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This page was last updated Friday, February 19, 2010 9:54 PM
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ENVIRONMENTAL STATUS OF |
| EXECUTIVE SUMMARY |
| The House Committee on Armed Services encouraged the Marine Corps to complete the Preliminary Assessment and Site Investigation (PA/SI) of the San Diego Shotgun Sports Association (SDSSA) trap and skeet range on Marine Corps Air Station (MCAS), Miramar as rapidly as possible so that appropriate mitigation measures may be taken and the range reopened without undue delay. The draft PA/SI issued by MCAS Miramar, like the six government studies that precede it, does not consider the possibility of reopening the range or the measures that would be necessary to do so. The draft PA/SI and the other studies have been conducted under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”), which is intended for evaluation and one-time action at closed sites, not ongoing management of operating sites. There appears to be no reason to use CERCLA to try to evaluate the possibility of continuing range operations (other than precedent to date at this site), and no reason to not evaluate the possibility of ongoing range operations in a regulatory context appropriate for shooting range operations. In January 2009 the U.S. Environmental Protection Agency (EPA), in a direct response to SDSSA regarding this range, issued a letter concluding that an environmental response under CERCLA was not required and that a comprehensive lead management plan should be able to address environmental concerns. The U.S. Environmental Protection Agency (EPA)’s 2001 guidance on best management practices for outdoor shooting ranges has not been considered by the draft PA/SI or any other government study of the site. This EPA guidance addresses operation of shooting ranges under the Resource Conservation and Recovery Act (RCRA), and describes the appropriate regulatory context and environmental management actions for operating shooting ranges consistent with case law and sound science. SDSSA developed a lead management plan to implement EPA guidance and case law under RCRA in environmentally sound ongoing management of the range. MCAS Miramar could comply with the Congressional directive by requiring SDSSA to implement EPA guidance via this lead management plan under a renewed lease. Richard K. "Dick" Peddicord, Ph.D. President Dick Peddicord and Company, Inc. Environmental Excellence for the Shooting Sports |
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