Submitted Electronically via eRulemaking Portal

My suggested changes are: 1) While it is a good idea to specify pH for water testing, one should apply the pH and other parameters specified by EPA for this purpose. pH should accordingly be 6.5-9.0 to represent normal range of typical freshwater bodies suitable for waterfowl habitat. It is my professional opinion that testing at pH of 4.0 will automatically cause most presently approved shot types to exceed SMAV's for many sensitive organisms. This would include most, if not all, types of coated/plated steel shot types! 2) Inventing an entirely new (and arbitrary) method of measuring and comparing shot hardness values is not a valid materials testing approach. Simply require the applicant to certify that the shot is softer than gun barrel steels, as determined by standard (e.g., ASTM testing) methods. 3) With respect to solubility (and/or "artificial gizzard") testing, allow applicants to either perform the indicated testing or submit published ( "in vitro" and/or "in vivo") data acceptable to USFWS. (There is no reason to "reinvent" data for common materials which have already been thoroughly evaluated in prior art.) 4) Require applicants to demonstrate effectiveness and availability of shot detection methods to USFWS's satisfaction, rather than calling out one particular type and source of a specific instrument.