Assembly Committee on Environment and Solid Waste
The Office of Legislative Services Office of Public Information
Room B50
State House Annex
P.O. Box 068
Trenton, NJ 08625-0068
Dear Chair Kennedy, and Honorable Members of the Assembly Environment and Solid Waste Committee,
We the undersigned organizations, representing tens of thousands of sportsmen and women, other conservationists, and outdoor enthusiasts across New Jersey, are writing to express our strong opposition to Assembly Bill 5021 (AB 5021) and Senate Bill 4225 (SB 4225), an unnecessary Act to ban the use of traditional lead ammunition for the purpose of hunting.
This proposed legislation would cause unintended but easily foreseen negative impacts on conservation efforts within the state. Blanket bans on traditional ammunition are unnecessary and will have negative impacts on hunter participation, DEP funding, and White-tailed deer management. Wildlife agencies across the country agree that the proper course of action regarding non-lead alternatives revolves around voluntary, educational, and incentive-based approaches.
Professional wildlife management agencies, who are responsible for managing and conserving native wildlife, and other groups of professionals that recommend voluntary and incentive-based programs over total bans include the New York Department of Environmental Conservation, Arizona Game and Fish Department, U.S. Fish and Wildlife
Service, Association of Fish and Wildlife Agencies, Northeast Association of Fish and Wildlife Agencies,Midwest Association of Fish and Wildlife Agencies, and the members of the North American Lead–Free Partnership, among many others.
Within the last few months, the New Jersey Fish and Game Council (Council) officially denied a petition for rulemaking to establish a regulation banning the use of lead ammunition for hunting. In the Council’s denial of the petition, they stated, “The Council further finds that an immediate regulatory prohibition, without sufficient stakeholder engagement and market readiness, may reduce voluntary compliance and complicate ongoing conservation outreach initiatives.” The Council’s statement further underscores the challenges of availability and enforcement as significant issues that are likely to stem from establishing such a ban.
The hunting community in New Jersey is already addressing concerns of lead ammunition used while hunting. In 2025, the New Jersey Department of Environmental Protection (Department) joined the North American Lead-free Partnership (Partnership), along with eleven New Jersey conservation and hunting organizations, to proactively address unintended ingestion of lead ammunition fragments by predatory and scavenging birds.
The New York State Lead Ammunition Working Group, in answer to similar legislative and regulatory inquiries published, “Such a ban would be challenging to advance and based on research conducted by the Working Group would come with significant social costs, potentially compromising the effectiveness of other conservation efforts.” The participants in the Working Group included the New York State Department of Health, New York State Department of Environmental Conservation, Audubon New York, Cornell University Wildlife Health Program, Venison Donation Coalition, and New York State Conservation Council. Beginning on page 23 of the report, there is an entire section on potential legislative or regulatory restrictions on lead ammunition that goes on to write that “Voluntary and incentivized programs promoting the use of non-lead ammunition in other areas of the country have had high rates of conversion and success at minimizing secondary mortality of scavenging wildlife that ingest lead fragments from gut piles of harvested big game animals”. The recommended actions from the Working Group included “advancing strategic educational outreach…” and “developing and disseminating the best management practices…”. They did not recommend pursuing a statutory or regulatory ban on lead-based ammunition.
It’s important to note that the form of lead in ammunition (metallic) is not the same, and is less easily absorbed into the bloodstream, than the form in paint or gasoline (organic or inorganic compound). It is disingenuous to conflate lead ammunition with more dangerous forms of lead when talking about elevated blood lead levels in people when there are various commercial uses of lead in cosmetics, brake shoes, waterproofing, children’s toys, and even water systems providing drinking water in major cities.
In reference to consumption of game meat eaten, outside of a mention for women who are breastfeeding, the CDC, FDA, EPA and American College of Pediatricians have no mention of potential human health exposure to lead through consuming meat harvested with lead ammunition. Additionally, the Iowa Department of Public Health (IDPH), a state agency that has tested the blood lead level of Iowa residents for over 15 years stated, “IDPH maintains that if lead in venison were a serious health risk, it would likely have surfaced within extensive blood lead testing since 1992 with 500,000 youth under 6 and 25,000 adults having been screened.”
When it relates to wildlife, what is often missing from the consideration of lead ammunition bans is the well-documented fact that secondary ingestion is only an issue with individual predatory and scavenging birds, not other classes of wildlife. Even then, the populationlevel effect is relatively minuscule and not a serious conservation concern. The best available science shows that accidental ingestion of lead ammunition fragments by some birds only depresses their population growth rate by less than 6%. Lead ingestion and rodenticides combined were found to be 4th in a list of golden eagle mortality causes nationwide, behind collisions, electrocution, and being shot.
The use of best management practices (BMPs) with incentivized voluntary and educational based efforts is the appropriate mechanism for compliance and buy-in from those who use traditional ammunition afield. The unintentional consequences of a ban will ultimately deter conservation funding and efforts in the Garden State by chilling hunting participation and creating an additional and unnecessary access barrier due to lack of availability and associated costs of alternative hunting ammunition.
With better solutions such as BMPs and voluntary and educational incentives, actual mitigation of the infrequent secondary ingestion of lead from predatory and scavenging birds can be realized than outright blanket bans. We ask that you trust in your state’s conservation technical experts and trained professionals in the Department and Council with their reasons expressed in their denial of the initial petition for regulatory change in New Jersey and reject AB 5021 and SB 4225.
Sincerely,
Congressional Sportsmen’s Foundation (CSF)
New Jersey State Federation of Sportsmen’s Clubs (NJFSC)
New Jersey Outdoor Alliance (NJOA)
National Shooting Sports Foundation (NSSF)
National Wild Turkey Federation (NWTF)
Safari Club International- Garden State Chapter (SCI-Garden State Chapter)
Safari Club International (SCI) Sportsmen’s Alliance
