Comment from Predatory Bird Research Group

TWIMC, The Predatory Bird Research Group at UC Santa Cruz strongly opposes the proposed 2026-27 hunting and fishing regulations for the National Wildlife Refuge System which rescind the prior lead phaseouts for refuges that had been adopted in the 2022-2023 and 2023-2024 rulemakings. Lead ammunition and tackle are well-documented health hazards, with scavengers such as eagles, vultures, hawks, and corvids ingesting lead fragments from carcasses and gut piles, waterfowl ingesting spent shot and lost tackle from wetland habitats, and hunters and their families facing health risks from lead fragments in harvested game meat, particularly young children who are most vulnerable to lead’s toxic neurological effects. The potential harm from lead ammunition and tackle threatens the wildlife populations refuges are meant to protect and poses unnecessary risk to the people who hunt and fish on these lands. Please don't take us backward when we need to be moving on from lead based hunting and fishing gear for the wellbeing of Americans and American wildlife. Zeka Glucs PBRG Director