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.
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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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