My irritation and the EPA

[leaningright]

I know I'll probably get lambasted for posting something that to so many seems trivial but like I said yesterday, some things are important to some folks. OK, I may not have said it that way but here it is:

On August 23, 2010, the Environmental Protection Agency (EPA) was petitioned by the Center for Biological Diversity and four other organizations to ban all lead in fishing tackle under the Toxic Substances Control Act. This includes sinkers, jigs, weighted fly line, and components that contain lead such as brass and ballast in a wide variety of lures, including spinners, stick baits and more.

The [my] reasons for opposing the ban are:

The data does not support a federal ban on lead sinkers used for fishing. In general, bird populations, including loons and other waterfowl species, are subject to much more substantial threats such as habitat loss through shoreline development. Any lead restrictions need to be based on sound science that supports the appropriate action for a particular water body or species.

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 changes from both the industry and anglers.

A federal ban of the use of lead in fishing tackle will have a significant negative impact on recreational anglers and fisheries resources, but a negligible impact on waterfowl populations.

America's 60 million anglers generate over $45 billion in retail sales with a $125 billion impact on the nation’s economy creating employment for over one million people.

More at link: http://www.capwiz.com/keepamericafishing/issues/alert/?alertid=16355526

I know this is a link to an organization that is obviously opposed to this ban where you can send your concerns via a generated letter (and I did) to various representatives and senators, but it contains the gist of the petition and ruling. My biggest problem with this is the elevated cost that would be involved for someone, especially young people and retired folks who both are usually on limited budgets, to take up or continue the hobby of fishing. I can afford the increase in cost but I can also remember a time when I couldn't. I see this as another back door effort to eliminate a lifestyle or hobby that I have been fortunate enough to grow into. Something that I am teaching my son to enjoy. Something that I see as a positive alternative to other kinds of entertainment/hobbies that so many get involved with. These kinds of efforts are why folks like me are wary of government organizations such as the EPA. Sorry guys, I had to vent and this is where I vent most of the time.

 

[Mott the Hoople]

I tend to agree with you. First, the volume of lead used by recreational fisherman is extremely low. Second, they use metallic lead which is fairly inert in aquatic conditions with low toxicity. It's lead compounds that are highly toxic and bioaccumulative, lead metal, ehh not so much. Third, TSCA strikes me as a rather inappropriate section of the Code of Federal Regulations in which to regulate the use of lead sinkers in recreational fishing. The intent of TSCA is to regulate how new chemical products are introduced into the market by requiring the manufacturers of these new chemical products to determine what the toxic properties of those new products are before they are introduced into the market place. How lead fishing sinkers used by recreational fishermen in our navigable water ways or wetlands fit into this regulatory framework is beyond me.

In regards to your challenge though, there is a large body or sound scientific evidence that these articles do pose a significant environmental risk, so their argument is not with out merit and with 500 peer reviewed paper attached to their petition, it sounds pretty much to me like the proponents of this petition have met your condition for basing such a prohibition on sound science.

 

[Mott the Hoople]

LR it appears your not up to date on this issue. Because the petition requested the regulation of lead shot, ammunition and fishing sinkers under the Toxic Substance Control Act (TSCA) and per TSCA regulations EPA is required to respond to such a petition with in 90 days. The petition was filed last month on August 3. EPA responed last week on Aug 27 denying the petition, as I predicted, because these articles are excluded from regulation under TSCA via TSCA sec. 3(2)(B)(v).

So you've nothing to fear, for now. Your free to use your lead sinkers for recreational fishing.

 

[leaningright]

Thanks for looking into it Mott. Maybe I misunderstood or wasn't clear in my OP. While the proposed ban by the TSCA did include recreational ammunition as well as lead used in fishing, I was under the impression that the August 27 ruling applied only to the ammunition part of the proposal and the fishing lead part was still under review. Here is the letter they wrote in response to the ammo part of the proposal:

http://www.epa.gov/oppt/chemtest/pubs/Owens_Petition_Response.pdf

I think my "ire" may be misdirected as I pointed it specifically toward the EPA in the title of my OP...it should have been more clear the direction was toward groups like the ones who made the proposal in the first place. With groups like this making proposals like this to a very powerful agency we have little control of [the people who are appointed and serve there], I still get un-nerved every time I read about something like this.

 

[Don Quixote]

i think that we put enough toxins into our environment

lead from lost fishing tackle permeates its way though eco-systems

 

[Mott the Hoople]

Thanks for looking into it Mott. Maybe I misunderstood or wasn't clear in my OP. While the proposed ban by the TSCA did include recreational ammunition as well as lead used in fishing, I was under the impression that the August 27 ruling applied only to the ammunition part of the proposal and the fishing lead part was still under review. Here is the letter they wrote in response to the ammo part of the proposal:

http://www.epa.gov/oppt/chemtest/pubs/Owens_Petition_Response.pdf

I think my "ire" may be misdirected as I pointed it specifically toward the EPA in the title of my OP...it should have been more clear the direction was toward groups like the ones who made the proposal in the first place. With groups like this making proposals like this to a very powerful agency we have little control of [the people who are appointed and serve there], I still get un-nerved every time I read about something like this.

Don't know if I can agree with you there either. It looks to me like these groups have an impressive collection of peer reviewed scientific data backing up their claims. The least we can do is be open minded about them. If the data does support their claims then maybe regulation of these articles are needed.

Now I'm not suggesting that we do so, I'm just saying let's be open minded and review the facts they presented before we make any decisions. As a fisherman, I desire preserving habitat and if lead anchors are indeed harming them, then I have no problem with making the changes that would be needed to protect those habitats, if that is factually the case, which is still an "if" at this stage of the game but my point remains, let's be open minded and do what's right based on the facts.

 

[Mott the Hoople]

i think that we put enough toxins into our environment

lead from lost fishing tackle permeates its way though eco-systems

The amount of lead that enters into our ecosystems from recreational fishing gear is laughably minute compared to that coming from mining and the burning of coal for electricity. Let's keep the issue in perspective. If the scientific data does bear out they this source of lead contamination poses a significant risk, the it should be regulated but let's establish this as a fact first.

 

[Don Quixote]

The amount of lead that enters into our ecosystems from recreational fishing gear is laughably minute compared to that coming from mining and the burning of coal for electricity. Let's keep the issue in perspective. If the scientific data does bear out they this source of lead contamination poses a significant risk, the it should be regulated but let's establish this as a fact first.

i am all for eliminating toxins from industrial sources like battery recycling (elemental lead from old batteries)

but lead from fishing adds up in rivers

weights are larger for ocean fishing than river, but it is all to the bad

hunters have been resisting changing from lead to iron bullets/pellets for years - seems no recreational user of lead wants to let go

i recently discovered that an iron mineral supplement (ironite) that i used to use for my lawn and roses contains lead

how many more toxins lurk in everyday usage that are either know to the user/manufacturer or not know at all until too late - like hexavalent chromium...

a strapping plant near one place i used to live used lead and it broadcast lead into the atmosphere for a several mile radius - i had to be tested for lead poisoning when the fact was published

 

[SmarterthanYou]

it was a bullshit petition that had to include all forms of lead for different things in order to hide a ban on ammunition.

 

[FUCK THE POLICE]

Even trace amounts of lead in freshwater can decimate amphibian population.

 

[Don Quixote]

it was a bullshit petition that had to include all forms of lead for different things in order to hide a ban on ammunition.

the principal ban of lead in ammunition was for bird shot, as birds mistook the shot for seeds and ingested it - hence its introduction into the ecosystem for people and other animals that ate foul that had ingested the lead

 

[Cypress]

I know I'll probably get lambasted for posting something that to so many seems trivial but like I said yesterday, some things are important to some folks. OK, I may not have said it that way but here it is:

On August 23, 2010, the Environmental Protection Agency (EPA) was petitioned by the Center for Biological Diversity and four other organizations to ban all lead in fishing tackle under the Toxic Substances Control Act. This includes sinkers, jigs, weighted fly line, and components that contain lead such as brass and ballast in a wide variety of lures, including spinners, stick baits and more.

The [my] reasons for opposing the ban are:

The data does not support a federal ban on lead sinkers used for fishing. In general, bird populations, including loons and other waterfowl species, are subject to much more substantial threats such as habitat loss through shoreline development. Any lead restrictions need to be based on sound science that supports the appropriate action for a particular water body or species.

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 changes from both the industry and anglers.

A federal ban of the use of lead in fishing tackle will have a significant negative impact on recreational anglers and fisheries resources, but a negligible impact on waterfowl populations.

America's 60 million anglers generate over $45 billion in retail sales with a $125 billion impact on the nation’s economy creating employment for over one million people.

More at link: http://www.capwiz.com/keepamericafishing/issues/alert/?alertid=16355526

I know this is a link to an organization that is obviously opposed to this ban where you can send your concerns via a generated letter (and I did) to various representatives and senators, but it contains the gist of the petition and ruling. My biggest problem with this is the elevated cost that would be involved for someone, especially young people and retired folks who both are usually on limited budgets, to take up or continue the hobby of fishing. I can afford the increase in cost but I can also remember a time when I couldn't. I see this as another back door effort to eliminate a lifestyle or hobby that I have been fortunate enough to grow into. Something that I am teaching my son to enjoy. Something that I see as a positive alternative to other kinds of entertainment/hobbies that so many get involved with. These kinds of efforts are why folks like me are wary of government organizations such as the EPA. Sorry guys, I had to vent and this is where I vent most of the time.

According to the EPA website, this lead ban wasn't EPA's idea. If you want to be pissed at someone, be pissed at the environmental and conservation groups who submitted the petition.

EPA is just doing its job. It's required by law to look at petitions, and their scientific basis, that citizens submit. You know, that whole "petition the government" constitutional right we have.

I seriously doubt EPA has any agenda to ban a lifestyle, or whatever. That's black helicopter stuff. EPA is pretty good about evaluating scientific data, and making balanced decisions. I seriously doubt this is going to end up with some catastrophic ban. Best case scenario for you, is that EPA denies the second part of the petition. Worst case scenario, EPA will promulgate some rules that will presumably phase in new requirements that take into account and balance scientific considerations, as well as economic ones. I can guarantee you whatever they do, there is not going to be a black helicopter showing up to enforce an immediate ban. Whatever EPA does is usually in a balanced, and phased-in approach.


You sound pretty informed on it. Maybe you knew this, but You can submit comments to EPA. It's your right as a citizen, and by law they have to read and consider your comments in any decisions they make. They are happy to take and consider your comments, particularly if they are well informed, and technically well-founded. Apparently, the formal public comment period is open until Sept. 15: in which case EPA is required to respond to your comments formally in writing.

 

[Mott the Hoople]

i am all for eliminating toxins from industrial sources like battery recycling (elemental lead from old batteries)

but lead from fishing adds up in rivers

weights are larger for ocean fishing than river, but it is all to the bad

hunters have been resisting changing from lead to iron bullets/pellets for years - seems no recreational user of lead wants to let go

i recently discovered that an iron mineral supplement (ironite) that i used to use for my lawn and roses contains lead

how many more toxins lurk in everyday usage that are either know to the user/manufacturer or not know at all until too late - like hexavalent chromium...

a strapping plant near one place i used to live used lead and it broadcast lead into the atmosphere for a several mile radius - i had to be tested for lead poisoning when the fact was published

You can't get away from them cause they exist in nature. Anywhere you find natural chromate salt formations you're going to find hex chrome, same with other toxic metal compounds, they don't just come from industrial production.

 

[Mott the Hoople]

Even trace amounts of lead in freshwater can decimate amphibian population.

That's true but how many lead sinkers would you need to drop into a lake with 10 miles of shore line to raise the lead concentration to 5 ppb, the standard set by the SDWA?

 

[Cypress]

I tend to agree with you. First, the volume of lead used by recreational fisherman is extremely low. Second, they use metallic lead which is fairly inert in aquatic conditions with low toxicity. It's lead compounds that are highly toxic and bioaccumulative, lead metal, ehh not so much. Third, TSCA strikes me as a rather inappropriate section of the Code of Federal Regulations in which to regulate the use of lead sinkers in recreational fishing. The intent of TSCA is to regulate how new chemical products are introduced into the market by requiring the manufacturers of these new chemical products to determine what the toxic properties of those new products are before they are introduced into the market place. How lead fishing sinkers used by recreational fishermen in our navigable water ways or wetlands fit into this regulatory framework is beyond me.

In regards to your challenge though, there is a large body or sound scientific evidence that these articles do pose a significant environmental risk, so their argument is not with out merit and with 500 peer reviewed paper attached to their petition, it sounds pretty much to me like the proponents of this petition have met your condition for basing such a prohibition on sound science.

Damn, check out the brain on Mott.

You have no idea how refreshing (and unusual!) it is to see something scientifically-literate in the backwaters of the jpp.com jungle.

 

[DamnYankee]

That's true but how many lead sinkers would you need to drop into a lake with 10 miles of shore line to raise the lead concentration to 5 ppb, the standard set by the SDWA?

Why does it matter? The lead doesn't go away, it will eventually meet some concentration. Besides, the standard is probably going to get lowered at some point in time. They usually do.

I'd rather not have the bottoms of ponds and rivers littered with metal that doesn't need to be there. Make the stuff out of steel so it eventually rusts away.

As far as the cost issue, gimme a fucking break. Who cares if an angler spends 15 times for products that he spends pennies on. So a weight costs a quarter rather than 2 cents. Maybe they'll pick the shit up when they drop it instead of leaving the crap lying around.

 

[Mott the Hoople]

Damn, check out the brain on Mott.

You have no idea how refreshing (and unusual!) it is to see something scientifically-literate in the backwaters of the jpp.com jungle.

Thank you. I'm sure I'll be flamed for it.

 

[Mott the Hoople]

Why does it matter? The lead doesn't go away, it will eventually meet some concentration. Besides, the standard is probably going to get lowered at some point in time. They usually do.

I'd rather not have the bottoms of ponds and rivers littered with metal that doesn't need to be there. Make the stuff out of steel so it eventually rusts away.

As far as the cost issue, gimme a fucking break. Who cares if an angler spends 15 times for products that he spends pennies on. So a weight costs a quarter rather than 2 cents. Maybe they'll pick the shit up when they drop it instead of leaving the crap lying around.

:eek3:

Are you feeling all right SM? You're not sounding like your ussual self.

Well you do have a point about litering but I think it makes a difference in that there should probably be some valid measure of environmental impact that can be scientifically validated before you implement federal regulations.

 

[FUCK THE POLICE]

That's true but how many lead sinkers would you need to drop into a lake with 10 miles of shore line to raise the lead concentration to 5 ppb, the standard set by the SDWA?

I don't know. But amphibian populations are being decimated everywhere because of, amongst numerous other causes, water pollution. I don't think it does them any favors and I'd rather it be at least studied rather than summarily dismissed.

 

[DamnYankee]

:eek3:

Are you feeling all right SM? You're not sounding like your ussual self.

Well you do have a point about litering but I think it makes a difference in that there should probably be some valid measure of environmental impact that can be scientifically validated before you implement federal regulations.

Contrary to you lib-tards constant assertion, we conservatives actually like clean water and not looking at someone else's shit when he hike, fish, hunt or camp.