The problem is that shooting on the ranges produces tons of lead waste. This is collected in various ways today. But the EU wants even better collection, and it is their proposals that the dispute is about. – The costs will be too great. There are not enough good alternatives to lead today, believes the Ski Shooting Association. The shooting organizations also believe that the solutions proposed by the EU agency for collecting the lead from the bullets on the shooting ranges are too bad. They write in their consultation responses that there are far better and cheaper solutions, and that what has been proposed is not good enough if activity and recruitment are to be maintained. A proposal from ECHA, the EU’s chemicals agency, has been out for consultation this summer. It goes a little further in granting exemptions from sport shooting than the original proposal from last year. But it is not good enough for either the Voluntary Shooting Association (DFS), the Norwegian Shooting Association or the Norwegian Skiing Association. ECHA wants mechanical so-called bullet traps that will collect over 90 percent of the lead. They can also agree that large piles of sand behind the discs should be able to act as bullet traps under certain conditions. But the conditions are too strict, believe the shooters’ organisations, who also point out that the ECHR has misunderstood the basis of figures in investigations that have been carried out. – Our fear is that the consequences of the measure will be so great that our 163 clubs do not have the financial muscle to cope with this introduction within five years, and thus have to reduce their activity or discontinue the biathlon groups, says facility and event consultant Christian Gedde-Dahl at the biathlon association . Who have calculated that a plant with 30 discs will cost a minimum of NOK 3 million to adapt to the proposed regulations. IBU: – Recruitment will stop completely The Norwegian Biathlon Union relies on the statements from the international federation (IBU), which has also reacted strongly to the proposal. They look darkly at the future if the consultation draft is turned into EU law. It will make biathlon too expensive. – Recruitment will stop completely, so will all activity in large areas, IBU predicts. They believe that ECHA has done too little to find good enough collection methods. What is new in the latest consultation round is that, in addition to steel bullet catches, ECHA will also allow sand piles behind the disks. – They have interpreted the test results completely wrong – Only two measures have been assessed, but there are many other methods for collecting the lead within what ECHA calls “Best Available Techniques”. Our conclusion is that the consultation draft is flawed and partly based on the wrong basis, write the IBU in its response to the consultation. DFS also envisages decommissioned facilities if the exemption does not improve. – ECHA has misunderstood. They have interpreted the test results from trials with alternative collection solutions completely wrong, says DFS general secretary Jarle Tvinnereim. The proposed conditions are that there must be bullet traps that collect at least 90 percent of the lead, and that the exception must only apply to normally approved ammunition for sport shooting. – But tests that we have done together with the Norwegian Armed Forces show that it is possible to collect 99 percent, says Tvinnereim. – What we hope is that the documentation we have submitted now will lead to ECHA realizing that they have interpreted the figures incorrectly, he adds. ECHA must summarize the consultation responses and send its proposal to the European Commission before Christmas. It is expected that the EU will make its final decision in the first half of 2023. MISINTERPRETATION: – The amendment proposal has misunderstood the numerical basis in the test report, says DFS Secretary General Jarle Tvinnereim Photo: Hans Henrik Bårtvedt / news Tvinnereim states that tests are being carried out with homogeneous copper balls or alloys with copper. There is such ammunition for hunting use, but not for weapons and calibers used for sport shooting. – This will be significantly more expensive, and will also not be able to be used in races on today’s competition weapons, says Tvinnereim. At today’s prices, this ammunition is becoming far more expensive than lead ammunition. It may, however, change if the production volume increases. – Could be the hook in the door When the European Commission aired the idea of a total ban on lead ammunition three years ago, the reactions were also strong. – It could be the hook on the door for biathlon, was the reaction of the International Biathlon Union (IBU) at the time. DFS also saw the future with a ban. Since then, the EU organization ECHA has worked to get the ban in place, and sent out two consultation proposals – one last year and a new and slightly modified one this year. In the first consultation round, an exception was proposed if the shooting ranges could have steel bullet grips. It will be expensive. In the second round of hearings, it is also decided to allow sand mounds as bulletproof vests. DFS believes that if all shooting ranges are to have solutions with steel bullet traps, and remove existing bullet traps, it will cost 375 million euros – more than NOK 3.5 billion. The Norwegian Environment Agency says no The Norwegian Environment Agency has also responded to the consultation, and they do not want an exception. They want a total ban on lead, also on shooting ranges with bullet grips made of steel or sand, which, according to the organisations, will collect well over 90 per cent of the lead. – Out of consideration for people and the environment, we will not support the proposal for an exception (for sport shooting, editor’s note), the directorate wrote in the hearing last year. They have not responded to the latest round of hearings, and inform news that it does not change their position. In response to written questions, section leader Anne Lise Filtvedt elaborates on the Norwegian Environment Agency’s position. – Lead can have several serious effects on health and the environment. That is why lead is on the Norwegian list of chemicals that the environmental authorities want to phase out. This is the reason why we do not want an exception for sport shooting. In Norway, for example, it has been forbidden to use lead shot on shooting ranges since the early 2000s, writes Filtvedt in an e-mail. TEST: The armed forces are trying out alternative ways to collect lead, here with shots against round balls Photo: Morten Andersen / news The shooting organizations react strongly to the attitude of the Environment Agency. They refer to work that has been done to deal with lead contamination on the shooting ranges. The voluntary shooting heritage (DFS) points out that the organization works closely with the Norwegian Armed Forces, and believes that a ban on lead ammunition also undermines Norway’s total defence. – Therefore, we think it is unfortunate that the directorate gives a resignation without us being consulted. We allow ourselves to ask that they do not issue new statements in favor of a total ban on lead on civilian shooting ranges, writes the Voluntary Shooting Association (DFS). – It is not natural for the Norwegian Environment Agency to contact sporting shooting organizations before they send a reply to the consultation. The Norwegian Environment Agency’s role is primarily to look after health and the environment, and shall not respond on behalf of anyone other than the environmental authorities, Filtvedt replies. Can collect at least 99 percent – ECHA has misunderstood the basis of the figures in the investigations. We have documented that the measures we propose have a far better effect than what ECHA claims, says Jarle Tvinnereim. ECHA is worried about the lead weathering in the sand. They believe the lead weathers by 5 per cent over the course of 11 months, and mixes with the sand. – But it is a completely wrong interpretation of the investigation reports. They show that it takes 50 times as long for 5 percent to weather, says Tvinnereim. HEAVY OF LEAD: Ammunition with lead is the only thing that is currently used in competitive shooting Photo: Phelan M. Ebenhack / AP IBU proposes that good solutions for the collection of lead be introduced at the largest facilities within five years, and at other facilities within ten years . ECHA wants a roof over the sand piles, so that rainwater will not carry lead dust into the ground and possible water runoff. This too will cost the shooting organizations enormous amounts, Tvinnereim believes. Runoff from sand-ball traps has been tested, with very good results. – Nothing came through. Everything was left inside the sand piles, says Tvinnereim. – Therefore, we believe that ECHA concludes on the wrong basis, and we have documented this through our consultation response, he adds. A lead ban will also greatly affect training conditions for the defense and the police, with whom DSF has a close collaboration, DFS believes. Christian Gedde-Dahl writes in an e-mail to news that there are very good bullet traps. A Norwegian-developed biathlon target has been shown to have a collection rate of 99.87 to 99.95 per cent of all lead. The association has reported it to ECHA. At the facility in Lillomarka outside Oslo, they have built a concrete structure around the disc rig, and it collects well over 90 percent, says Gedde-Dahl. – We support the EU’s work for a general ban on lead. But our fear is that it will be too expensive for many of our 163 clubs to adapt to the new rules within the proposed five years, says Gedde-Dahl.
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