Draft

PLEASE NOTE: Items below in black are from the original Draft Recommendation by local DCNR District Forester, Roy Brubaker. Items in red are responses to each point by former Target Range Task Force Member and DCNR Volunteer, Mike Sanni. ****************** Proposed Decision On The Michaux Target Range Based on current understandings of critical issues outlined in the Target Range Progress Report and the consideration of public input received during the Public Comment period from October 15-November 15, 2011, DCNR Bureau of Forestry and the Michaux State Forest District are proposing a conditional 3 year reopening of the target range at the current location. The intent of this reopening is to implement an adaptive management process to ascertain whether or not range operations can be administered in a sustainable manner into the future. - RESPONSE As a former Target Range Task Force member, long-time DCNR Volunteer, and the individual who originally brought the target range issue to the attention of the DCNR, I feel qualified to speak with some authority to this recommendation. During the first meeting of the Task Force Group, I made it clear to the others members and to the District Forester that I am not opposed to the establishment of a target range. However, I also made it clear that its current location was an undue burden on wildlife, other users to the area, and posed a potential risk to our communitys water source. A viable compromise was made to simply relocate the range and avoid many of the serious impacts associated with its current location. Now that the recommendation is being made to reopen the target range without moving it to a more appropriate location, I feel compelled to address each point of this recommendation to demonstrate its flawed and uncompromising nature to those in the community who are not aware of the relevant facts. My notes follow in red. The following is a summary of the primary justifications for this decision: 1) The Bureau of Forestrys mandate provides for the opportunity to utilize state forest land for this activity if it can be done compatibly with other aspects of the agencys mission, and within existing operational constraints.
1

Draft

- RESPONSE Is the mandate noted above referring specifically to the establishment of a target range or for the activity of hunting on state forest lands? I would be curious to know whether there is a clause within the mandate making the establishment and management of a target range illegal in DCNR by-laws. The compatibility of this target range has never been established by the DCNR or the Target Range Task Force Group. As a former member of the Task Force Group, (except for the November, 2011 Lead Analysis), there were no other impact studies, focus groups, surveys, etc., which were undertaken to validate the compatibility of many important issues associated with this range location. 2) The range provides a popular recreational experience for many visitors to the state forest. - RESPONSE This area is also visited by many other users such as fisherman, hikers, mountain bikers, kayakers, horseback riders, bird watchers, photographers, and for quiet family outings who are impacted significantly from noise generated at the range. In comparison, these passive users have little if any noticeable impact on other users, local wildlife, or the environment. 3) While there are numerous issues associated with the range (as outlined in the Target Range Report and Public Comments), none of these issues; either individually or collectively, clearly indicate immediate closure at the current site is the only or best public benefit option. - RESPONSE This is clearly inaccurate and can be demonstrated with a few casual observations including, safety issues (i.e., proximity to other users in the area, vandalism, hazardous waste contamination), etc. In its previous location, the target range was 0.3 miles from the RV Camp site along route 233. Due to safety concerns (proximity to area campers, hikers, mountainbikers, etc.), the DCNR relocated the range to its current location. However, the distance from the current location to the lakeshore and other users (campers, hikers, mountainbikers, fisherman, kayakers, canoeists, horseback riders, etc.), is also exactly 0.3 miles as determined by GPS. Hikers with or without maps, can stray into the vicinity behind or beside the range from Rocky Knob and other points which presents an immediate danger even if the range is outfitted with a wire fence.
2

Draft

Vandalism has been a constant issue at this site from its relocation and opening in 2004. Former District Forester, Mike Kusco dealt with shooters using computer monitors and similar items as targets at this site which were left for others to remove. Tires, trash and a very large fragment of iron is currently at this site with myriad holes from armor-piercing ammunition. Vandalism precipitated the 2010 closure of this range and saw damage to numerous signs and other items at the range including bullet-ridden trash cans, etc. Importantly, the Baseline Characterization Study (Contaminant Study) conducted by Groundwater Sciences Corporation in 2011, conclusively declares the accumulation of hazardous waste which now exists in multiple areas of both sites (rifle & pistol range) as a result of heavy user impact. After studying topographical maps of this area the Chair of Environmental Sciences at Wilson College stated in writing, USGS topographic maps show that the drainage plume from the firing range eventually drains into the Long Pine Reservoir. He also stated that although drinking water contamination is not a present danger, uptake of lead and other contaminants by plants and ingestion by animals (called biomagnification) could enter our food chain. Mr. Brubaker made a categorial dismissal to me in his office of noise impact on wildlife. However, there are numerous studies and other documentation which clearly demonstrate just the opposite. Please see: http://www.acousticecology.org/wildlandbiology.html http://www.airandnoise.com/animals.html http://www.nonoise.org/library/fctsheet/wildlife.htm Many studies exist and are readily available online on this topic. Therefore, contrary to what this recommendation report suggests, one may easily find copious evidence which either individually or collectively, shows why this target range should not be reopened at its current location. 4) Save for the baseline site characterization study, current hard data to describe the level, impact, or trajectories of any of the problematic issues associated with the target range at the current site are not available. Therefore, a decision at this point to either terminate or relocate the range, absent compelling empirical evidence that it is in the publics best interest to do so; would be arbitrary at best.
3

Draft

- RESPONSE DCNR, as the responsible agency is charged with protecting the Commonwealths natural and heritage resources, and for providing recreational opportunities for all Pennsylvanians and visitors to enjoy. An independent Contaminant Study should have significance and not be dismissed in any regard if an agency is tasked with protection of an important natural resource such as our reservoir. Unfortunately, and for reasons unclear, this draft recommendation seeks to quickly reopen this ill-placed target range rather than take the proper time to do appropriate impact studies for all issues relevant to the area or even to recommend another better location. No where in this report are the undesirable conclusions of the Contaminant Study cited which suggests a skewing of the facts. Since no hard data was ever sought by conducting preliminary impact studies for opposing users, safety, enforcement, and other issues, one cannot and should not make the claim that no hard data is available for these issues. The proposal to reopen the range is based on implementation of the following mitigation investments and changes to range management policies and procedures: 1) Controlled Range Access and Hours: Ability to control access to and range-use hours is the most critical best management practice suggested in most target range manuals. A woven wire fence and lockable gates will be erected around the range site and the range will operate around routine open and closed days throughout the week. Better control of site access and operational hours will address the following issues: a. Provide for greater safety by limiting accidental walk on - RESPONSE As a hiker, I have unintentionally strayed into this area after camping and hiking off trail by using dead-reckoning navigation to the reservoir from Rocky Knob (north of the range). The establishment of a wire fence does nothing to guarantee safety to hikers or others who happen to stray in close proximity to the proposed fence perimeter. b. Provide noise-free days at the lake and surrounding vicinity by scheduling non-use range days. - RESPONSE This specious argument exemplifies the phrase half of a bad thing is still a bad thing. To suggest many issues
4

Draft

associated with this range site will somehow be removed by limiting use days, is a testament to strained reasoning. The impact to this sensitive area whether it be during three days or seven, remains significant and consequential. Hazardous waste will still be accumulated, contaminant testing will still be required, other users will be impacted and will continue to protest, while enforcement, vandalism and safety issues will prevail. Wildlife inhabits this area 100% of the time and has no non-use days. Waterfowl and other animals will be affected whether use-days are limited or not, and will most likely abandon the area as when it was open. Moreover, this is a small range with limited parking and shooting capacity (no more than 5-6 shooters at one time). When the range was open from 2004-2010, I personally witnessed a queue of shooters along the service road waiting to enter. During this period, there were no restricted days so a compressed use-week as proposed, would seem to portend greater congestion and less safe circumstances. Even if 1% of the current 3,521 permit holders visited the range each day that would amonut to 35 users. Statistics cited by the respected Environmental Working Group notes that, At very modest levels of activity it is quite possible that every firing range in the U.S. is contaminated with lead levels that would trigger Superfund cleanups. And they also state that, In just 2 years, a typical firing range can have lead contamination equivalent to a 5-acre Superfund site. c. Increase the opportunity for user-group self-policing by concentrating use hours and limiting low/unobserved use opportunities. - RESPONSE Volunteerism is honorable but human nature historically suggests initial good faith efforts by many volunteers wane after initial enthsiasm. As a long-time DCNR volunteer myself, I know first-hand the good intentions of adopting a forest road and parking area (as I continue to do now and have done for many years). I also understand how these duties can be neglected or postponed due to everyday responsibilities in our busy lives.
5

Draft

To place a critical facility with such inherent dangers located on public lands in the responsibility of volunteers who are not officials of the state, is neither appropriate nor judicious. Whatever the outcome of this issue, one thing is certain; even if volunteers accept tacit responsibility for self-policing this site, the DCNR, PA Game Commission, Chambersburg Water Authority, Bureau of Forestry personnel (Minerals Section geologists and District management staff), DEP South Central Regional Environmental Clean Up Divisions Staff, and their respective officials are ultimately responsible for any detrimental consequences. 2) Establish Range Contaminants Management Plan and Mitigation Technologies: A site monitoring and mitigation plan will be developed for contaminants commonly associated with target ranges. Cooperating stakeholders for this effort will include the Chambersburg Water Authority, Bureau of Forestry personnel (Minerals Section geologists and District management staff) and DEP South Central Regional Environmental Clean Up Divisions Staff. Involvement of local academic expertise in an ombudsman role will also be desirable to ensure transparency and accountability. This site management plan will develop appropriate lead and other contaminant monitoring and management protocols to be used on the site to protect visitor safety, wildlife, and prevent ground and surface water contamination. As part of the process, least-cost lead mitigation backstop technologies will be sought and improved backstop technologies implemented at the site. - RESPONSE Contaminants may be commonly associated with target ranges but target ranges are rarely located near a communitys water source due to these very toxic contaminants and their obvious impacts. As cited by Dr. Wells, Chair of Environmental Studies Wilson College, The impacts of lead on the flora and fauna of Michaux State Forest, Long Pine Run Reservoir, and Caledonia State Park, can be substantial. As lead is a fat soluble substance and does not break down in the environment, it can pass up through the food chain and harm wildlife. Due to its location, the issues of additional expense and man-hours incurred from such a mangement plan; danger of contaminants; noise impact to wildlife; noise impact on other users; and many other issues
6

Draft

associated with the range in this sensitive area could be resolved, by the simple compromise of relocating the range. 3) Noise mitigation: Noise pollution and its impact on other forest uses was the most frequently cited concern based on public meeting comments. Overhead baffles at shooting stations will be constructed at both ranges (rifle and pistol) and shoot through mufflers will be provided for high caliber rifles at the rifle range. Limiting range hours to avoid early morning and late evening hours and splitting the week roughly in half between open and closed days (For example either Saturday or Sunday each weekend, and 2.5 days during the week) will also be used to mitigate conflicts with range use due to noise. - RESPONSE It cannot be stated enough that due to its location, many issues associated with the range in this sensitive area could be resolved, by the simple compromise of relocating the range. By Mr. Brubakers own written account, the use of noise mufflers was brought into question by a Task Force Member expressing concerns about the safety risk for a user compared to effective noise reduction. In response to my concern about reopening the range, he writes:[A member / proponent] brought up the question about the mufflers; Ive heard similar concerns that there is a tradeoff with them between user safety and noise mitigation ... - 02/21/12: The implementation of these recommendations will require increased office time and man-hours for the agencies and individuals mentioned above. This inevitably translates into greater expense for planning, implementation (including proposed new equipment and technology), and long-term operations. Compared to expenditures for hikers, paddlesport users, mountain bikers, horseback riders, fisherman and other passive activities, the costs for the target range user would necessarily be much greater. 4) Range Permitting: Access to the range will be provided through the Pennsylvania Game Commissions Target Range Access program (http://www.portal.state.pa.us/portal/server.pt?open=514&objID=620 410&mode=2) Either a current PA hunting license or PGC range permit will be required to utilize the range. 5) Range Regulations: While many of the current range use policies and regulations will remain consistent, there will need to be some
7

Draft

additions and revisions. Currently recognized issues to be addressed through range guideline revisions prior to reopening include: a. Development of shared understandings between DCNR and PGC on Michaux range enforcement i. Enforcement standards ii. Recommended level of deterrent/form of non-compliance iii. Process/jurisdiction for revocation of privileges b. Use of shoot through mufflers c. Process for opening/closing range - RESPONSE Notwithstanding past vandal activity, the above assumes all permitted users will adhere to the proposed rules and regulations (including always firing through mufflers and using the facility only during authorized days & hours, etc.). This is doubtful . . . Observation of rules and regulations in other areas around this reservoir are consistently dismissed by indifferent users and suggests great doubt as to whether those using this range will honor similar rules and regulations without 24 / 7 enforcement. Day-time swimming and diving, night-time swim parties at the base of the spillway, and trespassing on the spillway trail, have been a constant burden for the DCNR and enforcement officers. The fence across the spillway trail (similar to the proposed target range fence) has been cut through and trespassers hike over the spillway with impunity. I cannot imagine a scenario where the proposed target range fence will not suffer the same fate unless enforcement is present 24/7. Unlike other passive activities in the area (e.g., hiking, paddlesport, fishing, mountainbiking, family outings, etc.) the dangers inherent in a shooting range are exponentially greater simply by virtue of its nature. Alcohol use at the range during off-hours is not a could happen scenario. In fact, it has been documented via after-the-fact photographs as empty beer cans are shown. (please see photo gallery at: www.SaveLongPineRun.com). Range Maintenance Standards and Coordinated Volunteer Effort: Maintenance standards will be established for litter, spent shell casings, signage, and infrastructure repair. The range will be open one non-use weekend day every month to facilitate volunteer clean-up and maintenance efforts to meet these standards. When
8

Draft

volunteer efforts in any given month are insufficient to achieve range management standards, district maintenance staff hours required to ensure compliance with standards will be documented. 6) Communication and Information: Range Hours and Guidelines will be posted on the Michaux State Forest Website, posted at kiosks inside the target range and on the access gate. The range will also be indicated on the Public Use Map and other Trail maps as appropriate. Range hours, guidelines, and information will also be posted at the kiosk at Long Pine Run Reservoir to keep lake visitors informed about the presence of the range and how to limit its potential to conflict with their experience as forest visitors. Annual range reports will also be posted on the website over the next three years. - RESPONSE If noise was not such a serious issue to other users of the reservoir, it would be humorous to suggest a need to keep lake visitors informed about the presence of the range. Anyone who has attempted to enjoy a quality outdoor experience within miles of the range can attest to the relentless and explosive war zone-like noise generated by this range. It is quite a different thing to be a shooter engaged in this activity at the range and wearing ear-protection than someone trying to enjoy the quiet of the reservoir while hiking, fishing or boating. The above statement suggesting, how [lake visitors can] limit [the ranges] potential to conflict with their experience as forest visitors is offending to passive users who seriously value the outdoor experience in its tranquility and shows an important attribute of nature lost on some range proponents. This is a quality of life issue. This narrow perspective suggests that users of the range have not experienced the relentless and often rapid-fire from the water surface or nearby trails but only while shooting at the range itself. This selfcentered perspective lacks understanding and empathy for fellow users of the reservoir area. The real question is, why is the responsibility of limiting the ranges potential to conflict with another activity, placed on those who seek to enjoy the tranquility of this quiet location? Especially when quiet users do not similarly impact other users or this area? Sustainability Indicators To Be Used During Three Year Trial Period: The proposed decision to re-open the range is based on the assumption that by implementing missing best management practices and mitigating critical issues identified in the progress report and public comment period; public
9

Draft

target range activities at the current site represent a sustainable recreational activity within the Michaux State Forest that is in the publics best interest. However, this could be a faulty assumption. - RESPONSE To characterize in such a sweeping statement that this target range is in the publics best interest particularly with such an abundance of contraindicating information is presumptuous. I agree there are individuals to whom a target range would be of benefit and their needs should certainly be considered but not at the expense of a greater number of those whos enjoyment comes from the tranquility and quietude of this unique area and since a viable compromise has been offered. Adaptive management is a process in which decision outcomes are monitored using a set of measurable indicators to test whether or not underlying management assumptions are sound. In this case, given existing uncertainties spelled out in the target range progress report, reopening the range could be the wrong decision if doing so creates long-term public liability due to site/environmental contamination issues, exceeds district operational capacity in other areas of its mission, or measurably reduces other use values associated with the state forest. Therefore, the proposal to reopen the range is for a discreet trial period of three years, and will be conditional based on a number of measurable indicators used to test whether or not continued range use trajectories support or refute the assumption that it can be done sustainably at the current site. - RESPONSE I have always considered the three-year trial period a misleading and opportunistic proposal for the following reasons: A.) After great expense proposed to equip this location with a perimeter fence, locked gate, noise mufflers, new signage, updated shooting stations and many other enhanced accoutrements, not to mention man-hours for construction, enforcement etc., it would be viewed as wasteful to close it for non-compliance and would reflect poorly on DCNRs foresight and its management ability. B.) To reopen this range, provide membership through permits, allow users to again be active in their sport at this location for any period of time, only to then close it for whatever reason will bring a firestorm from the very users for whom District 1 officials are now advocating. C.) To believe that DCNR Officials would allow closure of this range for non-compliance after all of the expense, planning, and tempt
10

Draft

range users anticipation, would be nave, unfair to shooters and lacking judgement. Therefore, I am convinced if this range is re-opened, it will become a troublesome burden which will encumber District 1 and senior DCNR officials for many years to come. If the need to close this range does present itself, it will become even more problematic burdening District 1 and senior DCNR officials who will suffer exceptional pressure from betrayed range proponents to keep it open against any reason. The following are indicator areas that will be used by the district to evaluate the sustainability of range operations over the three year trial period: 1) Target Area and Scatter Zone Lead (and other contaminant) Levels and Contributing Range Use Behaviors1 Indicators: Annual (??) measurement of Lead impact area Annual (??) measurement of Scatter zone contaminant levels Number of citations for birdshot/unregulated target use Shotshells/clay bird/wadding/bird fragments/unregulated target use encountered during routine site monitoring. - RESPONSE How will this citation process work without an enforcement officer present during all open hours for monitoring? Can a volunteer be given such authority to directly cite violators? If not, doesn't this require official citation and reporting by authorized individuals on site at the time of incident? Reason for the indicator: At well managed small arms, single projectile ranges such as this one, scatter zone impacts should be minimal, as most of the lead and other contaminants should be concentrated between the shooting station and the target area. After clean-up of existing target area lead levels, the new lead management plan will require an annual sampling process to determine the average size of that years lead impact area around each target site. Keeping each successive years lead impact area as small and consistent as possible is critical to
1

The Scatter zone is the area surrounding the target area. When contaminant levels in the scatter zone become problematic, mitigation is extremely costly. 11

Draft

minimizing the short and long-term cost of site lead/contaminant mitigation. - RESPONSE As per conclusions of the rifle range in the Contaminant Study: "Soil is impacted by target shooting activities. Using Act 2 cleanup criteria, all of the soil areas of the rifle range have been impacted above the cleanup criteria in at least one sample. The soil sample collected in the target impact area has TCLP concentrations indicating that it is hazardous waste." As per conclusions of the pistol range in the Contaminant Study: "The shallow berm soil, however, meets the definition of hazardous waste." Greater annual taxpayer expenditure for the future would, without question, be the "new norm" for a reopened range scenario including annual tests for contamination, clean-up, increased man-hours, regular maintenance, etc. None of this however, addresses the many other relevant issues noted previously leaving this range as problematic as before. We must think about this issue in totality. Scatter zone samples will also be taken on an annual (??) basis. Indications of short-term accumulation of contaminants in the range scatter zone would suggest that either range users are intentionally setting up unregulated targets in the scatter zone (rather than in front of the intended backstop) or using birdshot. There is observational evidence at the current range that both of these practices occur (even though at this point they are statistically undetectable) though they are a violation of range regulations. Early evidence that continuation or, worse, an increasing trajectory of such undesirable range behaviors is occurring should represent an unsustainable use-burden on the non-range using segment of the public. - RESPONSE Again, there were no studies to support the notion that scatter zone samples are at present, statistically undetectable. However, there is significant visual evidence that trees surrounding the site have been impacted due to scatter. Without baseline studies, can one confidently appraise in the future, whether this metric has changed for better or worse? Monitoring range behaviors through enforcement and site monitoring as well as measurable site impacts will ensure range
12

Draft

activities do not represent a long-term, time-lag public liability. If in the three year period, measurable site impacts are still negative, but enforcement and monitoring indicators show continued or increased evidence of range use behaviors that will eventually contribute to a scatter zone impact, the future viability of the range will be considered, even without measurable scatter zone contaminant levels, less sustainable than if all four indicators show positive trends; particularly if coupled with undesirable trajectories in other indicator areas. - RESPONSE This recommendation is essentially a three-year experiment at the expense of a sensitive and extraordinary area which exhibits a rich diversity of wildlife, plant life and is enjoyed by numerous quiet users. Quiet users to this area have demonstated over the course of decades their negligible impact to other users, wildlife, the environment, etc. while the target range in just 6 years, has demonstrated the reverse and has elicited growing opposition. Impact on District Operational Capacity to Meet Other Areas of its Mission Indicators: Number of volunteer hours committed to range clean-up days Monthly maintenance staff hours needed to ensure Range Maintenance standards are met Annual Range infrastructure maintenance costs Availability of outside/partner funding to cover range management needs Ability to meet other recreational management goals and priorities during the three year period. (Potential measures could include): Trail inventory and Assessment Completed. Michaux State Forest Multi-Use Trail system Map ATV trail re-hab on Log Sled and Grave Ridge Camp Michaux Re-veg plan written(??) Big Pine Flats Ecological Management Plan in place and being implemented No decrease in Road Grading/brushing maintenance schedule.
13

Draft

Reason for the indicator area: Budget and resource constraints and transparency about the level of priority the district places on supporting target range activities/infrastructure vs. other recreational activities was raised as a concern by the Target Range Task force and numerous internal and external stakeholders during the Public Comment period. Prioritizing range operations at the expense of other recreational activities and infrastructure is not a sustainable option, given the heavy use and deferred maintenance costs associated with Michaux State Forests road and trail system. The components of this indicator area will provide a realistic test of range operating costs, the portion of those costs absorbed by the district in a given year, an indication of volunteer and partner support/defrayment of range operating costs, and the capacity of the district to achieve other critical management goals within the same three year period. - RESPONSE Compared to passive or quiet users (fisherman, paddlesports, hikers, family outing, etc.), who have had little if any impact on the environment or others, the expense to which the DCNR is willing to provide, without doubt suggests an unjustifiable and biased preference to a single user group. The deferred cost of road maintenance will exist in spite of, not due to, quiet user activities. 2) Impact on other forest use values: Indicators: Focus group and survey sampling of forest users recreating in the vicinity of the target range. - RESPONSE Mr. Brubaker has mentioned often the need for empirical data, and baseline studies are a requisite for any scientific comparison of such data. Therefore, why havent baseline studies been conducted on these impacts well before the range is reopened? Reason for Indicator Area: Concerns about recreational conflict between range use and other forest uses were critical issues raised by the progress report and reiterated during the public comment period. However no quantitative or systematically gathered evidence is available to measure how great this conflict is
14

Draft

and how much management or mitigation measures might reduce or eliminate it. Creating specific measures of range impacts on other forest uses in the vicinity during the three year trial period will help to both quantify and qualify user conflicts associated with range operations and allow for a more informed management decision about the future of range operations after the trial period. - RESPONSE Once again, there were no preliminary studies to establish a baseline for other user impact or impact to wildlife. This information should be established first. Without this data especially in the first year as proposed above, it would be impossible to make a comparative better or worse conclusion. As described above, actions to keep the range open or close it should be based on the results of a metric comparison and not an unscientific as we go process. Without initial baseline data in all areas there can be no credible comparison or conclusion to support any actionable decision. How Indicator Variables will be used during the trial period. An annual report will be produced each year during the three year trial period summarizing the variables measured for each indicator area and providing some analysis and interpretation based on that time periods management context. This report will be reviewed internally by BOF agency staff as well as by the Extended Range Task Force, cooperating partners and local elected officials. At the end of the three years, an evaluation process will take place based on overall trends established by tracking the established indicators during the trial period and the decision whether to continue range operations at the current site will be revisited. - RESPONSE This recommendation advocates moving ahead with all of the items below without conducting preliminary studies to assess: 1.) impact to other users, 2.) enforcement, 3.) volunteer efficacy, 4.) impact to wildlife, 5.) long-term expenditure and funding, 6.) user safety, and other items. Summary of Tasks Necessary for Range Reopening: Fence erected
15

Draft

Lead Management Plan written Existing Target Area and Shooting station contaminant levels mitigated to levels established by plan Shooting Stations with Overhead Baffles and Mufflers Constructed Low-cost Lead Capture backstops erected Permitting and Enforcement Understandings in place with Pennsylvania Game Commission/BOF Division of Operations/District Enforcement and Management staff Task Force Expanded to include Volunteer Group Leadership Range Operating Hours Established Range Site Maintenance Standards established for monthly cleanup efforts Monthly volunteer clean-up days scheduled Range Rules and Regs revised (with PGC advisors and Expanded Range Task force) Strategic law-enforcement efforts agreed upon by partners and Task Force Informational Signage developed and posted at Long Pine Run Reservoir and Target Range Kiosks and on Michaux State Forest Website Summary of necessary data flows to develop annual indicators report for range: 1) Ranger Incident Reports/Citations 2) Annual Lead/Contaminant Monitoring a. Target Impact Area b. Scatter Zone Impact Sample 3) Volunteer Clean up Day attendance 4) Outside funds/in-kind services contributed to range operations 5) Staff Maintenance hours and other Range expenses 6) Quarterly range inspection reports: a. Infrastructure depreciation and depreciation factors b. Evidence of birdshot/unregulated target use 7) Progress/status report on other district management goals and activities - RESPONSE The above list alone conveys the labor-intensive and cost-heavy nature of this recommendation in an atmosphere of funding cuts with many other programs such as Education, Health & Human Service, Transportation
16

Draft

suffering the budget axe. To then support the establishment of a Target Range and all its associated costs, would be fiscally unwise by any standard. It is also revealing that, the District Forester acknowledges his own uncertainty about this recommendation in an email when he explains, I am sorry the proposed decision is a disappointment to you and will be to others . . . and even, in my own divided self! - IN CONCLUSION In conclusion, this recommendation is essentially a three-year experiment at the expense of a sensitive and extraordinary area which exhibits a rich diversity of wildlife, plant life, and has been enjoyed by numerous quiet users for generations. Nevertheless, I am not opposed to the establishment of a public target range and have, in good faith, suggested a reasonable and viable compromise to simply relocate the target range to avoid many of the serious impacts and growing opposition to its current location.

17