Comment submitted by J. Robinson

I am writing to oppose the proposed EPA ban on lead in fishing tackle. This ban would have a significant impact on the recreational fishing community with minimal benefit for the referenced waterfowl. Lead is used not only in sinkers but in a wide variety of fishing lures and other tackle components. The petitioners’ document is replete with commentary unsupported by scientific data and rife with misunderstandings about the use of lead sinkers. Although the petition is aimed at reducing waterfowl death from lead sinker ingestion, a study by the U.S. Fish and Wildlife Service has shown that less than one percent of birds die from ingested sinkers. Lead fishing tackle does not present a population level problem to any bird species. In fact, loon populations are increasing throughout their breeding range. If a particular body of water is of concern, the issue is most effectively addressed by a local science-driven process, not a national ban. Fisheries and recreational fishing methods are best managed by state agencies. While supporters of this ban claim that there are many comparable alternatives to lead sinkers and jigs, this is not the case. 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 – and costly - changes from both the industry and anglers. The resultant decrease of fishing tackle purchases will diminish the dollars for fisheries conservation through fishing license sales and the federal manufacturers’ excise tax on fishing equipment. Something our country can ill afford. I urge you to deny the lead ban petition, because it will have a significant negative impact on the recreational fishing community and only a negligible impact on waterfowl populations. Thank you for your consideration.