was particularly hot to see was the Iron Rig decoy weights.

I know, “decoy weights?”

Well, the thing about these weights is that they’re lead free.  Not only are they lead free, they’re being advertised as lead free, which means it’s not just an afterthought.

I’ve spent a lot of time writing and talking about the lead issue, but my focus (like many other writers) has been on ammunition.  The thing is, fishing tackle has been an ongoing topic in efforts to remove lead from the environment.  Push aside the politically driven arguments for a moment, and consider that an emphasis on fishing tackle makes total sense, since lead is arguably more ubiquitous in fishing than it is in hunting (and there are far more fishermen than hunters).

Before you break your neck trying to follow my train of thought, I bring up fishing because waterfowl hunters have, for ages, used fishing weights to anchor our decoys.  And these weights are almost always made of lead.  Hence, any regulation that affects the use of lead in fishing tackle will impact waterfowl hunters as well.

How likely is a ban on lead fishing weights in this country?  It’s hard to say, but if I must prognosticate, I’d say a national, general ban is still a long ways off.  However, on an incremental level, I think we’re already seeing it start.  Some states, including California and Washington, are already making moves to prohibit the use of lead (of any kind) in sensitive waterways.  The Federal agencies overseeing wetlands and wildlife are also looking at restrictions on lead in the waterways they manage.  It’s not unreasonable to expect some lead tackle prohibition in National Parks, National Monuments, and possibly National Forests in the relatively near future.

On my only full day at SHOT, I had a chance to have a nice chat with Jena Muasher and Scott Griffith, the marketing team for Big Game International.  One of the first things I asked was what drove the decision to produce a lead-free decoy weight.  The general response was that the company saw the “writing on the wall”, and wanted to get ahead of legislation that would restrict the use of lead weights.  More specifically, they pointed to California regulations that appear to be on track to eliminate the use of lead tackle by 2019 (a contentious issue, of course, but not an issue on which I’m particularly well-informed).

So, why cast iron, decoy weights?

The simple answer is that it was an easy choice.  As Scott explained to me, the goal was to make changes that did not reduce performance.  Cast iron is heavy and relatively easy to cast in the sizes and shapes that are used for decoy anchors (it’s more of a challenge for smaller fishing tackle, which is another issue).  It’s also inexpensive, relative to lead, which actually enables a lower cost to the hunter.

Unfortunately, the weights available for display at the show are simply prototypes, so I wasn’t able to carry a handful home to test out before our season ended this year.  However, Scott and Jena told me the plan is to start getting these to market by summer, and promised to get some out to me to try out.  I’m particularly interested in seeing how these things hold up in the salty environment where I do much of my hunting (NC coastal salt marshes and brackish rivers).  You can bet I’ll be letting you know how it all pans out.

 

 

Lead Ban Chronicles – AZ Lead Ban Lawsuit Back On The Table

January 14, 2016

ILead Ban Chroncilest’s been quite some time since I did one of these.  I hope I remember how.

Actually, the lead ammo issue has been simmering quietly along for a while now.  It’s boiled up occasionally in Minnesota, where the discussion has ebbed and flowed (I love mixing metaphors), but the state is apparently moving steadily toward a ban on lead ammo for all hunting on state wildlife areas.

Interestingly, the topic has also been pretty heated in the U.K., as “environmental” groups have been pushing a strong line of rhetoric targeted at confusing/convincing non-hunters/shooters.  It’s largely based on the same unfounded or over-hyped arguments that we heard here in the U.S., pointing at the “risk” of lead shot poisoning humans and even the groundwater.  Likewise, the counter-arguments focus on the centuries of lead ammo use vs. the absence of related cases of lead poisoning in game consumers.  As they have pointed out, there’s more lead in the typical bottle of beer than there is in a pheasant or grouse killed by lead shot.

Of a little more interest here in the U.S., it looks like an appeals court is going to allow the Center for Biological Diversity (and crony organizations) to go forward with a lawsuit against the US Forest Service in  Arizona.  The suit charges that the Forest Service is failing to protect the endangered California Condor by refusing to ban the use of lead ammo on Forest Service lands.  The suit was denied earlier, because the plaintiffs were unable to show that the use of lead ammo harmed them personally, but the appeals court sees it differently.

This is sort of a big deal because of the amount of hunting land managed by the US Forest Service in Arizona.  Probably most notable is the Kaibab National Forest, which is one of the premier, big game hunting destinations in the U.S.   It may be extraneous to note that the widespread, voluntary use of non-lead ammo in this area by hunters has already resulted in an apparent reduction in lead-poisoning cases for scavengers like the condor and eagles.

It’s also important because if this suit is successful, it opens the doors for similar suits across the condor habitat, including Oregon and Utah.  It may also provide ammunition for lawsuits in other states, although without the banner of an endangered species for leverage, I can’t say how it will play out.

In much older news, President Obama signed the National Defense Authorization Act (NDAA) back in October.  Does this sound like a win for sportsmen?  On some levels, I think so.  Secreted away in the language of this Act is a provision that clarifies, once and for all, that the EPA does not have authority to restrict or control ammunition components (e.g. lead).  That should close the book on the CBD’s efforts to sue the EPA to ban lead bullets.  Of course, this act has nothing in it that limits the powers of other state or federal agencies to regulate ammunition.

Stay tuned.  After the SHOT Show (next week!), I should have a little more news on the lead front…

Lead Ban Chronicles – NSSF Fires Back At CA Lead Ban

April 13, 2015

Lead Ban ChroncilesOnce again, I found myself (albeit briefly) on the horns of a damned old dilemma.  To share this video here or not, that is the question.

The answer is, of course, obvious.  There it is, right down below these words.  I shared it, the same way I’ve shared some video and articles from the other side of the discussion (if you could call it a discussion).  I shared it because it is part of the whole, and if I’ve asked for your opinions on the other posts, it’s only fair to ask for your opinions on this one too.

But let’s be clear.  Sharing this video here does not necessarily mean I am in lockstep with the NSSF or the NRA when it comes to this topic.  Some of you who’ve been around a while know that already, but if you haven’t followed the Hog Blog, I’m telling you now.

I believe that, in the long run, we need to be skeptical of any special interest group’s involvement in such a politically charged issue.  In the same way so many of us want to challenge “sketchy” statistics, or thinly constructed arguments from our opponents, we really need to hold our “allies” equally to account.

So, now that I’ve totally primed you with preconceptions, have an objective look at the video, and let me know what you think.

Lead Ban Chronicles – Research Shows WV Vultures Carrying High Lead Concentrations

April 8, 2015

Lead Ban ChroncilesLet me preface by saying that the article in question doesn’t necessarily present any new information, especially as it relates to hunting with lead (or lead-free) ammunition.  In fact, it clearly states that an additional source of the lead is most likely the coal-fired power plants in the area.  But that’s the part that I find interesting… that the article does bring in additional sources of lead besides hunters.

Beyond that, as you can see in the comments, I found the article to be lacking some information that I thought would have been pertinent, such as whether there was an apparent impact on vulture populations in the area, or even if the vultures studied died from lead toxicity (or related causes).

Here’s the lede, such as it is..

A new study out of West Virginia University finds that lead poisoning in vultures is way more prevalent than expected. Researchers say the source of the lead is ammunition and coal-fired power plant emissions – prompting one researcher to liken vultures to the canaries miners once used to gauge if a coal mine was safe or not.

Give it a read. I’d love to hear your thoughts.

Lead Ban Chronicles – No Lead Ammo On CDFW Lands In 2015

April 2, 2015

Lead Ban ChroncilesThis is a reminder for the California hunters out there.

If you’ve been paying attention to the lead ban regulations, you’ll know that 2015 marks the phase-in of the statewide ban on hunting with lead ammo.  This year’s change will impact hunters using any of the lands managed by the CA Department of Fish and Wildlife (CDFW).

You can read a bit more about this in Ed Zieralski’s article in the San Diego Union Tribune.

Good luck!

Lead Ban Chronicles – Golden Eagles And Lead Video

March 20, 2015

Lead Ban ChroncilesI’ve debated how to present this, and I decided the best thing to do is just put it up here without my input for now.  Some of you who’ve been sort of following my discussions on this topic probably have an idea of what I think, but for the moment, I’m curious about what you think after watching this short video

Doesn’t matter if you agree with it or if you find fault, if you learned something or not, I’m really curious to get some other takes besides my own.  I will say that I had to allay my initial knee jerk reaction and pay attention to what the guy is actually saying.  I think that is the most productive approach.

So view on, and respond if you can spare a moment.

Lead Ban Chronicles – Texas Parks And Wildlife Lead Shot Vs Steel Shot For Doves

December 17, 2014

Lead Ban ChroncilesA couple of weeks back, I posted up the results of the TPW research into the effectiveness of lead shot vs. steel shot for dove hunting.  Some of you have probably heard the arguments that steel doesn’t kill birds as cleanly as lead, and this has been an ongoing rationale for the argument against steel shot requirements.  Unfortunately, the empirical evidence to support or refute this argument has never been available.

Until now…

TPW has completed a study to provide that evidence, and the results were published.  Along with publication, the TPW offered a webinar for interested parties to understand the study and the results (I couldn’t attend due to commitments to my day job).  I’d love to see more of this kind of communication from other organizations involved in the lead ammo discussion… particularly from organizations that are not specifically aligned, based on special interests (in other words, I’m not really interested in presentations from the Center for Biological Diversity, HSUS, or the NRA).

It’s a very long, and not very exciting video, but there’s a lot of really good info here.  If you plan to go out and talk about lead free ammo, either pro or con, I feel like it’s pretty critical that you follow stuff like this to inform your comments.  If you don’t want to watch the whole thing, at the very least, give the TPW study summary document a thorough read.

Here’s the video.

 

Lead Ban Chronicles – Was There Dirty Dealing In CA Lead Ban Legislation?

December 4, 2014

Lead Ban ChroncilesI’ll be honest.

When I received  this notice (video autoplay warning) in my news feeds, I hesitated to share it here.  In fact, I held off, initially, because I really wanted to see this reported in another, more reputable outlet.  I don’t think anyone would argue that the Washington Times doesn’t employ a strong, conservative bias.  Hell, they even manage to tie Obama to the issue in the headline.  But two days after the “story” broke, I still haven’t seen it show up anywhere else.  I’m not necessarily surprised that the piece didn’t make the Evening News, or the NY Times, but even the NSSF, mentioned prominently in the article, hasn’t written anything in the news releases, or even on their blog (as of this morning, there is a link to the Washington Times article.).

So, I don’t blame anyone for reserving a bit of skepticism in regards to the accuracy or the importance of this story.  But after reading it through a couple of times, I can’t help thinking it’s worth putting out here, if for no other reason than discussion.

So here’s the lede:

A pro-hunting group is up in arms after obtaining emails that it says indicate that a federal official withheld critical data on lead blood levels in the California condor until after gun control advocates in the California state legislature used the iconic bird’s plight to help push through a law last year to ban lead ammunition.

The gist of the story is that the US Fish and Wildlife Service biologists had compiled research showing that, despite five years of the lead ammo ban in the CA condor “zone” (2007-2012), the cases of lead toxicity had not declined.  The article goes on to suggest that, while this research was available as early as April of 2013, it was not released until after the legislature passed the bill to the Governor’s desk in September.  It also references an email thread which suggests that the paper was intentionally held back, so as not to influence the decision of the legislature.

Now, on the surface, that actually seems pretty damning.  If the study clearly demonstrated that a lead ammo ban was not helping the condors, then it would certainly have been helpful to some of the legislators in their decisions to pass the bill (AB711) into law.  A decision to withhold it from the legislature until after the debate definitely gives the appearance of an effort to subvert the process (despite the protestations of the USFWS spokesman quoted in the article).  If this is true, it is a bad, bad thing.

But how big of a deal is this, really?  What will be the outcome of this “scathing” expose?  It’s hardly likely to overturn AB711.

Personally, I see a couple of things here.

First, a major part of the rationale for expanding the lead ammo ban statewide was to make the localized (“condor zone”) ban more effective.  This suggests that, at least on some level, legislators and ban proponents recognized that the localized ban wasn’t working, because condors aren’t constrained by arbitrary lines on a map.  By that line of reasoning, the study by the USFWS would likely have only strengthened the resolve to expand the ban.

And the fact that condors were still showing up, regularly, with lead toxicity would not have been news in Sacramento.  While the USFWS report may have been the official, sanctioned document; preliminary studies, independent research, and anecdotal evidence have shown the same results consistently since the original lead ban was implemented.  In CA, condors were not getting any better despite the lead ammo ban.  We already knew that.

The question that arose, or should have arisen, is why wasn’t the ban working in CA, when voluntary lead mitigation measures appeared to be having significant success in Arizona?  What’s different in the implementation of lead mitigation tactics?  What’s different in the environment/habitat?  What’s different in feeding habits and sources?  Those are big questions.  My guess is that the real condor researchers are looking into these very issues, but that has not really been part of the public debate.

I have my own ideas, of course.  I don’t know a lot about the areas of AZ where the condors are living, but what I’ve seen of it suggests that big swaths are comprised of largely uninhabited, often pristine country.  Outside of the short, big game seasons, most hunting in the condor areas is limited to upland birds, and maybe a bit of small game.  Many (but not all, of course) of these hunting areas include controlled access and fairly significant law enforcement activity by both State and Federal agencies.  And, of course, a big swath of condor territory is not accessible to (legal) hunters at all, as it is part of the National Park System.

Overall, this suggests (to me, at least) that lead ammo is probably a significant source of lead in the condor’s environment.  Thus, by reducing the lead used by hunters, it makes complete sense that the exposure for condors (and other raptors/scavengers) would be reduced as well.  The program works… and it didn’t even require a law to do so.

On the other hand, I’ve spent a lot of time hunting and exploring the areas that make up the CA Condor Zone.  To begin with, the area abuts some of the largest, densest population centers in the country… Los Angeles on one end, and the SF Bay Area on the other.  The land in between is distinguished by a mix of old ranches and homesteads, mines, and gas and oil extraction, and agriculture… along with a few areas that are veritable wastelands of ruined land, salted to death by over fertilization and bad agricultural practices.  Hunting is a year-round activity in this area, including approximately three months of deer hunting, upland bird and waterfowl, extensive varmint shooting (ground squirrels, coyotes, etc.), and feral hogs.  Most of the land that is not privately owned, consists of lightly patrolled State and National Forests with multiple, uncontrolled access points.   Besides lead ammo (which I know is still commonly used in the area, let’s be honest), the potential sources of environmental toxins, including lead, are myriad.

In other words, reducing the lead ammo used by hunters in the California environment appears to have nominal impact on the survival of the condors because there are so many other potential sources.  Passing a law won’t change that, and extending that law doesn’t accomplish much either.  But that’s moot.  With some minor adjustments, it’s a done deal in CA anyway.  At this point, the only thing left to do is become actively involved in the implementation discussions.  There are still many open issues, particularly in regards to availability (For example, what are they doing about rimfire ammo?).   CA hunters need to stay active and vocal.  It may seem like beating a dead horse won’t make it get up and run, but you might be able to slide it across the ground a little further away, before it starts to stink.

So, if anything, this story is a cautionary tale.  If the article and its implications are accurate, it means that the challenge ahead in other states will be to hold government sources closely accountable (which we should be doing anyway).  Even if the decision to withhold the report was well-intentioned, it was wrong.  And if it were intentional… well, that needs to be proven and the USFWS personnel responsible need to be held to a whole different level of accountability.

But, then again, I have questions about the article itself that probably aren’t going to get answered.  Where is the full email exchange?  What else did it say about why the paper wasn’t released?  There’s a whole story here that isn’t being told, and without it, I can only put limited stock in what I read in this article.

Anyone out there in the Interwebz know more about this (factually and empirically)?

 

Lead Ban Chronicles – Texas Researchers Find No Difference In Effectiveness of Lead Shot vs. Steel On Doves

December 3, 2014

Lead Ban ChroncilesBack in 2008, the Texas Parks and Wildlife Department (TPWD) started collecting data on the use of lead ammunition and its impacts on doves (mourning dove, whitewing, and Eurasian collared doves).  I wrote about it in 2009, back on my old blog site.  Initially, the research was intended to discover the toxic effects of lead ammunition on the dove populations, but it quickly turned to focus on the effectiveness of lead alternatives (e.g. steel shot) on doves.  Many hunters have complained that steel isn’t as effective, and that it increases the number of wounded birds.

This study took aim at those claims, for obvious reasons.  If steel is proven to be ineffective and to increase wounding risk, then promoting steel would conflict with conservation goals.  On the other hand, if steel were to be proven just as effective as lead, it would disarm a fairly loud argument against the switch.

It took five years, but the results appear to be rolling in.

Dec. 2, 2014

TPWD Releases Dove Lethality Study Findings

AUSTIN – Texas leads the nation in dove hunting with roughly a quarter million hunters bagging 5 million mourning doves each fall. Their success afield should not change with the type of shot used, according to the results of a just-released study examining the lethality of lead versus non-toxic shot for mourning dove.

The field collection phase of the study was conducted in Brown, Coleman and McCulloch counties during the 2008 and 2009 Texas dove hunting seasons. After recording more than 5,000 shots fired by Texas hunters during the two-year project, and then necropsying 1,100 mourning dove, researchers determined no statistical significant difference in harvest efficiencies between the three loads tested, regardless of distance.

Non-toxic shot has been required for hunting waterfowl for more than two decades. Despite studies that have demonstrated the effectiveness of non-toxic shot for waterfowl and other game birds, the results of this study were not a foregone conclusion, at least not in the perceptions of dove hunters. Recent dove hunter surveys indicate that some hunters still believe non-toxic shot to be inferior to lead.

“Our findings address the efficiency of lead and non-toxic shot on mourning dove,” said Corey Mason, a TPWD wildlife biologist and one of the authors of the report. “There continues to be a spirited national discussion on the use of lead and other types of shot and these results help inform one aspect of the conversation.”

This study is the first on the lethality of lead versus non-toxic shot under typical hunting conditions for mourning dove to be published in a scientific journal. The Institute of Renewable Natural Resources at Texas A&M University, Thomas Roster, and Texas Parks and Wildlife authored report will be published in the March 2015 issue of The Wildlife Society Bulletin, a peer-reviewed, scientific publication containing papers related to wildlife management, conservation law enforcement, conservation education, economics, administration, philosophy, ethics, and contemporary resource problems. An advance release of the report is available online at http://www.tpwd.state.tx.us/huntwild/wild/game_management/dove_summary/.

TPWD officials believe the research findings may be useful to Texas hunters as they make decisions on the type of loads they choose for dove hunting.

“We absolutely believe in hunter choice and we also want hunters to be as informed as possible on matters affecting their outdoor pursuits,” said Carter Smith, TPWD Executive Director. “Dove are a shared international resource, and the question about whether or not lead shot should be banned for dove hunting is not something Texas is prepared to make independent of other jurisdictions and based solely on the findings of this study. This research offers an important data point in the larger discussion, but there are many other factors to consider.”

An internationally recognized shotgun ballistics expert, who has authored more than a dozen similar studies involving waterfowl and upland game birds, designed the study. The study examined three, 12-gauge, 2 ¾-inch loads designed and manufactured to mirror loads that are used most often by dove hunters. The different load types included: 1 ? ounce of No. 7 ½ lead shot, 1 ounce of No. 6 steel shot, and 1 ounce of No. 7 steel shot.

The cost of the study was approximately $500,000 and was funded with dedicated Migratory Game Bird and Texas White-winged Dove stamp revenue.

Any thoughts here?

Lead Ban Chronicles – Paper Discusses Alternatives To Banning Lead Ammo

November 18, 2014

Lead Ban ChroncilesI spend a good bit of time (probably too much) reading various articles, columns, and blog posts about lead ammunition.  I spend even more time responding to them, generally in a vain attempt to interject reason, fact, and common sense into the discussion.

It’s an unfortunate reality that, in lieu of actual knowledge or research, far too many journalists and writers have chosen to fall back on single-source information… and for the most part, at least in the mainstream media, that information is propagated either by the Center for Biological Diversity (CBD) or the Humane Society of the United States (HSUS).  As a result, the information is highly biased and driven by extremist agendas.

Of course, there’s plenty coming from the opposite end of the spectrum, such as the NRA (and its shadows) .  An awful lot of that is also riddled with misleading inaccuracies, and it’s also designed to push an agenda.    But for the most part, that information doesn’t get the attention of mainstream editors.  It shows up instead in the hook-n-bullet media, and most of that is Internet based.  It is hard not to notice that most of the major outdoors magazines and hunting television programs have steered well clear of the whole topic, except in specific cases where it makes real news (such as California’s legislation).

But I digress.  Most of the lead ammo articles and columns you see in the mainstream media are heavily influenced by “press releases” and “papers” distributed by the environmental and animal rights extremes.  You need only read a few articles and columns to start to recognize the striking similarities, redundant talking points, and even specific wording.

With that in mind, I also recognize that many of the voices that echo these “information sources” are pretty well-meaning.  I think it reflects poorly on the state of journalism in general right now, but I can’t say that many of the reporters and columnists out there are necessarily “out to get” hunters simply by virtue of swallowing and regurgitating bad information.  (Sure, some certainly are anti-hunters, but I don’t think it’s a majority.)  For that matter, I think that a lot of the people who support a ban on lead ammo aren’t necessarily anti-hunters.  It’s just that they value the objects of their passion (e.g. condors and raptors) more than they value the objects of ours (hunting and fishing).  I also think that a general ignorance about hunting, guns, and ammo, makes these folks more susceptible to the argument that the “dangers” of lead ammo can be easily addressed by simply banning lead outright… or that such a ban really wouldn’t have much of an impact on hunters and shooters.

So when I go out there to fight for truth and justice (but never while wearing my best trousers), I try to educate as well as influence the readers.  I call out the myths and misinformation from all quarters, and make an effort to set it right with objective fact.  Or at least, the facts as I understand them.   Information can evolve, and due to ongoing research, what I currently recognize as “fact” may, indeed, change.  I’m open to that possibility.

One thing that I’ve pushed on, over and over, is that there are many ways to mitigate the potential dangers of lead ammo.  Replacing lead bullets is certainly one very obvious method, but it’s hardly the only way to go.  I’ve described everything from burying or removing gut piles and carcasses, to selecting less frangible bullet types.  For those concerned with human health risks, studies in Minnesota have shown that proper meat care and careful preparation can reduce that risk to almost nil.  Etc.

I’ve also argued that, if protection and conservation of scavenger birds and raptors is the desired outcome, organizations like Audubon, CBD, and HSUS should be working hard to disseminate all of these various solutions instead of running the conversation into a brick wall by focusing narrowly on banning lead ammo.  Unfortunately, even the more scholarly papers on the subject tend to focus only on replacing the projectiles rather than finding other ways to protect wildlife.  Columnists, reporters, and editors… even those with a pro-hunting bent… seldom mention these mitigation strategies.

Imagine, then, the smile on my face when I saw this paper from the Oregon State University.

The review of scientific studies, conducted by biologists from several different institutions and agencies, was published in the July edition of the journal The Condor: Ornithological Applications. A companion perspective article, written by Clinton Epps, an associate professor in the Department of Fisheries and Wildlife at Oregon State University, examines the challenges of transitioning to non-lead ammunition.

In their papers, the researchers do not call for any policy changes, but they outline some of the challenges of reducing the use of lead and explore tactics that have been used to reduce lead exposure.

And…

The review outlines some steps to reduce lead exposure to birds, including redistributing shot in the surface soil by cultivating sediments; raising water levels in wetlands to reduce access by feeding birds; and providing alternative uncontaminated food sources.

“Managers have found a number of ways to reduce the risk of lead exposure to birds while preserving the important role hunting plays in wildlife conservation,” Haig said.

One example cited involved Arizona Game and Fish working with other groups in that state on a voluntary approach to the issue.

“They formed a coalition to educate hunters about the negative effects of lead,” Haig pointed out. “The result was more than 80 percent compliance with voluntary non-lead ammunition use among hunters on the Kaibab Plateau and no birds were found with lead poisoning the following year.”

This is the kind of thing I think we should be seeing, along with factual and practical (not hypothetical) information about the impacts of lead ammo on non-target species.  I would hope more media outlets pick up on this, and let’s turn this conversation into something productive.

In other, related news, Colorado Parks and Wildlife Commission rejected a petition to ban lead ammunition in the Centennial State.  While the obvious, primary reason the petition was rejected was that there were only 53 actual signatures and four letters of support (the 10,000 signatures collected online were not eligible for consideration, as the majority of them were from outside of Colorado), I also think the political ramifications of moving forward with the proposal would have been devastating.  After threatened (and to some extent, actual) boycotts by hunters in response to restrictive firearms legislation in 2012, I think Colorado officials recognize the danger of pissing them off again… especially with an ammo ban that has no valid justification.

This does look like a good opportunity for CO P&W to expand education and outreach about lead ammo.  When provided with the unbiased facts, many hunters will make the personal choice to take action to mitigate potential harm.  That, to me, seems like a positive outcome.

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