EPA Lead Fishing Tackle Ban Proposal...Here we go again!

August 31, 2010

Oppose the Proposed Federal Ban on Lead in Fishing Tackle - Public Comment Being Accepted

For more information, contact Gordon Robertson, vice president and Government Affairs lead or Alyssa Hausman, ASA Policy Fellow, x244.    

The Situation
On August 23, 2010, the Environmental Protection Agency (EPA) was petitioned by the Center for Biological Diversity and four other organizations to ban all lead in fishing tackle under the Toxic Substances Control Act. This includes sinkers, jigs, weighted fly line, and components that contain lead such as brass and ballast in a wide variety of lures, including spinners, stick baits and more.

It is important that industry members send comments now! Let your voice be heard!

On August 27, 2010, the EPA denied the petition for ammunition but maintained the petition to ban lead fishing tackle. Supporters of hunting and the shooting sports have been successful in having ammunition excluded from this ban.

The petition was presented with the aim of reducing bird deaths caused by the ingestion of lead sinkers and jigheads; however, a study conducted by the U.S. Fish and Wildlife Service found that less than one percent of all waterfowl and other birds such as eagles are killed by lead sinker ingestion.

The reasons for opposing the ban are:

• The data does not support a federal ban on lead sinkers used for fishing. In general, bird populations, including loons and other waterfowl species, are subject to much more substantial threats such as habitat loss through shoreline development. Any lead restrictions need to be based on sound science that supports the appropriate action for a particular water body or species.
   
• Depending on the alternative metal and current prevailing raw material costs, non-lead fishing tackle products can cost from six to 15 times more than lead products. Non-lead products may not be as available and most do not perform as well. Mandatory transitioning to non-lead fishing tackle would require significant changes from both the industry and anglers.
    
• A federal ban of the use of lead in fishing tackle will have a significant negative impact on recreational anglers and fisheries resources, but a negligible impact on waterfowl populations. 
   
• America's 60 million anglers generate over $45 billion in retail sales with a $125 billion impact on the nation's economy creating employment for over one million people.

Industry members are encouraged to support voluntary angler education programs for the use of lead sinkers and should urge state and federal fish and wildlife agencies to do the same.

How You Can Help
The EPA has opened the petition for public comments. Please take the following four simple steps to oppose this ban.

1. Officially submit your comments opposing this ban using the EPA's comment page at www.regulations.gov. Comments are due by September 15. You can copy and paste the template message below into the official comment form.
2. Voice your concerns directly to EPA Administrator Lisa Jackson through ASA's Legislative Action Center . This can be done through ASA's Legislative Action Center. Your letter to EPA Administrator Jackson will also be copied to your two Senators and House member.
3. In addition, we encourage you to turn the comments below into a letter to FAX to Administrator Jackson on your company letterhead. Please include information about your company. Her FAX number is: (202) 501-1450.
4. Please FAX a copy of the same letter to your Congressional delegation. You can find their FAX numbers by clicking here and entering your zip code. 

Comments to Submit to EPA

As a member of the sportfishing industry, I urge the Environmental Protection Agency (EPA) to dismiss the petition to ban lead in all fishing tackle.

The sweeping petition has many deficiencies including:

• Misinformation on sinker use and loss
• The actual impact to wild bird populations
• The economic impact of higher cost raw materials and that EPA can only regulate the interstate commerce of lead fishing products under the Toxic Substances Control Act (TSCA) and not the use or manufacture.

As stewards of our nation's natural resources, the sportfishing industry continues to seek new developments to minimize our environmental impact. In addition, the Sportfishing industry pays some $115 million in federal excise taxes each year for fisheries restoration.

I am concerned that the results sought by the petitioners greatly exaggerate the biological impacts on waterfowl; ignore the significant economic impacts to anglers, the industry and to fisheries management; and underestimate the potential impact of human health hazards when anglers seek to produce their own fishing sinkers.

In short, I find the proposal lacking scientific rigor and common sense, and urge you to reject the petition.