Guard officials seek revisions to critical EPA report on machine gun range at public hearing
High-ranking officials from the Massachusetts Army National Guard last night pushed back against the Environmental Protection Agency's draft finding that a proposed machine gun range at Joint Base Cape Cod could contaminate the region’s drinking water.
Colonel John Bagaglio, garrison commander of Camp Edwards, the base’s main training facility, told a public hearing that the Guard hopes to work collaboratively with the EPA to resolve concerns and allow work on the 138-acre gun range to proceed.
But local residents used the hearing at the Sandwich Center for Active Living to endorse the EPA’s draft findings and denounce the Guard’s plan, calling it variously “reckless,” “unacceptable,” “ill-conceived,” and “a nightmare.”
The proposed eight-lane machine gun range would be built above an aquifer that is the Cape’s sole source of drinking water. Last night’s hearing was the first and only public information session and discussion since the EPA released its draft report last month. If the report is finalized by EPA officials in Washington, the Guard would no longer have access to federal funds for the project, effectively killing it.
EPA officials called the public hearing an unprecedented addition to the environmental review process and said it reflected the high profile of the project and the importance of protecting the aquifer.
The Guard Defends its Process
The meeting opened with the EPA providing a brief overview of its report, which Guard officials were then invited to address. Addressing the public hearing, Bagaglio said the Guard has successfully received all environmental permits up until this point, emphasized the base’s past conservation successes, and asked the EPA to work with the Guard to revisit some specific concerns about the proposed range.
He said the Guard would provide a detailed written response to the draft report, but in the meantime he hoped to share some of the more “salient” points.
He said a core mission of the Massachusetts Army National Guard is to “protect the natural resources, specifically groundwater of the Reserve, while conducting compatible military training.” To that end, he said, the Guard has worked to complete environmental permitting requirements in compliance with the National Environmental Protection Act and Massachusetts Environmental Policy Act.
Bagaglio said EPA's own studies have found that chemical contaminants in ammunition that would be used on the proposed range — including copper, antimony, nitroglycerin, and others — do not transport to the water table.
“[But] we do acknowledge the EPA had some uncertainty with the results,” Bagaglio said, “and we kindly asked for the opportunity to reexamine collaboratively.”
In its draft report, the EPA described the Guard’s copper study as “inconclusive,” “missing samples,” and based on "inappropriate composition of the experimental solutions.” The EPA also said the Guard’s study lacked “discussion on differences between laboratory and field conditions,” and contained “incomplete analyses of contaminants of concern.”
After his public comments, Bagaglio clarified to CAI what collaboration with the EPA could mean.
“We're asking, ‘If you have concerns about how we did the test, let's go back and redo the test, or let's go back and redo the study, or add some of your input on how you want to do the study,’” he said. “We're more than willing to be collaborative or go back because we want to get it right, too.”
Also after the hearing, Colonel Matthew Porter, base commander at Camp Edwards, said he wanted to assuage the EPA’s concerns about “potential” chemical loading.
“They're being very protectionary [sic] because the future is unknowable, and that's the way they're looking at it,” he said. “[But] it's not based in historic science. It's not based on 100 years of field firing. It's not based on our studies. It's not based on what we've been dealing with. So what we can do is work with a mitigation measure, whether it's reduced net loading or something of that sort. And let's see if that helps them with their fear of net loading in the future.“
In its draft report, the EPA concluded that the range could pose a public health threat because of the makeup of the ammunition being fired in such high volume for decades to come in an area that’s already been contaminated.
The EPA in its report noted that the range would be built within an area and atop the aquifer that the military contaminated throughout the 20th century. In 1989, the area was declared a Superfund site, and a $1.4 billion cleanup is still ongoing.
Public Sides with EPA 5:1
Of the roughly three dozen public commenters at the hearing, supporters of the EPA’s draft findings outnumbered opponents by about five to one.
During the public comment period, George Tupper, a former Guard member who was once stationed at Otis Air Force Base, located within Joint Base Cape Cod, said he now wonders why a range couldn’t be built elsewhere.
“I really do support the military and their need for training,” he said. “But what doesn’t make quite so much sense is: is Cape Cod the only place to do it?”
“If we get this wrong,” he warned, “Cape Cod goes away.”
Several other veterans seconded his point.
“There’s too much uncertainty,” said John Currier, who said he’s retired from the Army National Guard. “And the fact that we have uncertainty as to what the outcome of this range would be 100 years from now, I’d say in order to ensure we do have the groundwater for a number of years, we should reject this gun range and put it someplace where there are no sole source aquifers.”
Kathy Fox Alfano, of Bourne, described this as a multi-generational issue.
"Our children, their children and beyond, trust us now to make the right decision for clean drinking water on the Cape,” she said. “Now, I do support the military, but I have to believe that there are other places for a machine gun range. There's no other place for our sole source aquifer because we have no alternative.”
Sandwich resident Jonathan Finn said the concerns should be heeded.
“While the Army National Guard has multiple sites to provide training, our fragile coastal region has only one aquifer,” he said. “We have one.”
One of the final speakers of the night was more succinct.
“You can’t be playing with our water,” said Christopher Noël Hall, after a brief spat with a commenter who supported the proposed range.
Range Supporters Challenge EPA
A number of speakers defended the Guard's proposed project.
Sandwich resident Dax Ferris said: “A range for our service men and women is a necessity for our freedoms.”
The Guard began the process of formally proposing the range about a decade ago. Officials say soldiers currently must travel hours to reach a range in Vermont or New York to complete weapons qualification requirements. A range on Joint Base Cape Cod would significantly cut down on that travel time, and make other training requirements easier to achieve.
“As far as the impacts, everything the EPA cited contains the words ‘may,’ ‘could,’ ‘potential,’” said man who identified himself as Andrew D. “If the EPA is so very concerned about the environmental impacts and you're so very convinced that something bad is going to happen, then say a certainty... And if you have such a big problem with it, then help them find a way to build the thing so it's not a concern. They say they need it. I believe it.”
The EPA will continue to accept written and verbal comments until June 26, before a recommendation on the draft report is sent to the EPA administrator in Washington, D.C.
Comments can be sent via email to R1SSAComments@epa.gov or voicemail to 617-918-1800.