To whom it may concern:
I firmly believe that the USFW and tax payers should not absorb the costs associated with the approval process of non-toxic shot. Adopting fees for the approval process would insure those individuals applying for the approval are serious and not wasting the USFW time and tax payer’s money.
In regard to a suitable and portable field test device that can differentiate a non-toxic shot from Lead. I believe the following regulations should be considered and/or added.
1. No field test shall be approved if it requires human intervention and/or interpretation. In other words the results of a field test cannot be influenced by the administer. As an example, a field test using rare-earth magnets HELD by a human from a string and OBSERVING the effects of the magnets when a shotgun shell was introduced to the magnet field requires human intervention and interpretation. Such field tests should not be approved.
2. A valid field test must not be influenced by external conditions such as wind, snow, rain.
3. All field tests must be non-invasive. Meaning no officer can cut open a shell to conduct a field test. However a game officer can cut open a shell to investigate further if given probable cause.
4. ANY shot that has a negative impact on the environment and/or wildlife shall be denied and revoked if approved.
5. ANY shot that has a negative impact on a game officer’s ability to use existing practices or equipment in their ability to identify Lead shall be denied and revoked if approved.
Submitted Electronically via eRulemaking Portal
This is comment on Proposed Rule
Migratory Bird Hunting; Nontoxic Shot for Use in Waterfowl Hunting
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