The Massachusetts Army National Guard has scaled back its proposal for a controversial machine gun range on Joint Base Cape Cod. But officials with the Environmental Protection Agency expressed skepticism that the new proposal would alleviate all their concerns.
The Guard's proposal comes as a response to a critical EPA draft report released a year ago that found the range could contaminate drinking water and create a significant threat to public health for hundreds of thousands of year-round residents on Cape Cod.
The new plan shortens the length of the two longest proposed firing lanes and reduces potential ammunition use from 1.3 million bullets per year to around 800,000, among other efforts to minimize environmental impact.
EPA officials sent a letter dated April 4, 2024, to the Massachusetts congressional delegation, detailing the plan. It noted that the Guard’s new plan would still triple the number of bullets fired on the base per year and only require collection of those bullets every 10 years, continuing concerns about pollutants reaching the aquifer below the base that provides Cape Codders with drinking water.
The letter, signed by EPA regional administrator David Cash, said agency officials will continue to evaluate the Guard’s revised proposal before sending the draft report with a recommendation about the project’s safety to the EPA’s national administrator, Michael S. Regan. Regan has the power to effectively kill the proposal range by denying federal funding.
Key points from the Guard’s revised proposal
The EPA’s letter reveals that, on and off from August, 2021, through January, 2024, the Guard and the EPA have gone back and forth about what constitutes “best practices” for the proposed machine gun range.
After the EPA released its draft report about the potential impacts on drinking water and public health in April 2023, the Guard followed up in December, 2023, with a revised proposal. The revisions are only becoming public now, according to EPA officials, because the Guard requested the new proposal be included in the letter to the congressional delegation. That letter was shared with CAI.
The Guard’s first public plan initially included an eight-lane machine gun range, of which two lanes would be 1,500 meters long — roughly a mile — so soldiers could practice firing the .50 caliber M82 sniper rifle and the M2 machine gun. The Guard has maintained that a key reason a Cape range is necessary is travel time; soldiers in the Guard have had to drive to training sites with machine gun ranges in Vermont and New York to complete required training each year.
In their newest proposal, Guard officials said they’d not only reduce the number of bullets fired per year, but eliminate the 1,500-meter lanes. Instead, the eight lanes would only support training on the 240B/M249.
That would make the proposed range much like another one currently under construction at Fort Devens in central Massachusetts, raising questions about the need for a range on Cape Cod.
Guard officials didn’t immediately return requests for comment.
In its revised proposal the Guard details plans to build berms that would catch projectiles and to develop a robust monitoring program to ensure berm integrity. Guard officials also said they would conduct a comprehensive sampling and monitoring program of surface soils, groundwater, and pore water, which offers an early warning of potential groundwater effects.
In the newly released documents, Guard officials detailed nine measures that they’ve adopted based on EPA recommendations, and eight that they rejected.
They accepted visual inspections of the range at least on a quarterly basis, after each training event, after storms, and at the direction of the Massachusetts Environmental Management Commission’s Environmental Officer. They also agreed to plant native vegetation on the berms and range floor, contour the land to prevent stormwater ponding on the range floor, and prohibit the use of “fire suppressant chemicals whenever possible.”
But the Guard rejected some EPA-proposed measures, saying they deemed them to be “not relevant or suitable for the range.”
Many of the rejected measures center around concerns about how the berms are built and how propellants are kept out of groundwater. For example, the Guard rejected the EPA’s recommendation to install containment blocks in the dirt berms to capture and contain projectiles. The Guard said these have been determined to contribute contaminants to the soil and change soil chemistry
EPA remains concerned, despite promises of new proposal
In their response letter, EPA officials told the congressional delegation that the Guard’s new plan relies on dirt berms as the primary means to contain bullets and doesn’t follow recommendations to recover spent munitions as frequently as prescribed.
“The revised proposal would add a 10-year bullet retrieval program,” EPA officials said in the letter. “In earlier discussions with [the Massachusetts Guard], EPA had suggested retrieval twice per year.”
The EPA expressed concerns that by taking what the agency considers a reactive, rather than proactive approach, pollution may have already occurred by the time the Guard finds anything in its inspection or monitoring plan.
“Region 1 [EPA] has expressed concern, both in the draft determination and in earlier discussions with [the Guard], that these action levels are set at levels where there could already be significant contamination,” the letter said.
In addition, the EPA’s letter said, the Guard’s initial proposal didn’t include comprehensive analyses, studies, or other information that adequately responded to a number of agency questions and concerns. Nor did the new proposal.
“No additional scientific analyses were provided to address the risk and uncertainty of a large-scale expansion of pollutant loading,” EPA officials wrote in the letter.
They concluded with a reminder: the Massachusetts congressional delegation had asked for "as much detail as possible on the status" of the EPA's process and engagement with the Guard.
"But as you know, the Commonwealth of Massachusetts has a role in projects through the [Environmental Management Commission]. The EMC has its own independent environmental performance standards and authorities to approve, deny, or condition projects that staff there are better positioned to address," states the EPA.
For now, it’s not clear when the EPA will finish its review and pass their recommendations about the machine gun range on to officials in Washington, D.C. That next step, insiders say, is crucial to how state officials and others in positions of power will respond to the project.
