Comment from Wildlife for All

I am submitting this comment in opposition to the proposed rescission of previously adopted lead ammunition and tackle restrictions at National Wildlife Refuges. As a PhD conservation scientist with twenty years of experience and Executive Director of Wildlife for All, I urge the U.S. Fish and Wildlife Service to retain the lead ammunition and tackle phase-outs adopted in the 2022–23 and 2023–24 refuge hunting and fishing regulations. The scientific evidence regarding lead toxicity is extensive and well established. Lead ammunition fragments left in harvested animals and gut piles are a significant source of poisoning for bald eagles, golden eagles, condors, vultures, and other scavenging birds, while spent lead tackle continues to threaten waterfowl and other aquatic wildlife. A 2022 study published in *Science* found that nearly half of 1,210 bald and golden eagles sampled across 38 states had bone lead concentrations indicative of chronic lead exposure, with ammunition fragments identified as a major source of contamination. The transition to non-lead alternatives is both practical and achievable. Hunters and anglers already have access to effective alternatives, including copper ammunition and steel or bismuth shot. Previous transitions, including the nationwide prohibition on lead shot for waterfowl hunting, have substantially reduced lead poisoning in wildlife without impacting hunting traditions and participation. National Wildlife Refuges exist first and foremost to conserve fish, wildlife, plants, and their habitats. Allowing the continued deposition of toxic lead into refuge ecosystems is inconsistent with that mission, particularly when effective alternatives are readily available. The Service thoroughly evaluated the science supporting these lead phase-outs during the previous rulemaking process. Rescinding these protections before they take effect would reverse evidence-based conservation policy without any new scientific justification demonstrating that the underlying risks have changed. I urge the Service to retain the previously adopted lead ammunition and tackle restrictions at the affected refuges and to continue expanding the use of non-toxic ammunition and tackle throughout the National Wildlife Refuge System. Doing so will better protect wildlife, improve ecosystem health, and uphold the conservation purpose for which the Refuge System was established.