Stuart Z. Cohen, Ph.D., CGWP (1997)
Environmental & Turf Services, Inc.
Outdoor Range Source Book, A Publication of The National Rifle Association of America
A focus on environmental compliance for outdoor shooting ranges should begin prior to land purchase. During the due diligence period, an audit should be done for potential/hidden environmental hazards. As part of an overall feasibility study, it should be determined whether development of the range will trigger the need for a costly and time-consuming environmental impact statement. three federal environmental statutes and dozens of regulations typically have relevance to outdoor ranges. Environmental regulatory scrutiny of outdoor ranges usually focuses on lead and arsenic (components of shot and bullets). Arsenic can be mobile in sandy soils, but it is present in ammunition at very low concentrations. (Mobility in this context means the ability to run off to surface water or leach through soil to ground water.) Lead has very low mobility in most environments. Scientifically, the greatest risk concern is the potential exposure of children to lead-contaminated soil after an outdoor range is closed. Politically, concern about surface water, wetlands, and ground water is often a more visible concern, particularly as subjects of citizen lawsuits under the Clean Water Act and the Resource Conservation and Recovery Act (the waste disposal law). A Best Management Practices program should be developed in advance that is based on sound science and engineering and that contains one or more of the following elements: recycling, vegetation management, soil amendments, and stormwater management. The goal of the BMP plan is not to eliminate all lead and arsenic; rather, the goal is to keep in place and limit exposure to any lead and arsenic that migrates into backstop soil or surficial soil.