Thread: Proposed banning of lead shot in sub gauge shotguns report from Southland

Sub Gauge Exemption to Lead shot - a report on the research and consultation completed in the Southland region in late 2012.

The Southland Council is considering the final stage in the non-toxic shot transition, removing the exemption that allows the continued use of lead shot to hunt waterfowl in the so-called ‘sub-gauges’ (.410, 28, 20 & 16 gauges). While most hunters are now satisfied that steel shot ammunition has improved significantly and accept the need to use it to avoid poisoning waterfowl, others seem to be unaware or unaccepting of the need to stop using toxic lead shot.

The need to change to the use of non-toxic shot was identified by the Minister of Conservation back in 1998, who requested that Fish & Game examine the options.
As a consequence, Fish & Game conducted research to assess the incidence of lead ingestion in waterfowl and concluded that lead shot ingestion was a significant problem in New Zealand (as had already been documented in many other countries). For example, in Southland 7.5% of mallards sampled had one or more ingested lead pellets. A #4 lead pellet is ground down to a point where it becomes undetectable by x-ray in around 20 days in a gizzard, so that 7.5% represents the proportion of the population that have ingested lead over the preceding 20 days. In science you can’t really extrapolate from one 20 day period to an annual figure, because ingestion rates are likely to vary from season to season depending on a whole host of different factors such as water depth, seasonal habitat use, alternate grit availability and seasonal food preferences.
However, if you did bend the rules so the 7.5% is a bit more meaningful and assumed that every 20 day period had the same ingestion levels, you could divide a year by 20 day periods and multiply it to get an annualised figure of 137% (365/20 x 7.5% = 137%). While not scientifically valid because of the assumed consistent ingestion rate, (and remember it could be higher in summer as water levels in wetlands drop) it does highlight that lead ingestion rates could have an effect at a population level.

Observation of our rangers and anecdote from industry insiders shows that the use of sub-gauges, primarily in 20 gauge, is becoming increasingly popular with those who wish to continue to use lead shot. Unfortunately, this increase in use will invariably deposit lead shot into our ponds and wetlands where it will continue to poison waterfowl and thereby gradually erode the benefits achieved requiring the change in 12 gauge.

Steel shot loads are commonly used to hunt waterfowl in North America in 20 gauge and some of our Council who have used these loads report that they are surprisingly effective.

The consultation process undertaken with hunters of the Southland Region so far, and nationally with other Fish and Game regions.

Submissions were sought from the public by advertising in the local daily paper.
There were 60 submissions; 57 in favour of retaining lead shot for 20ga shotguns, 2 in favour of removing the exemption and one that was not opposed provided suitable ammunition was available.

Most of the submissions against the proposal cited the poor performance of steel shot and the cruelty to ducks that it caused. Many believed that there was little evidence for the poisoning of ducks by lead or that the research was poor or not applicable to NZ.

Many claimed that young people, women and the elderly needed to use 20ga shotguns as the recoil using steel, especially in 12 ga was too much. Some said there was no evidence of more 20ga guns being used.

Those that favoured the change said it was unfair to allow some to use lead and not others, that Fish and Game was being hypocritical allowing the use of lead, that lead poisoning was a real issue, and that Fish and Game was trying to protect the environment.

There were also 92 (9 received late) submissions on a pre-printed form that stated “I am totally opposed to the introduction of STEEL for use in sub gauge shotguns for waterfowl hunting.” Many of these were not legible but contained a phone number and address as well as a signature. Most of these contained no extra comment but a few stated that steel was cruel. Lindsay Duncan (Shooters World, Gore) also sent in a petition containing 559 signatures. The petition had at the top “In favour of steel shot” and contained 5 columns, for name, address, phone and a tick for yes or no. Four people were in favour and the rest not in favour of steel shot.

We randomly chose 107 legible names and addresses from this petition list and found that 59% were current game licence holders, 24% were not on the database (no game or fish licence of any kind) and 17% had no current game licence or had a fish licence, either a current one or one in the last 5 years.

We also surveyed hunters from our hunter database.

125 hunters were selected at random from the licence holder database regarding the use of non-toxic shot in 20ga shotguns. Hunters were phoned by staff and asked the following question.

“Hi I am xxx from Fish and Game. The council is considering the use of lead shot in 20 & 16 gauge shotguns for the hunting of waterfowl over water. Initially this exemption was allowed because non-toxic alternative ammunition for these smaller gauges was not available, which is no-longer the case. Non-toxic shot is required when hunting waterfowl within 200m of a water body for 10 and 12 gauge guns, but smaller gauges can use lead. Do you think that this exemption should continue?”

Hunters were also asked “Do you use a 12 ga or a 20 ga shotgun for hunting waterfowl over water, or other”

Generally a discussion occurred and staff recorded the responses and an explanation.

63 (50%) hunters favoured a change, 12 (10%) were not sure and 50 (40%) were opposed to a change. 4% of hunters used sub gauge shotguns(5 20ga and 1 16ga).

The New Zealand Fish and Game Council has considered this matter at its November 24-25, 2012 meeting and has received responses from other regions. Five regions are in favour of removing the exemption, with six in favour of retaining it and one region is undecided. The undecided region (Hawkes Bay) wanted more information on the extent of use of sub gauge shotguns.

Other regions made little comment although some were made;
Northland, Auckland , Wellington, North Canterbury - opposed to the change with no explanation
Eastern - Agree with the change in a split vote (three against) but wanted a transition period.
Taranaki – no proof of more lead shot entering water ways, use of 20ga guns by juniors, females and those with injuries was considered to have merit. Opposed to the change.
Nelson, West Coast, CSI, agreed with the need for a change. Nelson wanted more data about the number of sub gauge users to support the decision. CSI offered the strongest support with several reasons, similar to the ones proposed by this council for the removal of the exemption.
Otago – opposed to the change, use of 20ga by junior hunters is still a valid reason to retain the exemption, and sub gauge use is still minor.

A reasonably common theme is that a change would disadvantage young hunters in particular and discourage their participation. Various members of our Council have promoted maintaining the exemption for junior hunters, recognising the increased recoil associated with using higher velocity steel shot loads.

At its December 2012 meeting the council considered this report and the written and oral submissions that were presented to it from hunters and the public.

At its February 2013 meeting the Southland Council considered all the evidence and submissions presented and other information they had research themselves and resolved:

“That the Southland Council prohibits the use of toxic shot in all “sub-gauges”, excluding 410g shotguns while hunting waterfowl within 200m of a waterway 3m or more wide and that an exemption be allowed for junior hunters. This will take effect over a three year transition period commencing game bird season 2014/5 by encouraging the voluntary use of non-toxic shot, in 2015/6 by requiring the use of non-toxic shot on public waterways, and in 2016/7 by requiring the use of non-toxic shot within 200m on all waterways over 3m wide. With the proviso that the Southland Council would adopt an alternative transition to ban non-toxic shot in “sub-gauges” if proposed by the New Zealand Council.”

Other fish and game councils will be asked if they would reconsider an amended phase out process based on the above.

Maurice Rodway, Manager
February 2013