The Massachusetts Army National Guard has proposed a multi-purpose machine gun range on Camp Edwards, part of Joint Base Cape Cod. The outline seems rather straightforward: install eight-firing lanes, clear-cut 170 acres of trees, create a 5,000-acre danger zone to collect projectiles and build support facilities.
But the 15,000 acres of Camp Edwards has been governed for the last two decades by Chapter 47 of the Massachusetts Laws of 2002. This law only permits military activity “compatible with the natural resource purposes of water supply and wildlife habitat protection.” The water supply here is the sole-source aquifer under Camp Edwards that supplies the drinking water for 150,000 Upper Cape residents plus visitors.
There remain many unanswered questions about the Guard’s proposal. Perhaps it’s time to play “Twenty Questions” with the Guard’s leaders. This is an old parlor game and radio show from the 1940s and 1950s. Then, the answers were constrained, as in “animal, vegetable or mineral” and simply yes or no. Here we seek broader answers.
1. We now know that this idea was initiated in 2012. Why did the Guard wait so long in reaching out to the affected communities and residents of the Upper Cape? Anticipating public concern, did the Guard attempt to sneak this past us quietly in the middle of a pandemic and national election?
2. The Massachusetts Guard was awarded an $11.5 million military construction project for the range in 2015. The range was to be built in 2020. Why was there no meaningful outreach to our communities until August 2020?
3. A similar proposal was rejected in 1998. What has changed to bring this machine gun range back again? And has the Guard’s actions warranted destroying the collaborative relationship with the Cape community over the last 20 years?
4. What does “multi-purpose” machine gun range mean? Precisely what automated weapons will be fired? Does this include grenade launchers? What about the next generation of Army weapons?
5. You have proposed six firing lanes of 800 meters in length. But you have also included two more lanes of 1,600 meters. Why? What “heavy weapons” will be used on these?
6. How many rounds do these weapons fire every minute, and how many tons of bullets are expected to be used annually?
7. Wouldn’t these bullets and their noise adversely affect the animal wildlife, including 37 protected species, in this area?
8. The proposal indicates that the range meets an environmental assessment used for smaller projects. But this is not a small proposal. From the beginning, why has the Guard refused to initiate a standard, comprehensive Environmental Impact Statement (EIS), actually mandated by federal law for projects ”significantly affecting the quality of the human environment?”
9. The only reason given for this proposed range is so that Massachusetts Guard members will have a more convenient location to qualify with machine guns. In this connection, why has there been no mention of using the new machine gun range at much more centrally located Fort Devens, Massachusetts? It is different from the Camp Edwards proposal, and similar to Fort Ethan Allen in Vermont. It is scheduled to open next year.
10. In connection with the Camp Edwards range, I have also heard that more out-of-state Guardsmen will actually be using the range than Massachusetts troops. Is this true?
11. There is great interest in our transportation corridors and bridge traffic during the summer months, when most training is expected. How many more buses and convoys will the new range bring between Memorial Day and Labor Day?
12. There is a special concern about noise, especially in the Forestdale section of Sandwich, at the Forestdale School and in the large subdivisions on or near Snake Pond Road. They already hear extensive arms firing throughout the day from the five existing ranges on Camp Edwards. They also worry about their home resale value. The Guard proposal says that noise levels should not peak much above 130 decibels (bursts of noise can damage hearing starting at 120 decibels). How can this noise pollution ever be contained within the base?
13. Regarding noise, what will be the hours of operation for the new range? Note that at the range at Fort Devens, the utilization is from 7:30 AM until 11 PM.
14. Regarding the recovery zone, it has been assumed that you selected the 5,000 acres for a surface danger zone based on some mathematical formula that predicted where bullets would return to earth, either directly or via ricochet. Is this sufficient for public safety? For animal safety? And how will you actually recover the projectiles over the 5,000 acres as their copper and steel seep into the fragile ecosystem, the ground and Upper Cape Water Supply Reserve? The stakes are high; in 2020, the Sandwich Water District withdrew 111 million gallons of water from this water supply.
15. We are in a period of severe climate change. The Woodwell Climate Research Center in Woods Hole has estimated that clear-cutting thousands of pitch pine and scrub oak trees would release some 17,000 metric tons of carbon dioxide and eliminate the capacity for the sequestration of another 300 metric tons of carbon annually. In addition, Camp Edwards currently includes an extensive network of roads that are utilized for convoy and driver training. Does it make any environmental sense to cut down 170 acres of trees?
16. When will the base Superfund cleanup finally be concluded? Does a machine gun range potentially affect this?
17. The US General Accountability Office (GAO) has recently reported that there are problems with PFAS—so-called “forever chemicals”—on 703 US military sites. Is Camp Edwards one of those locations? Might a machine gun range contribute to this problem?
18. It has been publicly suggested that one reason for the range proposal is that Joint Base Cape Cod is not currently economically viable. Is this true?
19. The Guard’s lease for Camp Edwards with the Commonwealth of Massachusetts expires in 2026. Does it really make sense to invest so much on such a short lease?
20. The Guard’s proposal includes the construction of a control tower, operations and storage facility, ammunition breakdown building, mess shelter and a range classroom building. These would be built on public conservation land. Article 97 of the State Constitution requires the approval of two-thirds of both houses of the state Legislature for such construction. Has the Guard reached out to the Cape legislative delegation or to state legislative leadership about their support?
Decision-making on the Guard’s proposal will be made soon by the Massachusetts Guard’s boss, Governor Charlie Baker, and the commonwealth’s three-member Environmental Management Commission (State Commissioners of Fish and Game, Conservation and Recreation, and Environmental Protection).
These 20 questions, and more, need to inform our discussion of the Massachusetts Army National Guard’s proposal for a multi-purpose machine gun range on Camp Edwards. This is no parlor game, nor is it a charade where Cape residents and public policymakers are easily fooled.