July 24, 2023

CSF Stridently Opposes Minnesota DNR’s Emergency Order Prohibiting Lead Ammunition on Certain State Lands

Article Contact: Bob Matthews,

Why It Matters: Across the United States, state fish and wildlife agencies make management decisions based on impacts to species at the population-level. Straying from this nearly universally practiced approach – particularly when creating a rule to prohibit lead ammunition, which is not readily available to meet the demands of sportsmen and women – may unnecessarily threaten the conservation of wildlife and their habitats through decreased conservation funding.


  • The Minnesota Department of Natural Resources (DNR) issued an emergency order prohibiting the use of lead ammunition on the state’s fifty-six Scientific and Natural Areas (SNAs).
  • The order did not go through the formal rulemaking process, which would have required the DNR propose the regulation and then allow the public to provide comments.
  • The DNR issued a similar emergency order in August 2022, only to reverse the order two months later in October, explicitly stating that there was not a sufficient supply of non-lead ammunition readily available, which would have significantly reduced participation and therefore adversely affected deer population management in the state.
  • The Congressional Sportsmen’s Foundation (CSF) strongly opposes the DNR order, given that it is not supported by the verifiable and repeatable scientific evidence that typically informs wildlife management decisions. Further, the order is likely to have negative financial ramifications on the DNR itself and the state’s economy, as hunting generates nearly $1.4 billion dollars each year in Minnesota.

The Congressional Sportsmen’s Foundation delivered a letter to the Minnesota DNR in strong opposition to its recent emergency order creating a rule that prohibits the use of lead ammunition on Minnesota’s fifty-six Scientific and Natural Areas. Wildlife management decisions by state agencies, including the Minnesota DNR, are made at the population-level rather than based on individual instances, and there is no verified or repeatable scientific evidence determining that lead ammunition impacts wildlife species at this population-level.

Further, in the current market conditions, non-lead ammunition is not readily available for hunters to purchase and utilize afield – something that the Minnesota DNR explicitly acknowledged in 2022 when it reversed a similar emergency order banning lead ammunition on certain state lands. The DNR admitted that without a supply of lead ammunition capable of meeting market demands, hunter participation would be reduced, and in turn the significant management benefits that hunters offer to white-tailed deer populations would be curtailed. The market conditions surrounding ammunition remain largely unchanged from a year ago, and in a time where fewer and fewer Americans are participating in hunting, this rule continues to increase barriers to participate and undermines the DNR’s ability to carry out its mission of conserving the state’s wildlife populations.

The Minnesota DNR relies on the unique “user pays – public benefits” structure of the American System of Conservation Funding, and given this rule’s negative impacts on both hunter participation and the ability for sportsmen and women to purchase the ammunition necessary to hunt, this rule stands to reduce revenue that the DNR would receive from the sale of hunting licenses and from excise taxes levied on outdoor sporting goods. According to the U.S. Fish & Wildlife Service (USFWS), last year hunting licenses alone generated more than $34 million for the Minnesota DNR – and when matched by the USFWS with Wildlife Restoration dollars (excise taxes on firearms, ammunition, and other items), that number grew to more than $68 million for the agency. On top of reducing the financial contributions that hunters make to support the DNR’s conservation efforts, this rule would also harm the financial benefit that hunting offers to the state, as the most recent estimates indicate that hunting contributes nearly $1.4 billion to Minnesota’s economy.

This emergency order stands to harm the strong community of Minnesota sportsmen and women that have long supported the DNR by creating an unnecessary barrier to participate in hunting. The ramifications of this rule pervade not only the outdoor traditions that Minnesotans have practiced for generations, but the conservation efforts of the DNR itself. CSF will continue to oppose this rule and others like it, which are not founded on established scientific evidence and instead undermine the very principles of wildlife conservation in America.

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