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EPA will accept public comments on its proposed decision until June 26, 2023.

During this time, the public and interested stakeholders may submit written comments for EPA’s consideration.

Written comments may be submitted to: [email protected].

Sample language:

To: David Cash, EPA Region 1 Administrator

Dear Administrator Cash:

I am writing in strong support of the Environmental Protection Agency Region 1 draft determination that the proposed multipurpose machine gun range (MPMGR) at Joint Base Cape Cod has the potential to contaminate the aquifer and would create a significant public health hazard. The proposed MPMGR would be located over the Upper Cape Water Supply Reserve and the Sagamore Lens, which is the single source of drinking water for the towns in the Upper Cape region. According to the EPA report, the MPMGR would produce a four-fold increase in the amount of ammunition and associated contaminants that would be deposited on the ground over the aquifer, thereby increasing the potential for those contaminants to reach the groundwater and pollute it. The Cape’s sandy, highly permeable soil further increases the potential for contaminants from the project to adversely impact regional water supplies.

The Massachusetts Army National Guard’s Environmental Assessment of the MPMGR project failed to adequately study and identify the potential environmental and human health impacts of the project, and the Guard has not proposed any meaningful mitigation that would prevent adverse impacts from occurring. The Cape Cod aquifer has experienced significant damage from many decades of JBCC activity, with cleanup efforts still ongoing. As pointed out in the EPA study, if current drinking water sources become further contaminated, new drinking water sources in Upper Cape towns may not be easily found, if they can be found at all. I therefore agree with the EPA determination that neither the aquifer nor the public should bear the risk and uncertainty of a large-scale expansion of pollutants impacting the water supply, and that the most effective way to mitigate significant future impacts to drinking water is for the MPMGR to not be constructed on the Upper Cape Water Supply Reserve.

I urge the EPA to finalize its draft determination, which would require that federal financial assistance not be allowed for this ill-conceived project.

Sincerely,
(Your name and address)

EPA Draft Determination on Machine Gun Range Talking Points

The Safe Drinking Water Act (SDWA) mandates strong protections where a drinking water supply is dependent on a single aquifer. The EPA has conducted a comprehensive evaluation of the proposed multipurpose machine gun range at JBCC, and has provisionally determined that the project has the potential to contaminate the aquifer, creating a significant public health hazard.

Here are key findings of the EPA study:

  • The MPMGR would be located over the Upper Cape Water Supply Reserve and Sagamore Lens, the most productive part of the aquifer. Sand and gravel soil make the aquifer highly vulnerable. 
  • Seven state-designated Zone II Wellhead Protection Areas are within 1,000 feet of the MPMGR, associated with 21 public water supply wells in Bourne, Falmouth and Sandwich. These 21 public wells are between 0.7 and 6.2 miles from the center of the MPMGR. The proposed MPMGR is near the top of the groundwater lens, so contaminant flow from the range may be in multiple directions. 
  • The Cape Cod aquifer has been significantly damaged over many decades of JBCC activity with remediation still ongoing. New drinking water sources in Upper Cape towns may not be easily found, if at all, if current sources become contaminated. 
  • Approximately 1.3 million copper bullets would be used annually. Copper, manganese, lead, chromium, strontium and antimony are contaminants present in the ammunition. Additional components include semi-volatile organic compounds such as nitroglycerin. The annual total mass (kg) of contaminants of concern in ammunition to be used at the range includes copper (4590 kg), manganese (15.1 kg), strontium (15.0 kg), lead (6.78 kg), antimony (4.32 kg), and chromium (1.13 kg). For alternate ammunitions, chromium input is higher at 8.91 kg per year. Both types of ammunition contain about 400 kg of nitroglycerin.
  • The 1.3 million bullets fired per year would be a four-fold increase in the current number of bullets deposited above the aquifer. There could be more than 275 tons of bullet components released to the environment over a 50-year project timeframe. The fact that contaminants from existing firing ranges have found their way into the soil concerns the EPA because the MPMGR will greatly expand the amount of munitions being fired.
  • The National Guard’s Environmental Assessment stated that any adverse impacts to groundwater would be insignificant. EPA, however, has provisionally concluded that accidental and expected contaminant releases from the MPMGR have the potential to contaminate the aquifer.
  • The Guard stated in its Environmental Assessment that “…no impacts to groundwater are anticipated” from the project. However, the Guard has not provided sufficient information to EPA to support this claim, nor has it proposed any mitigation measures to address potential releases of contaminants to groundwater.
  • Due to the project’s size, location, and intended use, EPA is uncertain that mitigation can reduce the potential to contaminate the aquifer. 
  • EPA has provisionally determined that neither the aquifer nor the public should bear the risk and uncertainty of a large-scale expansion of pollutant loading.
  • The EPA states that Department of Defense training policies have no bearing on whether other project alternatives should have been considered. The EPA concludes that the most effective way to mitigate significant future impacts to drinking water and maximize environmental benefits is to not construct the MPMGR.