Continued high lead levels in condors prove the need for nonlead ammo requirement

July 22nd, 2013 · by Garrison Frost


In the debate over current legislation that would require nonlead ammunition for all hunting in California, opponents continue to note that lead levels in California Condors continues to remain at high levels despite a 2007 ban on lead ammunition in their range. They tout this fact as proof that Assembly Bill 711 isn’t necessary, but they’re undercutting their own argument by referencing the condor. Clearly, they don’t know much about the condor, and haven’t read the research.

Research shows that lead levels in Turkey Vultures and Golden Eagles have dropped within the California Condor range since 2008, but levels in condors persist. The reasons for this have to do both with the condor and with our failed efforts thus far to reduce lead from ammunition in their range.

Published science is absolutely conclusive that the primary source of lead poisoning in condors is ammunition. This is due to isotopic comparison of lead in condors matches that from ammunition, identification of actual buckshot and bullets found in poisoned condors, and tracking sick condors back to carcasses that have lead in them.

Condors are incredibly efficient scavengers, covering a wide range and identifying numerous sources of food. This range is far greater than that of the Turkey Vulture or the Golden Eagle. Probability indicates that even if only 1% of carcasses contain lead, there’s a 50% chance that a condor will encounter that source in a year. If only 5% of the carcasses contain lead, the probability that a condor will encounter lead increases to nearly 100%. (See page 5 of the above-referenced study)

And it only takes that one encounter to sicken or kill a condor. Moreover, condors are flocking animals, increasing the chances that a single source of lead will poison multiple birds.

Lead ammunition continues to be a problem in the condor range for a number of reasons. Compliance with the 2008 law is far from universal, due to limited enforcement and inadequate hunter education. And poachers in the range are likely still using lead.

Condors continue to be poisoned for the simple reason that we haven’t done enough to remove lead ammunition from their environment. AB 711 is the latest in a series of efforts to accomplish this. Earlier measures – including public education, voluntary bans, and AB 821 – have thus far failed to eliminate the threat from lead ammunition for the condor. Clearly, we have tried measures that required less effort on our part, but these have failed.

This said, the California Condor is not the sole reason we are advancing AB 711. We are also deeply concerned about the danger that lead ammunition poses for other wildlife, as well as public health.




Categories: Audubon California · Bird conservation · California Condor · Lead ammunition · Pollution

7 Comments so far ↓

  • Anthony Canales

    Of course.

    I guess that means that all Audubon offices nationwide manifest and dispose of their fluorescent lights and compact fluorescent lights in landfills approved for wastes containing mercury.

    Given the presence of mercury contamination in fish at San Antonio Reservoir, south of Pinnacles National Park in Condor Country, one would have thought you would have been more up to date on environmental threats.

  • Garrison Frost

    Hard to keep track of the red herrings. Light bulbs?

  • anthony canales

    Mr. Frost’s reliance on “peer reviewed” science ignores the apparently common practice of researchers not showing all their data to their peer reviewers.

    In other words, garbage in, garbage out.

    As for tolerance of elements and chemicals, does Mr. Frost show as much outrage over the mass propagation of light bulbs containing mercury as he does for ammunition containing lead? Mercury in the environment adversely impacts fish and the bird species that feed on them. One can only wonder.

  • Garrison Frost

    All this seems to be begging for a long response, but I’m not going to bother, other than to say that anytime the lead lobby wants to support their claims with peer reviewed science, that’ll be great. Until then, we’ll interpret all of this muddle as another way of saying: a little lead in the environment is OK, and so is a little lead in your food. No matter what words they use, this is what the lead lobby is saying.

  • Anthony Canales

    The problem is one of selective language and parsing.

    Particles and fragments “consistent” with lead ammunition are likely come from the copper jacket material used in bullet construction. Made from guilding metal, these can contain copper, zinc and even lead under various specifications.

    But it’s also known that radiographs showing metallic lead fragments can also show exit wound indications, or exit wound indications are noted in the discussion related to the dissection of the carcass related to that particular radiograph.

    If the metallic lead core is fragmenting along with the jacket as claimed, what is causing the exit wound in these cases?

    Also, lead’s malleability generally speaks against the kinds of fragmentation that the Condor Team is proposing, given the relative dearth of “fragment positive” radiographs throughout the term of the program.

    In the meantime, evidence is piling up that behavioral training and conditioning by the Program is having no effect on condors gathering up microtrash. While the program continues to maintain that the microtrash threat is limited to condor chicks only, I personally have a hard time accepting that the shards of glass and other sharp items swallowed by adult condors is not having an injurious effect on them as well.

    If sharp items can become imbedded in loons and waterfowl, why not condors?

    As such, the microtrash threat is the more serious threat in my personal opinion than any alleged threat alleged due to lead ammunition.

  • Anthony Canales

    Mr. Frost’s impassioned comments above show serious flaws in thinking and an incomplete presentation of the research and evidence available to stakeholders and the public record. As such, I personally find it to be unpersuasive in it’s advocacy for AB 711.

    For example, in the UC Davis study cited above, authors Kelly et al cited limited golden eagle data from “before” and “after” periods from samples taken at Tejon Ranch. Time frames noted were late 2007 and Spring 2008 as the “before” time period used to establish a baseline of scavenger blood lead levels prior to the Condor Zone lead bullet ban due to be implemented on July 1, 2008.

    Unfortunately for the authors of the study and their hypothesis, Tejon Ranch implemented a voluntary lead bullet ban as of January 1, 2008. This included not only centerfire projectiles, but also included bird shot used in hunting upland game and rimfire rounds used in rodent control.

    Any elevated blood lead levels found in scavengers consuming lost game or offal in the field after January 1, 2008 on Tejon Ranch could thus not be related to claimed ammunition ingestion from hunters “pre-AB 821″. Yet it is clear from the record that vultures and eagles did have elevated blood lead levels. This suggests alternative sources of lead in the environment. Given previous evidence of vultures eating microtrash and attacking paint on buildings, these elevated lead levels in the vultures at least points to alternative sources of lead in the environment as a true source of lead in these avians.

    In addition, Mr. Frost’s reliance upon “conclusive” research related to isotopic compositional analysis of lead in condors is troubling given his claims that opponents of AB 711 “have not read the science”.

    In hearings with the California Fish & Game Commission in June and August of 2009, opponents of lead ammunition bans by regulation produced evidence and testimony to the factual errors and withheld data specific to the key isotopic study being presented at the time, Church et al 2006.

    One scientist, Dr. Erik Randich, noted the various false assumptions of the Church team regarding the traceability of the lead used in ammunition manufacture. In addition, he noted how they cited studies in a way that showed that they did not properly understand the data and conclusions in those studies, even one as simple and reliable as one on the manufacture of .22 ammunition.

    Another scientist, Dr. Don Saba (specifically a PhD chemist), produced additional evidence garnered from Freedom of Information Act documents gathered by stakeholders showing that the Church researchers excluded from data presented to their peer reviewers measurements in their possession showing condor blood lead isotope measurements outside of the narrow band that they are proposing as “evidence” proving a direct link between ammunition and elevated condor blood lead levels. Likewise these documents, in the form of emails between researchers, was presented to the Fish & Game Commission in August of 2009. This total presentation, including the data noted above, was instrumental in the Commission’s final vote of 4-1 against additional lead ammunition ban (in this case lead bird shot) being imposed in “Condor Country” dear zones.

    The data presented to the Commission was of sufficient scope to cause Commissioner Richard Rogers to comment to the effect that studies presented previously to that date in support of linking lead ammunition and lead in condor blood lead levels were “pseudo-science”. Church et al 2006 was one of the studies presented to the Commission in the Special Hearing on the Condor and Lead Ammunition in August of 2007.

    Continued reliance by lead ban proponents on a study that has the foundational and methodological flaws as Church et al 2006 does not lend any credence to Mr. Frost’s arguments.

    Another major failing in Mr. Frost’s arguments is related to “having not done enough” to reduce lead ammunition availability to condors.

    It is remarkable that ammunition ban proponents were able to ram through the AB 821 ban based upon the then arguments that only a “mandatory ban” would work.

    But evidence in the record shows good hunter compliance in California for AB 821, and also good hunter voluntary compliance in Arizona with various “free ammo” giveaways, discount tickets and a host of other subsidies and incentives for such practices as using “lead free” ammunition, burying gutpiles, or even transporting gutpiles to scientists in Arizona at a time when concerns over chronic wasting disease jumping from Eastern Utah to the Northern Arizona Strip were being discussed.

    In the Arizona case and the California case, one should see reductions of some kind in Condor blood lead levels given the reduction of exposure through compliance. This is especially so given that condors are usually not the first scavengers to arrive upon the scene of a carcass lost by hunters, or offal left in the field after a successful hunt.

    Documents obtained by stakeholders show that condors get a “late” start in each days carrion hunt when compared to ravens, crows, coyotes, vultures and eagles.

    Personal observation of crows and ravens along Highway 1 in the Big Creek area in June of 2011 shows that crows patrol for carrion along the road by sunup, around 6:00 AM. Turkey vultures were coursing over roadside sites, including DOT repair areas, as early as 7:30 AM. Data garnered by stakeholders, including GPS tracking data, shows condors not moving off of roost-sites until the mid-morning period (ie around 10 AM), and roosting up again in the afternoon (ie around 5 PM).

    As such, given the intense competition for carrion by avian scavengers and land scavengers, the idea that the “one and a million” exposure is based upon a statistical possibility of a whole carcass’s worth of exposure to a flock of condors is dubious at best.

    What is well known and documented, from Condor Program documents in the possession of stakeholders to studies such as Mee et al 2007, and “new” commentary by landowners in the Kolob Reservoir area of Utah and the Bear Valley Springs area of California is that condors are eating trash and contaminated materials not related to ammunition in prodigious quantities.

    Given that Joseph Brandt presented that 68 of 69 condors spent the June through Mid October period of 2012 in the Bear Valley Springs area, in a location where there is no evidence of hunting and in a time period before the major hunting seasons are getting underway, it is hard to rationalize that lead ammunition is the source of lead exposure to condors being found in USFWS blood lead data for that period. Given their relatively immediate relocation back to Bitter Creek by the end of October 2012, well deep into the condor zone, and while crossing Tejon Ranch’s prohibited lead ammo zone, and then being exposed to proffered feeding for fall trap up, it’s hard to imagine anything but non-ammunition sources of bioavailable lead being the culprit in these cases of elevated blood lead exposures in condors.

    Stakeholders have reached out to Audubon and it’s partners in the lead ban movement as to providing the raw data, and not cherry picked studies. One lobbyist even asked an NRA official as to, in effect ” what would it take” as far as data presentation to move the process along. When told that all the raw data was needed, no further cooperation seems to have been Audubon’s answer.

    It is up to the lead ban proponents to provide not just the “cherry-picked” “psuedo-science” here. It is up to the lead ban proponents to move the process back to the Department of Fish & Wildlife, and away from harried Legislators and their staffs whose job burden allows them only minutes to pour over tens of thousands of pages of documents and data to understand the case. Until then, there should be no support from hunting and shooting stakeholders for AB 711.

  • Mark Bower

    The study notes that condors have indeed fed on carcasses with lead fragments. If these carcasses were in the lead-free zone, then this is an issue of compliance. Hunter compliance rate has been 99% according California Fish and Wildlife. It’s more likely that poachers are the proximate cause of lead tainted carcasses and increasing the non-lead area will not reduce the number of poachers using lead. I question the purpose of the push for a larger non-lead zone and also that the requirements of the new law expand to include upland game loads. This appears to be more ant-hunting than sound science.