It’s disappointing how little interest this topic has generated and how few have actually read the consultation in any detail whatsoever. I accept that it’s daunting at 226pp and not in a particularly digestible format but it is important and anyone with an interest in shooting should make the effort to try and properly comprehend its contents and the potential outcomes.
The first item of importance is pp13, para 1, last 3 lines:
Military, police and non-civilian uses
are excluded from the scope of this request, as are indoor uses (such as at indoor
firing ranges) and lead-containing propellants
Whether cadet force shooting falls under this exemption (not derogation) is open to discussion and might require justification.
The unreality of the proposals starts to become apparent on pp21:
The Agency is aware that the use of lead shot is required for national and
international competitions in some outdoor sports shooting disciplines. Therefore, an
optional derogation could be considered, involving a licensing system to allow the
relevant athletes to continue training, and suppliers to continue sales to these
authorised athletes. This derogation would also include a licensing system for the
shooting ranges where this training takes place to ensure that lead collection
systems are in place to minimise the risks to the environment from this activity. This
optional derogation requires further consideration to ensure it is practical and
proportionate, noting that it would not be fully effective at removing all the
environmental risks identified.
A complete bureacratic nightmare, plainly dreamt up by someone with no knowledge of shooting sports.
The unreality of continues with the table on pp25-26. This predicts a total reduction in lead release over 20 years of 110,000 tons by banning the use of lead shot and lead bullets for hunting. Tucked away at the bottom of the table is the statement that extending a similar ban to target shooting may only result in a reduction of as little as 390 tons over 20 years. Given that this lead would be fired in a highly controlled situation where the majority of the lead would be recovered one has to question whether additional regulation is justified?
Bear in mind when considering the above figures, they do not include any data on non-civilian use.
I could go on almost indefinitely; pp59 data for Ocular Lesions in Bald Eagles, haven’t seen any of those round here lately; pp65 data relating to death of cattle near a shooting range in Calcutta, India, I’m sure their environmental standards exceed those in the UK. I hope that you get the picture, this apparently comprehensive paper is as full of dodgy data as the Iraq Intelligence Report.
I would urge everyone to make the effort to read the proposal and try to understand why it should be challenged.
Having done that you can then respond to the consultation with some knowledge to support your submission.