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EPA, National Guard to address disagreements over machine gun range risks with 'neutral facilitator'

The zeroing range can be divided into four areas: first, the protective zone, where soldiers who aren’t firing watch and wait. Then, just over the protective barrier, soldiers get down onto the ground and begin firing their weapons. Third, there’s the open field that stretches roughly a mile back where the rounds land. And finally, there are the trees and mountains that enclose the area.
Elodie Reed
A range in Vermont where Massachusetts Army National Guard soldiers go to train on the M2 machine gun. A new range at Joint Base Cape Cod was originally planned to allow this training locally, but the Guard's most recent plans have scaled back the proposed range, meaning soldiers may still have to travel long distances for their training.

The Environmental Protection Agency (EPA) and Massachusetts Army National Guard plan to gather with experts this fall to discuss potential impacts of a proposed machine gun range to the Sagamore lens, a major aquifer that provides drinking water to the Upper Cape.

The news comes a year and a half after the EPA released a draft report that found activity on the range could contaminate the aquifer.

Now, the National Academies of Sciences, Engineering, and Medicine (NASEM) plans to host the day-long meeting as a neutral facilitator, bringing in select experts in groundwater hydrology, geochemistry, aquifer monitoring, toxicology, facilities construction, and more to talk about scientific and technical issues that the range could pose to the aquifer.

A spokesperson for the EPA said their agency is not organizing or leading the meeting, but officials look forward to participating.

“EPA previously issued a draft determination under the Safe Drinking Water Act (SDWA) in which it found that the Guard had not provided persuasive studies, models, and data sufficient for EPA to conclude that this project meets the SDWA’s precautionary standard,” Jo Anne Kittrell wrote in an email.

According to a news release from NASEM, the meeting will take place on Wednesday, Oct. 30, where the experts will be asked to discuss:

  • “The most relevant scientific and engineering data, as well as monitoring and modeling approaches, needed to understand and protect the aquifer from potential impacts to groundwater by construction or operation of the MPMGR.
  • Specific potential contaminants and contaminant pathways that could impact the aquifer from the MPMGR.  
  • Limitations in research methods, monitoring, and/or mitigation related to construction and operation of the MPMGR and potential impacts to the aquifer.
  • Experiences from similar gun range sites, including best practices to prevent impacts to the aquifer.”

The meeting, which will be sponsored by the Guard, will be closed to the public and no “consensus opinions be reached,” according to the news release.

It’s not clear how much the EPA and Guard have been in contact since the EPA released its draft report on potential impacts of the proposed range to the aquifer in April 2023. But internal emails released in May 2024 revealed that communication between base officials and the EPA have broken down.

In them, Guard officials wrote about efforts to cut the EPA out of any “legal input or approval role” in the range project. They also leveled powerful accusations of “questionable practices” and “bad faith” action on the part of EPA.

CAI sent both agencies and NASEM nearly a dozen questions about the upcoming meeting. Those questions included:

  • Why this meeting now? Have EPA and Guard officials not been discussing the scientific and technical issues up until this point?
  • What is the ultimate goal of this forum as it relates to the release of the final EPA report?
  • Is there any precedent for the EPA meeting with an intermediary this way after a draft report? 
  • How will this meeting function knowing the Guard has accused the EPA in uncovered emails and documents of “questionable practices” and “bad faith” action? 
  • Why will this meeting be closed to the public?

Initially, neither NASEM nor Guard officials immediately provided a comment.

Shortly after 11 a.m. on Friday, Sept. 13, after the story was published, a National Guard spokesperson emailed a statement.

"“The Massachusetts National Guard has engaged with the National Academies of Science, Engineering and Medicine (NASEM) for an independent review of the environmental studies regarding the range project. We are early in the framework development for this review and details are limited at this time. This engagement is consistent with our position on strong environmental stewardship and is further testament to our commitment to upholding the prudent tenants of Chapter 47 and the acts of 2002.”

Before the story was published, Kittrell emailed to say she expects the meeting to help the EPA finalize its report; the next draft could again offer a negative view of the range, or it could present a safer picture.

”EPA believes that further study could help fill the gaps in the scientific analysis conducted so far and provide critical information about the potential impact of the project on Cape Cod’s aquifer,” she wrote.

The stakes are high: the report is expected to hold sway with state officials who could approve or deny the range.

“That information," she concluded, "is needed to allow all parties to make sound decisions about whether the project should proceed.”

This story was initially published on Thursday, Sept. 12, and was updated to include a statement sent by the Massachusetts Army National Guard, on Friday, Sept. 13.

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