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Lead Ban Chronicles – Breaking News – Ventana Wildlife Society Providing Lead-Free Ammo To Central Coast Hunters

March 27, 2012

This just came into my alerts box this morning… wish I’d had a little more notice!

Ventana Wildlife Society is offering 2 boxes of free non-lead ammunition to San Benito and Monterey county residents.

We know that hunters and ranchers have a long history of conserving wildlife. Hunting is an effective wildlife management tool and creates food resources for scavenging species, such as California Condors and Bald Eagles. However, these species are at risk of lead poisoning if they ingest lead bullet fragments in game carcasses and gut piles. By using non-lead ammo, you have an opportunity to protect wildlife and advance the long-standing tradition of wildlife conservation in our community. Act now to get your free non-lead ammunition while funding for this program lasts.

To get your ammo, go to the Ventana Wildlife Society’s web page and fill out the form you’ll find there.

Comments

33 Responses to “Lead Ban Chronicles – Breaking News – Ventana Wildlife Society Providing Lead-Free Ammo To Central Coast Hunters”

  1. J.R. Young on March 27th, 2012 14:05

    Awesome, I just sent them an email expressing my support.

  2. Tony on March 27th, 2012 16:23

    Phillip,
    Thanks again for the heads up.

    Given that CBD et al just filed a petition requesting a TSCA metals risk analysis for not just lead, but copper, tungsten and the alternate projectile materials, Ventana might just get nailed here if EPA gives in to the Risk Assessment request.

    After all, CBD et al’s lead argument amounts to a claim of population level effect of lead on condors, primarily due to their small population. Add to that the potential risk of the alternative materials, based upon previous EPA Metals Guidance, Ventana might just get dragged into an incidental take case.

    Also, it makes one wonder who is footing the bill. AZGFD cut back from 2 boxes per hunter in the AZ Strip mammal hunts to 1 box per hunter, due to costs.

    It will be interesting to see how long Ventana can sustain this without subsidies from outside. At least it’s a “voluntary program”, something that Dr. Cade and Friends have been fighting since 2005. Things might have been different if CBD, P-Fund and the rest had gone with the voluntary approach back in 2006.

    Commissioner Kellogg will likely be delighted.

  3. Joshua on March 27th, 2012 16:45

    Crap! I’m a “Central Coast hunter”, but I’m not a resident of those two counties. I got all excited, too.

    I’m heading down to Deedy’s in three weeks with my cousin and his good friend, after pigs. I’ll let you know how we do.

  4. Phillip on March 27th, 2012 17:18

    JR, good deal! I think that it will be appreciated.

    Tony, regardless of the politics or anything else, this is a case of the VWS putting their money where their mouth is. You want hunters to switch, pay for it. It obviously isn’t permanent, but it could be enough to let the skeptics see that lead-free ammo DOES work, and it works fine… at least as consistently as lead. If more of the organizations against lead would do the same, instead of pushing bad legislation, they’d get a lot more cooperation.

    All the CBD stuff, etc., is going on regardless of what VWS does. In this particular case, I’m happy to focus on the positive.

    Josh, please do let me know how it goes at Deedy’s. I haven’t spoken to her in ages, and have sort of been thinking about making a drive down that way… next time I’m in CA long enough to do so.

  5. Joshua on March 27th, 2012 18:48

    She’s swamped with turkey hunters right now. It makes me wish I knew how to hunt turkeys, so I could offer to guide for her for a free hunt. Alas, turkeys and I seem to be the same strong magnetic pole, because every time I hit the field after them they stay five miles from me. She sounds good, though.

    I’ll definitely let you know how we do.

    I was at Sportsmen’s Warehouse today (crying over their plethora of Chinese-made stuff and lack of American-made goods, like always) and thought about you: they’ve got a “Texas Grand Slam” exhibit on their wall.

  6. Phillip on March 27th, 2012 20:10

    Gotta know, what did they consider the Texas Grand Slam?

  7. Joshua on March 27th, 2012 22:19

    Corsican, mouflan, Texas dall and Hawaiian black rams.

  8. Tony on March 28th, 2012 08:11

    Dear Phillip,

    Re: “…Tony, regardless of the politics or anything else, this is a case of the VWS putting their money where their mouth is. You want hunters to switch, pay for it. It obviously isn’t permanent, but it could be enough to let the skeptics see that lead-free ammo DOES work, and it works fine… at least as consistently as lead. If more of the organizations against lead would do the same, instead of pushing bad legislation, they’d get a lot more cooperation…”.

    1. It would be interesting to see how VWS is funding this “free lunch”. If it truly is their money, that’s money not going to research from an organization that is fairly dependent upon donations, grants, and the ability to sell raptor data. If, on the other hand, the money is coming from a group like the Humane Society, I am not so sure the hunting community in California would agree with you.

    2. The key point of the debate back in late 2006 was the difference between a voluntary plan or a mandatory ban. Politics what is was back then, and that the weakness of the case against lead ammo was not as widely known as it is now, a voluntary plan would likely have been accepted in California before or by the Summer of 2007.

    As a comparative example, in Arizona cooperation to a degree between hunting interests and the Condor Team resulted in the “free ammo” concept for hunters in the Arizona Strip. Arizona has cut back on how many boxes they will give per hunter, but it is my understanding that the program is going to continue for the foreseeable future.

    But “hardcore” Condor Program team members (folks like Dr. Tom Cade, Dr. Noel Snyder, etc…) advocated in 2007 for a mandatory ban and nothing less in California.

    In the end, the Mandatory Ban folks “won” in California with AB 821. Unfortunately for them, the Mandatory Ban is not working from a condor-blood-lead-level standpoint. I cannot help but wonder that this “free lunch” is thus a kind of grudging admission in the least that the Mandatory Ban permanently cost the Condor Program progress and credibility with the hunters and shooters.

    I personally believe that they should have listened to the various groups, from NRA, CRPA and NSSF to even the Institute for Wildlife Studies (where it is my understanding that IWS was being funded by the Feds to specifically promote non-lead alternative ammunition) and agreed to the voluntary plan. That would have been the “deal” that would have benefited everyone the most politically.

    All water under the bridge now, though…..

  9. Phillip on March 28th, 2012 08:31

    Tony, of course I’m familiar with the history and development of the lead ban. I understand the politics at its root. But it is, as you said, “water under the bridge.”

    You can’t undo what was done. However, I do think it’s appropriate and fair to give an occasional pat on the back to an organization when it does something right. Should they have done something like this from the outset? Absolutely. But that’s in the past… it’s time to move forward.

  10. J.R. Young on March 28th, 2012 10:56

    I put my money where my mouth is as well, I called the Executive Director (Kelly) and told him I would like to donate $75 (the rough cost of two boxes of ammo).

    I’m curious if I get a response, I also remembered after the fact that I have a couple boxes of Federal Premium Barnes TSX ammo that I would be willing to donate since I handload now. It’d be cool if they would be willing to take it.

    I am curious as to where the fundamentals of the program are. Mostly because they have every non-lead company represented. This would leave me to believe they have not partnered with any producer, so where do the funds come from. I would think they would want to partner with one in hopes of getting a discount or donation. It would only seem smart for Nosler, Hornady and or Barnes (especially Barnes) to offer a discount or outright donation to the program.

  11. Tony on March 28th, 2012 15:36

    Phillip,
    I guess I am willing to “let bygones be bygones” if Ventana can convince Peregrine Fund, CBD, Project Gutpile, Audubon, American Bird Conservancy, and a host of others to live with voluntary programs instead of mandatory bans.

    But I cannot help but wonder what Drs. Cade, Snyder, Redig, Pokras and others are going to say about “settling” for such voluntary programs as they have in Arizona. From what I have read from these gentlemen, voluntary programs are not acceptable.

  12. Leland on March 28th, 2012 20:20

    I’m unsure how the source of funding seems to be something to worry about. HSUS would not help to fund a program that would actively promote and assist hunters in continuing to hunt. This seems to be an opportunity for organizations like the NRA, NSSF and others to work with an organization to promote hunting in what is the most ethically responsible way possible. Promotion of conservation is at the foundation of hunting in this country and this continues that proud tradition.

    I have a feeling that the folks working at Peregrine Fund would be quite offended at you claiming that they actively promoted the ban in CA. In the numerous discussions I have had with them, they were not in favor of the Ridley-Tree Act and have worked extremely hard in AZ to promote the voluntary effort. The “Condor Team” that worked in AZ with hunting interests and the state is the Peregrine Fund. They may have presented data on the AZ population to the Fish and Game Commission, at the commission’s request; my understanding is that they in no way advocated regulation.

    The continued problems with lead may reflect some of the many variables that are out there on the land. There are private lands, depredation permits, poaching and there always those that just refuse to change. Studies have shown a significant decrease in blood lead levels after the Ridley-Tree act in both golden eagles & turkey vultures (http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0017656). Work is also currently underway to determine the differences between condor blood levels pre- and post-ban. Primary partners conducting that study are UC Davis and the CA DFG. It all really comes down to how well people understand the reasoning for switching to non-lead bullets and whether they choose to.

    Unfortunately, speaking with as many hunters as I do, the idea that the Ridley-Tree Act is being complied with at levels even near 90% is hard to believe. There are many hunters who do follow the law but I constantly hear that many adamantly refuse to switch to non-lead bullets. Some areas see much higher compliance than others, and it is difficult to know what is happening on private lands. Unfortunately, a law is only as good as how well people understand why and there continues to be a disconnect between hunters and biologists. I continue to hope for the best from hunters, as I know how dedicated we are, as a community, towards conservation of not just the species we love to hunt, but in conserving all wildlife for the future.

    Many do not have a significant understanding of the differences between non-lead and lead bullets, resulting in poor accuracy and potentially poor terminal performance. In many cases moving to about a 30% lighter bullets (go from 180 gr lead to 150-165 gr non-lead in .30-06) will help to solve accuracy problems. Adjusting to polymer tipped non-lead bullets such as the Nosler e-tip, Barnes tipped TSX, and Hornady GMX will often solve issues with expansion. Also, point of aim can be adjusted a little deeper into the shoulder so the bullet passes through a bit more muscle. As a rule the non-lead bullets out penetrate lead core bullets. In many cases shifting to a slightly lighter non-lead bullet will not only help with accuracy but will result in terminal performance that closely matches the heavier lead bullet.

    Misinformation on bullet performance and lead toxicity itself has exacerbated the issue. Continued education including shooting demonstrations, as we at the Institute for Wildlife Studies has been continuously conducting since 2007, help to give the best available information in hunter’s hands. We put together http://www.huntingwithnonlead.org for that purpose to give folks a reasonable look at the gathered bullet tests, science and information available. Anyone looking for more information on bullets or possibly hosting a shooting event, particularly in the Bakersfield area can contact me through at brown@iws.org.

    Leland

  13. Leland on March 28th, 2012 20:21

    By the way, I just heard that this opportunity sold out all available stocks in 24 hours.

  14. Kelly Sorenson on March 29th, 2012 14:23

    First, thank you for posting this topic here. I can address some of these questions as I am the executive director of Ventana Wildlife Society, the group who just announced free nonlead ammunition in Monterey and San Benito Counties. As it turned out, there was a tremendous response to the offer and in just two days, we took nearly 500 orders and somewhere around 1,000 boxes are going out from Cabela’s as I write this. The funding we are using to pay for the ammunition has come entirely from private individuals who support safe hunting.

    We are honored to pass it on and only wish we had more. We’re committed to raising additional funding too so check back periodically at http://www.ventanaws.org/ammunition. Our mission is to conserve native wildlife and their habitats and it may be surprising to some that we’re even doing this. However, we understand and respect hunting and ranching and also understand that using nonlead ammunition is taking part in conservation, which is why we’re trying to help in this regard.

    Last, I want to thank J.R for reaching out to me and making a contribution and for making the switch to nonlead years ago! Happy hunting and hopefully next time we do this, we will be able to spread it out more.

  15. Tony on March 29th, 2012 16:00

    To Leland:

    From Dr. Cade’s study in 2007, which was published by the Peregrine Fund and which can be found at-

    http://www.peregrinefund.org/docs/pdf/research-library/2007/2007-Cade-condors-lead.pdf

    “…Although this Arizona program is a noble and commendable attempt to test the efficacy of voluntary actions to reduce lead exposure in condors to a safe level, it now appears that volunteerism alone likely will not suffice. Even so, this on-going program is a step in the right direction and may be an important, even necessary prelude to more effective solutions…” – (Page 2131 of that issue Journal of Wildlife Management; Page 7 of 9 of the PDF copy of that document on the PFund website)

    And-

    “…It is past the time for responsible state and federal agencies to follow the trend in California, and several other states, by exercising their statutory and regulatory authorities to ban the use of ammunition lead, not only for condors but for the welfare of wildlife generally, and as a precaution to protect human health. Although there may be other problems to overcome for an ultimately successful condor recovery– such as reducing the impact of other causes of death, mitigating factors that reduce productivity, and altering aberrant behaviors (Mee and Snyder 2007)– it must be understood that these problems are all secondary to, and in some cases dependent for solution on, reducing to a minimum the exposure of condors to lead poisoning…” (Ibid, Page 2132, or page 8 of 9 of the PDF version of the document published at the PFund site).

    Please note that Dr. Cade is still listed as an Officer of the Peregrine Fund (Founding Chairman as well)-

    Link:
    http://www.peregrinefund.org/directors

    And, of course, Dr. Cade signed the “Statement of Scientific Agreement” of July 2007, which was used extensively at the August 2007 Special Hearing on the Condor held by the California Fish & Game Commission. While that letter relies heavily on Church 2006, it notes that any reduction of lead ammunition use should improve the “…success of reintroduction…” of the California Condor.

    Link:

    http://www.biologicaldiversity.org/swcbd/SPECIES/condor/condor-lead-science.pdf

    Please also note that Mr. Bill Heinrich of the Peregrine Fund was a member of the CACO Lead Exposure Reduction Steering Committee at least as early as May 2003, which demonstrates early Peregrine Fund involvement with lead ammunition restrictions, policies, and movement towards bans of various kinds as an end result of the USFWS/Condor Recovery Program/”condor supporters” campaign throughout the 2000-2010 time frame.

    Interestingly enough, Dr. Cade’s advocacy of going to a total regulatory ban in the 2007 document was before the original agreed timeline noted in the May 2003 report. That timeline in turn was based upon the concept in support of a mandatory regulation should the case on lead ammunition be agreed to by what amounts to the “stakeholders” after a number of test programs and continuing science was accepted and agreed to.

    See the Lead Reduction Steering Committee Report at:

    http://www.biologicaldiversity.org/species/birds/California_condor/pdfs/LERSC-Report.pdf

    I am unaware of any letter of censure, or letter of clarification, from Peregrine Fund that indicates that the organization was in a policy disagreement with Dr. Cade’s position. If anything, records show that Grainger Hunt and William Cornatzer (both of the Peregrine Fund) were likewise involved in producing research dedicated to the proposition of banning lead ammunition in that same time period.

    It is my firm belief that the record shows that Peregrine Fund was involved in advocacy for AB 821, and in efforts to ban lead ammunition since.

    As for copper ammo and it’s variants, if it works for you that is fine. A voluntary program is fine so long as it is not supported by tax dollars, given other more pressing needs of the state. But a general concern within the shooting community that I am a part of is that regulations dealing with toxicity concerns of copper, tungsten, and other “nontoxic materials” are on parallel tracks for reduction and regulatory bans by other agencies having to address these specific concerns. The current process of trying to ban lead ammunition, while failing to simultaneously deal with efforts to restrict or ban copper, is a recipe for a multi-prong ban of all ammunition materials by incremental means.

    It is a situation of “leap before you look”, comparable to the switch to MTBE for fuels after there were demands to lead salts from automotive fuels. Now that MTBE is a significant concern in water sources across the US, I think it behooves the ammunition and science stakeholders to get the science right before finalizing regulations that could abrogate the Second Amendment.

    It is this possibility, intended or unintended, and for goals altruistic or malicious, that I oppose mandatory bans on ammunition materials. That is not limited to lead, but to bans on any of the other materials as well.

  16. Leland on March 30th, 2012 16:41

    Tony,

    Despite the fact that Dr. Cade used a Peregrine Fund address, that paper is a personal opinion and the opinions stated in that paper are his and his alone. The article is on the Peregrine Fund website despite his personal comments on how lead ammunition in the environment should be reduced, it has a large amount of very important data on lead exposure in the condor population. The organization has been committed to developing a comprehensive set of data to make scientifically sound decisions, in particular, consistently advocating for the voluntary use of non-lead ammunition in AZ. Actions taken by the organization give evidence their constant support of voluntary adoption of non-lead ammunition and far outweigh the opinion of a single individual. You can read the official Peregrine Fund position statement on lead ammunition here: http://www.peregrinefund.org/docs/pdf/commentaries/2007-position-lead-ammunition.pdf
    Most important: “The Peregrine Fund will continue its efforts to establish a condor population in Arizona and will work collaboratively with agencies, hunters, and other conservationists to insure that the condor becomes self-sustaining. We trust in the long-standing tradition of hunters to take a pro-active role in wildlife conservation and management, and we recognize the beneficial role they already have in helping condors thrive in the wild. We invite other hunters and hunting organizations to join with us in providing factual information to their hunting constituency that best serves the interest of hunters and the wildlife they help conserve and manage.”

    As for the Statement of Scientific Evidence, that is in fact just that. It chronicles the evidence that lead ammunition is in fact a cause of lead exposure for CA Condors. There is no recommendation in that document to ban lead ammunition. It simply recommends that a reduction in lead ammunition would increase the success of the condor recovery.

    When Bill Heinrich attending the Lead Reduction Steering Committee, you will note that it was also attended by Susan Lamson of the NRA, Richard Patterson of the NSSF and Suzenah Seymore of Safari Club International. I recommend everyone fully read that committee meeting report before deciding that it was as an early attempt for, as you say, “lead ammunition restrictions, policies, and movement towards bans of various kinds…”

    The studies conducted by Hunt and Cornatzer, cannot be viewed as “research dedicated to the proposition of banning lead ammunition.” These were tests of hypothesis to gather information. The data allows for decision making based on the best science available. The fact that they found high levels of fragmentation from lead bullets does not make the studies pro- or anti-lead ban.

    You are entitled to your opinion on the Peregrine Fund, but I disagree and believe that the evidence shows a dedicated effort by the Peregrine Fund to promote voluntary use of non-lead ammunition.

    Toxicity of copper has been tested in several species (kestrels and turkey vultures) and to my knowledge has shown no ill effects. Sorry no links. I’ll try to find them, but you should be able to get the papers from these:

    Risebrough et al. 2001 Absence of demonstrable toxicity to turkey vultures, Cathartes aura, of copper and tungsten-tin-bismuth-composite pellets.

    Franson et al. 2011 Copper Pellets Simulating Oral Exposure to Copper Ammunition: Absence of Toxicity in American Kestrels (Falco sparverius)

    If you have some information on attempts to regulate copper and other non-lead ammunition I would love to see it. I am not aware of any attempts.

  17. Phillip on March 30th, 2012 17:19

    I’ve been sitting back to let Leland and Tony chat here. The conversation is sort of beyond the initial topic, but that’s the nature of a conversation isn’t it? I believe both parties are pretty well-informed, and the discussion so far is educational… particularly for anyone who hasn’t been involved in this entire issue. Pay attention boys and girls, and if you’re not careful, you just might learn something.

    One particular note that I do want to interject, and it may be entirely moot… is that notably absent from the CBD petition to the EPA to ban lead ammo (the revived effort) is The Peregrine Fund.

    The only other thing I want to add, and I’d be remiss if I didn’t, is a thank-you to Kelly Sorenson for popping in and speaking up on behalf of the Ventana Wildlife Society (not to be confused with the Ventana Wilderness Association). Nothing like hearing it from the horse’s mouth (and saved me sending some emails).

    As you were…

  18. Tony on March 31st, 2012 02:39

    Dear Leland,
    Again, I wish to point out that not only does Dr. Cade note a Peregrine Fund address in his 2007 study, but Peregrine Fund itself published that same study.

    What is more, the lead position statement you cite is a) specific to the Arizona Condor 10 j) project; and b) notes the following:

    “…Given the extensive evidence that lead exposure from spent ammunition is harmful to wildlife it now appears obvious that responsible society will end the use of lead for hunting throughout much of the world…”.

    Personally, I believe this statement to be one of advocacy, since most of the raw data needed to evaluate the science that Peregrine Fund is citing has not been made readily available to this day to the public for review. In fact, I have a strong reason to believe that Peregrine Fund has declined to respond to a Public Records Request for data, despite that Federal Funding has been provided to cover some of the costs of the Peregrine Fund effort.

    In fact, evidence of deletion of critical data has been submitted to the public record regarding Church 2006, and I have strong reason to believe that at least one other key study from 2009 likewise involves the omission of publication of important isotopic compositional analysis data. Add to that the revelations related to Condor # 132 that were revealed in the NRA presentation in 2009, and I believe people have a right to be skeptical as to the various claims made in a number of cited studies related to lead ammunition and condors.

    Previous attempts to achieve a lead ammunition ban in Arizona legislatively and administratively, related to condor reintroduction, have been halted by the normal political processes involving the public. These attempts to ban lead ammunition in Arizona were made despite there being a condition applicable to the 10 j) program in Arizona and Utah that if the management of the experimental population of condors were to result in an adverse change in human activities as proposed in 1996, including hunting, the 10 j) flock would have to be recovered from the field and the reintroduction process in those states be re-applied for.

    In essence, the voluntary ban is the limit of what the Peregrine Fund and the Condor Recovery Program could achieve in Arizona and Utah without initiating a complete re-start of the condor reintroduction process in the 10 j) zone. I believe it is that reason why Peregrine Fund advocates for the voluntary program in Arizona. But I firmly believe that their preference would be for a mandatory regulatory ban instead, given the statements of some of the Peregrine Fund personnel involved.

    As for the Position Statement, it was released during the debate towards a mandatory ban in California that was ongoing in 2007. The California Fish & Game Commission was being sued by CBD and other plaintiffs to enact regulations banning lead ammunition statewide. At the same time, a parallel effort was ongoing in Assemblyman Nava’s carrying of AB 821 in the Legislature. In July 2007, there was no campaign in Arizona to ban lead ammunition. (That came later, in 2008 if memory serves.). Therefore I believe that it was released specifically in direct relation towards the lead ban campaign in California.

    It is the Lead Reduction Steering Committee document that has a direct impact on the public discussion related as to whether there will be stakeholder acceptance of the claims of lead ban proponents. The document was promulgated on the representation to NRA, NSSF and other stakeholders to the effect that if the science demonstrated lead ammunition as being the threat to condors as being claimed, and if voluntary programs were tried first only to “fail”, only then would mandatory regulatory options be considered. NRA’s withdrawal in late 2004 was a result of the move towards a litigation track by various parties who were not satisfied in complying with the agreement to try voluntary measures first. And surely the agreement was not made on the basis that critical data was being withheld from the public. If anything, the failure of certain parties to forward critical condor data to the Department of Fish & Game, the Fish & Game Commission, the stakeholders and the public might be considered by some as a kind of “breach” of the agreement itself.

    The copper issue is interesting because copper itself is a metal of concern under a number of marine and riparian conditions and locations. Furthermore, discharge of copper into the environment is being reduced, or even being prohibited, for a number of consumer and industrial uses through new regulation. State Senator Christine Kehoe shepherded SB 346 into law in September of 2010. SB 346 reduces copper content in brake pads by over 90%, after a phase-out period for current inventory. Similar legislation was passed in Washington State earlier in 2010. In 2011, Senator Kehoe introduced legislation to ban copper in hull paint. Currently, SB 623 has passed out of the State Senate is is now in the California Assembly.

    Information related to copper toxicity at the Mugu Lagoon cleanup was presented to the CA Fish & Game Commission in June 2009. Other environmental toxicologists can confirm that copper is a metal of concern in such waters as the Columbia River and in the waters around Portland, Oregon. Since Oregon is under active investigation for future condor releases, this is an issue that requires monitoring until understood more fully.

    I also have strong reason to believe that a number of condor necropsies note elevated copper levels as primary reasons related to those condor’s mortality.

    In addition, an email from Chris Parish to Kathy Sullivan, dated in January 2007, was submitted to the public record in 2009. That email involves discussion of copper toxicity specific to the Barnes Varmint Grenade, and that Grainger Hunt was discussing that potential with Barnes personnel.

    Those particular concerns were not made known to the public at the time of the AB 821 debate. In fact, it took a Public Records Act Request to the Arizona Department of Game and Fish to obtain that particular document.

    Tungsten toxicity is a newer topic, though Guandalini et al 2011 seems to indicate a strong link between tungsten exposure and kidney damage in mice. Other work seems to result in a strong hypothesis that wounding with certain tungsten alloys may lead to certain forms of virulent cancer. Admittedly that line of investigation is in it’s infancy. But given the controversies over wounding potential of waterfowl when using the alternative materials, and the nature of the Migratory Bird Treaty Act, the tungsten issue is only going to become more complicated over time unless changes to various environmental laws are made at the Federal and State levels.

    The Franson-kestrel study you cite is one I am not aware of, but then that’s what online access is for. I will go and get it to see the methodology and conclusions.

    Obviously the debate will not go away any time soon. The lack of effectiveness of the mandatory ban in reducing condor blood lead levels will be a major point of debate in any future public hearings. Debates over compliance by hunters, whether it’s the Department’s initial report that compliance is high, or allegations by others that compliance is not, will likely also be part of the debate. I have heard enough complaining from hunters that unlike yourself, I believe compliance in the Condor zone is high. Time and objective evidence will tell.

  19. kathy on April 2nd, 2012 13:55

    This is Kathy Sullivan from AZ Game and Fish – sorry for the late response, I was staffing a non-lead ammo shooting booth at a sportsman’s expo this weekend. I have coordinated the voluntary free non-lead ammo program in AZ since 2005. I usually avoid blogs, but since my name was mentioned, and as previously stated, all parties seem well-educated on this issue, I feel the need to clarify some information.

    First, I want to thank Leland for helping to shed some light on the intracies of this issue. I concur with everything he has stated. Leland and his predecessor, Jake have done some great work in CA. Also, kudos to Ventana, for this good faith effort – I was happy to give them some advice on logisitcs 🙂

    Second, I would like to comment on The Peregrine Fund’s role in our lead reduction program. Since I work directly with their condor program director – Chris Parish, I can assure you that I’m a credible source for this information. Chris is an avid hunter and extremely passionate about our voluntary lead reduction program in AZ. He has worked side-by-side with AZ Game and Fish Dept. since the begining and has NEVER advocated a lead ammunition ban. To the contrary, Chris has gone out of his way to assist me with our voluntary program. He is an extremely valuable resource, and AZ Game and Fish is fortunate to have him on our side. In addition to Chris, the Peregrine Fund staff in Boise has also supported our voluntary lead reduction program. They have been good partners in this effort.

    Tony, I am familiar with the e-mail you refered to about the copper varmint bullets. Chris and I were simply refering to the fact that non-lead varmint bullets are
    frangible, therefore condors would ingest the copper (and now in some cases, tin) powder that they are composed of. As wildlife biologists, of course we wondered about the potential negative effects of this. To our knowledge, we have not observed a surge in copper toxicity, however. Although a couple necropsy reports have indicated high copper levels (most likely from ingesting part of the copper jacket from lead-core bullets), copper toxicity has never been documented as a source of mortality in condors in AZ and is not an issue we are currently concerned about.

    I hope this helped to clarify some of the information. I encourage discussions such as these, where the parties blogging are actually educated on the issue. Don’t hesitate to contact me anytime if you want first hand information about our lead reduction program in Arizona: ksullivan@azgfd.gov

  20. Phillip on April 3rd, 2012 07:34

    Thanks for popping in, Kathy. I’ve actually corresponded with you a bit a year or so ago, and I appreciate your taking the time to comment here again.

    I wish more people were listening to this conversation, as I think it covers some pretty important ground.

  21. Neil H on April 3rd, 2012 08:54

    Listening in, just more interested in listening than commenting. I really appreciate hearing from those folks who have been more directly involved in this issue.

    Like many, I am opposed to any further generalized ban, though I currently shoot all copper for big game. Nothing said here has changed either of those positions. Thanks Leland for the tips on achieving better terminal performance with non-lead, since I do have some concerns about expansion based on the very limited experience I have with them.

    Thanks to the Ventana Wildlife Association for this program. Perhaps they would be interesting in extending it to those from other countiies who draw area specific special hunts such as G21?

  22. Tony on April 3rd, 2012 12:55

    Dear Ms. Sullivan,
    Thank you for clarifying your position on the mandatory ban issue. Given some of the emails that I have seen, subsequent to PRAR’s sent to Mr. Fabritz at AZGFD, your dedication to converting hunters to the use of copper ammunition had caused me to believe otherwise.

    The copper, as well as zinc, issue with condors is interesting. The dispute as to whether Fry 2003 accounts for all sources of bioavailable metals, especially lead, was one that I tried to speak to Dr. Fry about back in August 2007 at the Special Hearing at the California Fish & Game Commission in Sacramento. He has his position though, despite the various indications of lead and other metals exposure from non-ammunition sources.

    For example, sources of copper and zinc to condors and other scavengers can be found in microtrash (pennies at Mather Point, for example) in more credible scenarios than that with the ingestion of Nosler’s (gilding metals) or Barne’s fodder (copper with 500 ppm lead, more or less).

    Perhaps though you can answer a puzzling question- When will Mr. Chesley publish his isotope data outside of a select set of conferences? I was hoping that a peer reviewed study would have resulted by now, given that the assignment of the “Heritage” funds was in 2004 and 2005. I have seen the emails between yourself and him discussing the nature and timing of the data release that would go with that study. Any hints on a “premiere”?

    Respectfully,

    Anthony Canales

  23. Chris Parish on April 4th, 2012 08:43

    Howdy, Chris Parish here….. I figured since I am being quoted, I might add in a comment. First – to Leland and Kathy, Thanks for the nod. I surely appreciate it.

    I have hunted all of my life, and will continue to do so as long as I am physically able. I have worked on the Condor Program with both the Arizona Game and Fish (4 years), and more recently I’ve directed the Condor Program in Arizona and Utah for The Peregrine Fund since the year 2000, but then again, you read my emails, so you likely believe you know enough about me. What surprises me, is that despite the misinterpretation of one email in particular, is that you don’t comment on any others where it is obvious that The Peregrine Fund, where the rubber meets the road in the Arizona program, hasn’t ever supported or otherwise pushed for a ban. I am sure that I won’t be able to convince you otherwise, but that is not my intention. My intention is to give readers of this blog (those who don’t read my emails) an opportunity to hear from me, someone working to reduce lead by VOLUNTARY means by practicing what I preach and spreading the word of our findings and our effort over the past 15 years.

    Ask anyone in the Condor Program if we have ever advocated for a ban. Yes, you are right in pointing out our founders opinion on the matter, but that doesn’t translate into The Peregrine Fund’s opinion. For a clear statement on our opinion on lead, I direct your readers to our position on lead ammunition:

    http://www.peregrinefund.org/docs/pdf/commentaries/2007-position-lead-ammunition.pdf

    Our actions on the ground should be solid proof of this, but as you say, folks have their positions.

    A few clarifications:
    My email to Kathy Sullivan, and the other inquiries with Barnes were because prior to that point the readily available copper ammo was solid (thus, not fragmenting in my tests). The old fail-safe was a great bullet in that regard, even though it still contained lead behind layer of steel. It didn’t fragment. If I can remember back that far, I said, ” I just wonder about the toxicity of the new frangible non-lead bullets by Barnes. My worries were, and still are, that if a critter was thought to have died of copper toxicity (due to its now smaller and more numerous pieces of the bullet) in relation to eating an animal shot with non-lead, the environmental jackwads would go after all ammunition. Sound familiar? Yeah, that was my concern. I was not trying to come up with another angle to shoot down another type of non-lead ammo as a means of gun or ammunition control.

    I now even go farther to clarify points stated in my emails to make sure that there isn’t any potential misunderstanding of my meaning. I sometimes even address the potential FOYA lawyers in the body of my emails complete with keywords, so that in the future, whomever has to wade through them, they can make sure and read the whole email, not just the part that fits their search image. I would hope that this will surprise you and you’ll likely not believe it, but just ask anyone in the condor program if, as you state, The Peregrine Fund is behind the lead ban.

    Ask the Arizona Game and Fish
    Ask Ventana. Ask them who first presented the voluntary solution?
    Ask anyone I have ever talked with, or given a presentation to.
    Ask The Sierra Club.
    Ask Defenders of Wildlife
    And, especially ask CBD. They hate us more than you do.

    Now, I ask readers to think for a moment and ask themselves a question. How can both sides of such a highly political argument be so upset with the people actually doing the work where the rubber meets the road? I constantly argue with both sides. You want to know why? It’s because both side are so far out on the extremes that nobody will represent what is really happening on the ground. Furthermore, the extremes don’t represent the average hunter, and that my friend, we should all be ashamed of. I’ll go anywhere any time to present our findings and encourage the use of non-lead? I, representing The Peregrine Fund’s Condor Program, have presented to thousands of hunters. The response is overwhelmingly positive. They comment, “ if I would have known that this was true, I would have switched a long time ago. I just thought that the whole thing was fabricated.” Most are very happy to consider changing their habits even though it sometimes costs more money. Now, how can that be? Am I that much of a smooth talker to pull the wool over their eyes, or do the facts speak for themselves. Hunters want to put the animal down that exists in the sights, not the non-target scavengers who consume the offal left in the field. An X-ray speaks a thousand words. Furthermore, when I ask hunters if, knowing what they know about lead, they would knowingly eat it. There have been three that said yes, and only one person said they would knowingly feed lead to their children or grandchildren. It’s a free world, knock yourself out.. That’s out of thousands of folks ive talked to along. I know, I know, some folks state that there is not “credible” scientific evidence that lead from “traditional” ammunition is harmful to those who consume game meat. Fine, eat it, it’s your choice………choice…… Recognizing that it is a hunters choice, we simply ask them to consider using non-lead to help prevent lead poisoning in the critters that eat the gut-piles and remains left in the field.

    Did you know that the NRA supported our reasonable approach to dealing with the lead issue in Arizona before the threats of litigation began in California? One of their board members stated it on the record at a commission meeting in Phoenix. Ask them if we have ever threatened them with lawsuits? Read their emails. They encouraged us to go home, build up local support for our voluntary lead reduction program, and go from there. We did just that. We presented our findings to AZGFD, and together we have come this far…..90% participation last year and over 80% for the past five years! I say to any who advocate for a lead ban, “90% voluntary participation because we investigated, shared, and asked hunters in northern Arizona for their support; compare that to any data on compliance to any law!”

    REALLY Tony, ASK ANYONE INVOLVED IN THE CONDOR PROGRAM IF WE HAVE EVER BEEN AN ADVOCATE FOR A LEAD BAN? I would suggest names, but there’s no need. Call anyone I have ever spoken or worked with…… In addition I would ask why you assume that all of those who do support a ban are really after your right to hunt. Don’t get me wrong, I know there are a lot of those types out there.

    I presented to the CAL F&G commission on two separate occasions prior to the ban because I felt that if I didn’t represent data that I was a part of collecting, the activists would do it for us and misrepresent our findings to fit their need to push (threaten) a lead ban in California. I cautioned the commission from not putting the cart before the horse in San Diego and I continue to advocate, YES, advocate for VOLUNTARY actions to solve this problem. This is supported by our ACTIONS in Arizona and Utah. The key to successfully reducing lead in the field is sharing this information with hunters and asking for their support, ban or no ban! I’ve stated time and time again to those who push for a ban, “what would you do if the ban didn’t reduce lead exposure and lead related deaths to a sustainable level?” You’d then begin doing your work to educate the hunters and try and earn their support after they’ve been offended….. That is exactly what is happening in California. I applaud Leland’s efforts, Ventana’s efforts in having the backbone to continue to go to hunters even after the ban to ask for their support. You’ll find that the people behind the ban were not the ones doing the work on the ground actually talking to and working with hunters. Many who have advocated for a ban could care less about your and my ability to hunt. I believe we have shown the voluntary effort to be effective in Arizona and we are now working with Utah to incorporate a similar program. Is the problem solved? NO, nor has it been solved by the ban in California. We have a long way to go. The key is education. I’m sure that the other side will now pound on me for making this statement, but I believe what I believe.

    Assuming that because our founder published a paper denouncing lead and calling for its removal, that we at The Peregrine Fund, are behind the lead-ban — band wagon is just wrong.

    You have targeted fellow hunters Tony. There are true threats out there, but your energy would be better utilized in targeting them. We didn’t sign either petition to the EPA, nor were we on the list for California’s condor protection bill! Thank you Phillip for noticing.

    Before this goes too long and gets drawn out, ooops, too late, I suspect a personal conversation might be best. I come over to California frequently to visit family and quite enjoy chasing hogs……let’s get together and go hunting. Or, I’ll offer a trip to Lake Powell for some fishing ; stripers, LM and SM bass are just starting to turn on. I’d bet Leland and Kathy might even join us. I could use a little time on the water after all of this. If you care to take me up on this, shoot me an email with your contact information and give me the opportunity to share with you what we have done, and compare it to what you have heard and read.

    I won’t banter back and forth on this blog spot, but had to at least attempt to offer some clarity on what I, in the last 12 years of representing The Peregrine Fund and hunters, have been trying to accomplish.

    Despite my love for guns and ammo, I don’t want yours or anyone else’s, nor do I wish to have your rights to keep and bear arms be limited. I only ask that you consider using non-lead for hunting or hauling out lead-tainted remains; both options, in my opinion, represent the potential of the true conservation ethic of hunters.

    Best,

    Chris

  24. TonyC on April 4th, 2012 12:03

    Dear Mr. Parish,
    It is good to hear from you as well, as it makes the debate more interesting to say the least.

    Your comment in the January 2007 email as to “…copper is toxic…” was in the context of the Barnes Varmint Grenade, as I had initially stated. The email is now a public record submitted to the California Fish & Game Commission, so I can get a copy for internet posting if you like. Believe me, I would have given up something personally valuable to have had a copy of it in August 2007, rather than just in the summer of 2009.

    While shooters and varminters know that a Varmint Grenade is a frangible, so that the core will come apart upon impact, it’s also clear that the jacket will fragment as well. As such, copper from both the core powder and jacket fragments will be deposited in the environment both at shooting ranges and when folks go varmint hunting. This is what was discovered at Fort Edwards, and documented in the US Army Corps of Engineers delineation study published in 2007 (TR07-5), among other documents.

    Since condors are being fed rats and rabbits in the captive part of the program, they are being conditioned to feed on carrion that does not otherwise fit the historical “megafauna”/large ungulate description of food sources for condors. Thus condors in both California and in the 10 j) Zone are potentially being exposed to copper particles and jacket fragments, and with Peregrine Fund’s/Condor Program’s apparent blessing, for those rodents shot with the Varmint Grenade and other copper-based frangibles.

    Also, since that a large portion of the anti-lead ammunition argument is devolving to a zero-tolerance argument related to claims of lead “micro-particles” not easily seen in xrays, I cannot help but wonder why Peregrine Fund would advocate for a material that can compound the false-positives problem without further study (Copper and Tungsten Dosing studies, for example).

    Perhaps then you could answer the question as to what happened to the copper dosing studies for copper particles? At least those that Mr. Petterson recommended in March 2007, which appear to not have not been done and published yet? Is the Franson 2011 citation from Mr. Leland the only one? ( I will be looking at that one shortly, especially any discussion of sublethal effects.).

    Given the large number of missing/non-recovered/not able to determine-mortality-cause condors that are reported to exist by the program participants, the certainty that no other metals from all other environmental sources, and all other bioavailable forms, is not a problem nor contributory to incidental take is not supportable in my mind. Dr. Mee’s work on microtrash alone could support that position, though there is newer reporting on other non-ammunition sources of toxic harm to condors.

    Personally, I would not mind using a Varmint Grenade if I was helping a rancher friend control ground squirrels and other rodents tearing up a facility. (I have nothing against Barnes, though I am a Sierra customer when I want to bullet to fly straight and true.). Technically that is no different a management goal than what National Park Service does at Pinnacles NM, given the damage that squirrels reportedly do to a number of facilities out there. It is my understanding that their live-trap approach is not as successful as needed. It is also my understanding that neighboring rancher’s don’t want to receive live trapped squirrels on their properties in any way, shape or form (Apparently they have enough of their own to worry about….). Other than convening large hordes of falconers frequently, traditional control methods seem warranted.

    But I have yet to see any open admission to the public from anyone in the Condor Team, until this particular thread here at Phillip’s blog, as to the potential problems with the alternative materials. In an interesting way, I personally believe that you are conceding to a degree that point with your comments.

    But with the parallel move by other environmental activist groups and politicians, some examples of which I have cited in posts above, one would have to have their head buried in sand to not know that copper and the so-called “nontoxic” materials are being targeted for additional regulation and eventual permanent restriction.

    I also believe that we have showed how flawed the science on lead ammunition being the sole culprit, or even the primary culprit, is. We are aware of the infrequency of “lead positive” xray films. We are also aware of the false positives problem that Peregrine Fund and the Condor Recovery Program have been having in distinguishing lead particles and fragments from those that are non-lead.

    Add to that what I might personally call “massaging” of the material in certain Peregrine Fund studies on the issue, and that the May 2008 Conference produced a large number of “studies” that are essentially abstracts only, it should be no wonder to anyone that there will be “push back” over Peregrine Fund’s role in the ammunition debate.

    Perhaps you yourself are solely dedicated to a voluntary program funded by taxpayer dollars. One could establish your authenticity on the issue by the personal meeting you describe. I am not against such a meeting, for one goes to where the information is.

    Furthermore, subsidization for the purposes of a government policy is an old concept. If the public wants to pay the costs, far be it from me to step in Peregrine Fund’s or the ammo maker’s rice bowl. As such, the $ 90 k or so per year that AZGFD roughly spends on copper ammo alone is relative “chicken feed”.

    That is, except when the “voluntary ban” is a set up for a progressive, incremental and total ammunition ban. That is when counter- activism is warranted.

    I am sure you are well aware of Dr. Cade’s own activism on the issue. I find it hard to believe that he is without policy influence at Peregrine Fund. The letters I have seen from him to the Condor Team are pretty clear on the subject. When viewed in the context of what was available scientifically at the time of their writing, my belief is that there is as much there in the form of advocacy as anything CBD or Project Gutpile have done since 2005. Likewise with Dr. Cornatzer and certain others.

    But if Peregrine Fund was only for a voluntary program, though, and not a mandatory ban as advocated by CBD, Dr. Snyder, and others, why did not Peregrine Fund withdraw from the Lead Reduction Steering Committee like NRA and Safari Club did in 2004? Peregrine Fund could have remained a Program Partner without participation in that particular steering committee. Given that NRA was heavily involved in the Minnesota Raptor Center-sponsored conference and paper in 2003, one could venture that it took a lot of perfidy to chase NRA out of the Condor Program.

    Also, if memory serves, there was no Peregrine Fund amicus brief on the CBD v BLM case over the Arizona Strip case? (The one that Judge Rosenblatt ruled on last year. Admittedly, it’s my understanding that Peregrine Fund did offer the Department of Interior assistance towards the “interpretation” of any Peregrine Fund documents that CBD had obtained by discovery, PRAR, or by FOIA should the case have proceeded to trial.) .

    In other words, there are multiple ways to “sell” a lead ban as a policy initiative. The CBD et al way is coercive litigation and lobbying, a la AB 821 and TSCA I and II. Another way that I am sure you are familiar with is to hire polling and public image firms and “tweak” a message with enough one-tailed “conclusions” and factoids to obtain an agenda goal. When one sees records of a polling company involved with the various program efforts whose billing nearly matches the annual expenditure for one year’s worth of subsidized ammunition in Arizona, one wonders as to what is really going on behind the scenes. To me personally, these approaches are potentially two sides of the same coin.

    Would you confirm to me then that Peregrine Fund, and the Condor Program in general, does not coordinate with public relation firms to help “sell the message” that lead ammunition should not be used, or that the science against lead ammunition as the primary source is “solid”? And likewise “sell the message” that copper and tungsten and bismuth are “nontoxic”? Incidental take is a strict standard, perhaps as strict as the liability standard under the Migratory Bird Treaty Act. Even under the revised “review” by Risebrough et al 2012, it’s known to the team that copper is an incidental take threat to condors.

    Perhaps what I really hope is for hunters and shooters to finally realize that if the various environmental groups, as well as certain recovery programs, keep going the way they are going, only hard-to-get changes in a variety of environmental laws and the Endangered Species Act itself will save the Second Amendment and firearms hunting itself for future generations. USFWS does not have the only “say” in determining what is and what is not suitable under environmental regulation (Hence the attempt by CBD to involve the EPA). I would rather do what I am doing now, than sit by and be boiled slowly like the proverbial frog. Only concerted efforts will save all ammunition (copper, lead, tungsten, steel and the rest) from incremental regulatory bans, in my personal opinion.

    Respectfully,

    Anthony Canales

  25. Phillip on April 4th, 2012 18:45

    Well, once again a conversation here has gone to unexpected places… this time with the participation of folks like Chris and Kathy. I can’t tell you how much I apprecaite hearing from the folks who are directly involved in this issue. It means a heck of a lot more than reading my interpretations and pontifications, that’s for sure!

    Chris and Tony, I hope you guys do sit down and have that conversation. I’d love to be a fly on that wall, and I bet a lot of folks who read this site would like to hear it too.

  26. TonyC on April 5th, 2012 09:56

    Dear Phillip,
    First thing, a correction:

    That’s Rideout et al 2012, not Risebrough et al 2012 in that last post. Sorry about that.

    Second, Mr. Parish seems to be reaching out here, and it is something that I appreciate most sincerely. I hope that we can “get ‘er done” when it comes to setting a meeting. Things look promising, and I hope that the schedules can be worked out.

    Respectfully,

    Anthony Canales

  27. kathy on April 5th, 2012 16:49

    Phillip – Thanks for giving us this opportunity – and yes, I remember our conversation too. Good job!

    Tony – I couldn’t get past the first paragraph of your response to me. I wasn’t clarifying my position on the lead ban issue, I was clarifying The Peregrine Fund’s. I hope my position has never been in question – AZ Game and Fish Department has never and will never support a lead ammunition ban within the condor range – PERIOD.

    AZGFD entered an amicus brief for the CBD vs. BLM case stating we opposed a lead ammo ban on the AZ Strip. AZGFD also sent in comments to the EPA opposing a national lead ammo and fishing tackle ban as petitioned by the CBD.

    Our dedication to convincing hunters within the condor range to either use non-lead ammo or remove their gut piles proves that we are passionate about our VOLUNTARY program and helping reduce lead exposure in condors! We take the promise we made to the public 15 years ago to not restrict any land manangement practices (including hunting) due to the 10(j) condor program, very seriously.

    Please don’t base your opinion on a couple e-mails you’ve read (out of thousands). I’ve extended this invitation in the past, but I’ll do it again. I would be more than happy to take you, Don Saba, or anyone else representing the NRA out in the field during the fall hunting season so you can witness the overwhelming support we have from Arizona hunters. They understand that this is a wildlife conservation issue and they have responded accordingly (reconfirming their proud wildlife conservation heritage). We’d also be happy to x-ray and dissect the gut piles and that we retrieve from the field so you can see the lead fragments for yourself.

    It’s not only individual hunters that support our voluntary program (we had 90% participation from successful Kaibab hunters last year); our local sporstman’s groups including the AZ Elk Society, AZ Deer Association, AZ Antelope Foundation, AZ Desert Bighorn Sheep Society, and AZ Wild Turkey Federation all signed onto a coalition supporting our voluntary lead reduction program after we presented the dat to them. The Western Association of Fish and Wildlife Agencies also released a position statement supporting voluntary lead reduction programs when population effects have been documented – such as in the case of the condor.

    I completely understand the position the NRA has been put in. A few entities involved in this issue do have an anti-hunting agenda. They were warned that their participation would turn this into a political issue and degrade the credibilty of this effort, but they still chose to engage in the dialog. Unfortunately that has turned this issue into yet another polarized political issue. We consider ourselves the rational voice in the middle trying to bring both sides together. We will continue to get the information out there and let hunters make their own choice.

    Here is what we know:
    – Lead poisoning is the leading cause of death in condors
    – 22 condors have died of lead poisoning in AZ/UT since 2000 – confirmed by
    necropsy and toxicology tests
    – Like humans, all condors have background blood lead levels
    – While in captivity condors only show background lead levels
    – Only released condors feeding on carrion in the wild show elevated lead levels
    – Free flying condors are trapped and tested for lead exposure on a regualr basis
    – Each year, 50-95% of the population tests positive for lead exposure = lead
    levels above background levels
    – Condor lead exposures peak every year between November-January
    – Transmitter location data indicates that during this time, condors concentrate on
    the Kaibab Plateau (AZ) and Zion areas (UT)
    – The fall hunting season occurs in both areas during this timeframe
    – Condors are obligate scavengers and eat carrion
    – Condors have been documented feeding on wounding loss animals and gut piles
    during the fall hunting season (several reports by hunters)
    – 500-900 gut piles are left in the field on the Kaibab Plateau alone during the fall
    hunting season
    – A peer-reviewed published study determined that 100% of hunter killed deer
    carcasses and 90% of the resulting gut piles contained lead fragments regardless
    of whether the bullet passed though or remained in the carcass.
    – Ballistics gel and water jug testing of lead bullets also indicate that lead bullets
    fragment significantly (try it and be your own judge)
    – Since lead is a soft metal and hunting bullets are designed to expand, lead
    fragments break off when a high velocity bullet travels through game
    – Lead fragments and lead shot have been found in the digestive tracts of several
    condors
    – A lead isotope studies by the U of AZ has determined that the lead in condor
    blood is recycled lead (matching that of ammunition), not background lead found
    in the environment
    – No other source of lead that appears seasonally (during the fall/winter) on the
    Kaibab Plateau has been identified
    – Therefore AZGFD belives that lead ammunition remaining in animal carcasses is
    the leading source of lead poisoning in condors

    Tony – I would also like to respond to a few points you brought up:

    1) Our free ammo program is NOT paid by the tax dollars or hunting dollars. We use lottery and Indian gaming revenue to pay for the program.

    2) AZGFD also did not withdraw from the lead reduction steering committe when lead bans were proposed by outside entities. That in no way shape or form meant that we supported lead bans – that was not the purpose of that committee. The purpose was for stakeholders to work together at identying the lead source and come up with solutions to the problem. The lead reduction steering committe NEVER supported or recommended a lead ban.

    3) I believe Chris and I adressed the other issues you bring up about non-lead alternatives – and we do not refer to them as non-toxic – never have – we simply say non-lead ammunition.

    4) I actually talked to U of A staff at a February Wildlife Society meeting. The primary investigator on the study left the U of A some time ago and apologized for “letting life get in the way” and not publishing the data before he left. We discussed how the work still needed to be done, and I am confident that a published paper will be forthcoming – finally 🙂

  28. TonyC on April 6th, 2012 10:34

    Dear Ms. Sullivan,
    Thank you for your kind reply.

    The question as to what is Peregrine Fund’s position on a mandatory ban is still in question, and has not yet been answered by any posted or private communications so far. The July 2007 Statement letter pre-dated Dr. Cade’s 2007 (excerpts which were cited and linked above). There seems to be internal differences at Peregrine Fund as to the issue of support for voluntary programs versus mandatory bans, if I read Mr. Parish’s communications correctly. Perhaps if Peregrine Fund would issue a new policy statement, signed off by the key policy makers, then this issue as to where they stand as an organization could be laid to rest. This would be especially re-assuring, given what seems to be going on with key Peregrine Fund personnel along the “mandatory ban” front.

    The question as to what is AZGFD’s position was not the question I raised. AZGFD supports and maintains a program that distributes 1-2 “free” boxes of primarily copper-based ammunition to hunters that draw a big game tag in a number of Arizona Strip hunting zones. Whether money is paid for by taxes, or money is laterally transferred from gaming funds is a small argument, given the fungible nature of governmental general funds these days. Money diverted from Indian gaming revenues for ammunition is not available for schools, public health care, transportation repair, etc. Given the wide degree of spending needs, Arizona taxpayers might want to re-prioritize the use of money spent on copper ammunition given changing priorities. Since Ventana was recently able to get some kind of private funding to furnish up to 1000 boxes of copper ammunition, and given their limited means, I am sure that Arizona taxpayers should be quite interested in seeing how Ventana “did it”.

    Citation of AZGFD’s positions on the issue of the day, rather than Peregrine Funds’, is not what I was addressing. It even seems a bit irrelevant, unless AZGFD and Peregrine Fund are “joined at the hip” on all things condor in Arizona. I am glad that AZGFD itself supports the 10 j) limitations on land use changes related to the condor. It again would be quite interesting to get a newer statement of policy from Peregrine Fund on the matter.

    The thousands of pages of PRA material from Arizona that I have reviewed is obviously not the complete record of what is going on related to the condor program in the 10 j) zone. For starters, those documents seem to indicate that certain documents “asked for” were not provided despite them being available. I assume that it will take more aggressive efforts to get these in the future.

    That does not mean that some of the more “personal” communications that were reviewed do not have value. Mundane matters, such as who is house-sitting someone’s cat or the meeting point for a conference, ended up alongside key documents related to billing “oddities”, how gift certificates were derived, and what I have come to call the “false positives” problem with xrays and chemical tests. To me, all that means is that the AZ Condor Program is wide-ranging in it’s exchange of communications, including coordination with those who promulgate the public message.

    The gutpile xray issue is a case in point. The xrays will show fragments or particles, though xrays themselves cannot distinguish between metallic fragments from various kinds of grit that can still lead to an “indication” on the xray film itself. This is a problem widely known to the Fish & Wildlife Service, and presumably wildlife officials who use xrays in the course of their field work.

    To me, the problems of claims that all fragments and particles found in game and gutpiles consist only of lead is compounded by the construction of modern lead ammunition and the existence of exit wounds in the game being xrayed. Given some of the “parsing” seen in Condor Program communications, where fragments recovered from a gutpile or a condor are “consistent with lead ammunition” can easily be used to describe a copper jacket fragment, and not a lead fragment. This will have be clarified if trust is to be built for future relations.

    The 90% participation issue in Arizona is an observed point of contention within certain AZGFD communications that I have reviewed. Chief Nancy Foley reported to the CA Fish & Game Commission in March of 2009 that first year’s compliance with the mandatory ban under AB 821 was well over 90%. You in a way are confirming high compliance among hunters one way or another for voluntary efforts in Arizona. The upcoming battle regarding hunter compliance, where folks like Mr. Brown seem to be claiming that hunter compliance is much lower and in violation of law, will be a focus point as to a long-time policy move that would ban the sale and possession of lead ammunition for any reason in states with “iconic” predators and other species.

    The problem, as you call it, for NRA is one actually of the science behind the claims on lead ammunition, and as well as what is a “rational middle ground”.

    What is known is that:

    – Raw data from the 10 j) project is not transparent. Requests for access to that raw data have been rejected from key program partners like Peregrine Fund.

    – Claims of lead, or even lead ammunition, as the leading cause of death of condors is questionable given a) the lack of access to the raw data I have mentioned above; b) the inability to distinguish the lead found in condors between sources found in the 10 j) zone; and c) the large numbers of missing condors or those condors where cause of mortality cannot be determined for a variety of reasons. This last is not a problem unique to the 10 j) zone, it’s a problem in California as well.

    – Given the lack of transparency that I have mentioned above, the claim of 22 condors dying due to lead ammunition is in dispute. 6 of those alone appear related to the single event in June 2000, something that still has the “law enforcement investigatory cone of silence” imposed on data related to what really happened. Since the statute of limitations on ESA cases is 4 years, I find it unreasonable whenever the Condor Program use a law enforcement investigation as a reason to withhold data older than 4 years. Perhaps you can talk to the folks at USFWS about that in relation to Arizona cases.

    – The issue of what is a backround blood lead level, and what that number should be, is another issue of contention. Condor blood lead levels in captivity have varied as high as 6-8 ug/dL, as noted in the AOU Blue Ribbon Panel Report of 2008. On the other hand, the North Dakota study on blood lead of humans consuming game showed an average blood lead level in the 2-3 ug/dL level, with notable exceptions related to those who live in houses with lead paint or are exposed to other bioavailable forms of lead in the environment (energy cogeneration of biosolids in the Midwest is an interesting new line of research related to the total “lead exposure budget” in that geographic region.). Given that exposure levels in living condors have been measured higher than 700 ug/dL in condors captured in the field, the level of lead tolerance seems to be an issue of discussion for lower animal forms than humans.

    -There are numerous reasons why free-flying condors can have blood lead levels that are elevated (ie greater than 10 ug/dL). That includes ingestion of lead contaminated microtrash or paint chips (Condors 132, 550 are examples of these). As I am sure you are aware, there is a microtrash problem in the 10 j) zone that is just beginning to be documented. I think it extremely premature in the least for the claim that the only sources of lead to condors are from carrion.

    – AZGFD records seem to indicate biannual trapping and testing of condors as the “regular basis” that you note. This is apparently done primarily in the spring and in the fall. Given the depuration issue and that condors have been found with elevated blood lead levels outside of a hunting season, I personally view the selection of the spring and the fall condor trap ups as a form of “one-tailed” design that is a key flaw in the current claims of a direct relationship to hunting.

    – The lack of public access to condor blood lead data from the 10 j) zone forces me to question the 50-95% claim of above “backround” blood lead levels. Is backround 2-3 ug/dL per your standard, or is it higher at say the 9-10 ug/dL level? Are the blood lead test results coming from a laboratory test, or from a field meter? Public access to condor blood lead data from 1997 to the present would be most useful at this juncture. Surely Peregrine Fund has shown you that data as part of your participation in the number of studies you are a co-author on?

    – Like with the condor flocks in Central and Southern California, I expect that condors frequent areas that also include proffered feeding sites. Records seem to indicate both release and proffered feeding sites in South Utah (Hurricane, Kolob Reservoir) as well as in the Vermillion Cliffs areas. In a sense, condors can be drawn to an area through a combination of purposeful release and feeding. As such, it is not surprising that condors are found in the Zion Park/Kolob Terrace level, regardless of season.

    – Oddly enough, there is documentation that condors have been observed to have killed a sick baby seal along the Big Sur Coast. This calls into question the issue as to how much a condor is an obligate scavenger, though admittedly more observation and research is needed here. Condors may prey upon weak or sick animals, which is a complicating factor when apportioning risk assessments of causes of mortality.

    – There is much discussion California as to whether condors photographed or “observed” to be feeding on a wounding loss carcass actually were doing so. A photograph of a condor feeding on a claimed wounding loss buck deer turned out to be a picture of a condor feeding on a road kill deer. There is at least one irate California Fish & Game Commissioner that I know of over that misrepresentation. It would be interesting to see what data/documents these hunters have presented as to establish the wounding loss and gutpile feeding observations, and as to how many.

    – Dr. Eric Loft of the CA DFG Wildlife Branch has noted that access by condors of lost game and gutpiles is limited by their preferred terrain characteristics. Areas where condors cannot easily extract themselves from competitive predators/scavengers are apparently less utilized than others. In addition, if the deer or mammal was found in heavy cover, the likelihood of the condor getting to that particular gutpile is apparently less. While I have seen enough elk hunt photos to anecdotally believe that all elk are found in “tough cover”, I have never seen a study showing what percentage of kills of elk or deer were found in such heavy cover versus more open cover suitable for condor scavenging. As such, and given the terrain desirability calculations and observations noted in the Tehachipi Uplands Multi-Species Habitat Conservation Plan, I believe that I can say that not all of the 500-900 gutpiles that you mention are available to condor scavenging efforts. Risk of exposure to metal fragments and particles of all kinds may be greatly reduced when this is taken into account.

    – In regards to the fragmentation issues noted/claimed in Hunt 2004/2006, Hunt 2009, and the Minnesota DNR studies, it is my belief that xrays themselves cannot discriminate between lead fragments and copper jacket fragments. Since you bring it up, exit wounds are extremely common in hunting. The existence of exit wounds would indicate to me that a substantial part of the lead core of a traditional bullet is NOT fragmenting as claimed, not to mention that it is exiting the game entirely. Given that the copper used in bullet jackets can contain lead, the ICP-MS measurement of lead in meat claimed to contain a lead bullet fragment appears to me to be something to be questioned sincerely. The fragment may be of copper. Given that lead is malleable, and that copper is more likely to shear and tear upon jacket expansion, I believe that this issue is not as clear as has been represented by lead ban activists.

    – The question of the efficacy of ballistic gelatin and water jug testing exists, since it is not readily visible in the studies nor the Youtube videos that temperature and mixing controls were maintained on the gelatin used. In addition, range to target from the muzzle is a key determinant as to the degree of fragmentation of the jacket material, and to whether a case can be made that velocity is causing “significant” fragmentation at all. Again, the exit wound issue is a complicating factor. I have recovered intact Sierra Game King Slugs from Utah mule deer shot at 200+ yards, with the classic “mushroom” shape well evident. Given issues of actual hydrostatic “resistance” of game being different from polyethylene containers filled with water, I believe that such testing has a limited utility in describing what is going on with ammunition of all types.

    Minnesota’s testing with captive sheep shot at 50 yards is interesting, but may not be representative of hunting ammunition without knowing the production line source of the projectiles used in the .308 ammunition noted in the study. Different projectiles of different calibers can have different jacket characteristics, and this would have to be taken into account as to whether there was more or less jacket delamination given how close the game were shot.

    – As to the fragments discovered point: significantly more condors have been found with elevated blood lead levels where no lead fragment was discovered. Some particles claimed to be lead fragments from ammunition appear so small in xray films that the relationship to ammunition cannot be determined visually. I have yet to see such a particle with the name of a major manufacturer on the side as well.

    – The lead isotope “study” from U of A that you cite appears to be only a presentation and an abstract, and not a peer-reviewed study. Some raw data from that was visually reviewed, but other key data needed for a thorough evaluation was not made available. Others and myself have been waiting with “baited breath” for a final version and a chance to review all the raw data.

    Studies also show a broad range of isotopic ratios of lead are available in the environment for lead that does not come from ammunition. Likewise lead in ammunition does not have a narrow range of isotopic ratios as has been claimed in Church et al 2006.

    Strangely enough, you comment that these values found in condor blood lead levels match “recycled lead” lead signatures. Recycled lead is found in so many other products than ammunition as to boggle the mind. Lead is one of the most recycled materials in our industrial society. Given the condor’s proclivity for microtrash alone, and that you are matching certain isotope signature ratios to recycled lead, I cannot by the life of me understand why you continue to discount other forms of lead exposure. To me, this calls into question AZGFD’s findings on the lead ammunition issue.

    -Regarding the Lead Reduction Steering Committee Report, found at:

    http://www.biologicaldiversity.org/species/birds/California_condor/pdfs/LERSC-Report.pdf

    While true that there is language in the report that Claims that the Committee is not recommending a strategic plan “…directed at eliminating the use of lead ammunition…”, I believe that this is in the context that not all ammunition uses are for hunting. There is also belief that the use of non-lead ammunition is “… a way to break the the lead exposure pathway…”. Note that the use of non-lead ammunition is not being cited as the “only way” to break the lead exposure pathway.

    But on Page 14 of 18,

  29. TonyC on April 6th, 2012 10:42

    To All,
    OOPS, hit the wrong button- here is the complete post-

    Dear Ms. Sullivan,
    Thank you for your kind reply.

    The question as to what is Peregrine Fund’s position on a mandatory ban is still in question, and has not yet been answered by any posted or private communications so far. The July 2007 Statement letter pre-dated Dr. Cade’s 2007 (excerpts which were cited and linked above). There seems to be internal differences at Peregrine Fund as to the issue of support for voluntary programs versus mandatory bans, if I read Mr. Parish’s communications correctly. Perhaps if Peregrine Fund would issue a new policy statement, signed off by the key policy makers, then this issue as to where they stand as an organization could be laid to rest. This would be especially re-assuring, given what seems to be going on with key Peregrine Fund personnel along the “mandatory ban” front.

    The question as to what is AZGFD’s position was not the question I raised. AZGFD supports and maintains a program that distributes 1-2 “free” boxes of primarily copper-based ammunition to hunters that draw a big game tag in a number of Arizona Strip hunting zones. Whether money is paid for by taxes, or money is laterally transferred from gaming funds is a small argument, given the fungible nature of governmental general funds these days. Money diverted from Indian gaming revenues for ammunition is not available for schools, public health care, transportation repair, etc. Given the wide degree of spending needs, Arizona taxpayers might want to re-prioritize the use of money spent on copper ammunition given changing priorities. Since Ventana was recently able to get some kind of private funding to furnish up to 1000 boxes of copper ammunition, and given their limited means, I am sure that Arizona taxpayers should be quite interested in seeing how Ventana “did it”.

    Citation of AZGFD’s positions on the issue of the day, rather than Peregrine Funds’, is not what I was addressing. It even seems a bit irrelevant, unless AZGFD and Peregrine Fund are “joined at the hip” on all things condor in Arizona. I am glad that AZGFD itself supports the 10 j) limitations on land use changes related to the condor. It again would be quite interesting to get a newer statement of policy from Peregrine Fund on the matter.

    The thousands of pages of PRA material from Arizona that I have reviewed is obviously not the complete record of what is going on related to the condor program in the 10 j) zone. For starters, those documents seem to indicate that certain documents “asked for” were not provided despite them being available. I assume that it will take more aggressive efforts to get these in the future.

    That does not mean that some of the more “personal” communications that were reviewed do not have value. Mundane matters, such as who is house-sitting someone’s cat or the meeting point for a conference, ended up alongside key documents related to billing “oddities”, how gift certificates were derived, and what I have come to call the “false positives” problem with xrays and chemical tests. To me, all that means is that the AZ Condor Program is wide-ranging in it’s exchange of communications, including coordination with those who promulgate the public message.

    The gutpile xray issue is a case in point. The xrays will show fragments or particles, though xrays themselves cannot distinguish between metallic fragments from various kinds of grit that can still lead to an “indication” on the xray film itself. This is a problem widely known to the Fish & Wildlife Service, and presumably wildlife officials who use xrays in the course of their field work.

    To me, the problems of claims that all fragments and particles found in game and gutpiles consist only of lead is compounded by the construction of modern lead ammunition and the existence of exit wounds in the game being xrayed. Given some of the “parsing” seen in Condor Program communications, where fragments recovered from a gutpile or a condor are “consistent with lead ammunition” can easily be used to describe a copper jacket fragment, and not a lead fragment. This will have be clarified if trust is to be built for future relations.

    The 90% participation issue in Arizona is an observed point of contention within certain AZGFD communications that I have reviewed. Chief Nancy Foley reported to the CA Fish & Game Commission in March of 2009 that first year’s compliance with the mandatory ban under AB 821 was well over 90%. You in a way are confirming high compliance among hunters one way or another for voluntary efforts in Arizona. The upcoming battle regarding hunter compliance, where folks like Mr. Brown seem to be claiming that hunter compliance is much lower and in violation of law, will be a focus point as to a long-time policy move that would ban the sale and possession of lead ammunition for any reason in states with “iconic” predators and other species.

    The problem, as you call it, for NRA is one actually of the science behind the claims on lead ammunition, and as well as what is a “rational middle ground”.

    What is known is that:

    – Raw data from the 10 j) project is not transparent. Requests for access to that raw data have been rejected from key program partners like Peregrine Fund.

    – Claims of lead, or even lead ammunition, as the leading cause of death of condors is questionable given a) the lack of access to the raw data I have mentioned above; b) the inability to distinguish the lead found in condors between sources found in the 10 j) zone; and c) the large numbers of missing condors or those condors where cause of mortality cannot be determined for a variety of reasons. This last is not a problem unique to the 10 j) zone, it’s a problem in California as well.

    – Given the lack of transparency that I have mentioned above, the claim of 22 condors dying due to lead ammunition is in dispute. 6 of those alone appear related to the single event in June 2000, something that still has the “law enforcement investigatory cone of silence” imposed on data related to what really happened. Since the statute of limitations on ESA cases is 4 years, I find it unreasonable whenever the Condor Program use a law enforcement investigation as a reason to withhold data older than 4 years. Perhaps you can talk to the folks at USFWS about that in relation to Arizona cases.

    – The issue of what is a backround blood lead level, and what that number should be, is another issue of contention. Condor blood lead levels in captivity have varied as high as 6-8 ug/dL, as noted in the AOU Blue Ribbon Panel Report of 2008. On the other hand, the North Dakota study on blood lead of humans consuming game showed an average blood lead level in the 2-3 ug/dL level, with notable exceptions related to those who live in houses with lead paint or are exposed to other bioavailable forms of lead in the environment (energy cogeneration of biosolids in the Midwest is an interesting new line of research related to the total “lead exposure budget” in that geographic region.). Given that exposure levels in living condors have been measured higher than 700 ug/dL in condors captured in the field, the level of lead tolerance seems to be an issue of discussion for lower animal forms than humans.

    -There are numerous reasons why free-flying condors can have blood lead levels that are elevated (ie greater than 10 ug/dL). That includes ingestion of lead contaminated microtrash or paint chips (Condors 132, 550 are examples of these). As I am sure you are aware, there is a microtrash problem in the 10 j) zone that is just beginning to be documented. I think it extremely premature in the least for the claim that the only sources of lead to condors are from carrion.

    – AZGFD records seem to indicate biannual trapping and testing of condors as the “regular basis” that you note. This is apparently done primarily in the spring and in the fall. Given the depuration issue and that condors have been found with elevated blood lead levels outside of a hunting season, I personally view the selection of the spring and the fall condor trap ups as a form of “one-tailed” design that is a key flaw in the current claims of a direct relationship to hunting.

    – The lack of public access to condor blood lead data from the 10 j) zone forces me to question the 50-95% claim of above “backround” blood lead levels. Is backround 2-3 ug/dL per your standard, or is it higher at say the 9-10 ug/dL level? Are the blood lead test results coming from a laboratory test, or from a field meter? Public access to condor blood lead data from 1997 to the present would be most useful at this juncture. Surely Peregrine Fund has shown you that data as part of your participation in the number of studies you are a co-author on?

    – Like with the condor flocks in Central and Southern California, I expect that condors frequent areas that also include proffered feeding sites. Records seem to indicate both release and proffered feeding sites in South Utah (Hurricane, Kolob Reservoir) as well as in the Vermillion Cliffs areas. In a sense, condors can be drawn to an area through a combination of purposeful release and feeding. As such, it is not surprising that condors are found in the Zion Park/Kolob Terrace level, regardless of season.

    – Oddly enough, there is documentation that condors have been observed to have killed a sick baby seal along the Big Sur Coast. This calls into question the issue as to how much a condor is an obligate scavenger, though admittedly more observation and research is needed here. Condors may prey upon weak or sick animals, which is a complicating factor when apportioning risk assessments of causes of mortality.

    – There is much discussion California as to whether condors photographed or “observed” to be feeding on a wounding loss carcass actually were doing so. A photograph of a condor feeding on a claimed wounding loss buck deer turned out to be a picture of a condor feeding on a road kill deer. There is at least one irate California Fish & Game Commissioner that I know of over that misrepresentation. It would be interesting to see what data/documents these hunters have presented as to establish the wounding loss and gutpile feeding observations, and as to how many.

    – Dr. Eric Loft of the CA DFG Wildlife Branch has noted that access by condors of lost game and gutpiles is limited by their preferred terrain characteristics. Areas where condors cannot easily extract themselves from competitive predators/scavengers are apparently less utilized than others. In addition, if the deer or mammal was found in heavy cover, the likelihood of the condor getting to that particular gutpile is apparently less. While I have seen enough elk hunt photos to anecdotally believe that all elk are found in “tough cover”, I have never seen a study showing what percentage of kills of elk or deer were found in such heavy cover versus more open cover suitable for condor scavenging. As such, and given the terrain desirability calculations and observations noted in the Tehachipi Uplands Multi-Species Habitat Conservation Plan, I believe that I can say that not all of the 500-900 gutpiles that you mention are available to condor scavenging efforts. Risk of exposure to metal fragments and particles of all kinds may be greatly reduced when this is taken into account.

    – In regards to the fragmentation issues noted/claimed in Hunt 2004/2006, Hunt 2009, and the Minnesota DNR studies, it is my belief that xrays themselves cannot discriminate between lead fragments and copper jacket fragments. Since you bring it up, exit wounds are extremely common in hunting. The existence of exit wounds would indicate to me that a substantial part of the lead core of a traditional bullet is NOT fragmenting as claimed, not to mention that it is exiting the game entirely. Given that the copper used in bullet jackets can contain lead, the ICP-MS measurement of lead in meat claimed to contain a lead bullet fragment appears to me to be something to be questioned sincerely. The fragment may be of copper. Given that lead is malleable, and that copper is more likely to shear and tear upon jacket expansion, I believe that this issue is not as clear as has been represented by lead ban activists.

    – The question of the efficacy of ballistic gelatin and water jug testing exists, since it is not readily visible in the studies nor the Youtube videos that temperature and mixing controls were maintained on the gelatin used. In addition, range to target from the muzzle is a key determinant as to the degree of fragmentation of the jacket material, and to whether a case can be made that velocity is causing “significant” fragmentation at all. Again, the exit wound issue is a complicating factor. I have recovered intact Sierra Game King Slugs from Utah mule deer shot at 200+ yards, with the classic “mushroom” shape well evident. Given issues of actual hydrostatic “resistance” of game being different from polyethylene containers filled with water, I believe that such testing has a limited utility in describing what is going on with ammunition of all types.

    Minnesota’s testing with captive sheep shot at 50 yards is interesting, but may not be representative of hunting ammunition without knowing the production line source of the projectiles used in the .308 ammunition noted in the study. Different projectiles of different calibers can have different jacket characteristics, and this would have to be taken into account as to whether there was more or less jacket delamination given how close the game were shot.

    – As to the fragments discovered point: significantly more condors have been found with elevated blood lead levels where no lead fragment was discovered. Some particles claimed to be lead fragments from ammunition appear so small in xray films that the relationship to ammunition cannot be determined visually. I have yet to see such a particle with the name of a major manufacturer on the side as well.

    – The lead isotope “study” from U of A that you cite appears to be only a presentation and an abstract, and not a peer-reviewed study. Some raw data from that was visually reviewed, but other key data needed for a thorough evaluation was not made available. Others and myself have been waiting with “baited breath” for a final version and a chance to review all the raw data. Hopefully the author will “finally” publish shortly.

    Studies also show a broad range of isotopic ratios of lead are available in the environment for lead that does not come from ammunition. Likewise lead in ammunition does not have a narrow range of isotopic ratios as has been claimed in Church et al 2006.

    Strangely enough, you comment that these values found in condor blood lead levels match “recycled lead” lead signatures. Recycled lead is found in so many other products than ammunition as to boggle the mind. Lead is one of the most recycled materials in our industrial society. Given the condor’s proclivity for microtrash alone, and that you are matching certain isotope signature ratios to recycled lead, I cannot by the life of me understand why you continue to discount other forms of lead exposure. To me, this calls into question AZGFD’s findings on the lead ammunition issue.

    -Regarding the Lead Reduction Steering Committee Report, found at:

    http://www.biologicaldiversity.org/species/birds/California_condor/pdfs/LERSC-Report.pdf

    While true that there is language in the report that Claims that the Committee is not recommending a strategic plan “…directed at eliminating the use of lead ammunition…”, I believe that this is in the context that not all ammunition uses are for hunting. There is also belief that the use of non-lead ammunition is “… a way to break the the lead exposure pathway…”. Note that the use of non-lead ammunition is not being cited as the “only way” to break the lead exposure pathway.

    But on Page 14 of 18 of the Report, it says also-

    “…To insure satisfactory progress in enhancing condor survival, it must be recognized by all parties that if in 5-7 years, it is clear that this proposed program has not been rigorously applied or usable results are not being achieved, regulatory control may be considered. It is the Committee’s position that through the current level of intensive management of condors, the recovery program would not be unduly compromised within this timeframe while the voluntary approach to lead mitigation is being implemented…”

    In other words, regulatory control (mandatory ban) is under consideration by the Committee should the voluntary program “not work out”. The purpose of the Committee was for various stakeholder to work out details behind closed doors as to what conditions it would be acceptable to enact such a regulatory ban.

    Others disagree with the premise, and have been “disagreeing” ever since.

    Respectfully,

    Anthony Canales

  30. kathy on April 6th, 2012 11:34

    This will be my last correspondence. Tony if you want to address this issue further please contact me directly. I don’t feel you are portraying accurate information and this has become too political. I am not a professional lobbyist, I am a hunter and a wildife biologist and my credibility means everything to me – anyone who has worked with me during my 18 year career knows that.

    Lead poisoning IS a serious problem in condors, it has been linked to lead ammuniton and huning, and we will continue to work with hunters to SOLVE this problem on a VOLUNTARY basis. Even the NSSF has stated that it is a valid issue in condors and should be addressed on a voluntary basis by the state. The proposed national lead ammo ban is the issue that we should all be working on together. I really don’t understand why you are attacking our successful voluntary program. I don’t feel you’re representing hunters’ best interests on this issue.

    The invitation still stands – come out in the field with us to observe this first hand – and then form your opinion.

    Philip, I respect you and appreciate this opportunity, but I think I will refrain from blogging on this site in the future.

  31. Phillip on April 6th, 2012 12:06

    Kathy, I understand. As a public servant and representative of the State of Arizona, you should be circumspect in your choice of conversations. Tony is digging into sensitive ground here, and it’s easy to see how even a carefully considered response could be misinterpreted (or misappropriated). I wish this blog were considered a safe and appropriate place to lay this whole issue on the table and dissect it piecemeal, but I know that’s not the case.

    I do hope you’ll stick around, and possibly comment on less politically charged topics. It’s incredibly valuable to have information coming directly from the source. I do my best to offer things as factually as I can, but I do interpret through my own filters (I’m as fallible as anyone), and I know I don’t always have all the data. It’s also good to hear information from more than one source in situations like this one. Tony is well-equipped with data, but seldom is there a foil to offer qualified debate or reply.

  32. Neil H on April 6th, 2012 19:24

    I want to thank everyone who commented.

    Kathy, I know you are hesitant given your position to engage in debate, but I really appreciate the clarification of AZ policy and your point of view. I think it’s fair to say that we can take all of your opinions and observations at face value. Obviously different people will take a different views of some of this, but I feel like everyone here is being honest with the facts as they see them.

    If there’s not incremental views and action on this, I’m afraid it will just become yet another all or nothing issue where giving the tiniest bit of ground is an invitation to total defeat, or conceding a point or understanding another person’s argument becomes total betrayal to a cause; a status that is all to common with issues that are complex landscapes of many shades of grey but have nonetheless become black or white. We live in a country were if someone is pro-choice but is uncomfortable with late term abortions, or is personally opposed to abortion but thinks they should still be legal, they are unwelcome in either camp. In reality though, that’s the type of thinking that is most often the most useful and sincere.

    I fully support the voluntary approach that Arizona has adopted, and I’m impressed with how Arizona hunters have responded- without resorting to laws that infringe on target shooters or choices for personal defense.

    I’ve recently switched to copper, though I haven’t hunted yet in the condor zone (in spite of the fact that I have a buddy with a pretty awesome lease on some great pig hunting near Paso Robles). I have a lot of feelers out for property in general down there, and if the call comes in for a hunt on a property, I want to be ready. The other part of it is for me. Maybe lead ammo is harmful to people or not, but the lack of it in the meal I just ate sure couldn’t hurt.

  33. Leland on April 10th, 2012 14:05

    Phillip, as always thank you for providing a space for this conversation. I think that this will be my last post on this particular thread as well.

    The issue at present is that valid scientific studies have proven lead ammunition to be a source of lead poisoning in California Condors and other species . The constant attack on biologists who are attempting to preserve both wildlife and hunting for future generations is starting to wear a little thin. Concerns can be addressed by replicating the studies questioned.

    As Chris and Kathy have mentioned, I am also more than willing to work with folks to understand the issue. Feel free to contact me anytime at brown@iws.org. As I mentioned before, I can schedule events with any groups who want to compare lead and non-lead ammo side by side. I do try to focus my efforts in the Ridley-Tree Act zone in CA. Education is what we are all about. We, as hunters, have a long history of conservation using the best available science to drive our decisions. This is an opportunity to continue that tradition.

    Neil, I’m glad to hear that you switched. I think that non-lead will work extremely well for you and hope you will be pleasantly surprised.

    Thank you,
    Leland

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