A proposed machine gun range on Joint Base Cape Cod could create a “significant public health hazard” by contaminating drinking water for 220,000 year-round residents on the Cape, according to a much-anticipated draft report by the U.S. Environmental Protection Agency.
For the last 20 months, the EPA has conducted an “exhaustive” scientific review of the Massachusetts Army National Guard’s design and operational plans for the proposed site. The agency’s scientists specifically studied potential impacts to the Sagamore Lens, the aquifer that provides Upper Cape towns with nearly all their drinking water.
If finalized, the findings of the EPA’s Sole Source Aquifer Determination could effectively kill the Guard’s decade-long, hotly contested effort to build the $11.5 million, eight-lane gun range on Cape Cod.
“In the way that they've proposed this, it presents this potential for significant harm,” David Cash, regional administrator for the EPA, said in an interview Wednesday.
The finding contradicts the Guard’s repeated assertions about public health and environmental safety issues raised by the proposed range. Guard officials did not immediately respond to a request for comment.
If the final report receives sign-off from EPA Administrator Michael S. Regan, funding from the Department of Defense would be pulled from the project, "unless the funding is for plans or designs for the project that will assure that it will not contaminate the aquifer," the report said. That would effectively doom it.
Such a result would be a blow to Massachusetts Guard officials and a triumph for environmentalists and locals who have fought the range installation since CAI broke the story in August 2020.
The EPA’s findings
In the draft report, the EPA found that if the range were built, the quantity and composition of ammunition, combined with existing aquifer damage, could produce significant harm.
The estimated 1.3 million bullets per year that would be used on the proposed machine gun range would nearly quadruple the total annual bullet load currently being deposited into the berms and range floors of the active small arms training ranges at Joint Base Cape Cod.
There are currently four active small arms ranges at the base.
“This amount of bullet use on the machine gun range may indeed get into the soil and therefore get into the groundwater and therefore get into people's drinking water,” Cash said. “And it's our job to protect public health and the environment.”
Ultimately, the EPA scientists found, if the range were built and the aquifer further contaminated, surrounding towns might need to “construct and operate expensive advanced drinking water systems.”
The groundwater beneath Camp Edwards, which is located on Joint Base Cape Cod, provides up to 3 million gallons of drinking water daily to Camp Edwards and nearby towns, including Bourne, Sandwich, Falmouth and Mashpee, according to the Guard.
Cash said that as bullets are fired, fragments are degraded, and their contents could introduce significant amounts of copper, nitroglycerin, and other chemicals to the aquifer. The ammunition constituents of concern, he said, are “their core, their jacket, and the propellant—or you could call it 'gunpowder'.”
Significantly, the water supply beneath the base is defined as a sole source aquifer, which the EPA describes as one that supplies at least 50 percent of the drinking water for its service area, with no “reasonably available alternative drinking water sources” in case of contamination.
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Superfund Site: the environmental history of JBCC
Additional contamination of the aquifer from the proposed machine gun range would compound decades of damage caused by past military activity, Cash said.
From the 1940s through the 1970s, essentially from World War II through the Vietnam War, military activity on the base was robust, with artillery, explosives, and other training at their peak.
But at the time, there was little understanding of industrial waste management and how damaging it was to dump fuel and chemicals straight into Cape Cod’s sandy, porous soils.
In 1989, after a series of studies, Joint Base Cape Cod was designated a Superfund Site because of high levels of hazardous waste imperiling the aquifer.
A $1.2 billion cleanup effort is ongoing.
“We're still not finished cleaning up what's happened in the past, and so we shouldn't be adding more cumulative impacts of these chemicals into the aquifer,” Cash said.
The Guard claimed “no significant” environmental impacts
The EPA study’s findings follow years of assurances by the Massachusetts Army National Guard that, as described in its official Environmental Assessment, the proposed range would have “no significant impact on the quality of the human or natural environment.”
Representatives for the Guard have expanded on that claim in multiple email, phone, and in-person interviews with CAI.
“Our Environmental and Safety Offices have spent years looking at a variety of factors on how to preserve the safety and the environmental vitality of the local area,” a Guard official wrote in a 2021 email.
Asked this week whether the Guard should have recognized the danger to drinking water described in the EPA report, Cash said he could see why there was such a large gap between what the Guard and his agency found.
“Their mission is training and national security. And I totally understand and respect that,” he said. “Our role is to protect human health and the environment, and particularly in areas that have been damaged and we're trying to bring back. So I'm not surprised that we don't see things the same way.”
How the machine gun range project drew community frustration
The EPA’s finding is the latest development in a decade-long saga surrounding the Guard’s efforts to build a machine gun range on Joint Base Cape Cod.
For years, the Guard said, the range has been needed to reduce soldier travel time. Soldiers currently have to travel several hours to bases in other states to complete required small arms training each year, and that travel time can mean they’re unable to receive other training, or receive weapons training to the necessary standards.
But environmentalists and neighbors of Joint Base Cape Cod rejected that justification as inadequate to offset concerns about threats to water quality. They also object that, to build the range, the Guard would have to clearcut 170 acres of trees in the largest, unfragmented forest ecosystem on Cape Cod. Additional concerns have been raised about noise, traffic, and impacts on wildlife habitat.
Next steps
Before a final conclusion is reached by regional EPA officials, Cash said the Guard will be able to respond to the report’s findings with “different data.”
“Or they may come back to us and say, 'We are going to propose different operations, or different practices,' and then we'll sit back and we'll really evaluate what was sent to us,” Cash said. “And in that analysis, we’ll either come to the same conclusion that we have here or come to a different conclusion. And that's what we'll send to Washington, to the administrator.”
Asked whether there might be room for negotiation between the Guard and the EPA, Cash said the process is less a give-and-take than an ongoing environmental review based on any new data that might be provided by the Guard.
Guard officials would also be “welcome” to submit another proposal, Cash said, but “it may mean they would have to… do this kind of training elsewhere in New England or elsewhere.”
The review by the EPA was not mandated by law, but was undertaken at the agency’s discretion after significant public criticism of the proposed range and claims that the Guard’s process lacked transparency and adequate community input.
The EPA will accept public comment on its report for 60 days, until June 26, before a recommendation is sent to the EPA administrator in Washington for a final decision.
Comments can be submitted via email to R1SSAComments@epa.gov. The EPA will also hold a public hearing on May 24 at the Center for Active Living at 70 Quaker Meetinghouse Road in Sandwich. The formal public hearing will begin at 7:00 p.m. and will be preceded by a public meeting beginning at 6:30 p.m. Individuals with accessibility or translation requests may contact Melanson.kate@epa.gov for assistance.
