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E.P.A. calls for 'unprecedented' public review of machine gun range over potential water quality impacts

A guardsman waits to fire on the Sierra Range at Camp Edwards. It is a 300 meter automated rifle qualification range where soldiers are tested on rifle marksmanship.
Eve Zuckoff
A guardsman waits to fire on the Sierra Range at Camp Edwards. It is a 300 meter automated rifle qualification range where soldiers are tested on rifle marksmanship.

Responding to criticism that the proposed machine gun range on Joint Base Cape Cod has lacked transparency during the 10 years it's been in development, the U.S. Environmental Protection Agency (E.P.A.) will launch an “unprecedented” public participation process.

Since August, the E.P.A. has been investigating whether the proposed range could create a significant public health hazard by contaminating the drinking water that runs beneath the base. That water supplies all Upper Cape towns, and since 1982 it has been protected under E.P.A.’s Sole Source Aquifer program.

The findings of the investigation will be compiled in a draft report known as a Sole Source Aquifer Determination, to be released this spring. Following the release, the E.P.A. will open a 30-day public comment period and set a date for a public hearing.

“The reason we're doing it is to build some public confidence and to provide transparency,” said Jane Downing, who runs the drinking water program at E.P.A. New England. “And we are taking all of these months to do our homework, to do our due diligence.”

Since news of the project was made widely public in August 2020, the Massachusetts Army National Guard has been slammed by criticism that it created plan largely in secret, and that the range could irreparably harm the environment and communities around the base. The project calls for more than 170 acres of clearcutting, and locals have raised concerns about noise impacts, increased traffic, habitat loss, and impaired drinking water.

The project incurred further criticism after it was revealed that a similar machine gun range is slated to be built on Fort Devens, northwest of Boston, a fact not earlier disclosed by the Guard.

Joint Base Cape Cod continues to be a Superfund Site, as designated in 1989, as a result of contamination to the aquifer by activities on the base, and subsequent cleanup efforts to the water supply continue.

Guard officials insist that they’ve carefully studied and mitigated the potential impacts of the proposed machine gun range, and that it’s necessary for supporting soldier training. This fall, the Guard launched guided public tours to offer a firsthand look at the activities and the landscape on the base. It has also been participating with the E.P.A. on the the Sole Source Aquifer review.

A Guard spokesperson was not able to comment on the E.P.A. announcement of a public hearing process in time for the publishing of this story.

With the Guard’s help, the E.P.A. has spent months evaluating whether the machine gun range project will impact the aquifer enough to pose a significant risk to the public.

“There are three different criteria to determine the significant hazard,” Downing said. “The first one is a question about whether drinking water standards will be exceeded at points where people are drinking water. The second one is, ‘Are there any other adverse public health impacts due to the project?’ And the third one is, ‘Will additional treatment be necessary at the current public water supply systems because of the proposed project?’”

Downing said “subject matter experts” are now exploring to how contaminants like lead and other metals could impair the sole source aquifer.

“In this case, the primary contaminant of concern is copper. And that is because the bullets are made of copper,” Downing said. “[We’re also looking at] any other contaminants, such as contaminants that are part of the propellants that are used for the bullets.”

The E.P.A.’s release of the report this spring will include recommended next steps for the Guard.

“At the end of the day, we may recommend additional best management practices to further protect the aquifer. On the other hand, we could conclude that the project presents significant hazard to public health. And in that case, we may work with the Army National Guard to modify the project,” Downing said. “And in addition, through all of this, we will be sharing the administrative record so that the public can look through all of the information that we evaluated in reaching that determination.”

Downing said at that point she hopes members of the public will weigh in, either in written or verbal comments. Information on the date, time and how to register for the public hearing will be announced in the coming months.

“[We want], of course, to see what the public has to say, to look at all of their comments and determine if those comments should affect our final decisions," Downing said." So all of the comments received will be reviewed and considered, and we will make changes as we feel necessary.”

This is the first time, she said, the public has ever been engaged following the release of a draft Sole Source Aquifer Determination.

“E.P.A. has listened to concerns about transparency, and we have listened to the interest for the public to be involved. And that is why we have taken these unprecedented steps to build in a public participation process,” she said. “We have not heard of any other case across the country where they have built such a process into their review. Typically, the review is fairly straightforward and just ends with a letter from E.P.A. to the funding agency.”

Members of the congressional delegation released a joint statement applauding the effort.

"This review process is crucial to understanding the impact the gun range poses to public health, public safety and our public lands with input from both abutters and those who rely on Cape Cod’s sole source aquifer for safe, clean, and plentiful drinking water,” said Sens. Elizabeth Warren and Ed Markey, and Rep. Bill Keating in a statement. “We remain concerned about the unknown effects that the construction of this gun range could have on the aquifer and are hopeful that this review will provide much-needed answers to the residents of Cape Cod.”

Range opponents, including Andrew Gottlieb, executive director of the Association to Preserve Cape Cod, also weighed in.

“E.P.A.'s commitment to transparency and providing a meaningful opportunity for public comment is commendable and stands in stark contrast to the Guard's refusal to be open and engaging with the public,” he said in an email. “While E.P.A. review is limited in scope to just one of the many threats to the environment posed by the [machine gun range] proposal it is an important step forward.”

The state of Massachusetts, rather than the federal government, holds the power of final decision on whether the range gets built, but Downing said she hopes this goes some way towards building public trust back into the process.

“We are working very closely with the Massachusetts Department of Environmental Protection,” she said. “[They] have been closely working with the National Guard… so they have a wealth of information and experts. But ultimately, it will be E.P.A.'s decision.”

Dec. 2, 2021. This story was updated to include the statement from the congressional delegation.

Eve Zuckoff covers the environment and human impacts of climate change for CAI.