APCC Opposes the Proposed Multipurpose Machine Gun Range on the Upper Cape Water Supply Reserve

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Update 10/19/2023

MPMGR bids exceed available funding – APCC has obtained documents from a public records search that indicate the cost to construct the multipurpose machine gun range, which according to EPA threatens the Cape’s water supply, is more than the funds appropriated for the project.

The Massachusetts National Guard has resisted APCC’s requests for information, but other sources of public information have revealed an apparent shortfall in funding needed to build this as-yet permitted project.

While APCC has no direct knowledge of what the Guard plans to do to address the funding deficit, APCC has had direct conversations with the offices of Senator’s Elizabeth Warren and Ed Markey as well as Congressman William Keating, asking them to block any efforts the Guard may undertake to seek supplemental funding from Congress to build this ill-conceived project. (See letter.)

Even though everything related to Congress is confusing and uncertain these days, APCC remains vigilant in trying to prevent any additional public funds to be set aside for a project that has been identified as a potential significant risk to the Upper Cape Water Supply Reserve.

Update 5/17/2023

Wednesday, May 24 public hearing will begin at 7:00 p.m. and will be preceded by a public meeting beginning at 6:30 p.m. It will take place at: Center for Active Living, 70 Quaker Meetinghouse Road, Sandwich, MA

Written comments due to EPA by June 26th. Email to: [email protected] For sample email and talking points, click here.

Update 05/04/2023

APCC Calls on Gov. Healey to Support EPA Findings on Machine Gun Range

Update 04/27/2023

CLICK HERE for the EPA draft determination and information about the public hearing process. https://www3.epa.gov/region1/eco/drinkwater/capecod/adminrecord/ssa-report-eport-final-april-2023.pdf

Click here for the entire administrative record. https://www3.epa.gov/region1/eco/drinkwater/capecod/adminrecord/

EPA will hold a short public informational meeting followed by a public hearing to accept oral comments.

Wednesday – May 24, 2023
Public Meeting – 6:30 pm
Public Hearing – 7:00pm
Center for Active Living
70 Quaker Meetinghouse Road
Sandwich, Massachusetts

*for accessibility or translation requests, please email [email protected]

If you would like to send written comments, please email them to: [email protected]

Update 04/24/2023

APCC calls on the governor to reconsider the uses at Joint Base Cape Cod. See APCC’s letter to Governor Healey here (PDF) and the related press release here (Word).

Update 04/19/2023

APCC learned of a 50 year lease extension for the JBCC until 2099. Concerned by the lack of public process with the lease extension APCC requested all related documents (PDF). The Guard converted all documents into paper and sent them to APCC and we scanned and digitized them for publication. The following are PDF links to the documents we received:

Supplemental Agreement No3
Military-Civilian Community Council MC3 Meeting
Major General Gary W. Keefe Email
Memorandum For ARNG-IEP-R
Colonel Sean D. Riley Email
Colonel Matthew Porter Email
Colonel Richard Cipro Email
Colonel Jason D. Oberton Email
Colonel Timothy Mullen Email
Christopher Faux Email
Public Records Request
Colonel Jason D. Oberton Email
David Shannon Email

Update 10/26/2022

The status of the multipurpose machine gun range continues to be in a holding pattern as the U.S. Environmental Protection Agency conducts its sole-source aquifer study related to potential impacts to drinking water from the project. The state’s Environmental Management Commission (EMC), which has the authority to approve or deny the project, will not take up consideration of the machine gun range until the EPA is finished with its study. It is anticipated that the EPA study will extend to the end of 2022, making a decision on the project by the EMC unlikely until 2023. APCC continues to closely monitor the project and will keep the public updated as events warrant, including issuing alerts and providing information on actions you can take.

Update 11/12/2021

In light of the news that a machine gun range was funded for Fort Devens, APCC submitted a request for public records on October 13 to deduce whether the Fort Devens’ machine gun range was included in the alternatives analysis for the proposed multi-purpose machine gun range on the Upper Cape water supply. A response (PDF) was received November 3, 2021 from Timothy F. Cullen, Massachusetts Military Division, Legislative Liaison, Joint Force Headquarters who said in his email that there were no studies, reports, and analyses specific to Ft. Devens that met our request. Click here (PDF) for the records they released to us.

Update 10/13/2021

In the news: From WCAI – A proposed machine gun range on the Cape has come under fire. A second in the state just got funded by Eve Zuckoff; from the Cape Cod Times – Fort Devens is getting a new machine-gun range. Why didn’t JBCC officials mention it? by Jeannette Hinkle

Update 9/27/2021

APCC formally requested that Governor Baker use his authority to stop the misguided pursute of the siting of a Multi Purpose Machine Gun Range atop the Upper Cape Water Supply Reserve. A copy of the letter can be viewed here (PDF).

Update 9/8/2021

After filing not one, but two public records requests under the Massachusetts Public Records law and then having to appeal to the Secretary of Commonwealth to compel full disclosure, APCC finally and belatedly received records from the Massachusetts National Guard that contained emails from Brigadier General Christopher Faux, Joint Base Cape Cod executive director, which expressed concern that the proposed multipurpose machine gun range could not sustain the scrutiny of a full environmental study, and if it was required, the Guard “will most likely lose the project and its funding.”

These illegally withheld records are the smoking gun that reveal, in the Guard’s own words, what we suspected all along. The Guard was afraid of a full Environmental Impact Study. It is not much of a leap then to see why the Guard ignored legitimate public comments and concerns on their internal Environmental Assessment; doing so was the only way to avoid a full EIS. Given how the Guard’s own statements lay bare their abuse of, and disregard for, the public’s right to participate in the protection of its sole source of drinking water it is obvious why the Guard would not want the public to see these emails.

To read APCC’s press release, click here (PDF). To read the emails in question, click here (PDF).

Update as of 8/2/2021

All meetings concerning the machine gun range have been postponed until further notice. Please check back or sign up for our emails for future meeting notices and alerts.

Update as of 6/17/2021

The meetings of the Community Advisory Council (CAC) and the Environmental Management Commission (EMC) on the proposed multi-purpose machine gun range have been postponed. No new dates and times have been announced.

Update 6/7/2021

It has been apparent to APCC that the Massachusetts National Guard has viewed the public process associated with the proposed Multi-Purpose Machine Gun Range as something to endure and not as an opportunity to assess and address public comments and concerns. That view was validated last week based upon a communication from the commanding general of Joint Base Cape Cod to the Cape Cod Chamber of Commerce where he derided the almost 400 people who formally commented on the project as “naysayers, activists and anti-military groups.” The Guard has, in its own words, provided evidence that it lacks respect for public comments not fully supportive of the project (of which, as stated by the Guard, there were almost none). The statement provides the proof that invalidates the public review process that led to their own declaration that the project would have No Significant Impact on the environment.

APCC has written to Governor Baker, to call on him to restore the public trust that has been violated by the Guard’s own actions and words by rejecting the range project. APCC believes that decisions about the use of public resources must be reliant on full and impartial consideration of the public interest and that it is now unmistakable that the consideration of the machine gun range has been tainted by the expressed bias of the Guard. Without a valid review, there is no legal basis upon which the project can be approved.

The next step in the process is the meeting of the Community Advisory Council on Thursday, June 17th. (The details of the meeting are not yet available.) APCC urges the public to participate in this meeting and convey concerns directly to the CAC as it considers its recommendation to the full Environmental Management Commission, which will meet on July 12 to determine the fate of the project.

Not only is the protection of the public resource that is the Upper Cape Water Supply Reserve at issue here, but so is the right of the public to a full and fair hearing under the law. If this project, and the flawed and biased process used to promote it, are deemed acceptable, the public will have lost more than its drinking water and wildlife habitat.

APCC sent a letter to Gina McCarthy, White House National Climate Advisor you can read here.

  For the several hundred of you who emailed Senators Warren, Markey and Congressman Keating with your opposition to the proposed machine gun range, thank you. Here was the immediate result: your elected officials sent a letter to the National Guard and you can read it here.

The Massachusetts Army National Guard has proposed to locate and construct a machine gun range within the Upper Cape Water Supply Reserve on the northern 15,000 acres of Joint Base Cape Cod. The reserve was established in 2002 to protect drinking water and wildlife habitat, and to allow military training that is compatible with those uses.

The machine gun range project would require 199 acres of land disturbance, including 170.5 acres of forest area to be clear cut to accommodate the range footprint, operations and control area facilities, roads, firebreaks and other aspects of the project, according to the Guard’s Environmental Assessment. The project plan also includes the creation of a Surface Danger Zone area on approximately 5,197 acres, or over one-third of the 15,000-acre Upper Cape Water Supply Reserve, where projectiles fired on the range would land.

APCC obtained, through a public records request, copies of all public comments submitted to the Guard on the machine gun range. APCC provides these comments on this website for the purpose of ensuring a full disclosure of the general public’s response to the project.

Map of Proposed Machine Gun Range on Cape Cod
+ Click on image above to enlarge
v Of the 367 public comments received by the Guard, 330 opposed the project. Nine comments were in support of the project. An additional 28 took a neutral position, most of those seeking information or requesting an extended comment period.
Making these public comments available is part of APCC’s continuing effort to make certain that the environmental issues associated with the project are understood, fully examined and appropriately addressed.

APCC has undertaken a detailed assessment of the draft Environmental Assessment (EA) and finds it severely lacking and deficient. The full text of APCC’s comments can be found HERE.

Click here to access the draft EA

Cape Cod Pine Tree