Comment from The Trumpeter Swan Society
The Trumpeter Swan SocietyOpposeAdvocacy
Summary: The Trumpeter Swan Society, a nonprofit scientific organization, opposes the proposed rule because it rescinds existing lead-free requirements at ten National Wildlife Refuges and opens new hunting and fishing opportunities without adequate lead exposure analysis for swans. They argue that lead from ammunition and fishing tackle poses a significant mortality risk to trumpeter and tundra swans and request that the Service maintain existing protections and require non-toxic alternatives.
The Trumpeter Swan Society (TTSS) submits the attached comment letter in response to the proposed rule "National Wildlife Refuge System 2026-2027 Station-Specific Hunting and Sport Fishing Regulations" (91 FR 31580, May 27, 2026). TTSS is a nonprofit scientific organization dedicated to the conservation and restoration of wild trumpeter swans. TTSS is not opposed to expanding hunting and fishing opportunities on National Wildlife Refuges. Our comments focus specifically on lead exposure risks to trumpeter and tundra swans created by this rulemaking, including the rescission of finalized lead-free requirements at ten National Wildlife Refuges and the opening or expansion of hunting and fishing at stations within confirmed swan range without equivalent protections.
Please see the attached letter for our full comments, findings, and recommendations. Attachment A, also included, provides a range map showing current trumpeter swan distribution relative to the affected refuges. TTSS is available to provide additional technical information regarding the lead poisoning research and swan health issues discussed in these comments.
Attachments
- TTSS_Final_Submission (PDF)
- TTSS Lead Position Statement October 2021 (PDF)
- Enviro Toxic and Chemistry - March 1989 - Blus - Lead poisoning and other mortality factors in trumpeter swans (PDF)
- Slabe-et-al_2022_Demographic-implications-of-lead-poisoning-for-eagles-across-North-America (PDF)
- Franson_et_al_Lead_fishing_Weights_Waterbirds (PDF)
- Degernes et al_ (PDF)
- Lagerquist et al_ (PDF)
- field_manual_of_wildlife_diseases (dragged) (PDF)