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Last Chance to Stop the WDFW Proposed Lead Ban - Act Before Nov 19!

Don't quit now; the Fisheries Commission needs to hear your views by Nov 19 or else they will pass their first Lead Ban on 13 lakes in Washington!  Yes, many of you already sent in your letters on this topic, but the Commission needs to hear your voice one more time before they make their final decision.  Please resend your earlier comments, or take a couple of minutes to simply fill out the form below and email it in!

 

Only 9 loon carcasses in 13 years are suspected to have died from fishing tackle anywhere in the State, of which only two loon carcasses were suspected to have died from lead toxicosis on breeding grounds, the very land this ban is supposed to address. 

 

To this date (despite being asked) the loon advocates have never provided necropsy documentation that even verifies these 2 deaths occurred by lead toxicosis (for instance, maybe the loons had ingested lead, but actually died from another disease).
 
There is no scientific data to support this ban; WDFW biologists have stated to our Advisory Group they have never studied or performed a "Limiting Factors Analysis in Washington State for the Common Loon".  Without such a study, any purported "remedy" is simply a sociological decision rather than a scientific decision.  This is contrary to the mission of the Fisheries Commission and WDFW, and is a dangerous precedent.
 
For instance, there is clear and recent scientific evidence that the Common Loon is harmed more (i.e. breeding success is compromised) by what are called "Disturbance Factors".  Loons are solitary birds that do not thrive in the presence of humans.  The very act of watching loons, like the Loon advocates practice, disrupts breeding success more than lead fishing tackle ever can.  Sounds far fetched, but look at the 2010 study http://scholarworks.umass.edu/cgi/viewcontent.cgi?article=1161&....  Read about the harm caused by kayakers to loon breeding success. 
 
BTW, I provided this Disturbance Factor study to WDFW as a member of the Citizen's Advisory Group, and they never shared it with the other members or their own biologists.  The Group leader stated we were only focused on the "lead" issue, not other issues that may affect Loon populations.  That is when I really knew my time was being wasted as they weren't interested in loon populations, but rather emotional issues.
 
The Loon advocates that wrote the ban recommendation are professional loon photographers.  Look at their website (www.loonlakewildlifegallery.com) at what they charge for loon photographs.  If the commission is serious about loon populations, instead of banning lead tackle should they ban loon photography?  What would the commission do if someone submits a proposal to this effect to the Commission, based upon the study referenced.
 
Incidentally, the advocates of this ban are credited with the loon photographs on WDFW's brochures and web site information.
 
The forthcoming decision by the Commission is totally absurd.  The 2010 study cited disputes many of the claims made by the loon advocates, and the actual study area is the same area used in the early studies (Pokras et al) that reportedly show lead tackle can be a problem.
 
The loon advocate's study also wrongly conclude that the contraction of the southern border of the range of the Loon is also proof that lead toxicosis is a problem.  To the contrary, the Disturbance Factor study blames this contraction to Climate Change, as it documents an expansion of the northern boundary of the Loon range that corresponds with the southern boundary contraction.  The fact of the matter is that Washington is on the fringe of the range, and climate change, shoreline development, and disturbance factors all play a role in loon breeding success in Washington; not lead fishing tackle.
 
If this passes, how can it not be followed with expanding requests to the entire state (which was the loon advocates request in the first place), and also then include fishing line, hooks, or anything else the loon advocates specify?

 

 

 

Take Action. Now.

Washington State Anglers Face a Ban on Lead Fishing Tackle

Send a message to the Washington Fish and Wildlife Commission opposing unwarranted fishing tackle regulations

Despite public opposition, the Washington Fish and Wildlife Commission (WFWC) has before them a proposal for a complete ban of lead fishing tackle on 13 lakes. A ban on lead fishing tackle on the proposed lakes will have a significant negative impact on recreational anglers and fisheries resources in Washington, but a negligible impact on the loon populations that it seeks to protect. Such a ban is not supported by sound science.

How You Can Help
Click here to send a message to the Washington Fish and Wildlife Co...

The Situation
In 2009, a loon advocacy organization presented the WFWC with a proposed rule to ban the use of small lead fishing tackle on the 13 lakes where loons breed in Washington. Before acting on any proposed changes, the WFWC established an advisory committee and sought public input. Even through the committee was unable to come to a consensus and public opinion was largely against lead fishing tackle regulations, the WFWC is currently considering a ban on all lead fishing tackle on these 13 lakes.  In 12 of the lakes the proposal would to make it “[u]nlawful to use fishing tackle containing lead. Tackle includes, but is not limited to, weights, sinkers, jigs, lures, flies, and lead-core line.”  On one lake that is currently open only to fly fishing, the ban is for lead in flies and fly line. This proposal is more severe than the original suggested rule.

On November 4, the U.S. Environmental Protection Agency (EPA) rejected a petition to ban all lead fishing tackle on all U.S. waters, stating that the petitioners did not demonstrate that a ban of all lead fishing tackle is “necessary to protect against an unreasonable risk of injury to health or the environment.” The WFWC’s proposed ban is even less justified; advocates of the proposed regulations have cited only nine loon mortalities from lead fishing tackle ingestion over a 13 year period. According to the Department of Fish and Wildlife, Washington’s loon numbers are increasing.

A complete ban of lead fishing tackle on 13 Washington lakes is not reasonable or warranted. Fishing tackle made from alternatives to lead can be much more expensive and do not perform as well. If anglers don’t act soon, the cost of fishing in Washington may increase significantly.

Act Now!
November 19 is the deadline to submit comment on the proposed lead fishing tackle ban on 13 Washington lakes. Please take action now to ensure that the Washington Fish and Wildlife Commission will reject the proposed ban; click here to let your voice be heard!



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Replies to This Discussion

Permalink Reply by RFatt16 on November 10, 2010 at 3:43pm
WOW is this for real? Didn't they just shoot one of these down like last month?


sent. Is there any way to get a "counter suit" banning these looneys from taking pics of the birds because it disrupts the loons breeding?




Last- Are loons on the east side? Can they be hunted or are they endangered? If not it is now my goal this weekend when i'm bird hunting to help the loon's cause.
Permalink Reply by Marc Marcantonio on November 10, 2010 at 3:55pm
Please post this information on any website where it may help, we need to get the word out fast. Jordan, can you post this on the other groups, and also on Gamefishin...I tried on Gamefishin but didn't do something right...
Permalink Reply by Gary Lucas on November 10, 2010 at 7:46pm
Is this meetting open to the puplic there is not much time for the board members to read all the coments. We may need to be there to show them that we dont like it. My poster will be made in time. The showing of the pepole can work to chang there minds.

Marc Marcantonio said:
Please post this information on any website where it may help, we need to get the word out fast. Jordan, can you post this on the other groups, and also on Gamefishin...I tried on Gamefishin but didn't do something right...
Permalink Reply by Marc Marcantonio on November 10, 2010 at 8:04pm
Gary, I don't know the technical answer to your question, but what I am told is that they will not accept input at their Dec. meeting. That is why they established a Nov 19 date as the last day they will accept input. I suspect they want to avoid the type of confrontation you are willing to provide. I wish there was time to put a billboard up on I-5 in Olympia to protest.

So please spread the word to your friends (hunting and fishing), and on other internet boards, etc.

Marc Marcantonio


Gary Lucas said:
Is this meetting open to the puplic there is not much time for the board members to read all the coments. We may need to be there to show them that we dont like it. My poster will be made in time. The showing of the pepole can work to chang there minds.

Marc Marcantonio said:
Please post this information on any website where it may help, we need to get the word out fast. Jordan, can you post this on the other groups, and also on Gamefishin...I tried on Gamefishin but didn't do something right...
Permalink Reply by Gary Lucas on November 10, 2010 at 8:46pm
Lets protest the loudist voice will win

Marc Marcantonio said:
Gary, I don't know the technical answer to your question, but what I am told is that they will not accept input at their Dec. meeting. That is why they established a Nov 19 date as the last day they will accept input. I suspect they want to avoid the type of confrontation you are willing to provide. I wish there was time to put a billboard up on I-5 in Olympia to protest.

So please spread the word to your friends (hunting and fishing), and on other internet boards, etc.

Marc Marcantonio


Gary Lucas said:
Is this meetting open to the puplic there is not much time for the board members to read all the coments. We may need to be there to show them that we dont like it. My poster will be made in time. The showing of the pepole can work to chang there minds.

Marc Marcantonio said:
Please post this information on any website where it may help, we need to get the word out fast. Jordan, can you post this on the other groups, and also on Gamefishin...I tried on Gamefishin but didn't do something right...
Permalink Reply by Rodney Heupel on November 10, 2010 at 9:32pm
I have done my part and also put this link on the Western Bass Club site. United we will win!
Permalink Reply by Mark Byrne on November 11, 2010 at 6:51am
Gentlemen – Over the past several days I have spoken to each of you about a proposal to engage anglers with the WA Department of Fish and Wildlife to better understand interactions between loons and anglers. The Commission, which has a vote looming on a lead ban in fishing equipment, is interested in such an alternative approach. We are still discussing this with Commissioners and there is no decision yet on whether that is the direction they will go. I can tell you that some on the Commission still lean toward some sort of lead ban on the 13 lakes listed in the rule. The fact remains that lead is not a factor in loon population health in Washington and according to the Department of Fish and Wildlife’s own report loon populations are increasing in the state – and many other major threats exist to loons. A vote to restrict certain lead uses or a ban, as proposed now, is not based on the science at hand and will make no difference in the status of loons in WA. Such a vote will be based on emotion, not fact and takes the Commission down the path of poor decision making and sets a precedent that will disadvantage anglers. The deadline for comments to the Commission is November 19. Aside from joining the proposal I have earlier provided you for consideration, please encourage your membership to speak out on this issue – I know the advocates for a lead ban are sending their emails and letters to the Commission so the angler voice needs to also be heard. Please forward the link below to your membership and encourage them to get online and send a letter to the Commission. Anglers need to speak up and demonstrate to the Commission that they are involved in these issues. The link is to ASA’s KeepAmericaFishing.org™ site for angler advocacy. Thanks for you assistance. Gordon

http://salsa.wiredforchange.com/o/6394/p/dia/action/public/?action_...

Gordon C. Robertson
Vice President
American Sportfishing Association
225 Reinekers Lane, Suite 420
Alexandria, Virginia 22314
703-519-9691 x 237
Fax 703-519-1872
www.asafishing.org
Permalink Reply by Rodney Heupel on November 15, 2010 at 8:47pm
Permalink Reply by Gary Lucas on November 15, 2010 at 9:52pm
Has every one done there part on this? The baning is not to be let happen lightly!
This is not a good thing Washington is not varey smart when in comes to oure out doors living.
Permalink Reply by Pat on November 16, 2010 at 9:23am
bend over grab ankles the lead ban is coming
rgardless of what fishermen do the enviromentalists will have there way in Washington state
Permalink Reply by Gary Lucas on November 16, 2010 at 8:14pm
The only reson the enviromentalists are geting there way is becouse they are not grabing there ankles. They are standing tall and pounding at law makers doors.

Pat said:
bend over grab ankles the lead ban is coming
rgardless of what fishermen do the enviromentalists will have there way in Washington state
Permalink Reply by Marc Marcantonio on November 17, 2010 at 8:44am
Here is another letter I am sending in to WDFW today. Please take a moment and write one of your own and submit by November 19. It doesn't have to be long like mine; a simple one line sentence will work! If WDFW doesn't hear from you they will assume you simply don't care!

ciao,
Marc

November 17, 2010

WDFW Rules Coordinator
600 Capital Way N
Olympia, WA 98504

Subject: “No” on Lead Fishing Tackle Ban Proposal


Dear Washington Fish and Wildlife Commission and Director Phil Anderson,

You are on the verge of making a decision regarding the ban of lead fishing tackle on 13 lakes considered potential nesting habitat for the Common Loon. The citizens expect your decision to be clearly supported by scientific data.

Let me state the bottom line up front; the Commission and the Washington Department of Fish and Wildlife do not have the scientific data to support this proposed ban.

I served on the “Ad Hoc Citizen’s Advisory Group” that was formed (supposedly) to review the science. We were given the biased document you were presented by the loon advocates which distorts causes of loon mortality and leaps to conclusions not rooted in fact. I presented more recent peer reviewed scientific studies that provide a much different picture regarding limiting factors to the Common Loon. The Department chose not to share the information with the group or on its public website claiming that the Ad Hoc Group was formed to discuss only lead fishing tackle. This narrow perspective invalidates any effort to reach consensus and disregards the welfare of the loon population.

Consider the comprehensive study published in 2010 that discusses the importance of “Disturbance Factors” to loon breeding success (I provided this study but it was not shared). http://scholarworks.umass.edu/open_access_dissertations/171/
This study reveals far more important issues than lead fishing tackle. For example, in addition to shoreline development, predation, disease, inadequate forage, trauma, and other well-known factors there are more recently documented significant factors including kayaking and loon watching/photography that affect breeding and rearing success. Where the ban proponents conclude declining rearing success in Washington is proof that lead tackle should be banned, this study points to different factors including Climate Change (and other disturbance factors).

Washington is on the southern fringe of the natural breeding range of the Common Loon. This study documents Climate Change as a major cause, and this hypothesis is supported by a corresponding expansion of the northern nesting range. The overall Loon population continues to increase despite loss of nesting habitat at the southern range because nesting habitat has increased along the northern range.

The ban proponents would have you believe a lead tackle ban would reduce loon mortality on the potential 13 nesting lakes. By their own admission only two loon mortalities in more than 13 years resulted on nesting lakes (the other seven were not in nesting areas). Despite being asked by the Ad Hoc Group they never produced necropsy reports verifying these 2 mortalities were from lead toxicosis and not the result of trauma or other disease. Again, even if true 2 mortalities in 13 years in the entire State is statistically insignificant and does not warrant a ban on lead tackle on the 13 nesting lakes.

The fact of the matter is that the Department has not conducted a Limiting Factors Analysis for the Common Loon in Washington State. I have coauthored a similar type of document as a fisheries biologist regarding Salmonids in WRIA 12. http://www.co.pierce.wa.us/xml/services/home/environ/water/PS/leade...
Without such a study you do not have the data to support such an important decision that will have unintended consequences of major impact (beyond loons).

By now you are aware that the loon organizations pushing this proposal also petitioned the EPA to impose a lead tackle ban nationwide, and the EPA recently rejected the petition because the science did not demonstrate a ban was warranted.

If the Commissioners and WDFW feel the Common Loon in Washington is at risk (from factors within the Department’s ability to control), then you have the obligation to consider funding a study with your biologists to determine which limiting factors can be reduced or mitigated.

Public education should be considered to reduce loon mortality and disturbance factors rather than reducing recreational opportunities. Anglers are wildlife stewards and care about loons as well as fish. Anglers provide funding for the Department biologists through license sales and Sport Fishing Restoration Act taxes. Angling organizations educate members and perform habitat improvement projects. The Department could be partnering with fishing organizations and loon advocacy organizations to work collaboratively rather than pitting them against each other.

I encourage you to not risk the credibility of the Department and its hard-working biologists. I ask you to not restrict outdoor opportunities by banning lead fishing tackle without sound scientific data.

Sincerely,

Marc Marcantonio

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