A First Look at Possible Lead Free Slug Problems
- Thread starter Ballisticboy
- Start date
If we airgunners keep lead pellets from showing up in the gullets of ducks and predatory birds, then this kind of legislation is unlikely to affect airgunning.Just stating a few " FACTS ". The " LEAD BAN " has been in place for years throughout the USA
QUOTE
" The ban on the use of lead shot for hunting waterfowl was phased-in starting with the 1987-88 hunting season. The ban became nationwide in 1991. Nontoxic shot regulations apply only to waterfowl, defined as the family Anatidae (ducks, geese, [including brant], and swans) and coots. Nontoxic shot is defined as any shot type that does not cause sickness and death when ingested by migratory birds. "
But, it's just a matter of time before the " LEAD PELLETS & SLUGS PROJECTILES " , will also be BANNED...
In other words pick up the critters your shoot and eat, bury, or compost them. Don’t let other animals eat them and ingest the lead.
ETA: don't shoot next to bodies of water where pellets will land and get scooped up by ducks, as shotgun shot can.
Now if we are not extremely careful in hunting and pest control, and eagles and condors start showing up with lead poisoning tracked back to actual pellets, then it could be game over for plain lead.
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That was exactly my point... IF. the " GOVERNMENT: US FISH & GAME / EPA ...etc.
Has / have already determined that " LEAD- Shot, Bullets, ..etc.", is a " HAZARDOUS ENVIRONMENTAL MATERIAL ".
Why would they stop @ BANNING ALLL LEAD PROJECTILES, in the very near future...
LEAD Pellets & SLUGS are manufactured from the same type of " LEAD PB BULLETS "...
I've read of a few Shooting Ranges, that don't allow any " LEAD " on their range.
EXAMPLE:
TEJON RANCH HUNTING
RULES & REGULATIONS
It is the hunter's responsibility to know and comply with all local, state and federal laws and hunting regulations. Regulations can be found at www.dfg.ca.gov and www.fws.gov, respectively.No lead ammunition is permitted on Tejon Ranch. NO EXCEPTIONS. Download our Lead ban Agreement....."
Tejon Ranch
hunt.tejonranch.com Last edited:
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I was under the impression that barrel twist weights were not specific to the weight of the ammo, but to the length, as different lengths needed different twist rates to stabilize.
Did I misunderstand something here?
Did I misunderstand something here?
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I've seriously considered " Casting " my own " ALLOY BISMUTH - Bullets & SLUGS ..
Lead-Free Bullet Casting Alloy Bismuth based
This ratio of~ 87.25% Bismuth, 0.75% Antimony and 12% Tin is the best ratio we have come up with as a substitute for lead. This alloy melts at about 395 F and is best cast or poured at about 500F. Testing the hardness with a Lee Hardness Testing Kit, we came up with an average of 19.3 on the Brinnell Hardness Scale, although there was a range during the testing.The bismuth gives you the weight (as close to lead as possible) and the tin helps holds it together and makes it less brittle. This is an alloy we have been asked to make a few times so we decided to make a larger batch and have it easily available to everyone. As we are still testing this alloy, we are offering it at a lower cost and asking customers for feedback and their thoughts on how it works. Yes, we know it costs way more then a lead version, but hopefully with more volume, we can offer better prices in the future. One item of feedback we got from our customer follows:
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Referrs to firearms , federal we are imitation firearms.Just stating a few " FACTS ". The " LEAD BAN " has been in place for years throughout the USA
QUOTE
" The ban on the use of lead shot for hunting waterfowl was phased-in starting with the 1987-88 hunting season. The ban became nationwide in 1991. Nontoxic shot regulations apply only to waterfowl, defined as the family Anatidae (ducks, geese, [including brant], and swans) and coots. Nontoxic shot is defined as any shot type that does not cause sickness and death when ingested by migratory birds. "
( I bet,, You would be required to use " NON-TOXIC / LEAD-FREE SHOT." IF, you were using an " Air Powered Shotgun " to Hunt Waterfowl ),
Nontoxic Shot Regulations For Hunting Waterfowl and Coots in the U.S. | U.S. Fish & Wildlife Service
The ban on the use of lead shot for hunting waterfowl was phased-in starting with the 1987-88 hunting season. The ban became nationwide in 1991. Nontoxic shot regulations apply only to waterfowl, defined as the family Anatidae (ducks, geese, [including brant], and swans) and coots.www.fws.gov
QUOTE
Nonlead Certification for Ammunition Manufacturers
Effective July 1, 2008, ammunition used for hunting of big game and nongame species within the range of the California condor must use a projectile which has been certified to contain less than or equal to 1 percent lead by weight. Projectiles here are defined as "any bullet, ball, sabot, slug, buckshot or other device which is expelled from a firearm through a barrel by force...."
Nonlead Ammunition in California
The Department of Fish and Wildlife manages California's diverse fish, wildlife, and plant resources, and the habitats upon which they depend, for their ecological values and for their use and enjoyment by the public.wildlife.ca.gov
Somehow the " AIR POWERED " Rifles & Pistols were overlooked by the FEDERAL GOVT ? EPA ? ....?
View attachment 315369
Nonlead Ammunition in California
The Department of Fish and Wildlife manages California's diverse fish, wildlife, and plant resources, and the habitats upon which they depend, for their ecological values and for their use and enjoyment by the public.wildlife.ca.gov
But, it's just a matter of time before the " LEAD PELLETS & SLUGS PROJECTILES " , will also be BANNED...
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Barrel twist rates necessary for stability are governed by a lot of things, including, slug length, slug shape, internal mass distribution, moments of inertia and muzzle velocity. The closer the muzzle velocity is to Mach 1 (1116.5 ft/sec) the higher the twist rate needed for stability. Many of the graphs in the original post are based on the slug length.
However, many shooters choose their slugs on slug mass, not slug length, that is why I have included some graphs based on slug mass. When changing the slug material, it is the mass, not the length, that we are mainly changing. This is why I have said if you want to maintain slug mass you will need a much longer slug, which will further increase the barrel twist rate needed.
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Here's an interesting " You-Tube " video testing Slugs at lower " FPS ".
My current understanding thus far....
VISUAL EXAMPLE
.25 cal 16.54-grain GTO Pellet / .25 cal 19.91-grain H&N Baracuda Green Pellet / .25 cal 30-grain H&N LEAD SLUG.
I will need a " 35-grain LEAD Mold ", to cast a " LIGHTER 25 grains & LONGER Slug ", using an " ALLOY BISMUTH ".
Based on my rough " GUESTIMATES "..
The " Alloy Bismuth 25 grain Slug ", might work @ a short distance of 0 - 25 yards ..?
( Factory barrel twist: Airacuda Standard. 1: 17.7 )
The Slug might need a bit more ( Faster ) twist for stability @ longer distances 25 + Yards ...?
My current understanding thus far....
VISUAL EXAMPLE
.25 cal 16.54-grain GTO Pellet / .25 cal 19.91-grain H&N Baracuda Green Pellet / .25 cal 30-grain H&N LEAD SLUG.
I will need a " 35-grain LEAD Mold ", to cast a " LIGHTER 25 grains & LONGER Slug ", using an " ALLOY BISMUTH ".
Based on my rough " GUESTIMATES "..
The " Alloy Bismuth 25 grain Slug ", might work @ a short distance of 0 - 25 yards ..?
( Factory barrel twist: Airacuda Standard. 1: 17.7 )
The Slug might need a bit more ( Faster ) twist for stability @ longer distances 25 + Yards ...?
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The minimum gyroscopic stability occurs immediately after the slug leaves the barrel. As the slug travels down range, the gyroscopic stability increases. This is because the rate of spin loss is much less than the rate of forward velocity loss. Thus, the ratio of spin rate to velocity increases, which is what mainly increases the gyroscopic stability. There may also be some changes in the aerodynamics, giving further increases in stability. The barrel twist rate is normally dictated by the stability requirements at the muzzle.
The relative increase in spin with range may also give a decrease in dynamic stability, leading to an increase in maximum yaw, which will cause group sizes to increase more than normally expected with range. This effect will be dependent on the projectile design. It is all about getting the correct balance between the gyroscopic and dynamic stability factors for the best behaviour at all ranges.
The relative increase in spin with range may also give a decrease in dynamic stability, leading to an increase in maximum yaw, which will cause group sizes to increase more than normally expected with range. This effect will be dependent on the projectile design. It is all about getting the correct balance between the gyroscopic and dynamic stability factors for the best behaviour at all ranges.
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I'm still hoping somebody in the near future, will offer " .25 cal LEAD-FREE SLUGS ", in various weights ( 25 - 30 grains ) to " TEST FIRE "...
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To the author: Great writeup. Sadly, today the stupids at the CA Fish and Game Commission denied my regulatory petition (which has been waiting for a decision for years) to allow big bore BB devices as method of take for wild pig, and as the Commissioner's only stated rationale for the decision one of them mumbled something about not being able to approve this because of the "lead" issue. (BB devices, regardless of the size / caliber, are not firearms in California and are thus legally exempt from California's lead-free requirements that hunters using firearms are required to abide by with ammo.)
No regulation has changed (just another innovative approach denied), but you see where their walnut sized brains are going.
See also: https://www.airgunnation.com/thread...-game-commission-meeting.1280264/post-1425653
Edit, note: Tim Hofstetter, in the past, has answered some of my questions about potential lead-free casting of boolits for actual firearms - specifically in curio and relic calibers, 7.62x54 and 7.62x39. Here is Tim's wisdom, shared with you below:
I have quite a few thoughts to bring to bear here. With luck, I’ll be able to present them in a more-or-less coherent fashion. I’ll avoid beating up on California’s nutty laws for now.
Bismuth alloys seem like an almost-acceptable substitute for lead alloys for bullet casting except for two glaring problems: hardness and brittleness. Bismuth’s baseline (without alloying) Brinell hardness is about twice that of lead, and increases with the addition of tin. Fortunately, it still doesn’t approach the Brinell hardness of copper or gilding metal, so in that respect it’s suitable as cast for many modern firearms provided that the hardness is well compensated for in the selection of powder charges.
The second problem, though, is tougher to deal with: bismuth is an inherently brittle metal, so - although it casts well (better with tin for wetting improvements) it really needs to be cast to size and when fired, unless plated with gilding metal, it may not obturate to fill the rifling grooves of the firearm, leading to cutting, deformation, poor accuracy, and even barrel damage.
Although I can’t speak from personal experience, it’s a very, very strong bet that cast bismuth-alloy bullet will be difficult or impossible to swage in a resizing die from cast size to desired size without introducing microfractures into the bullet, possibly even breaking the bullet outright inside the die. Certainly, even in the best of worlds, bismuth-alloy bullets will require far greater force to run through a resizing die than any but the hardest lead-alloy bullets require.
Something to take into serious consideration in the choice of bullet-casting dies is the fact that all the lead alloys have a positive thermal expansion coefficient… but the bismuth alloys have a negative thermal expansion coefficient. In lay terms, cast lead bullets shrink when they freeze and cool but cast bismuth bullets expand when they freeze and cool; a die which drops 0.311″ lead bullets may drop bismuth bullets that are several thousandths larger in diameter, requiring considerable resizing (see the resizing notes above).
I’m familiar with RotoMetals, having done some small amount of business with them in the past. Today I’m very strongly tempted, just for the sake of my own academic curiosity, to acquire a small amount of their suggested bismuth-tin alloy and try casting bullets using my own bullet molds; I happen to personally own an Ideal 311–467 mold, for example, which throws very nice 180gr RN-GC bullets in my own proprietary lead-antimony-tin alloy and should be expected to throw (some diameter of) bismuth-tin bullets at about 155gr. That mass loss is unfortunate as heck, but I don’t know how to do anything about it short of adding tungsten powder to the alloy, and that would wreck any resizing dies (if the bullets could be resized at all). I’d also be interested to know how those bullets respond to being resized through my own resizing dies. Even if nothing else, they’ll surely want a very different resizing lube than I’ve been using because of the greatly increased resizing force / pressure.
Man it’s irritating that California did that!
I’m curious… 7.62x54r? Mosin-Nagant? For longer distances than the SKS is suited for? Not a bad choice! The bullet diameters of the x39 and the x54r are even very, very nearly compatible - enough that if you used lead-alloy bullets you could use the same bullets for both.
My immediate recommendations? Several. First, slug your guns. Know for sure exactly what bullet diameters they both crave. Be prepared, if necessary, to make undersized bullets and paper-patch them to full diameter. Next, seriously consider swaging your own copper jackets from 5/16″ OD copper refrigeration tubing; that could be done without too much trouble in a custom swaging die. Determine the ID after swaging and cast bismuth-alloy cylindrical slugs to that ID (or one thousandth larger) so the swaged copper tubing gives you an excellent jacket around the slugs. The jackets would beg to be fully annealed after swaging to bring back their softness, then the bismuth slugs pressed into place before crimping the bullet bases. The copper jackets will obturate to to rifling much better than will bare bismuth bullets, and will cost very little in bullet mass (because copper’s density is very close to that of bismuth).
Complicated as heck, I know.
It would be good, too, to experiment with casting bismuth-alloy bullets in .308WIN or .300 Lapua Magnum or .30–40 Krag (all are .308″). Since the alloy expands on freezing, even those may be have too large a diameter, though. If undersized, they could always be paper-patched up. It’s a lot harder to go the other way without shaving by a cutting-type resizing die.
There was one more thing I wanted to address, but I can’t think what it was. … Oh, yes! Loads! If you determine that resizing is even possible with unjacketed bismuth-alloy bullets, and that you’re willing to take the risk of the brittle bullets fragmenting upon impact, do not treat your reloading manual’s “cast bullets” section or “jacketed bullets” section as gospel. Neither will be correct for unjacketed bismuth-alloy cast bullets, which will have a hardness somewhere between the two. Lean toward the “cast bullets” section, which will call for lower powder charges than the “jacketed bullets” section, but work toward the high end, approaching the “jacketed bullets” minimum loads. You’re in mostly uncharted territory. Don’t approach the “jacketed bullets” maximum loads, experiment with a variety of different powders, and tailor for accuracy instead of velocity.
Notes that I've compiled (my own contribution and addition to Tim's excellent answer above):
Equipment Notes for the 7.62x54r: Lyman 2-Cavity Bullet Mold #314299 303 Caliber (314 Diameter) 200 Grain Round Nose Gas Check.)
Equipment Notes for the 7.62x39 (specific to the Yugo 59/66): probably Lee 2-Cavity Bullet Mold C312-185-1R 303 British (312 Diameter) 185 grain 1 ogive radius gas check and C312-160-2R, .311 push through sizer and .30 cal Hornady gas checks
Additional Notes for 7.62x54r: A 314 Dia. cast bullet can be run through sizer. (Slug bore and use sizer to get 312 or 311) However, as Tim Hofstetter mentioned above, if using bismuth alloys, extra precaution should be taken, because “cast bismuth-alloy bullet will be difficult or impossible to swage in a resizing die from cast size to desired size without introducing microfractures into the bullet, possibly even breaking the bullet outright inside the die. Certainly, even in the best of worlds, bismuth-alloy bullets will require far greater force to run through a resizing die than any but the hardest lead-alloy bullets require. (…) a die which drops 0.311″ lead bullets may drop bismuth bullets that are several thousandths larger in diameter, requiring considerable resizing (see the resizing notes above).
Example: Lee Precision .311 bullet sizing kit w/ 7/8x14 threads for any reloading press.
For sizing, Lyman 4500 Lube Sizer Bullet Sizer and Lubricator (or instead, the RCBS Lube-A-Matic-2 Bullet Sizer and Lubricator) plus Lyman Lube and Sizer Die 312 Diameter (or Lyman Lube and Sizer Die 311 diameter). The sizer die mentioned fits Lyman 450/4500 Lube Sizer and RCBS Lube-A-Matic-2 Bullet Sizer/Lubricator.
Which cast bullets are appropriate for the SKS? Notes: So long as you achieve a proper fit in both bore and throat, many cast bullet designs will suffice if not excel. Suggested ones I have seen recommended: Lee’s C.E. Harris-designed C312-155-2R or CTL312-160-2R (tumble lube) or Lyman‘s #311410. Also, if you have Lyman #311291 or #311041 and if they cast large enough. Lastly, even the very old Lyman #321232, also has been recommended for the SKS because it can be sized to fit the rifle.
(ahem)
So, it looks like I won't be buying that airgun after all
Not so long ago I was eyeing a BB device / airgun (some Texan SS that was fully configured, tuned and scoped out by someone who apparently was an experienced airgunner) that had been put on consignment at a local FFL that I visit. It's not the normal place you'd see an airgun, but maybe the seller figured, more eyes will be on it there. I would have "pulled the trigger" on it if this regulatory petition had passed since I would have been able to use it for wild pig hunting. Well, no more. (I will still try to appeal that decision, but certainly no guarantees there.)
So I'm back to hunting with my curio and relic firearms in CA for wild pig. So far my best hunts have been with an old Chi-Com SKS using a variety of lead-free ammo. Go figure.
Cheers (and hope you can escape CA if you are still here).
No regulation has changed (just another innovative approach denied), but you see where their walnut sized brains are going.
See also: https://www.airgunnation.com/thread...-game-commission-meeting.1280264/post-1425653
Edit, note: Tim Hofstetter, in the past, has answered some of my questions about potential lead-free casting of boolits for actual firearms - specifically in curio and relic calibers, 7.62x54 and 7.62x39. Here is Tim's wisdom, shared with you below:
I have quite a few thoughts to bring to bear here. With luck, I’ll be able to present them in a more-or-less coherent fashion. I’ll avoid beating up on California’s nutty laws for now.
Bismuth alloys seem like an almost-acceptable substitute for lead alloys for bullet casting except for two glaring problems: hardness and brittleness. Bismuth’s baseline (without alloying) Brinell hardness is about twice that of lead, and increases with the addition of tin. Fortunately, it still doesn’t approach the Brinell hardness of copper or gilding metal, so in that respect it’s suitable as cast for many modern firearms provided that the hardness is well compensated for in the selection of powder charges.
The second problem, though, is tougher to deal with: bismuth is an inherently brittle metal, so - although it casts well (better with tin for wetting improvements) it really needs to be cast to size and when fired, unless plated with gilding metal, it may not obturate to fill the rifling grooves of the firearm, leading to cutting, deformation, poor accuracy, and even barrel damage.
Although I can’t speak from personal experience, it’s a very, very strong bet that cast bismuth-alloy bullet will be difficult or impossible to swage in a resizing die from cast size to desired size without introducing microfractures into the bullet, possibly even breaking the bullet outright inside the die. Certainly, even in the best of worlds, bismuth-alloy bullets will require far greater force to run through a resizing die than any but the hardest lead-alloy bullets require.
Something to take into serious consideration in the choice of bullet-casting dies is the fact that all the lead alloys have a positive thermal expansion coefficient… but the bismuth alloys have a negative thermal expansion coefficient. In lay terms, cast lead bullets shrink when they freeze and cool but cast bismuth bullets expand when they freeze and cool; a die which drops 0.311″ lead bullets may drop bismuth bullets that are several thousandths larger in diameter, requiring considerable resizing (see the resizing notes above).
I’m familiar with RotoMetals, having done some small amount of business with them in the past. Today I’m very strongly tempted, just for the sake of my own academic curiosity, to acquire a small amount of their suggested bismuth-tin alloy and try casting bullets using my own bullet molds; I happen to personally own an Ideal 311–467 mold, for example, which throws very nice 180gr RN-GC bullets in my own proprietary lead-antimony-tin alloy and should be expected to throw (some diameter of) bismuth-tin bullets at about 155gr. That mass loss is unfortunate as heck, but I don’t know how to do anything about it short of adding tungsten powder to the alloy, and that would wreck any resizing dies (if the bullets could be resized at all). I’d also be interested to know how those bullets respond to being resized through my own resizing dies. Even if nothing else, they’ll surely want a very different resizing lube than I’ve been using because of the greatly increased resizing force / pressure.
Man it’s irritating that California did that!
I’m curious… 7.62x54r? Mosin-Nagant? For longer distances than the SKS is suited for? Not a bad choice! The bullet diameters of the x39 and the x54r are even very, very nearly compatible - enough that if you used lead-alloy bullets you could use the same bullets for both.
My immediate recommendations? Several. First, slug your guns. Know for sure exactly what bullet diameters they both crave. Be prepared, if necessary, to make undersized bullets and paper-patch them to full diameter. Next, seriously consider swaging your own copper jackets from 5/16″ OD copper refrigeration tubing; that could be done without too much trouble in a custom swaging die. Determine the ID after swaging and cast bismuth-alloy cylindrical slugs to that ID (or one thousandth larger) so the swaged copper tubing gives you an excellent jacket around the slugs. The jackets would beg to be fully annealed after swaging to bring back their softness, then the bismuth slugs pressed into place before crimping the bullet bases. The copper jackets will obturate to to rifling much better than will bare bismuth bullets, and will cost very little in bullet mass (because copper’s density is very close to that of bismuth).
Complicated as heck, I know.
It would be good, too, to experiment with casting bismuth-alloy bullets in .308WIN or .300 Lapua Magnum or .30–40 Krag (all are .308″). Since the alloy expands on freezing, even those may be have too large a diameter, though. If undersized, they could always be paper-patched up. It’s a lot harder to go the other way without shaving by a cutting-type resizing die.
There was one more thing I wanted to address, but I can’t think what it was. … Oh, yes! Loads! If you determine that resizing is even possible with unjacketed bismuth-alloy bullets, and that you’re willing to take the risk of the brittle bullets fragmenting upon impact, do not treat your reloading manual’s “cast bullets” section or “jacketed bullets” section as gospel. Neither will be correct for unjacketed bismuth-alloy cast bullets, which will have a hardness somewhere between the two. Lean toward the “cast bullets” section, which will call for lower powder charges than the “jacketed bullets” section, but work toward the high end, approaching the “jacketed bullets” minimum loads. You’re in mostly uncharted territory. Don’t approach the “jacketed bullets” maximum loads, experiment with a variety of different powders, and tailor for accuracy instead of velocity.
Notes that I've compiled (my own contribution and addition to Tim's excellent answer above):
Equipment Notes for the 7.62x54r: Lyman 2-Cavity Bullet Mold #314299 303 Caliber (314 Diameter) 200 Grain Round Nose Gas Check.)
Equipment Notes for the 7.62x39 (specific to the Yugo 59/66): probably Lee 2-Cavity Bullet Mold C312-185-1R 303 British (312 Diameter) 185 grain 1 ogive radius gas check and C312-160-2R, .311 push through sizer and .30 cal Hornady gas checks
Additional Notes for 7.62x54r: A 314 Dia. cast bullet can be run through sizer. (Slug bore and use sizer to get 312 or 311) However, as Tim Hofstetter mentioned above, if using bismuth alloys, extra precaution should be taken, because “cast bismuth-alloy bullet will be difficult or impossible to swage in a resizing die from cast size to desired size without introducing microfractures into the bullet, possibly even breaking the bullet outright inside the die. Certainly, even in the best of worlds, bismuth-alloy bullets will require far greater force to run through a resizing die than any but the hardest lead-alloy bullets require. (…) a die which drops 0.311″ lead bullets may drop bismuth bullets that are several thousandths larger in diameter, requiring considerable resizing (see the resizing notes above).
Example: Lee Precision .311 bullet sizing kit w/ 7/8x14 threads for any reloading press.
For sizing, Lyman 4500 Lube Sizer Bullet Sizer and Lubricator (or instead, the RCBS Lube-A-Matic-2 Bullet Sizer and Lubricator) plus Lyman Lube and Sizer Die 312 Diameter (or Lyman Lube and Sizer Die 311 diameter). The sizer die mentioned fits Lyman 450/4500 Lube Sizer and RCBS Lube-A-Matic-2 Bullet Sizer/Lubricator.
Which cast bullets are appropriate for the SKS? Notes: So long as you achieve a proper fit in both bore and throat, many cast bullet designs will suffice if not excel. Suggested ones I have seen recommended: Lee’s C.E. Harris-designed C312-155-2R or CTL312-160-2R (tumble lube) or Lyman‘s #311410. Also, if you have Lyman #311291 or #311041 and if they cast large enough. Lastly, even the very old Lyman #321232, also has been recommended for the SKS because it can be sized to fit the rifle.
(ahem)
So, it looks like I won't be buying that airgun after all
Not so long ago I was eyeing a BB device / airgun (some Texan SS that was fully configured, tuned and scoped out by someone who apparently was an experienced airgunner) that had been put on consignment at a local FFL that I visit. It's not the normal place you'd see an airgun, but maybe the seller figured, more eyes will be on it there. I would have "pulled the trigger" on it if this regulatory petition had passed since I would have been able to use it for wild pig hunting. Well, no more. (I will still try to appeal that decision, but certainly no guarantees there.)
So I'm back to hunting with my curio and relic firearms in CA for wild pig. So far my best hunts have been with an old Chi-Com SKS using a variety of lead-free ammo. Go figure.
Cheers (and hope you can escape CA if you are still here).
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As I am always seeking some sort of administrative remedy (or perhaps court remedy) to create more options for hunters in CA, recently I authored a new CA petition (Request) for Partial Reconsideration which I submitted to the Fish and Gand Commission's FGC email on Feb. 15, 2023 pursuant to California Government Code 11340.7(c) and the statute to which it refers (11340.6).
Functionally this was submitted as an appeal of the Commission's February denial of my big bore airgun petition to allow hunting of wild pig in CA (2021-007). The Commission has not yet responded to my appeal (technically called a Request for Reconsideration under CA law), despite that the Commission is legally required by law to respond to my new Petition (Request for Reconsideration), which as mentioned is functionally an appeal of the Commission's earlier decision.
As I have already told the Commission, please note that the Petition (Request) for Partial Reconsideration is complete. As noted in the Petition (Request for Partial Reconsideration), where I cited and quoted the California Government Code,
"(c) Any interested person may request a reconsideration of any part or all of a decision of any agency on any petition submitted. The request shall be submitted in accordance with Section 11340.6 and include the reason or reasons why an agency should reconsider its previous decision no later than 60 days after the date of the decision involved. The agency’s reconsideration of any matter relating to a petition shall be subject to subdivision (a)."
The California Fish and Game Commission was required to abide by the California Government Code and process my request for reconsideration but so far hasn't done so.
On February 15, 2023 I submitted the Petition for Partial Reconsideration (a request for reconsideration) to the Fish and Game Commission as is allowed to me under California Government Code 11340.7.
California Government Code has certain requirements. In part, California Government Code Sec. 11340.7 Subsection (a) states the following:
"Upon receipt of a petition requesting the adoption, amendment, or repeal of a regulation pursuant to Article 5 (commencing with Section 11346), a state agency shall notify the petitioner in writing of the receipt and shall within 30 days deny the petition indicating why the agency has reached its decision on the merits of the petition in writing or schedule the matter for public hearing in accordance with the notice and hearing requirements of that article."
This section requires that the Commission notify me in writing of the Commission's receipt of my Petition for Partial Reconsideration (my request for reconsideration) which I sent in on Feb. 15, 2023. As one can see from reading California Government Code 11340.7 Subsection (c),"Any interested person may request a reconsideration of any part or all of a decision of any agency on any petition submitted. The request shall be submitted in accordance with Section 11340.6 and include the reason or reasons why an agency should reconsider its previous decision no later than 60 days after the date of the decision involved. The agency's reconsideration of any matter relating to a petition shall be subject to subdivision (a)."
For this reason, subsection (a) does require the Commission to notify me in writing of its receipt of my request for reconsideration, in the words of the law, "upon receipt." The Commission should therefore have already have notified me in writing of its receipt of my request for reconsideration on Thursday Feb. 16, 2023, the business day following the evening when I emailed in my request to the FGC. Since the Commission has not yet notified me in writing of its receipt of my request for reconsideration, I must assume that staff did not generate and send a letter as required by California Government Code.
I believe an appropriate remedy is for staff to generate this letter of receipt now, to send it to me and to follow the requirements remaining for the Commission under CA Gov. Code 11340.7 (and I have informed the Commission of this).
For all of what the FGC must do, see https://casetext.com/statute/califo...tion-on-petition-upon-receipt-by-state-agency
What this means:
- Within 30 days from Feb. 15, 2023 the FGC is required by law to either deny my request for reconsideration (a petition for partial reconsideration of an FGC decision), or set the matter for hearing.
- The Commission should have already notified me in writing of its receipt of my request, but it can do so now and that part of the requirement will be satisfied so far as I am concerned.
- The Commission must follow the law and process my request for reconsideration. The fact that the Commission already reached a decision at its February meeting does not excuse the Commission from having to either deny my request for reconsideration (a petition for partial reconsideration of an FGC decision), or set the matter for hearing.
- The request for reconsideration is not a matter to be decided by the DFW (Department). By law, it is a Commission decision.
- Finally, the Request for Reconsideration (functionally an administrative appeal process back to the Commission) does not preclude me from later taking up the matter in court if I desire, as the law expressly states that pursuit of reconsideration does not keep the petitioner from following up in court on the matter.
Functionally this was submitted as an appeal of the Commission's February denial of my big bore airgun petition to allow hunting of wild pig in CA (2021-007). The Commission has not yet responded to my appeal (technically called a Request for Reconsideration under CA law), despite that the Commission is legally required by law to respond to my new Petition (Request for Reconsideration), which as mentioned is functionally an appeal of the Commission's earlier decision.
As I have already told the Commission, please note that the Petition (Request) for Partial Reconsideration is complete. As noted in the Petition (Request for Partial Reconsideration), where I cited and quoted the California Government Code,
"(c) Any interested person may request a reconsideration of any part or all of a decision of any agency on any petition submitted. The request shall be submitted in accordance with Section 11340.6 and include the reason or reasons why an agency should reconsider its previous decision no later than 60 days after the date of the decision involved. The agency’s reconsideration of any matter relating to a petition shall be subject to subdivision (a)."
The California Fish and Game Commission was required to abide by the California Government Code and process my request for reconsideration but so far hasn't done so.
On February 15, 2023 I submitted the Petition for Partial Reconsideration (a request for reconsideration) to the Fish and Game Commission as is allowed to me under California Government Code 11340.7.
California Government Code has certain requirements. In part, California Government Code Sec. 11340.7 Subsection (a) states the following:
"Upon receipt of a petition requesting the adoption, amendment, or repeal of a regulation pursuant to Article 5 (commencing with Section 11346), a state agency shall notify the petitioner in writing of the receipt and shall within 30 days deny the petition indicating why the agency has reached its decision on the merits of the petition in writing or schedule the matter for public hearing in accordance with the notice and hearing requirements of that article."
This section requires that the Commission notify me in writing of the Commission's receipt of my Petition for Partial Reconsideration (my request for reconsideration) which I sent in on Feb. 15, 2023. As one can see from reading California Government Code 11340.7 Subsection (c),"Any interested person may request a reconsideration of any part or all of a decision of any agency on any petition submitted. The request shall be submitted in accordance with Section 11340.6 and include the reason or reasons why an agency should reconsider its previous decision no later than 60 days after the date of the decision involved. The agency's reconsideration of any matter relating to a petition shall be subject to subdivision (a)."
For this reason, subsection (a) does require the Commission to notify me in writing of its receipt of my request for reconsideration, in the words of the law, "upon receipt." The Commission should therefore have already have notified me in writing of its receipt of my request for reconsideration on Thursday Feb. 16, 2023, the business day following the evening when I emailed in my request to the FGC. Since the Commission has not yet notified me in writing of its receipt of my request for reconsideration, I must assume that staff did not generate and send a letter as required by California Government Code.
I believe an appropriate remedy is for staff to generate this letter of receipt now, to send it to me and to follow the requirements remaining for the Commission under CA Gov. Code 11340.7 (and I have informed the Commission of this).
For all of what the FGC must do, see https://casetext.com/statute/califo...tion-on-petition-upon-receipt-by-state-agency
What this means:
- Within 30 days from Feb. 15, 2023 the FGC is required by law to either deny my request for reconsideration (a petition for partial reconsideration of an FGC decision), or set the matter for hearing.
- The Commission should have already notified me in writing of its receipt of my request, but it can do so now and that part of the requirement will be satisfied so far as I am concerned.
- The Commission must follow the law and process my request for reconsideration. The fact that the Commission already reached a decision at its February meeting does not excuse the Commission from having to either deny my request for reconsideration (a petition for partial reconsideration of an FGC decision), or set the matter for hearing.
- The request for reconsideration is not a matter to be decided by the DFW (Department). By law, it is a Commission decision.
- Finally, the Request for Reconsideration (functionally an administrative appeal process back to the Commission) does not preclude me from later taking up the matter in court if I desire, as the law expressly states that pursuit of reconsideration does not keep the petitioner from following up in court on the matter.
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I love your persistence,
your language skills (Chinese, Japanese, Legalese — all of these languages are difficult to understand and to learn),
and your ability to tunnel through government quagmires.
Matthias
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Just an " FYI " for anyone that missed the post...
www.airgunnation.com
I'm not sure what alloy materials ( TIN ? / ZINC ? / BISMUTH..? ) ZAN is using to manufacture their " LEAD - FREE SLUGS "... ?
But, I'll be purchasing a few boxes to Test, when they are available @ " AIRGUNS of ARIZONA " .
First test zan lead free .22 cal and .25 cal
- Thread starterMalsonb
- Start dateFeb 21, 2023
First test zan lead free .22 cal and .25 cal
33 feet in basement disco .22cal altaros reg cp tactical holo sight. Left shot was sight in. 6 shots kneeling with rest.
www.airgunnation.com I'm not sure what alloy materials ( TIN ? / ZINC ? / BISMUTH..? ) ZAN is using to manufacture their " LEAD - FREE SLUGS "... ?
But, I'll be purchasing a few boxes to Test, when they are available @ " AIRGUNS of ARIZONA " .
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Why are you putting antimony in here? Antimony is a toxic metal. Why exchange one toxic material for another?I've seriously considered " Casting " my own " ALLOY BISMUTH - Bullets & SLUGS ..
Lead-Free Bullet Casting Alloy Bismuth based
This ratio of~ 87.25% Bismuth, 0.75% Antimony and 12% Tin is the best ratio we have come up with as a substitute for lead. This alloy melts at about 395 F and is best cast or poured at about 500F. Testing the hardness with a Lee Hardness Testing Kit, we came up with an average of 19.3 on the Brinnell Hardness Scale, although there was a range during the testing.
The bismuth gives you the weight (as close to lead as possible) and the tin helps holds it together and makes it less brittle. This is an alloy we have been asked to make a few times so we decided to make a larger batch and have it easily available to everyone. As we are still testing this alloy, we are offering it at a lower cost and asking customers for feedback and their thoughts on how it works. Yes, we know it costs way more then a lead version, but hopefully with more volume, we can offer better prices in the future. One item of feedback we got from our customer follows:
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