MA-DEP ramping up to go after trap fields

[terraformer]

Watch the fudds cry now!
Instead of rewriting this from scratch, here are the emails I have been writing to folks on the subject. The context is a recently released paper (link below) authored May 11th detailing how trap/skeet ranges should be considered Stage II ecological risks requiring remedial action.

I would hate to be Minuteman or any club with a popular trap range. BTW: I already emailed Jim Wallace so no need to inundate him.

I have a design in my head which I came up with a while back knowing lead shot fall is terribly unmanageable to begin with. Basically the idea is to use shot curtains with a drainage chase under the curtain to funnel the shot into a holding tank. The problem with this idea and this paper below is you would need to put a steel mesh over the chase to prevents birds from ingesting the pellets. That increase management needs. Also, you need to deal with water drainage which I have an idea for too. All of this would cost time resources to build but most clubs could do the labor with their volunteers. The curtains cost $325 per 34.5' x 8.5' curtain not including rigging (telephone poles, steel cables and pulleys/guides) and they last 5 years (so the mfg says), or less with the kind of pounding they would get at a heavily used field. Also, to make this work, the curtains have to be placed closer to the firing line in order to trap more of the shot.

http://www.mass.gov/dep/service/compliance/riskasmt.htm#lseco
If this is used to change policy, this is going to shut down every trap field in the state. It's also a hatchet job. Most of the studies they rely on are not directly relevant and are outdated. They are looking at studies of lead shot in birds that are no longer hunted, but which were hunted at the time of the study. They are also not looking at what is the lead concentration in water foul (which is all they have studies for) now, with today's management practices on trap/skeet fields.

I should be more specific. This passage (3.1.3):

The MCP (310 CMR 40.0995(3)(b)) defines as Readily Apparent Harm: “Visible presence of oil, tar, or other non-aqueous phase hazardous material in soil within three feet of the ground surface over an area equal to or greater than two acres, or over an area equal to or greater than 1,000 square feet in sediment within one foot of the sediment surface.” The readily apparent harm provision is aimed primarily at sediment and soil containing oil and tar, but the presence of lead shot is an essentially analogous condition; it is visible and known to be harmful. Most SPR shot fall zones are likely to have conditions that meet the definition of readily apparent harm. If MCP risk assessments are applied to lead shot sites, it may be appropriate to consider a shot density criterion for readily apparent harm in addition to the area criterion described above.
is what leads me to believe what is on the horizon.

BTW: Remediation is only required if it meets this std: (3.1.5.2)

* Visible presence of oil, tar, or other non-aqueous phase hazardous material in soil within three feet of the ground surface over an area equal to or greater than two acres, or over an area equal to or greater than 1,000 square feet in sediment within one foot of the sediment surface;

* Continuing discharge of contaminated groundwater to surface water where surface water or sediment concentrations already pose a significant risk or exceed Massachusetts Surface Water Quality Standards.

 

[atilla]

this should be interesting as NLRG is both an example of how things are done according to DEP standards and a pretty popular skeet and trap field.

if i was more connected with the guys at the club i'd probably know more but i know the club has been around for a while and is always under tight scrutiny from the DEP due to the groundwater in close proximity to the range.

 

[TomH]

The anti's attacking the FUDD culture is actually a good thing for our cause. Maybe some will wake up and see that they don't just care about "assault weapons". Right now we're too split and the anti's are winning by chipping away.

 

[Marcus in the Darkus]

Wonderful. Mass DEP's Office of Research & Standards goes out to find ecological risk assessments at analagous shotgun practice range sites and they turn up a few DOD installations. Guess what? Let's just say the typical gun club in Mass can't afford to spend money the way the military does.

What we really need here is a statutory answer to the issue similar to the pesticide exemption under the MCP. If you have a site with elevated pesticide concentrations in surficial soil, you get a get-out-of-jail-free card if you can make a good argument that the contamination results from pesticides that were implied "in a manner consistent with their labeling." There are many former apple orchard sites in Massachusetts (now residential properties) with elevated concentrations of lead and arsenic in soil that would have require remediation if that exemption did not exist. As it was, they didn't even enter the MCP, because the exemption is on the front end.

I'm a Massachusetts LSP with a fair amount of sediment metals eco and human health risk assessment experience and I would be willing to do some pro bono work on this issue on behalf of GOAL or some other appropriate organization.

 

[terraformer]

Wonderful. Mass DEP's Office of Research & Standards goes out to find ecological risk assessments at analagous shotgun practice range sites and they turn up a few DOD installations. Guess what? Let's just say the typical gun club in Mass can't afford to spend money the way the military does.

What we really need here is a statutory answer to the issue similar to the pesticide exemption under the MCP. If you have a site with elevated pesticide concentrations in surficial soil, you get a get-out-of-jail-free card if you can make a good argument that the contamination results from pesticides that were implied "in a manner consistent with their labeling." There are many former apple orchard sites in Massachusetts (now residential properties) with elevated concentrations of lead and arsenic in soil that would have require remediation if that exemption did not exist. As it was, they didn't even enter the MCP, because the exemption is on the front end.

I'm a Massachusetts LSP with a fair amount of sediment metals eco and human health risk assessment experience and I would be willing to do some pro bono work on this issue on behalf of GOAL or some other appropriate organization.

I doubt that would ever happen. Gun ranges are not unsuspecting home owners in the eyes of the legistraitors.

 

[drgrant]

Oh noes the lead pellets are gonna kill everyone... aieeee!

This is just end-around gun control. These jerkwads act like the fallout of every trap field is going to be sprinkling some ducks in some wetlands or some crap like that.

Can't these jerks stick to dealing with real environmental problems, instead of trying to pretend that every shooting range is the next love canal disaster waiting to happen?

-Mike

 

[Zappa]

This really isn't anything new. The Skeet and Trap ranges at Riverside in Hudson were forced to ban lead shot years ago because of wetlands on the property.

 

[Marcus in the Darkus]

I doubt that would ever happen. Gun ranges are not unsuspecting home owners in the eyes of the legistraitors.

If Bob Durand were still in the senate or EOEA he would / could help. Assuming a pro-RKBA entity forms to try to help DEP make sense of this issue, they would be well advised to look up Bob at his current firm. The pesticide exemption was put in not necessarily to protect innocent homeowners (many of those sites were still undeveloped in 1993 when that language was included in the MCP), but to explicitly keep certain sites out of the MCP where previous landowners engaged in historic lawful activities that, by current standards, may present an environmental consequence. Seems like a pretty good analogue to SPRs to me.

 

[terraformer]

If Bob Durand were still in the senate or EOEA he would / could help. Assuming a pro-RKBA entity forms to try to help DEP make sense of this issue, they would be well advised to look up Bob at his current firm. The pesticide exemption was put in not necessarily to protect innocent homeowners (many of those sites were still undeveloped in 1993 when that language was included in the MCP), but to explicitly keep certain sites out of the MCP where previous landowners engaged in historic lawful activities that, by current standards, may present an environmental consequence. Seems like a pretty good analogue to SPRs to me.

A) I said unsuspecting, not innocent wrt to homeowners. B) All of that is well and good, but the point is, these two topics are not the same. If there is an agenda, it won't take much to go after the clubs since everyone hates gun owners. Even if they don't go after the clubs, by your own logic they can and will shut down the trap ranges at these clubs for any future behavior without mitigation of the supposed harm. What is insidious about this is that this is not lead leeching, which is easy to stop, but bird ingestion of lead pellets. The only way to stop that is to keep the birds away from the lead. That is much more difficult.

Although, I can envision laying out 18" poles in a grid pattern and laying out massive amounts of that anti bird netting gardeners use.

 

[terraformer]

This really isn't anything new. The Skeet and Trap ranges at Riverside in Hudson were forced to ban lead shot years ago because of wetlands on the property.

This would basically extend that to all clubs then.

 

[the_doctor]

Watch the fudds cry now!
Instead of rewriting this from scratch, here are the emails I have been writing to folks on the subject. The context is a recently released paper (link below) authored May 11th detailing how trap/skeet ranges should be considered Stage II ecological risks requiring remedial action.

I would hate to be Minuteman or any club with a popular trap range. BTW: I already emailed Jim Wallace so no need to inundate him.

Holbrook Sportsmen Club voluntarily improved their range. They are one of the best clubs out there with a fully compliant DEP trap range.

Bill

 

[Madball13]

Ipswich has already installed these screens due to the wetlands behind the trap field. Currently we let our lead fall to the ground and the DEP has already signed off on our field. We are currently in the process of upgrading our second field to be compliant with the lead shot initiative.

The nets can only stop specific ballistics closer than 80 yards from the shooting line. We erected out poles before we decided on using the netting and had to downsize to #8 or smaller shot to maintain the integrity of the nets.

 

[terraformer]

Apparently you all are missing that this report is not part of the lead shot initiative. This is far beyond what that says. This says that any time lead shot is on the ground at a concentration higher 1.50kl per 1000 it is considered hazardous and needs to be cleaned up. This is NOT a matter of keeping shot out of waterways, but a matter of keeping loose shot off of the ground and out of the top 3 FEET of top soil. This is a huge requirement for anyclub, including those with curtains.

 

[CrossFrire]

Maybe you'll find a way to dodge this atatck.
But they people who run the "Sheeples Socialist Democrat Republic" are out to run every aspect you your daily life from the instant you draw your first breath till the clumps drop on your casket.
Untill EVERY DEMOCRAT is removed from every office in the State and Liberals are stopped from indoctrinating every school child in the State with Socilaist doctine and the Media is clensed of Liberal propaganda tools the subjects of Massachetts will continue to slip deeper and deeper into a State of absolute domination.
I no longer believe that Massachusetts will ever be turned around at the ballot box. As worse yet, Liberals from Massachusetts, and many indoctrinated here, are driving America down the same dead end road.

 

[Kicker96FS]

Just use steel shot instead of lead, whats the big deal?

(noob trap shooter asking)

 

[wahsben]

Just use steel shot instead of lead, whats the big deal?

(noob trap shooter asking)

Steel and other alternative shot are usually much more expensive then lead and steel is less effective then lead at the same shot size.

 

[dwarven1]

I'm a Massachusetts LSP with a fair amount of sediment metals eco and human health risk assessment experience and I would be willing to do some pro bono work on this issue on behalf of GOAL or some other appropriate organization.

Marcus, you should be PMing GOAL or MrsMagnum directly with this offer, or calling them on Tuesday morning to make the offer in person.

 

[the_doctor]

Maybe you'll find a way to dodge this atatck.
But they people who run the "Sheeples Socialist Democrat Republic" are out to run every aspect you your daily life from the instant you draw your first breath till the clumps drop on your casket.
Untill EVERY DEMOCRAT is removed from every office in the State and Liberals are stopped from indoctrinating every school child in the State with Socilaist doctine and the Media is clensed of Liberal propaganda tools the subjects of Massachetts will continue to slip deeper and deeper into a State of absolute domination.
I no longer believe that Massachusetts will ever be turned around at the ballot box. As worse yet, Liberals from Massachusetts, and many indoctrinated here, are driving America down the same dead end road.

Have you ever considered that some public servants are only trying to protect the public? Why do not consider this instead of making outlandish statements. They do not enact laws. DEP does not allow any individual a break when it comes to contaminating the land or water.

Bill

 

[cekim]

Have you ever considered that some public servants are only trying to protect the public?

Well, that would be a shift in policy to be sure

Even those few that are well intentioned fail to accomplish this for lack of objectivity, rational thinking or common sense...

This state's legislature is the model of "knee jerk liberal" for the entire nation. They enact policies based upon impulsive reactions to headline sound bites that are perceived as a problem rather than actually trying to solve useful problems, looking at prior attempts to see if they work and generally finding a balance between regulation and freedom...

Government normally has a tendency to do this, but the governance of this state has refined such reactive governance to a science (unfortunately).

So, no, I don't find CrossFire's statements "outlandish." While they may be restating the obvious, they reflect a rational anger and distrust of an activist agenda driven government that violates the letter and spirit of this nation's founding as well as the state's constitution and legacy as not only one of the founding colonies but the origin of the American Revolution...

 

[seanc]

This really isn't anything new. The Skeet and Trap ranges at Riverside in Hudson were forced to ban lead shot years ago because of wetlands on the property.

singletary's ranges have been shut down for years as well. Their skeet and trapranges shoot out over "wetlands". As far as I know they have still not been able to reopen those ranges.


fin fur and feather had the same issue, they were forced to switch to steel several years ago as well.

 

[the_doctor]

Well, that would be a shift in policy to be sure

Even those few that are well intentioned fail to accomplish this for lack of objectivity, rational thinking or common sense...

This state's legislature is the model of "knee jerk liberal" for the entire nation. They enact policies based upon impulsive reactions to headline sound bites that are perceived as a problem rather than actually trying to solve useful problems, looking at prior attempts to see if they work and generally finding a balance between regulation and freedom...

Government normally has a tendency to do this, but the governance of this state has refined such reactive governance to a science (unfortunately).

So, no, I don't find CrossFire's statements "outlandish." While they may be restating the obvious, they reflect a rational anger and distrust of an activist agenda driven government that violates the letter and spirit of this nation's founding as well as the state's constitution and legacy as not only one of the founding colonies but the origin of the American Revolution...

This is absurd. To say that lead can not cause harm is untrue. To decide to ignore the potential dangers is callous. To continue is negligence.

You must be responsible for yourself. Quite frankly, I do not think that the DEP should visit a range for an inspection. There should be no need because it should have already been handled by the club.

Failure to do so leads one to think of deliberate intention to cause harm if not recklessness.

If one thinks that they can fight the DEP, then they are wasting their breath. It would serve better to create a remediation plan and a trap plan as it shall only cost a lot less and provide piece of mind.

Ever consider the PR talk about your club tarnishing the environment?

Time to get real and take care of your responsibilities. To say everyone is against you makes one think of lunacy.

 

[EddieCoyle]

The DEP shut down the trap range at the Shirley Rod and Gun Club years ago for this reason.

It can happen.

 

[cekim]

This is absurd. To say that lead can not cause harm is untrue. To decide to ignore the potential dangers is callous.

I didn't say lead cannot cause harm... Those are your words you are trying to put into my mouth...

I simply said that you cannot say that CrossFire's comments are "outlandish" because there is historical precedent for absurdity of legislation and enforcement of many forms in this state (and that's putting it lightly)...

I am being neither callous nor negligent - only demanding that any DEP action be based on objective data and analysis not fear mongering over the mere presence of lead...

 

[namedpipes]

Have you ever considered that some public servants are only trying to protect the public? Why do not consider this instead of making outlandish statements. They do not enact laws. DEP does not allow any individual a break when it comes to contaminating the land or water.

Bill

By and large, no, I haven't considered that.

DEP is a fiefdom with a worthy cause, but with both too much and too little power to actually finish the job.

 

[terraformer]

The DEP shut down the trap range at the Shirley Rod and Gun Club years ago for this reason.

It can happen.

Which reason? Shooting out into wet lands or lead shot on the ground?

 

[EddieCoyle]

Which reason? Shooting out into wet lands or lead shot on the ground?

Shooting over wetlands.