## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

1 

## October 2010

I. Federal and State Regula tions and Initiatives

A. Federal

1. U .S. Environmental Protection Agency In 1992, the Environmental Defense Fund (EDF) and others petitioned EPA to initiate rulemaking to require that warning labels accompany the sale of le ad fishing sinkers. In 1993, EPA granted the petition.

On March 9, 1994, EPA issued a proposed rule under TSCA section 6 to ban certain size lead and zinc fishing sinkers. After two extensions, the written comme nt period closed November 9, 1994. Two public hearings were held and on January 6, 1995, the co mment period to the hearings closed. EPA did not finalize the rule.

2. U S. Fish and Wildlife Service In 1999, USFWS opened a public comment period for lead-free fishing areas in Refuges (Proposed Rule 64 FR Page 43835) (USDOI 1999). In 2000, USFWS published a Final Rule regarding the 1999-2000 Refuge-Specific Hunting and Sport Fishing Regulatio ns (65 FR 30772) (USDOI 2000). In the rule, USFWS stated they would not be making a decision regarding fishing sinkers but would make a final decision in a subsequent rule. That ruling has not occurred.

3. National Wildlife Refuge System The National Wildlife Refuge System is managed by USFWS. While currently there is no regulation for all Refuges within the United States, there are, Refuge s that have issued their own rules with regard to lead-free fishing (USEPA 2010a). A lthough there is not a comprehensiv e database of all the Refuges, known Refuges are: Rappahannock River Valley NWR, VA (lead-free fishing in their freshwater ponds since 2004), Seney NWR, MI (since 2002), Patuxe nt NWR, MD (since April 2010) (USEPA 2010a), Union Slough NWR in IA (USEPA 2010c), Rachel Carson NWR in ME (USDOI 2010a), and Red Rock Lakes NWR in MT (USDOI 2010b). Assabet NWR in Massachusetts is currently regulated under Massachusetts restrictions (USDOI 2010c). Lead tackle is banned in Yellowstone National Park (USDOI 2010d).

4. National Parks Service On March 10, 2009, NPS sent out a press release stat ing “Our goal is to eliminate the use of lead ammunition and lead fishing tackle in parks by the end of 2010.” (USDOI 2009). Since the release, the NPS has implemented changes in NPS related activities, such as culling operations or the dispatching of wounded or sick animals. The NPS has also developed educational materials to increase awareness about the consequences of lead exposure and the benefits of using lead -free ammunition and fishing tackle. NPS has compiled all available scientific research for NPS consideration (USEPA 2010b).

B. State Regulations

The following information is taken from the States’ websites.

1. Maine As of 2003, in Maine it is “unlawful to sell or offer for sale a lead sinker for fishing that weighs 1/2 ounce or less. This does not include artificial lures, weighted line or lines, or jig heads” (State of Maine 2003).

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

2 2. Massachusetts In 2001, the Fisheries and Wildlife Board prohibited the use of all lead sinkers for the taking of fish in Quabbin and Wachusett Reservoirs, the loons' primary habitat in the state. In 2009, the Fisheries and Wildlife Board unanimously voted to pr ohibit the use of lead sinkers, lead weights, and lead fishing jigs with a mass of less than 1 ounce in all inland waters of Massachusetts. This regulatory change will not take effect until January 1, 2012 (MADFW 2010).

3. New Hampshire In 2000, New Hampshire was the first state to ban lead sinkers and jigs to protect common loons and other diving birds. The law banned the use of lead sinkers weighing one ounce or less and jigs less than one inch long on freshwater lakes a nd ponds. In 2004, a state law passed that prohibits the use of certain sizes of lead sinkers and jigs in all fresh waters in the state. The 2004 law also extended the ban to the use in rivers and streams as of January 2005, and, beginning in January 2006, also prohibits the sale (NHFGD 2010).

4. New York 

### On May 7, 2004, the sale of lead fishing sinkers weighing 1⁄2 ounce or less was prohibited (NYDEC 2004)

.

5. Vermont In 2004, Vermont passed a bill banning the sale (e ffective January 2006) of lead sinkers weighing 1/2 ounce or less, and then the use (effective January 2007) of those lead sinkers in the state (State of Vermont 2004).

6. Washington In fall 2009, a proposal for a lead tackle restriction was included in draft 2010 – 2012 Sportfishing Rules for public review. On December 6, 2010, the Washington Department of Fish and Wildlife Commission will consider adopting the proposed rule on lead tackle. If adopted, it would go into effect on May 1, 2011 (WADFW 2010).

C. Voluntary State Education Programs

1. Illinois In July 2009, the Illinois Legislature passed an Act establishing an educational program designed to discourage the use of lead sinkers and lead jigs (State of Illinois 2010).

2. Minnesota In 2002-03, the state Legislature considered banning th e sale and use of lead tackle. However, after a series of stakeholder discussions, the Legislature de cided that a better approach would be to educate anglers about the alternatives to lead tackle and to offer them opportunities to try out non-lead sinkers and jigs. Minnesota also has hosted Get the Lead Out! lead tackle exchange programs. In this program the state and a wide variety of educational partners host tackle exchange events throughout Minnesota. At these events anglers can swap out their old lead tackle and receive samples of lead-free sinkers and jigs in trade. From 2001 to 2008, nearly 7,000 pounds of lead tackle were collected, and hundreds were educated on the dangers that lead poses to people and wildlife. The program however, has been discontinued (MPCA 2010).

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

3 3. Wisconsin The state promotes a program called Get the Lead Out! Some of the goals of the Get the Lead Out! Wisconsin campaign are to bring awareness to angler s about lead poisoning in fish and other wildlife from lead tackle ingestion, outfit kids ́ tackle boxes with non-lead weights, and conduct programs teaching “How to dispose of your lead tackle properly” (WDNR 2010).



## II. S ubstitute Analysis

The non-lead fishing sinker market has continued to develop since the EPA Proposed Rule was published in 1994. Since then, new products have entered the market. With improvements in technology, changes in consumer preferences, state-level restrictions, an d increased market competition, the market share for lead fishing sinkers is expected to decrease while the market share for s ubstitutes is expected to increase.

A. Fishing Sinker Market Due to the nature of the fishing sinker market, specific market share for the different options is not readily available and complicated to calculate. As disc ussed in the 1994 EPA Proposed Rule, fishing sinkers enter the marketplace through large retail chains, sm all local shops, local Do-It-Yourselfers (DIY) who make sinkers at home for retail sale, and DIY who make sinkers solely for personal use. With the growth of the internet over the past 16 years, internet based retailers have created a new point of entry into the fishing sinker market. This is important for some of the newer substitute options because they are not yet available in typical retail stores like Bass Pro Shops . Substitutes that are biodegradable, ceramic, or limestone are mainly available from the producer directly or websites dedicated to selling nontoxic fishing tackle (e.g. Greentackle.com, Tacklesmith.com).

The market is dominated by metal sinker options: lead, steel, tin, and tungsten. Sinkers produced from these metals likely account for almost all of the market. Lead, due to a variety of factors including historical use, price, and proven effectiveness still holds the largest percentage of the fishing sinker market. The market share of lead is assumed to be 85 percent or less based on the 1994 Proposed Rule and assuming the substitute market share ha s grown due to new state regulations.

Tungsten is a popular substitute for le ad because the sinkers tend to be smaller in size for the same weight and in general perform better than lead. Tungsten is assumed to have the second largest share of the fishing sinker market; its market share appears to be increasing as anglers choose to stop using lead. Despite its higher price, tungsten is assumed to be more popular and command a larger market share than steel based on product availability . Based on angler comments, t ungsten is generally considered a superior fishing sinker to lead, because it is a denser metal. Therefore smaller sinkers are used to obtain the same sink pattern as a comparable lead sinker. Smaller sinkers are preferred because of fewer snag problems and fewer fish are deterred than with larg er sinkers. The only consistent complaint found for tungsten is its price compared to le ad. Tungsten sinkers simply appear to be outperforming lead and other sinker substitutes. Some anglers are w illing to pay the higher cost for t ungsten in order to capitalize on the benefits (Bass Pro Shop, Cabela’s , Greentackle, Tacklesmith).

Steel fishing sinkers are cheaper than tungsten but are larger than comparable lead sinkers. Tin is typically only used for split-shot sinkers because of its low density so it represents a small portion of the market because of limited product us age (Bass Pro Shop, Cabela’s).

Table 1. Summary of Fishing Sinker Market Share

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

4 Choosing non-metal substitutes over lead takes advanced planning because they are not generally available in stores and are brand new in the marketplace. Therefore, their market share is assumed to be very small. Ceramic, biodegradable, and limestone fishing sinkers are only available from specific online retailers, which limits angler access to the products. If these sinker alternatives prove effective and can be price competitive, their market share will increase over time through word of mouth and as anglers switch from lead. When enough anglers demand a given subs titute, normal stores will stock the item to meet customer needs, improving chances for future increa ses in market share. Table 1 summarizes general market share of the various fishing sinker options and how the market is expected to continue to change.

The breakdown of market shares described above should be used as general guidelines. At the time of the 1994 Proposed Rule the fishing sinker market was nearly all lead as tungsten, steel, and bismuth were relatively new to the market. During the past 16 years these substitutes have been tested by anglers and either accepted (tungsten, steel) or rejected and no longer considered a viable substitute (bismuth). Specific market share breakdowns can only be calc ulated by obtaining production volumes from fishing sinker producers, following a similar methodology used in the 1994 Proposed Rule. Specific percentages for each option are not provided because without production and sales volume from industry they cannot be accurately determined.

While the specific market shares of fishing sinker opti ons cannot be determined at this time, some general assumptions can be made based on observed changes in market size and angler behavior since 1994. Type 1994 2010 Expected Future Change Reason for Change

Lead >90% Assumed to be ≤ 85% decrease concerns over toxicity

Steel not on market small increase ch eaper than other substitutes

Tungsten not on market second to lead increase most popular substitute, superior performance to lead

Brass small small decrease other substitutes perform better, toxicity

concerns

Zinc small very limited decrease toxicity concerns, currently hard to find on market, smallest found was 1oz

Bismuth very small no longer on market remain off market inefficient substitute

Tin very small small remain constant limited applicability for lead substitute

Plastic brand new very limited uncertain development of new plastics is common

Biodegradable not on market brand new increase inexpensive, 'green' product, good reviews from anglers

Ceramic not on market brand new uncertain depends on product improvements

Putty brand new small increase allows for flexibility, reusable, primarily used in fly fishing

Limestone not on market brand new increase inexpensive, 'green' product, good reviews from anglers

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

5 First, the size of the fishing sinker market has decr eased since the 1994 Proposed Rule. This assumption is based on a 17 percent decline in anglers from 1991 to 2006 based on the National Survey of Fishing, Hunting, and Wildlife-Associated Recreation published in those years (USFWS 1991 and USFWS 2006). The decline in anglers may be a result of economic forces, unpopular changes to fishing regulations (catch limits, moratoriums), or shifts in recreational preferences over time. Fewer anglers fishing means less fishing equipment, tackle, and other associated products are needed to meet market demand.

Second, the market share of lead sinkers has decreased since 1994. Most states in New England have banned the sale and/or use of lead sinkers since the Proposed Rule. In order to comply with new regulations, anglers and retail stores had to switch from lead to one of the available substitutes in these areas. Tungsten is the current subs titute of choice for most anglers, so its market share has increased considerably since 1994 to meet sinker demand in New England.

Third, some anglers seem to be voluntarily switching fr om lead sinkers to nontoxic alternatives because of health or environmental concerns. This would cause a decrease in the lead market share for sinkers and increase the market share for nontoxic sinker options.

B. Retail Prices for 2010 Retail prices of bullet sinkers for lead and a set of common substitutes is provid ed in Table 3. These prices were pulled from national chains when possibl e, but due to patents or similar constraint, some products have limited sources. However, all products are available nationwide via the internet. Lead sinkers cannot legally be sold in (or shipped to) some states in certai n sizes or at all. For those states the price of lead provided is inapplicable. The prices are meant to provide a general sketch of cost differences between lead sinkers and available substitutes.

Table 3 displays the retail price per sinker using the largest package sold by the retailer. Most sinkers are sold in packages; the price per package was divided by the number of sinkers it contained to arrive at the prices displayed in the table. Since not all sinker packages contain the same number of sinkers, these calculations were done to provide a consistent comparison across all weights and types.

Table 3. Retail Price of Lead Bullet Sinkers and Substitutes Type 1/8 oz 1/4 oz 3/8 oz 1/2 oz Adjustable Source

Lead $ 0.08 $ 0.14 $ 0.19 $ 0.25 n/a Bass Pro Shop
Steel $ 0.11 $ 0.13 $ 0.16 n/a n/a Bass Pro Shop Tungsten $ 0.92 $ 1.50 $ 2.12 $ 2.83 n/a Bass Pro Shop

Brass $ 0.42 $ 0.71 $ 0.83 $ 1.00 n/a Bass Pro Shop
Zinc n/a n/a n/a n/a n/a smallest found 1oz
Bismuth n/a n/a n/a n/a n/a found for jigs only
Tin n/a n/a n/a n/a n/a split-shot only
Plastic n/a n/a n/a n/a n/a found for jigs only Biodegradable $ 0.21 $ 0.30 $ 0.60 $ 0.60 n/a Tacklesmith
Ceramic n/a n/a n/a $ 0.42 n/a Big Ten Tackle Putty a n/a n/a n/a n/a $ 6.49 Green Tackle

Limestone $ 0.25 $ 0.30 $ 0.60 $ 0.60 n/a Rocky Brook Sinkers

a putty is labeled ‘adjustable’ because the angler can make the weight in any shape or weight by molding the putty onto the line and adding or removing putty until th e desired shape and size is achieved. The putty is also reusable.

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

6 

## III. Overview of Comments Received

Over 7,500 emails have been submitted to the dock et center via the OPPT inbox. More than 8,600 comments have submitted on regulations.gov. Since th e letter to deny the ammunition portion of the petition was sent to the petitioners, approximately 4,000 of the 8,600 comments have been submitted. Of these 4,000 comments, over 3,000 are specific to lead fishing sinkers.

Of the actual letters uploaded to da te on regulations.gov, there were (6) letters submitted on behalf of States or signed by government officials, (10) from organizations against the ban, (3) from organizations for the ban, and (1) from an organization neither for nor against the ban.

Of the original comments submitted many addressed th e following key issues (for specific comments see Section IV):

Scientific

 Ingestion of fishing sinkers has toxic effects, how ever it is not demonstrated at a population level

 Loon populations are increasing

 More anglers may melt their own lead to make sinkers at home and therefore increase risk from inhalation State-Based

 States, in conjunction with USFWS, are constan tly working towards cons ervation, research and are already taking the necessary steps to protect lead-related risks from hunting and angling activities

 Policy development is biologically, socially and economically complex and should be held at the state level Alternatives and economic

 Alternatives are not readily available, less practical and can be significantly more expensive

 The cost of raw materials drives the price of the alternative, not market demand

 Increased cost of alternatives w ill cause a decrease in anglers, th erefore create a loss in sales and tax dollars for state and natural resource management and conservation

 Economic impact to the recreational fishing industry would be significant



## IV. Details of Comments Received

Note: All comments can be found on www.regulations.gov

A. The following were letters submitted from states or signed by government officials against the ban on lead fishing sinkers: 1. Arizona Game and Fish Department – signee, Larry Voyles, Director 2. Kentucky Department of Fish and Wildlife Resources –signee, Dr. Jonathan Gassett, Commissioner 3. Virginia Department of Game and Inland Fish eries – signee, Robert W. Duncan, Executive Director
4. Association of Wildlife and Fish Agencies – signee, 

### John E. Frampton, President and Director of the South Carolina, Depart ment of Natural Resources
5. National Assembly of Sportsmen’s Caucuses (s ignees Rep Mike Pitts (SC), Rep Mike Burris (AZ), Senator Robin Webb (KY)) 6. Nebraska Legislative Sportsmen’s Forum – signee State Senator Fulton

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

7 B. The following organizations submitted letters against the ban on lead fishing sinkers: 1. Allied Conservation Groups ( 30 undersigned organizations)
1. American Fly Fishing Trade Association 2. American Sportfishing Association 3. Archery Trade Association 4. BASS, LLC 5. Berkley Conservation Institute 6. The Billfish Foundation
7. Boone and Crockett Club 8. The Campfire Club of America 9. Catch-A-Dream Foundation 10. Center for Coastal Conservation 11. Congressional Sportsmen’s Foundation 12. Conservation Force 13. Dallas Safari Club 14. International Game Fish Association 15. Mule Deer Foundation 16. National Assembly of Sportsmen’s Caucuses 17. National Marine Manufacturers Association 18. National Rifle Association 19. National Shooting Sports Foundation 20. North American Bear Foundation 21. Northwest Sportfishing Industry Association 22. Quality Deer Management Association 23. Rocky Mountain Elk Foundation 24. Ruffed Grouse Society 25. Safari Club International 26. Shikar Safari Club 27. Shimano Sport Fisheries Initiative 28. Texas Wildlife Association 29. Wild Sheep Foundation 30. Wildlife Forever 2. Allied Sportsmen’s Associations of Florida 3. American Sportfishing Association 4. Association of Northwest Steelheaders
5. Boat US – Boat Owners Association of the United States 6. Crappie.com
7. Garden State Seafood Association 8. National Marine Manuf acturers Association 9. Southeast Alaska Fishermen’s Alliance 10. Michigan United Conservation Clubs

C. The following organizations submitted a letter supporting the ban on lead fishing sinkers: 1. Loon Preservation Committee 2. National Wildlife Federation 3. The Wildlife Society

D. The following organizations have submitted le tters neither supporting nor opposing the ban on lead fishing sinkers: 1. Sport Fishing Institute of British Columbia (Canadian organization)

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

8 E. Summary of State or government official comments 1. Arizona Game and Fish Department

 Natural waters of Arizona do not readily dissolve lead therefore exposure to lead from sinkers would occur through direct ingestion only

 Most water bodies in Arizona are too deep a nd/or are urban reservoirs therefore exposure from direct ingestion is unlikely

 Type of species most affected by ingestion of lead sinkers are not prevalent in Arizona

 Wildlife management should be made at a population level

 The issue of lead sinker regulations should be a scientifically based and localized effort

 The economic impacts would be substantial an d reduction in fishing would occur due to increased costs

2. Kentucky Department of Fish and Wildlife Resources

 Little evidence is available which supports that th e loss or ingestion of lead sinkers by birds is an issue in Kentucky

 Common loon and trumpeter swan populations are stable

 States where loon populations are declining have implemented restrictions as listed in the State regulations (Section I) above.

 Kentucky supports monitoring and modeling for exposure and population level effects as well as additional scientific research

 The economic impacts on the angling community would create unnecessary hardships

3. Virginia Department of Game and Inland Fisheries

 States, in conjunction with USFWS, are consta ntly working toward conservation, research and are taking the necessary steps to protec t lead-related risks from hunting and angling activities

 Policy development is biologically, socially and economically complex and should be managed at the state level. While some states require regulation, others are successful using voluntary mechanisms and therefore should be handled at the state level

 EPA regulation is unnecessary due to state fish and wildlife commitment and management

 References submitted by the Association of Wildlife and Fish Ag encies (#5 below)

4. Association of Wildlife and Fish Agencies

 States, in conjunction with USFWS, are consta ntly working towards conservation, research and are taking the necessary steps to protec t lead-related risks from hunting and angling activities

 Policy development is biologically, socially and economically complex and should be managed at the state level

 Does not believe that risk to fish and wildlife from lead fishing tackle poses an unreasonable risk

5. National Assembly of Sportsmen’s Caucuses

 The economic burden on anglers could result in the loss of state income due to a decline in license sales and taxes

 Policy development is biologically, socially and economically complex and should be managed at the state level.

 While some states require regulation, others are successful using voluntary mechanisms and therefore should be handled at the state level

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

9 6. Nebraska Legislative Sportsmen’s Forum – Senator Fulton (signee)

 A ban would not be biologically justified

 The economic burden on anglers could result in the loss of state income due to a decline in license sales and taxes

 Substitutes are not readily availa ble and costs are substantial

 Policy development is biologically, socially and economically complex and should be managed at the state level

F. Summary of unique organizational comments a gainst the ban on lead fishing sinkers

 Banning lead will prevent innovatio ns such as create coatings or bonded materials which allow lead sinkers to pass through the body without toxic impact (ASA)

 Lead exposure most likely occurs through direct ingestion and is soluble in instances where the water is very basic or acidic therefore fishing would not occur. (ASA)

 Handling lead fishing sinkers does not pr esent a health hazard to humans (ASA)

 Concern about the stock of lead sinkers that fish ermen currently own, and what would happen to them after a ban. (Crappie.com/NMMA)

 Potential impact to the commercial fishi ng industry (Garden State Seafood Association)

o Commercial fishermen operate predominately in non-U. S. Waters

o Lead sinkers used by commercial fisherman are not readily digestible and losses are at a minimum

 Wildlife exposure in marine envi ronments are less likely and have very little scientific evidence (Garden State Seafood Association)

 A ban is unnecessary and currently adequate ly regulated where needed (Michigan United Conservation Club)

G. Summary of organizational comments neither for nor against the ban on lead fishing sinkers

 Reasoning behind why Environment Canada decide d not to proceed with a ban on importation and manufacture of small lead-base fishing lure s and weights (Sport Fishing Institute of BC)

H. Summary of organizational comments for the ban

 Provided additional studies and further suppor t for the petitioners argument for a ban

 Provided reference paper; Sources and Implications of Lead Ammunition and Fishing Tackle on Natural Resources (The Wildlife Society)

 Provided reference paper, Technical Review #67, Lead in the Environment (National Wildlife Federation)

 Provided policy positions on lead in fishing sink er and ammunition (e. g. support for less toxic alternatives, education to community, resear ch) (The Wildlife Society & National Wildlife Federation)

I. Summary of unique individual comments against the ban

 Economic concerns; specifically whether fishing w ould still be affordable if lead tackle were no longer available

 The Petition does not contain enough scien tific evidence to warrant a ban

 Suggested a two year phase-out of lead tackle sale s to protect small business’ inventory instead of immediate ban on lead manufacture

 Believes that lead pollution should be addressed locally for waterways

 Suggested warning labels on lead tackle

 Believes that it is unfair to grant the fishing si nkers portion of the petition but deny ammunition

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

10 

## V. References

1. Massachusetts Division of Fisheries and Wildlife (MADFW). (2010). Website. Lead Sinkers/Jigs and Loons in Massachusetts. Retrieved September 21, 2010 from http://www.mass.gov/dfwele/dfw/recreation/fishing/lead_sinkers_loons.htm

2. Minnesota Pollution Control Agency (MPCA). (20 10). Website. Let’s Get the Lead Out: Non-lead alternatives for fishing tackle. Retrieved September 21, 2010 from http://www.pca.state.mn.us/index.php/living-gr een/living-green-citizen /household-hazardouswaste/nontoxic-tackle-let-s-get-the-lead-out.html

3. New Hampshire Fish and Game Department (NHFGD ). (2010). Brochure. Let’s Get the Lead Out. Retrieved September 21, 2010 from http://www.wildlife.state.nh.us/Fishing/Fishing_PDFs/Lets_Get_the_Lead_Out.pdf

4. New York State, Department of Environmental C onservation (NYDEC). (2004). Press Release. Sale of Small Lead Sinkers to Be Banned in Ne w York. Retrieved September 21, 2010 from http://www.dec.ny.gov/press/12605.html

5. State of Illinois. (2010). Public Act 096-0061. Lead Sinker & Lead Jig Ban. Retrieved September 21, 2010 from http://www.ilga.gov/legislation/billstatus. asp?DocNum=1269&GAID=10&GA=96&DocTypeID=SB &LegID=42210&SessionID=76&SpecSess =

6. State of Maine. (2003). 12 §12663-A. Unlawful Sale of Lead Sinkers. Retrieved September 21, 2010, from http://www.mainelegislatu re.org/legis/statutes/12/title12sec12663-A.pdf

7. State of Vermont. (2004). H.516 An Act Relating to a Prohibition Against the Use and Sale of Lead Sinkers. Retrieved from http://www.leg.state.vt.us/docs/legd oc.cfm?URL=/docs/2004/bills/passed/H516.HTM

8. U. S. Department of the Interior, Fish and Wild life Service. (2010a). Website. Rachel Carson NWR Visitor Opportunities. Retrieved September 27, 2010 from http://www.fws.gov/northeast/rachelcarson/opportunities.html#fishing

.

9. U. S. Department of the Interior, Fish and Wild life Service. (2010b). Website. Red Rock Lakes NWR Fishing Information. Retrieved September 27, 2010 from http://www.fws.gov/redrocks/FishingRegulations.htm

.

10. U. S. Department of the Interior, Fish and Wild life Service. (2010c). We bsite. Assabet NWR Visitor Opportunities. Retrieved September 27, 2010 from http://www.fws.gov/northeast/assabetriver/opportunities.html

.

11. U.S. Department of Interior, Fish and Wildlife Service. (2000). Federal Register. Vol. 65, No. 93. 1999-2000 Refuge-Specific Hunting and Sport Fishing Regulations. Final Rule. May 12. 30772. http://www.gpo.gov/fdsys/pkg/FR-2000-05-12/pdf/00-11410.pdf

12. U.S. Department of Interior, Fish and Wildlife Service. (1999). Federal Register. Vol. 64, No. 154. Establishment of Lead-Free Fishing Areas. Proposed Rule. August 11. 43834-43836.

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

11 13. U. S. Department of Interior, National Park Serv ice. (2010d). 2010 Yellowstone National P ark Superintendent’s Compendium. Retrieved October 4, 2010 from http://www.nps.gov/yell/planyourvis it/upload/supt_compendium.pdf

14. U. S. Department of Interior, National Parks Serv ice (2009). News Release. National Parks Service Gets the Lead Out! March 10. http://home.nps.gov/applicati ons/release/Detail.cfm?ID=855

15. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1991 National Survey of Fishing, Hunting, and Wildlife Associated Recreation.

16. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation.

17. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New Hampshire.

18. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – Maine.

19. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New York.

20. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation
– Vermont.

21. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2001 National Survey of Fishing, Hunting, and Wildlife Associated Recreation.

22. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2001 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New Hampshire.

23. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2001 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – Maine.

24. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2001 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New York.

25. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2001 National Survey of Fishing, Hunting, and Wildlife Associated Recreation
– Vermont.

## Background Document TSCA § 21 Petition; Pb in Fishing Sinkers and Other Components

12 26. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2006 National Survey of Fishing, Hunting, and Wildlife Associated Recreation.

27. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2006 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New Hampshire.

28. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2006 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – Maine.

29. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2006 National Survey of Fishing, Hunting, and Wildlife Associated Recreation – New York.

30. U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census 2006 National Survey of Fishing, Hunting, and Wildlife Associated Recreation
– Vermont.

31. U. S. Environmental Protection Agency. (2010a). Email. Office of Pollution, Prevention and Toxics and U. S. Fish and Wildlife Service. September 22.

32. U. S. Environmental Protection Agency. (2010b). P hone call. Office of Pollution, Prevention and Toxics and National Parks Service. September 30.

33. U. S. Environmental Protection Agency. (2010c). Phone call. Office of Pollution, Prevention and Toxics and Union Slough NWR. Sept. 27, 2010.

34. U. S. Environmental Protection Agency (USEPA). (1994). Draft Report. Lead Fishing Sinker Proposed Rule: A Summary of Public Comments. September.

35. Washington Department of Fish and Wildlife (WDFW). (2010). Website. Common Loon: Conserving Common Loons by Managing Use of Lead Fishing Tackle. Retrieved September 21, 2010 from http://wdfw.wa.gov/conservation/loons/

36. Wisconsin Department of Natura l Resources (WDNR). (2010). Website. Get the Lead Out – Wisconsin! Retrieved September 21, 2010 from http://dnr.wi.gov/fish/pages/gettheleadout.html