[In response to “Opinion/Your Turn: Support EPA in fight against JBCC machine gun range proposal” by Mark Forest and Eric Turkington, Cape Cod Times, June 18, 2023, https://www.capecodtimes.com/story/opinion/columns/2023/06/18/opinion-cape-codders-must-support-epa-stand-on-jbcc-machine-gun-range/70322918007 (Subscription required)]

In opposing the Massachusetts National Guard’s Multipurpose Machine Gun (MPMG) Range project at Joint Base Cape Cod, Mr. Mark Forest and Mr. Eric Turkington cling to an outdated narrative that ignores the research, planning, and interagency cooperation over the past 25 years. Their skewed characterization of the 1998 Community Working Group and subsequent work to establish Massachusetts General Law Chapter 47 of the Acts of 2002 omits key parts of the story. The working group was an important first step, but since then there have been numerous orders, environmental documents, and Environmental Protection Agency (EPA) decisions that have defined the Massachusetts Army National Guard’s responsibility to protect habitat and groundwater while conducting military training.

Mr. Forest and Mr. Turkington fail to recognize the progress over the last two decades that enabled the Massachusetts National Guard to return to small arms live fire on the Cape, including pistols, rifles, and even machine guns. These activities resumed with the full participation of the Environmental Management Commission, the EPA, the Upper Cape towns, the public at large, and the Massachusetts National Guard. Instead of being vilified, Camp Edwards Army National Guard Training Site should be celebrated as a model of environmental stewardship.

In fact, the range projects initially proposed in 1998 were not vetoed, as Mr. Forest and Mr. Turkington assert, but “removed from consideration” so that planners could develop a more refined and deliberate approach for the Northern Training Area, also known as the Upper Cape Water Supply Reserve (UCWSR).

To be clear, the Modified Record Fire Range has been operational since 2012 to include the use of machine guns. Construction of this range was possible because of the guiding principles adopted from the Community Working Group Master Plan, which carried forward into the Final Area-Wide Environmental Impact Report from July 16, 2001. Central to these principles is appropriate environmental oversight and management to ensure military training occurs in harmony with protection of drinking water and wildlife habitat on the UCWSR.

Under EPA oversight, the Impact Area Groundwater Study Program found no evidence that small arms activities caused groundwater contamination. As a result, the Massachusetts Army National Guard constructed three ranges in 2007 after being granted a pilot program to fire lead ammunition into bullet containment systems.

By 2012, the Army had released the copper Enhanced Performance Round (EPR), which the Environmental Management Commission reviewed and approved for use. This led to the opening of Sierra Range—the same Modified Record Fire Range “removed from consideration” by the Community Working Group.

In 2015, EPA Region 1 released its decision document on the Small Arms Ranges Operable Unit at Joint Base Cape Cod, which concluded that “The overall results of groundwater evaluations conducted to date indicate that the small arms ranges are not currently a source of any significant groundwater contamination.” The EPA further stated that “studies indicate that propellants [from small arms ammunition] do not leach to groundwater because they are bound [chemically] in nitrocellulose.”

The EPA’s findings led to the Massachusetts National Guard’s request and ultimate approval in 2017 to modify Administrative Order 2 that previously prohibited the use of small arms ranges. The EPA published a five-year reviewof this modification in May 2023. The report reaffirmed that small arms firing at existing ranges on the UCWSR is “protective of the environment.”

For more than two decades, countless local officials, community organizations, and individuals have supported the Massachusetts National Guard in its efforts to develop necessary and compatible training sites such as the MPMG Range. Unfortunately, Mr. Forest, Mr. Turkington, and a few other outspoken opponents are relying on an incomplete accounting of history to suggest the Guard is ignoring its obligation to protect the groundwater, habitat, and communities around Joint Base Cape Cod.

The Massachusetts National Guard is committed to maintaining the unique environment of the UCWSR because it has a vested interest in protecting this valuable training resource. Camp Edwards is the largest military training venue in New England and the only property with the capacity to host this vital training site. Having to travel outside the Commonwealth for training makes it that much more difficult for Guard members to fulfill the dual mandate to protect the homeland and fight our nation’s wars.

A review of the publicly available documents on this project and the findings of experts who have dedicated their careers to the protection of groundwater, habitat, and compatible military training on the UCWSR show that the Massachusetts National Guard has faithfully upheld the tenets of Chapter 47. The MPMG Range project is the result of years of diligent work and thousands of hours of planning with oversight by the Environmental Management Commission at every step. Far from ignoring the past, the MPMG Range is the product of a clear-eyed understanding of its history.

To support our Commonwealth’s National Guard Soldiers and Airmen, please message the EPA by Monday, June 26th:

  • Written comments may be submitted to: [email protected]
  • Verbal comments may be submitted on a voicemail box at (617) 918-1800

By Landon Mavrelis
NGAMA President