SD GFP Shooting Complex,

SD Game, Fish and Parks proposed shooting range, in Meade County SD, just east of Elk Vale Road and north of Elk Creek. – Now called the proposed “South Dakota Shooting Sports Complex”, previously it was named after Rapid City, but the Meade County Commission objected to naming a facility in Meade County after Rapid City. 

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Agency   Actions

First below find, in chronological order, updates and list of actions/approvals  that were taken, where text was written in the past and tiered to specific past comment  deadlines or actions  –  all the formal comment opportunities are past, but there may be discussion of associated issues in those alerts. The ones closest to the top are the most recent.  So this is a chronological review of actions and decisions that created the shooting range.

Issues/Facts

 Scroll below a long way to find a discussion of the issue and facts and maps (“Reasons to oppose at this time” Just before you arrive there, you will start seeing maps

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Kristi Noem allocates funds to the shooting range in March, an allocation that becomes public in September 2024 –

 Searchlight article – “Some lawmakers upset after Noem awards millions to project they refused to pay for” Governor using money from state’s Future Fund to help build shooting range”  By: Joshua Haiar -on  September 12, 2024 7:00 pm

Quote from the article

While legislators were passing a law in March requiring more information from Republican Gov. Kristi Noem about a fund she controls, Noem was awarding $13.5 million from the fund to a project legislators had declined to financially support.” To read the article go to link:

https://southdakotasearchlight.com/2024/09/12/some-lawmakers-upset-after-noem-funds-project-they-refused-to-pay-for/

The Article alleges that Noem allocated the $13.5 million award in March, 2024,  from the “Future Fund”, which she has authority to make appropriations from. Legislators are supposed to get a report twice a year on what she is doing with the Future Fund, but they had not gotten such report yet on Sept. 12th, 2024.

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INADEQUATE PROTECTION OF HISTORIC PROPERTIES BY SDGFP

TIMELINE OF ACTIONS

June 2024 update

     In  December 2023  SDGFP’s contractors broke ground to start the dirt work at the shooting range. On January 18th,  2024 SDGFP withdrew its’ request to the USFWS for federal grant money to fund a part of the cost of the shooting range. 

History of Cultural Surveys and effects of the project to cultural properties:

       The Archaeological Research Center, a program of the SD State Historical Society, did a Class III Cultural Survey of the proposed shooting range, a survey that was prepared for SDGFP and they published the results on Nov. 12, 2021. On Nov 18th, 2021 the State Historical Society (State Historic Preservation Office – SHPO), wrote a letter confirming there was one site eligible for listing on the National Registry of Historic Places and 4 sites that were not.  They concluded that no sites eligible for listing, would be affected by the project. That November 2021 letter also said that: “Concurrence of the SHPO does not relieve the federal agency official from consulting with other appropriate parties, as described in 36 CFR 800.2(c).”

        SDGFP and the USFWS did a Draft Environmental Assessment  (EA) in early spring of 2022, and a final EA in August of 2022 and also later issued a FONSI.  After getting approval from USFWS, the SDGFP worked on getting approval from Meade County Commission, which was not finished till spring of March of 2023 (3/28/23).

      On May 12th, 2023 SDGFP informed the USFWS of the new design of the shooting range – a new design that was due, at least in part, to requirements of the new Meade County shooting range ordinance. In this new design SDGFP also chose to add new shooting bays near historic properties eligible for listing under the NHPA.  Upon review of the new design, UWFWS told GFP that all federal compliance requirements needed to be revisited and a new Environmental Assessment needed to be written. 

       On  July 28th,  2023, after reviewing the new plans, the State Historic Preservation Society (SD Historic Preservation Office – SHPO)  told  SDGFP in a letter said that if various conditions were obeyed they found no affect on eligible properties but that USFWS had to consult with the tribes over historic properties at the shooting range. (Section 106 consultation with the Tribes  is a federal historic preservation law requirement)

        Six days after SHPO told them they had to consult with the tribes and before the USFWS had even released a new draft EA, GFP chose in early August (8/3/23)  to publish a request for bids on the dirt work for the project (thus planning to contract for dirt work, work that could obliterate any unknown sites, without waiting for the required consultation to occur)  

     On August 30th, 2023 the USFWS told SDGFP that they required that GFP do section 106 consultation with the Tribes (a historic preservation law requirement), and that SDGFP would have to delay all project work.  One month and 22 days after SHPO told them they had to consult with the tribes, GFP entered into a dirt work contract in mid September (9/18/23) without tribal consultation having even been initiated. They signed contracts to proceed with dirt work (cost of $5,878,008), which dirt work we (PHAS)  were told would start in January 2024.     

      On Sept 22, 2023 USFWS informed tribes of the proposed design changes, provided the 2021 cultural survey report and invited tribal consultation. In late Sept 2023 the USFWS released a new draft Environmental Assessment with a comment deadline of 10/26/23. This draft EA was never finalized and a FONSI was never issued. 

         On Nov. 5th, 2023 the Flandreau Santee Sioux Tribe  (FSST) did their own cultural/historical/archeological surveys and found 7 additional historic properties eligible for listing under the National Historic Preservation Act.  They informed other parties of that on Nov. 7th, 2023.  FSST also said the entire landscape is a Traditional Cultural Property, a place for ceremony and historical remembrance. They found more properties then the earlier survey (11/12/2021) found – which older survey found 1 site eligible for listing  (2 cairns on two hill tops) as well as 4 sites not eligible for listing.  

        USFWS was working towards a meeting with tribes in later January.  So the USFWS could not move forward to finalize the 2023 version of the Environmental Assessment or issue a FONSI and could not give them any federal money without the consultation concluded .

       On Nov 9th, 2023 SDGFP put another contract related to the shooting range out for bid.  They opened the bid Dec 14th and signed the next contract on January 19th, one day after the SDGFP informed the USFWS they were withdrawing application for federal funds. This contract was for $11,953,668.71 dollars. This is a total of about 17.83 million contracted for by January 2024.

       The GFP also failed to update the Army Corps of Engineers (ACE) about the new evidence of sites eligible for listing under the National Historic Preservation Act. Thus the SDGFP violated their permit from the ACE and  the ACE  in early 2024 (3/29/24) shut down all activity by GFP in about a half acre of land that needed ACE permits to do dredge and fill.  However by that point, the dredge and fill had already been done.

SDGFP WITHDRAWS REQUEST FOR FEDERAL FUNDING

       SDGFP started dirt work on the site in December. We have been told that Governor Noem ordered the construction to start.  On January 18th, the SDGFP withdrew their request for federal funding for the shooting range.  Thus USFWS oversight for the National Historic Preservation Act (a federal law) was terminated, however the ACE oversight remains, but over a half acre of the property.  SD State Codified law, only requires consultation with tribes, if the state agencies actions will effect persons living on the reservations and while the tribes have a procedural rights to such consultation, they have no substantive rights (the agency can ignore their comments/requests). 

       The GFP will lose the grant dollars from USFWS for the shooting range and GFP has to raise about 20 million dollars from other donors. We will verify amount foregone. However we suspect that GFP may be able ask USFWS to reallocate its’ Pittman Robertson allocations to other projects, thus not losing the money generally,  but just for this project.  We are told it is likely the SDGFP has bull dozed all the identified historical properties, except the cairns on the hill tops.

         The Advisory Council on Historic Preservation wrote a letter on  February 5th, 2024  that said: 

           “In being notified about this situation, the ACHP learned that the SDGFP has similarly applied for federal funding and later            withdrawn its application after beginning the Section 106 review for other projects. These actions appear to indicate a pattern of behavior in which the SDGFP changes course for its proposed projects after learning about historic properties located in the projects’ area of potential effects and the federal requirement to take into account the effects of the undertaking on those historic properties.” (emphasis added)

 

SD SEARCHLIGHT ARTICLE ON THE SUBJECT OF CULTURAL SITES

https://southdakotasearchlight.com/2024/03/30/parks-department-skips-federal-funding-for-shooting-range-to-avoid-additional-site-scrutiny/

Storm Water Management

       Prairie Hills Audubon Society remains concerned about the storm water management planned on the site and the potential for lead contaminated water to enter waters of the state. We are afraid of water flows from hills above the shooting bays, intermingling with water coming out of the shooting bays and such storm waters not being contained on site & entering the waters of the state.   

            SD DANR has no water quality monitoring plans for the lead that may happen due to the the runoff. (last we knew).  Neither SDGFP or SD DANR had plans to collect baseline surface water values. (last we knew  We have thus started our own project to collect baseline samples of water for lead and pH and have collected at 2 sites and dropped off at professional lab for testing. . 

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BELOW HERE ARE HISTORIC ALERTS MOSTLY IN CHRONOLOGICAL ORDER

ALL OF THESE ALERTS ARE PAST, but you see the history of permitting and review actions

and you see alerts with talking points on issues/problems with the range to comment about.

PAST

NEW EA, Sept 2023

 
NEW SEPT 2023 Environmental Assessment, comment deadline 10/26/23

in late Sept 2023, the USFWS released a new draft EA – link to the 2022 version. https://www.fws.gov/media/rapid-city-shooting-range-final-ea

PAST

Almost a year ago, in late August of 2022 the USFWS released a “Final” EA and FONSI (Finding of No Significant Impact),  but SDGFP redesigned the project (in part to satisfy Meade County) so the old EA was out-dated.

NEW EA October COMMENT DEADLINE

There is a new 2023 opportunity to comment to the USFWS  on the shooting range- a new draft EA has been released by the USFWS.  
the deadline Thursday Oct 26th. Link  to PHAS alert on the new draft EA:

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 PAST

In mid September 2023, the SDGFP approved a bid for some of the dirt work.  I think it was about 5 million dollars.

 PAST

3/28/23 MEADE COUNTY HEARING for Final approval of Range

In December 2023, Meade County adopted a shooting range ordinance. The terms of that ordinance required SDGFP to submit an application and also to make some changes to  the design of the facility.  On March 28th, 2023  the Meade County the Meade County Commission approved the application  in a 4 to 1 vote, and this is the last hurdle of approvals.

Go to Board Docs to find the Commission Agenda for 3/28/23 – https://go.boarddocs.com/sd/meade/Board.nsf/Public

 

PAST

December 20th, 2022 – Section Line Relocation Hearing 

December 20th, 2022 was the Meade County Commission public hearing on SDGFP proposed relocation of the section line in the middle of the property to the south end of the property. The Commission approved the section line relocation. The Commission included a requirement that SDGFP build the road along north edge of the pond (south side of property)  until road was past  the pond & it’s inlet. 

PAST

Nov 22nd, Meade County Commission Hearing – Shooting Range Ordinance

Public hearing on a  proposed shooting range ordinance for Meade County – second reading before the Commission was:

10 am on Tuesday, November 22nd,  2nd Floor of the Erskine Office Building, 1300 Sherman Street, Sturgis, SD 57785

The County passed the Ordinance & SDGFP must comply with it. It will have to do some redesign work to do so, as Ordinance does not let them shoot over section lines..

SD GFP proposes to build a large shooting range at Elk Vale Road near Elk Creek in Meade County. PHAS is concerned as shooting ranges are de-facto

lead mines.  Lead bullets are deposited from guns and  ater reclaimed, but a shooting range does not have the protective environmental regulation that an actual lead mine does.

Lead is a toxic substance with threat to the environment and human health. 

SDGFP did a very inadequate environmental assessment with very unclear disclosure of mitigations and totally inadequate

response to comments.   https://www.fws.gov/media/rapid-city-shooting-range-final-ea

The County is finally going to adopt ordinances to govern the location and construction of such facilities (This is permitted by SDCL 21-10-32. )

This gives the public an opportunity for better  oversight of any shooting ranges build in Meade County.  The County Conmmission approved the first reading of Ordinance with no changes, 

but indicated they would think about comments they heard & might make changes at second reading

Link to proposed ordinance:https://go.boarddocs.com/sd/meade/Board.nsf/files/CJWLBH55AA5B/$file/Proposed Shooting Range Ordinance.pdf

First reading of ordinance – version 1

https://go.boarddocs.com/sd/meade/Board.nsf/files/CL8TV779295E/$file/Ord 56 first read.pdf

Marked up version (red highlights for public comment)
Second reading’s version

For more information on the shooting range  contact Nancy 605-787-6466, nhilding@rapidnet.com.   

 It needs better oversight of the water quality concerns & needs to consider impacts to Native American sacred, cultural or historic sites

Please remember Meade County has Bear Butte.   See talking points below. 

Written comments for the Meade County Commission can be posted on:   https://www.meadecounty.org/commission
A list of Commissioner contacts is also on this web page, there are 5 of them:
 Todd Seaman <tseaman@meadecounty.org>, 
Rod Bradley  <rod.bradley@meadecounty.org>, 
 Doreen Creed <dcreed@meadecounty.org>
Staff person in charge who can be sent a letter and ask her to share with all of them: – Rhea Crane – <rcrane@meadecounty.org>,
 
To see Agenda of the meeting go to Board doc for meeting on 11/22/22
 
TALKING POINTS FOR ORDINANCE:
 
Please add these points to the Draft Ordinance:
 
Proponents shall design range so it’s  design  insures it can comply with EPA’s “Best Management Practices for Lead at Outdoor Shooting Ranges” – EPA-902-B-01-001, Revised June 2005, Region 2. The County shall consider if the suggested location complies with EPA’s guidance on proper locations.  Failure to offer a  design that complies with the EPA’s BMP may be a reason to deny the application.  See https://www.epa.gov/sites/default/files/documents/epa_bmp.pdf 
 
Design of storm water management systems for use after construction and during operation will be disclosed.   If there are man made ditches/pipes and/or retaining ponds to be used to collect storm water run off, proponent shall disclose design of system, including  the location of components and holding capacity of components. They shall disclose the intensity of storm event they are designed to contain. Distance of the site from flood plains shall be disclosed.  Proponents will discuss if lead contaminated stormwater will flow to SD waters and how storm water runoff will be monitored for lead. Failure to design credible long term storm water management may cause denial of application.
 
The shooting range shall provide copies of DANR water quality monitoring done in all perrennial and intermittent ponds/lakes and streams of the state who are immediately down stream of the proposed site. Such monitoring must at least include monitoring for lead and Ph. If there is no monitoring being done & no base line data exists, proponents shall hire an accredited entity approved by DANR to do such monitoring for lead, Ph, TSS, & TSD to establish base line values &  provide a copy of data to Meade County. 
 
Design of range shall insure that bullets shall not be shot into surface waters.
 
Lead recycling plans and equipment to be used shall be discussed.  If recycled lead and/or soil that has been contaminated with lead & later collected will be stored on site, such storage will be discussed and location of storage & the lead mitigations discussed. Proponent shall discuss any incentives offered for use of lead free bullets.
 
The shooting range shall provide a soils map for the range and a base line Ph test for the soils where bullets land or lead contaminated storm water runs across or sits.
 
The shooting range shall do base line air quality monitoring at the site for dust and lead, if such has not been done by DANR or an entity approved by DANR.
 
The shooting range shall estimate attendance at range  & impacts to County roads of vechicle traffic going to the range.  Planned mitigations to  the road impacts shall be discussed
 
Design of range shall insure that bullets that bullets shall not fly over highways& that they  do not leave the site.
 
The shooting range proponents shall consult with SHPO and THPO about historic & cultural sites that are on or near enough to the site to be impacted and provide a copy of their request(s) for consultation,. They will disclose who  were letters sent to & any reply they received.  County may require impacts to cultural, historical sites to be mitigated and if County judges mitigation inadequate, then the site may be rejected. Meade County shall not allow shooting ranges so close to Bear Butte, so that quiet at the Butte & Native American use of the Butte is disturbed. Noise impacts  to cemeteries & public parks should be considered & constrained.
 
The shooting range proponents shall consult with SD GFP about impacts to biodiversity & provide a copy of GFP response. Adverse impacts to habitat or individuals of rare species may cause denial of the application or require mitigation.
  
Distance from barns, corrals or other places where livestock are concentrated and their movement is restricted shall be discussed. Noise shall not disturb livestock in contained locations, nor shall bullets come near them.
 
Fire control & fire mitigation shall be discussed  & additional mitigation may be required by County.

Next Upcoming Deadline – Maybe December 13th, please verify date

 Likely upcoming hearing date of Dec 13th, 2022 on Section Line Relocation – date to be confirmed on 11/22/22.

 
On Nov 22nd Meade County Commission will consider a request to set public hearing date to hear the petition to relocate a portion of the section line right-of-way, Vacation commencing 33′ East of the Section Corner Common to sections 33 and 34 of T. 4N., R. 8 E and Sections 3 and 4 of T. 3N., R.8E., All of the B.H.M., Meade County, South Dakota. 

A petition was submitted to the Auditors office by SD Game, Fish and Parks, and 7 O Ranch LLC to Relocate a portion of a section line.  The Auditor requests that the public hearing date be set for December 13th, 2022 at 10am, to allow time for the required newspaper publications to be made. 
 
Petition to relocate the section line
 
Map of relocated section line
 
Map 2 of relocated section line – rotate
 
Aerial  photo overview of relocated section line
 
Aerial photo  showing a large area overview
 
Aerial photo overview w/ neighboring landowners ID
 
Aerial photo overview w/section numbers

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PAST 

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 A. Recent past deadline – June 28th, 2022, Meade County, 1 pm

UPDATE 6/28 results – On 6/28/22 Meade County Commission unanimously denied SDGFP section line relocation request, but GFP was expected to submit a new revised relocation proposal.  The USFWS approved a FONSI without the section line relocation being completed. We believe this violates NEPA.

Meade County Commission Public Hearing on Section Line Relocation at GFP proposed shooting range  (near Elk Vale Road and Elk Creek) was at 1 pm on Tuesday June 28th. The meeting will have begun at 9 am. There is a recording of the meeting on the Meade County Facebook page – scroll down to June 28th .https://www.facebook.com/meadecountysd/

Game, Fish and Parks still intends to submit a petition to relocate the section line along the south edge of their property. . They intend to build a road along the south edge of property as they got the message that a road across the high water mark of the pond and across the inlet would be expensive and problematic for ranchers to do alone.
 

County Building is located at 1300 Sherman Street STE 212 | Sturgis, SD 57785,

PAST

Go to Board docs for details and agenda of the Commission meeting, using this link. 

https://go.boarddocs.com/sd/meade/Board.nsf/Public

The 6/28 agenda is  posted & you can go to the June 28th meeting agenda to – and see various documents related to issue to download

Petition to relocate section line
3. Topo  Maps
2 Aerial Maps
 
 
           
 
Meade County Commission,  1300 Sherman Street STE 212 | Sturgis, SD 57785, staff contact is Jerry Derr, jderr@meadecounty.org, 605-720-1625, You can look up Commissioners and send them a message at: https://www.meadecounty.org/commission/
 
Leaving the section line in current place (with 66 foot right-of-way), would bi-sect the shooting range and shorten or relocate at least the long ranges. Relocating the section line to the southern edge of SDGFP property would drop the new section line into the high water line of a pond and bisect a dug-out – making it’s use as path or road extremely difficult. GFP now propose a curvey alternate section line relocation.
 
Specific reasons to oppose Section Line Relocation – 
1) Local opposition by adjacent landowner. Landowners living to east of Elk Vale and wanting to build a road to develop their land will have more difficulty, expense and more permitting hassle building a road crossing  and running through the overflow area of inlet  leading into the pond and the steep side slopes to that drainage. Length of future road is increased. Cattle would be driven over side slope of drainages.
 
2) SDGFP failed to provide a range of action Alternatives in the draft Environmental Assessment (EA). In March GFP knew of objections to the section lion relocation. The Draft  EA just offered one action alternative – the preferred design in March had the section line relocated into the high-water area of the pond (thus insuring access/future road building across high water area of pond and bi-secting the dug-out)..  GFP now offers a new design/layout for section line relocations, trying to avoid the pond –a  new layout that was not explained in the Draft EA in March.  The Meade County Commission should continue this hearing until SDGFP publishes the final Environmental Assessment (expected out in July). Hopefully GFP will comply with NEPA and provide at least 2 action alternatives – showing us a range design with the new section line relocation and one without any section line relocation.  The March version of the range design is included below (scroll down). 
Also the draft EA in March was severely inadequate and many questions about pollution mitigation were unanswered. Meade County should continue the hearing until the Final EA is available for review. 
PAST 
PAST
B.Late August 2022 Event — USFWS – Final EA
The USFWS released a final EA .They had promised another  thirty day comment period….but in the end, chose not to offer that.  Please read the final EA – https://www.fws.gov/media/rapid-city-shooting-range-final-ea
 PAST
C. Iterative deadlines -SDGFPP Commission Meets
  Contact the SDGFP Commission
You can still write in concern about or opposition to proposed shooting range, but at this point, we suggest that you ask for stricter environmental protections, reduced footprint or to use the land for some other purpose – such as a park, as they have bought the land 

 Written comments can be uploaded here or submitted at an on-line comment portal   https://gfp.sd.gov/forms/positions/ . If you want the Commission  to read your comments before meetings, which are normally on Thursdays submit by midnight CT on Sunday before the meeting.  Comments can be given to Commissioners directly as individuals, at each’s contact address/phone  any time:  https://gfp.sd.gov/commission/members/  , https://gfp.sd.gov/commission/information/ Agenda will be posted here when close to the date : https://gfp.sd.gov/commission/information/  If you check the agenda and  attend the Commission meeting by Zoom you will usually hear updates on the Shooting Range.

 PAST 

Written comments by Sunday July 3rd, 2022 at midnight CT.   https://gfp.sd.gov/forms/positions/ 

 PAST – March 3 & 4th, was a formal Commission meeting– Game, Fish & Parks Commission meeting in Pierre & Zoom. GFP Commission considered a resolution to purchase the property from the Foundation, who bought it in 2021 to hold for GFP while formal appraisal of the property was done.  in 2021 GFP promised to buy the land & GFP bought it in 2022.

 https://gfp.sd.gov/UserDocs/meetings/21-03_Resolution_-_Authorizing_purchase_of_Rapid_City_Shooting_Range_(3).pdf

 

B. REASONS TO OPPOSE AT THIS TIME 

Rapid City Shooting Range – Please either oppose or ask for an EIS to be done before building or funding it

Protect the water quality in the area from lead pollution.

You can write or call Meade County Commission, Game, Fish & Parks (GFP) staff and/or GFP Commission will make decisions. Read the draft EA & call up DANR staff reviewing the EA. The USFWS staff in Denver is overseeing a NEPA analysis but GFP and had released the EA for comment  (first comment period is closed).  (GFP is asking for the USFWS’s Pittman Robertson’s grant program to help pay for the project. Either the federal government or the USFWS policy requires NEPA for projects creating outdoor gun ranges. If FWS approves funding it will stipulate some requirements in a contract).  You can write or call your legislator (as GFP was asking the legislature for money to pay for this project & failed to get it in 2022 – scoll down)

 

 Game, Fish and Parks has been unable to fund raise enough donations or grants to pay for building the range and were asking  the 2022 legislature for millions to help fund the project & did not get the 2.5 million, perhaps they will try again next year . Thus folks can contact your SD Legislator with concerns.

SDGFP hoped to break ground in spring 2022. They were asking the SD National Guard to help them build it – but the Guard said NO.

The site is hilly & especially rugged in north end. The EPA recommends flat areas for shooting ranges, thus we assume major land sculpting & storm water management has to happen. That will be expensive. What other GFP projects for wildlife or parks could be afforded if a site that better conformed with EPAs location guidance had been chosen? 

SDGFP will be relying in part on Pittman Robertson funding given to them by the USFWS. FWS staff thus must sign off on a NEPA document, either an environmental assessment (EA) or an environmental impact statement (EIS).  Folks should insist on an EIS as the project won’t comply with the EPA Best Management Practices for shooting ranges – GFP selected a site that does not match the site selection guidance.. 
EPA and DANR only regulate shooting ranges at closure, or during construction for storm water runoff. EPA provides guidance (Best Management Practices)  but that guidance is not enforceable, except we can request discussion of this non-compliance in the NEPA document and ask for an EIS. The EIS’s range of alternatives should offer an alternative site selection. Another request for the SD Legislature would be for Dept of Agriculture and Natural Resources (used to be DENR) to be given authority to regulate location, construction and operation of shooting ranges, for lead management concerns (it doesnt have that power now). 
 
 
Map of proposed GFP shooting range, it is off Elk Vale Road north of Elk Creek
 
 
 
 
 

John Kanta at SDGFP knows about the shooting range.  Some engineering plans have been drawn up.

Money to help pay for the project is being sought under Pittman Robertson from the Denver USFWS office,  A totally inadequate draft “environmental assessment” has been written, Public scoping for the EA did not happen.  Comments were due March 24th.
 
SDGFP Commission’s Resolution about land purchase using South Dakota Parks and Wildlife Foundation as a temporary intermediary to hold the land, can be found at below link (The range will be in Meade not Pennington County)
This resolution was adopted in Jan 2021 after about a 30 minute presentation to the Commission.
 It commits the Commission to buying the property from the Foundation at a fixed cost for property – that in January 2021 was not yet appraised and for a site not yet reviewed by the public. The appraisal was less than what they promised to pay. They paid 2,220 per acre and we heard it was appraised at 1,400 per acre.  This hasty action violated at least 4 sections of the SDGFP Land Acquisition Priorities and Guidance – link to that document.
GFP sheet about firing range.
Plans/Drawings of proposed Range
 
Meade County Map showing area’s land parcels
 
TALKING POINTS:
 Some environmental issues associated with shooting ranges can be –
1) Lead contamination from bullets with impacts to ponds/creeks and ground water in area – this is a pollution risk to fish, waterfowl and people. Do folks living along Elk Creek have wells into a water table that is influenced by Elk Creek?
2) Noise of gun fire from hundreds of shooting positions,
3) Disturbance to waterfowl wildlife, livestock and homes/ranches from noise and activity of people. Whooping crane, a federally endangered species, have been seen on the pond just to the south of the project.
4) Bullets traveling to neighboring lands, including over areas with slopes/valleys, with possible impacts to livestock,
5.) Fire risk, 
6) Impacts of traffic to about 3 miles of dirt road resulting in noise, dust and wear and tear and cost of maintenance to Meade
county. Will GFP pay to finish paving Elk Vale Rd, as the County requests?
7)  Supervision of the property and law enforcement costs – What new security costs will be assumed by Meade County vs. GFP? What increase in crime to the neighborhood?
8) Section line relocation could be put too close to wetlands, pond high-water mark & dugout in pond’s inlet
9) Potential impacts to tribal archaeological resources
 
The pond/wetland immediately to the south of the property has excellent birding. Whooping cranes have been seen on it.  This range will be about 2.5 miles from Sevey Lake, a popular birding spot.  Impacts to wildlife and fish are not just those on the property, but those nearby who would be impacted by the noise and disturbance or water pollution downstream. Lead pollution is a major issue, especially as the site does not meet the EPA criteria for siting of ranges (not-flat -too much slope).
Fact sheet on Lead Pollution at Outdoor Firing Ranges:
EPA on BMP on managing lead at shooting ranges 
 
We quote that document at page II-5:
 
“The most important site selection criteria to consider when selecting a new range
location include: topography; surface water flow patterns; and depth to groundwater. If
possible, ranges should be developed on flat terrain, as it facilitates reclamation and reduces
the chance of off-site migration due to surface water runoff as compared with highly sloped
terrain. When considering a prospective location for a range, ask yourself: What is the direction of
surface water runoff? Does the site drain to surface water (e.g., streams, rivers) on-site?
Off-site? Can the range design be modified to minimize potential runoff? Is reclaimation
equipment accessible to the area to clean the range?” (Emphasis added).
  
.  There are several ponds/impoundments  near edges of the property, inside the property & one has some wetlands associated with it.  The range’s south boundary bisects or borders a pond on an unnamed tributary of Elk Creek.  GFP won’t have access to all or parts of the 2 edge/boundary ponds, as they are on private land. The proposed shooting range is divided between Elk and Antelope Creek drainage basins, with at least most of the northeast-end of range draining to Antelope Creek and the south-end will be draining to Elk Creek.   As the crow flies the range is closest to Elk Creek, but as water flows toward the two drainages, it is closer to Antelope Creek.  
 
 In the pink map below, the shooting range’s south boundary crosses the heart shaped pond just east of Elk Vale Rd and 3/4 mile north of Elk Creek, that sits on a tributary that flows southeast to Elk Creek – merging with Elk Creek in several miles. It’s north boundary is near the slight bend in Elk Vale Rd at a mile and a quarter above that pond. The slight bend in road is on the ridge top.  Property is a half mile wide and a mile and a quarter tall.
 
The topography at the north end is much more hilly, with the north entrance at a ridge top. The smaller shooting bays in the north, are in a descending valley – carved into the western slope.  Some of the southern shooting bays are placed in side drainages. The whole property is descending from the ridge towards the pond.  This site does not meet the EPAs guidance for siting shooting ranges: the EPA wants them on flat sites.  Soil has clay in it . It is harder for reclamation machines to recover lead from clay soil and the machines need flat surfaces.
Reclamation lead bullets/fragments from clay may require washing. It will likely require removal or burning of grass cover, which vegetation 
concentrate lead.
 
Survey of the site has identified cultural properties, but has not yet done Section 106 consultation with tribes.
 
 
 
 
 
 
 
 

 
 

 
CUMULATIVE NOISE
 
See map below. Each of the smaller shooting bays may have 5 -10 shooting lanes/each. There are 29  such bays, 12 are in the south . The 200-400 ft bays may have 20 shooting position/each, 2 are in the south unit. The extra long bays may have 40 positions, 2 are in the south unit. The shooting clays have 12 positions/each.    The south-end range may be used for local shooters. There are 180 shooting positions there.  The north-end range may be used for competitions or training activities and some bays are called “action bays” without assigned lanes. There are 12 positions at the sporting clays.
Decibels from each gun fire are significant 150dB-163.2 dB  ; https://earinc.com/gunfire-noise-level-reference-chart/.  The north end is in a more steep and rugged location, it has a small flat area at the top, but descends into valleys and rugged territory.. 
 
 
 
PAST  DEADLINES
 You can write or call Meade County Commission, Game, Fish and Parks Commission and your legislator (as GFP is asking the legislature for money to pay for this project.) The USFWS staff in Denver is participating in NEPA analysis 
 PAST 
PAST

C. Past/EXPIRED deadlines with respect to this alert 

  1.   Release of an Environmental Assessment for public comment,.  It is posted on USFWS website for the 30-day public comment period. This EA is seriously flawed. It does not provide sufficient information on management of storm water or lead on the site — it just claims it will comply with EPA’s “Best Management Practices for Lead at Outdoor Shooting Ranges”, without adequate details.  It includes no indication of any baseline testing of  surface or underground water, air or soil & does not provide for an alternative of selecting another site. Its’ conclusions about surface waters on & near the site & associated fish & wildlife are inadequate/wrong. It’s discussion on lead reclamation is just part of a sentence. It does not consider impacts to archeological resources from visitors to facility.  Discussion of various impacts too cursory or missing.  The EA is extremely inadequate and does not justify a FONSI (finding of no significant impact) or justify the Legislature supporting SB 175.  PHAS comment letter to House Members on SB 175:   https://www.scribd.com/document/563057586/Please-Oppose-SB-175-a-Bill-to-Partially-Fund-the-Proposed-Shooting-Complex-of-GFP-at-Elk-Vale-Rd-Near-Elk-Creek-in-Meade-County 

======

Public comments were accepted for a 30-day  comment period, ending March 24, 2022, [revised deadline] and could be electronically submitted to: fw6_FAGrants@fws.gov  Copies of the Draft EA, which include details of the proposed action and the alternatives considered, are available online at: https://fws.gov/library/collections/wsfr-rapid-city-south-dakota-proposed-shooting-range  Those without internet access may request copies by calling the Services’ Wildlife and Sport Fish Restoration Program at 303-236-8165. Comments will be accepted until March 24, 2022, and should be sent to: Chief, Wildlife and Sport Fish Restoration Program, U.S. Fish and Wildlife Service, P.O. Box 25486, Denver, CO, 80225.

Link to Draft Environmental assessment 

 https://fws.gov/media/rapid-city-shooting-range-initial-environmental-assessment

Links to Appendix

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix-b

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix-c-f

Link to Press release

https://fws.gov/press-release/2022-02/proposed-shooting-range-rapid-city-south-dakota 

PAST

2  Meade County Commission (MCC) is being asked to take actions related to this project, but has not yet done so.  Game, Fish & Parks made a presentation to the Meade County Commission on the morning of Tuesday 2/8/2022. They have sent a letter to the Meade County Commission (MCC)which was discussed at the Feb 22nd meeting of the Meade County Commission, stating intent to ask for relocation of a section line and offering a future proposal about road maintenance – link to letter: https://go.boarddocs.com/sd/meade/Board.nsf/files/CBRQES68F69D/$file/SDGFPLETTER.pdf SD GFP while seeking funding from the legislature, wants to be able to say they have worked out issues with the Meade County Commission. The Meade County Commission does not want Meade County to bear the cost of the maintaining 3 miles of gravel road, that the traffic from Rapid City and from other counties, will travel across to the range. The Commission has suggested it be paved. SDGFP needs to get a section line vacated or relocated and they have to ask the Meade Commission to do that. 

Meade County Commission could adopt an ordinance about location and construction of shooting ranges, but has not yet chosen to do that, and if they don’t before construction starts this range would be grandfathered in.  Visit  Meade’s Board docs to see agenda for 2/22/2022. The Meade County Commission took no action on 2/22/22. Just listened to report of staff on communications with GFP.

 MCC will still be asked to take action on this project.  To contact Commission visit link:    https://www.meadecounty.org/commission

Sturgis City Council considered a draft letter on 2/22/22/ stating approval for the proposed Shooting Range, but took no action (Sturgis remained neutral).

PAST

3. PAST  (- Bills killed). Look up votes and thank those who voted against SB 175 

    Oppose SB 175 – https://sdlegislature.gov/Session/Bill/23361/231510 – about 5 million dollar appropriation request. This was in Senate Agriculture and Natural Resources Committee  on Thursday 2/10/2022. It was referred first to Joint Appropriations, Then to Senate Appropriations – for a hearing on 2/17/22. It passed both committees with 2 votes against in each committee.   It went to Senate floor and was scheduled for Tuesday 2/22nd, 2022 and had to be voted on by Wednesday.  They needed two thirds of senate to vote for it, due to emergency clause & it  passed with 5 votes against it.  It went back to the House &  the House sent it to House Appropriations Committee– in Committee 3/2/22 in afternoon 3 pm or  15 minutes after session.   Hyperlinks to  our testimony against this bill in Senate Agriculture and Natural Resources and Senate Appropriations are posted to our legislature web page.  This was killed in House Appropriations Committee, but it was  “smoked out” for a vote on Monday 3/7/22.  A majority vote was needed to put it on the calendar and then 2/3rds must vote to approve it.  PHAS comment letter to House Members:   https://www.scribd.com/document/563057586/Please-Oppose-SB-175-a-Bill-to-Partially-Fund-the-Proposed-Shooting-Complex-of-GFP-at-Elk-Vale-Rd-Near-Elk-Creek-in-Meade-County    The bill failed to pass the House – vote YEAS 39, NAYS 30, The Reconsideration motion failed – vote    : YEAS 35, NAYS 34.

 MORE RECENT ACTIONS – LAST DITCH EFFORT 

There was an attempt to put SB 175 into HB 1166 at aConference Committee Meeting on that HB 1166 on 3/9/22. at 11:30 pm CT. All 6 people on the Committee voted for SB 175 on the floor  – one is the bill sponsor David Johnson. The conference committee could not agree on what to do and thus we believe HB 1166 and the attempt to amend it is dead.  Link to info on Conference Committee:  https://www.sdlegislature.gov/Session/ConferenceCommittees/64    Link to the proposed amended version of HB 1166: https://mylrc.sdlegislature.gov/api/Documents/236283.pdfTh

Thursday and Friday are the last 2 days of the legislature. We don’t think any more attempts to try to insert amendments to funding bills in conference committees were planned.

PAST 
 

 4. March 3 & 4th, was a formal Commission meeting- Game, Fish & Parks Commission meeting in Pierre & Zoom. GFP Commission considered a resolution to purchase the property from the Foundation, who bought it to hold for GFP while formal appraisal of the property was done.  

Results – Commission approved the land purchase. You can still write in opposition to it, but at this point, need to ask for strict environmental protections or to use the land for some other purpose – such as a park.

https://gfp.sd.gov/UserDocs/meetings/21-03_Resolution_-_Authorizing_purchase_of_Rapid_City_Shooting_Range_(3).pdf

hhttps://gfp.sd.gov/commission/archives/63/

 Written comments in opposition to the land  purchase or the shooting range can be uploaded here or submitted at an on-line comment portal   https://gfp.sd.gov/forms/positions/ .  

SD Game, Fish and Parks Commission meetings  Evening of 2/21/22, 5:30 – 7:30 pm CT, informal – one-on-one meeting opportunity at Arrowwood Resort, Oacoma, RSVP by 2/16/22, Rachel.Comes@state.sd.us,

 
 .   Meade County –  Past Deadline 2/8/2022 – A letter from SDGFP  was discussed February  22nd
Please express concerns about the shooting range to Meade County
==========
PAST
5. On 12/21/21 the Meade County Commission (MCC) discussed a draft letter to Gov. Noem, about Meade County’s concerns about the costs to Meade County from the proposed shooting range off Elk Vale Rd, just north of Elk Creek, but came to no conclusions except to talk to SDGFP some more. 
Go to the Meade County’s BoardDoc page for agenda of the meeting  Shooting range discussion was expected after 10 am on 12/21/21
To submit written comments on-line:
1300 Sherman Street, Suite 212, Sturgis, SD 57785, 605.720.1625 | Fax: 605.720.1633
 

MCC could send that or another letter to the governor . Meade County does not have zoning but 
state law allows counties to create ordinances about shooting ranges that address construction and location 
(SDCL 21-10-32 offers authority and 21-10- 28 limits it )
Draft letter:
.Meade County is asked by SDGFP to relocate a section line running east-west down to the south edge shooting bay area. SD law reserves 66 feet

 along the section line for public access – without the move, this reservation might influence  Range  design/management .Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance costs. Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance costs.

No formal section line relocation request has been submitted yet. Commission & GFP have not agreed on any road proposals — only ideas have been explored in discussions by GFP with Meade’s transportation staff.

 
 PAST
6.   Deadline – January 28th, 2022 – letters to John Kanta Rapid City Shooting Range  –  Comment To SDGFP 
  January 28th, was the deadline to comment to John Kanta of SD GFP if you object to the National Guard assisting with construction of the shooting range proposal. john.kanta-state.sd.us” <john.kanta@state.sd.us> .If you don’t object by the deadline you waive the right to object.  A public notice says:
“This project can’t be completed in its’ entirety without assistance from the National Guard” However the National Guard said no to helping with the project – how will SDGFP afford the entire project without National Guard help at earth moving?

 
 PAST

7. January 25th , 2022 House Agriculture & NaturalResources killed HB 1049, that would have appropriated 5 million for the shooting range. Senator David Johnson responded with a similar bill – SB 175 in the Senate, which has passed the Senate sent back to the House. Killed in Appropriations, Smoked out on floor, up on March 7th on floor. Killed on House floor. Attempt to insert funding text to another bill about funding roads near Palisades State Park –  HB 1166, in conference committee. That failed also.

PAST

8 . January 4th, Tuesday, 2022 – range was discussed at the  SDGFP Commission Meeting

PAST

9. December 21st, 2021 Tuesday –  Meade County Commission Meeting discussed project and listened to to GFP and public proponents, and to opponents but took no action on the proposed letter about the shooting range..Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance cost

 
 

“Some lawmakers upset after Noem awards millions to project they refused to pay for” Governor using money from state’s Future Fund to help build shooting range”

in

 ============================================================================================

SHOOTING COMPLEX

SHOOTING RANGE

SD Game, Fish and Parks proposed shooting range, in Meade County SD, just east of Elk Vale Road and north of Elk Creek. – Now called the proposed “South Dakota Shooting Sports Complex”, previously it was named after Rapid City, but the Meade County Commission objected to naming a facility in Meade County after Rapid City.

First below find list of 4 actions to take, 

Below that is a discussion of the issue and facts.

PAST

A. Immediate deadlines with respect to this alert on SD Game, Fish and Parks proposed shooting range, in Meade County SD,

  1.    Release of an Environmental Assessment for public comment, comments due 3/20/24. (revised deadline).  It is posted on USFWS website for the 30-day public comment period. This EA is seriously flawed. It does not provide sufficient information on management of storm water or lead on the site — it just claims it will comply with EPA’s “Best Management Practices for Lead at Outdoor Shooting Ranges”, without adequate details.  It  includes no indication of any baseline testing of  surface or underground water, air or soil & does not provide for an alternative of selecting another site. Its’ conclusions about surface waters on & near the site & associated fish & wildlife are inadequate/wrong. It’s discussion on lead reclamation is just part of a sentence. It does not consider impacts to archeological resources from visitors to facility.  Discussion of various impacts too cursory or missing.  The EA is extremely inadequate and does not justify a FONSI (finding of no significant impact) or justify the Legislature supporting SB 175.  PHAS comment letter to House Members on SB 175:   https://www.scribd.com/document/563057586/Please-Oppose-SB-175-a-Bill-to-Partially-Fund-the-Proposed-Shooting-Complex-of-GFP-at-Elk-Vale-Rd-Near-Elk-Creek-in-Meade-County 

.Public comments will be accepted for a 30-day  comment period, ending March 24, 2022, [revised deadline] and can be electronically submitted to: fw6_FAGrants@fws.gov  Copies of the Draft EA, which include details of the proposed action and the alternatives considered, are available online at: https://fws.gov/library/collections/wsfr-rapid-city-south-dakota-proposed-shooting-range  Those without internet access may request copies by calling the Services’ Wildlife and Sport Fish Restoration Program at 303-236-8165. Comments will be accepted until March 24, 2022, and should be sent to: Chief, Wildlife and Sport Fish Restoration Program, U.S. Fish and Wildlife Service, P.O. Box 25486, Denver, CO, 80225.

Link to Draft Environmental assessment 

 https://fws.gov/media/rapid-city-shooting-range-initial-environmental-assessment

Links to Appendix

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix-b

https://fws.gov/media/rapid-city-shooting-range-draft-ea-appendix-c-f

Link to Press release

https://fws.gov/press-release/2022-02/proposed-shooting-range-rapid-city-south-dakota

PAST

2  Meade County Commission (MCC) is being asked to take actions related to this project, but has not yet done so.  Game, Fish & Parks made a presentation to the Meade County Commission on the morning of Tuesday 2/8/2022. They have sent a letter to the Meade County Commission (MCC)which was discussed at the Feb 22nd meeting of the Meade County Commission, stating intent to ask for relocation of a section line and offering a future proposal about road maintenance – link to letter: https://go.boarddocs.com/sd/meade/Board.nsf/files/CBRQES68F69D/$file/SDGFPLETTER.pdf SD GFP while seeking funding from the legislature, wants to be able to say they have worked out issues with the Meade County Commission. The Meade County Commission does not want Meade County to bear the cost of the maintaining 3 miles of gravel road, that the traffic from Rapid City and from other counties, will travel across to the range. The Commission has suggested it be paved. SDGFP needs to get a section line vacated or relocated and they have to ask the Meade Commission to do that. Meade County Commission could adopt an ordinance about location and construction of shooting ranges, but has not yet chosen to do that, and if they don’t before construction starts this range would be grandfathered in.  Visit Board docs to see agenda for 2/22/2022. The Meade County Commission took no action on 2/22/22. Just listened to report of staff on communications with GFP.

 MCC will still be asked to take action on this project.  To contact Commission visit link:    https://www.meadecounty.org/commission

Sturgis City Council considered a draft letter on 2/22/22/ stating approval for the proposed Shooting Range, but took no action (Sturgis remained neutral).

PAST

3.  April 7-8, formal Commission meetingGame, Fish & Parks Commission meeting in Watertown & Zoom.

 

Game, Fish and Parks during the month of March is buying the property from the Parks and Wildlife Foundation.

 Written comments can be uploaded here or submitted at an on-line comment portal   https://gfp.sd.gov/forms/positions/ . If you want the Commission  to read your comments before April 7th, submit by midnight CT on Sunday April 3rd.  Comments can be given to Commissioners directly as individuals, at each’s contact info. any time:  https://gfp.sd.gov/commission/members/ Agenda will be posted here when close to the date : https://gfp.sd.gov/commission/information/  .If you check the agenda and  attend the Commission meeting by Zoom you will hear updates on the Shooting Range.

May 5-6 formal Commission meeting– Game, Fish & Parks Commission meeting Custer State Park and Zoom, Written comments by Sunday May 1st at midnight CT.   https://gfp.sd.gov/forms/positions/ 

 PAST – March 3 & 4th, was a formal Commission meeting– Game, Fish & Parks Commission meeting in Pierre & Zoom. GFP Commission considered a resolution to purchase the property from the Foundation, who bought it to hold for GFP while formal appraisal of the property was done.  

Results – Commission approved the land purchase. 

 https://gfp.sd.gov/UserDocs/meetings/21-03_Resolution_-_Authorizing_purchase_of_Rapid_City_Shooting_Range_(3).pdf

You can still write in concern or opposition to it, but at this point, you need to ask for strict environmental protections or to use the land for some other purpose – such as a park.

PAST

4. PAST  (OVER- Bill killed). Look up votes and thank those who voted against SB 175 

    Oppose SB 175 – https://sdlegislature.gov/Session/Bill/23361/231510 – about 5 million dollar appropriation request. This was in Senate Agriculture and Natural Resources Committee  on Thursday 2/10/2022. It was referred first to Joint Appropriations, Then to Senate Appropriations – for a hearing on 2/17/22. It passed both committees with 2 votes against in each committee.   It went to Senate floor and was scheduled for Tuesday 2/22nd, 2022 and had to be voted on by Wednesday.  They needed two thirds of senate to vote for it, due to emergency clause & it  passed with 5 votes against it.  It went back to the House &  the House sent it to House Appropriations Committee– in Committee 3/2/22 in afternoon 3 pm or  15 minutes after session.   Hyperlinks to  our testimony against this bill in Senate Agriculture and Natural Resources and Senate Appropriations are posted to our legislature web page.  This was killed in House Appropriations Committee, but it was  “smoked out” for a vote on Monday 3/7/22.  A majority vote was needed to put it on the calendar and then 2/3rds must vote to approve it.  PHAS comment letter to House Members:   https://www.scribd.com/document/563057586/Please-Oppose-SB-175-a-Bill-to-Partially-Fund-the-Proposed-Shooting-Complex-of-GFP-at-Elk-Vale-Rd-Near-Elk-Creek-in-Meade-County    The bill failed to pass the House – vote YEAS 39, NAYS 30, The Reconsideration motion failed – vote    : YEAS 35, NAYS 34.

MORE RECENT ACTIONS – LAST DITCH EFFORT

 There was an attempt to put SB 175 into HB 1166 at a Conference Committee Meeting on that HB 1166 on 3/9/22. at 11:30 pm CT. All 6 people on the Committee voted for SB 175 on the floor  – one is the bill sponsor David Johnson. The conference committee could not agree on what to do and thus we believe HB 1166 and the attempt to amend it is dead.  Link to info on Conference Committee:  https://www.sdlegislature.gov/Session/ConferenceCommittees/64    Link to the proposed amended version of HB 1166: https://mylrc.sdlegislature.gov/api/Documents/236283.pdfTh

Thursday and Friday are the last 2 days of the legislature. We don’t know if any more attempts to try to insert amendments to funding bills in conference committees are planned.ere


B.  REASONS TO OPPOSE AT THIS TIME

Rapid City Shooting Range – Please either oppose or ask for an EIS to be done before building or funding it

Protect the water quality in the area from lead pollution.

 You can write or call your legislator (as GFP is asking the legislature for money to pay for this project.) or Meade County Commission, Game, Fish & Parks (GFP) staff and/or GFP Commission. The USFWS staff in Denver is overseeing a NEPA analysis but GFP and has released the EA for comment on 2/18/22.  (GFP is asking for the USFWS’s Pittman Robertson’s grant program to help pay for the project. Either the federal government or the USFWS policy requires NEPA for projects creating outdoor gun ranges. If FWS approves funding it will stipulate some requirements in a contract)

 

 Game, Fish and Parks has been unable to fund raise enough donations or grants to pay for building the range and are asking  the 2022 legislature for millions to fund the project. Thus folks can contact your SD Legislator with concerns.

SDGFP hopes to break ground in spring. They were asking the SD National Guard to help them build it – but the Guard said NO.

The site is  hilly & especially rugged in north end. The EPA recommends flat areas for shooting ranges, thus we assume major land sculpting & storm water management has to happen. That will be expensive. What other GFP projects for wildlife or parks could be afforded if a site that better conformed with EPAs location guidance had been chosen?

 
SDGFP will be relying in part on Pittman Robertson funding given to them by the USFWS. FWS staff thus must sign off on a NEPA document, either an environmental assessment (EA) or an environmental impact statement (EIS).  Folks should insist on an EIS as the project won’t comply with the EPA Best Management Practices for shooting ranges – GFP selected a site that does not match the site selection guidance.. 
EPA and DANR only regulate shooting ranges at closure, or during construction for storm water runoff. EPA provides guidance (Best Management Practices)  but that guidance is not enforceable, except we can request discussion of this non-compliance in the NEPA document and ask for an EIS. The EIS’s range of alternatives should offer an alternative site selection. Another request for the SD Legislature would be for Dept of Agriculture and Natural Resources (used to be DENR) to be given authority to regulate location, construction and operation of shooting ranges, for lead management concerns (it doesnt have that power now). 
 
 
Map of proposed GFP shooting range, it is off Elk Vale Road north of Elk Creek
 
 
 
 
 

John Kanta at SDGFP knows about the shooting range.  Some engineering plans have been drawn up.

Money to help pay for the project is being sought under Pittman Robertson from the Denver USFWS office,  A totally inadequate draft “environmental assessment” has been written, Public scoping for the EA did not happen.  Comments are due March 20th.
 
SDGFP Commission’s Resolution about land purchase using South Dakota Parks and Wildlife Foundation as a temporary intermediary to hold the land, can be found at below link (The range will be in Meade not Pennington County)
This resolution was adopted in Jan 2021 after about a 30 minute presentation to the Commission.
 It commits the Commission to buying the property from the Foundation at a fixed cost for property – that in January 2021 was not yet appraised and for a site not yet reviewed by the public. The appraisal was less than what they promised to pay. They paid 2,220 per acre and we heard it was appraised at 1,400 per acre.  This hasty action violated at least 4 sections of the SDGFP Land Acquisition Priorities and Guidance – link to that document.

  
 
 
GFP sheet about firing range.
Plans/Drawings of proposed Range
 
Meade County Map showing area’s land parcels
 
TALKING POINTS:
 Some environmental issues associated with shooting ranges can be –
1) Lead contamination from bullets with impacts to ponds/creeks and ground water in area – this is a pollution risk to fish, waterfowl and people. Do folks living along Elk Creek have wells into a water table that is influenced by Elk Creek?
2) Noise of gun fire from hundreds of shooting positions,
3) Disturbance to waterfowl wildlife, livestock and homes/ranches from noise and activity of people. Whooping crane, a federally endangered species, have been seen on the pond just to the south of the project.
4) Bullets traveling to neighboring lands, including over areas with slopes/valleys, with possible impacts to livestock,
5.) Fire risk, 
6) Impacts of traffic to about 3 miles of dirt road resulting in noise, dust and wear and tear and cost of maintenance to Meade
county. Will GFP pay to finish paving Elk Vale Rd, as the County requests?
7)  Supervision of the property and law enforcement costs – What new security costs will be assumed by Meade County vs. GFP? What increase in crime to the neighborhood?
 
The pond/wetland immediately to the south of the property has excellent birding. Whooping cranes have been seen on it.  This range will be about 2.5 miles from Sevey Lake, a popular birding spot.  Impacts to wildlife and fish are not just those on the property, but those nearby who would be impacted by the noise and disturbance or water pollution downstream. Lead pollution is a major issue, especially as the site does not meet the EPA criteria for siting of ranges (not-flat -too much slope).
EPA on BMP on managing lead at shooting ranges
 
 
We quote that document at page II-5:
 
“The most important site selection criteria to consider when selecting a new range
location include: topography; surface water flow patterns; and depth to groundwater. If
possible, ranges should be developed on flat terrain, as it facilitates reclamation and reduces
the chance of off-site migration due to surface water runoff as compared with highly sloped
terrain. When considering a prospective location for a range, ask yourself: What is the direction of
surface water runoff? Does the site drain to surface water (e.g., streams, rivers) on-site?
Off-site? Can the range design be modified to minimize potential runoff? Is reclaimation
equipment accessible to the area to clean the range?” (Emphasis added).
 
Fact sheet on Lead Pollution at Outdoor Firing Ranges:
 
 
.  There are several ponds/impoundments  near edges of the property, inside the property & one has some wetlands associated with it.  The range’s south boundary bisects or borders a pond on an unnamed tributary of Elk Creek.  GFP won’t have access to all or parts of the 2 edge/boundary ponds, as they are on private land. The proposed shooting range is divided between Elk and Antelope Creek drainage basins, with at least most of the northeast-end of range draining to Antelope Creek and the south-end will be draining to Elk Creek.   As the crow flies the range is closest to Elk Creek, but as water flows toward the two drainages, it is closer to Antelope Creek.  
 
 In the pink map below, the shooting range’s south boundary crosses the heart shaped pond just east of Elk Vale Rd and 3/4 mile north of Elk Creek, that sits on a tributary that flows southeast to Elk Creek – merging with Elk Creek in several miles. It’s north boundary is near the slight bend in Elk Vale Rd at a mile and a quarter above that pond. The slight bend in road is on the ridge top.  Property is a half mile wide and a mile and a quarter tall.
 
The topography at the north end is much more hilly, with the north entrance at a ridge top. The smaller shooting bays in the north, are in a descending valley – carved into the western slope.  Some of the southern shooting bays are placed in side drainages. The whole property is descending from the ridge towards the pond.  This site does not meet the EPAs guidance for siting shooting ranges: the EPA wants them on flat sites.  Soil has clay in it . It is harder for reclamation machines to recover lead from clay soil and the machines need flat surfaces.
Reclamation lead bullets/fragments from clay may require washing. It will likely require removal or burning of grass cover, which vegetation 
concentrate lead.
 
Survey of the site has identified cultural properties, but has not yet done Section 106 consultation with tribes.
 
 
 
 
 
 
 
 

 
 

 
CUMULATIVE NOISE

 
See map below. Each of the smaller shooting bays may have 5 -10 shooting lanes/each. There are 29  such bays, 12 are in the south . The 200-400 ft bays may have 20 shooting position/each, 2 are in the south unit. The extra long bays may have 40 positions, 2 are in the south unit. The shooting clays have 12 positions/each.    The south-end range may be used for local shooters. There are 180 shooting positions there.  The north-end range may be used for competitions or training activities and some bays are called “action bays” without assigned lanes. There are 12 positions at the sporting clays.
Decibels from each gun fire are significant 150dB-163.2 dB  ; https://earinc.com/gunfire-noise-level-reference-chart/.  The north end is in a more steep and rugged location, it has a small flat area at the top, but descends into valleys and rugged territory.. 
 
 
 
PAST  DEADLINES
 You can write or call Meade County Commission, Game, Fish and Parks Commission and your legislator (as GFP is asking the legislature for money to pay for this project.) The USFWS staff in Denver is participating in NEPA analysis 

1.   Meade County –  Past Deadline 2/8/2022 – A letter from SDGFP  was discussed February  22nd

Please express concerns about the shooting range to Meade County
 
On 12/21/21 the Meade County Commission (MCC) discussed a draft letter to Gov. Noem, about Meade County’s concerns about the costs to Meade County from the proposed shooting range off Elk Vale Rd, just north of Elk Creek, but came to no conclusions except to talk to SDGFP some more. 
Go to the Meade County’s BoardDoc page for agenda of the meeting  Shooting range discussion was expected after 10 am on 12/21/21
To submit written comments on-line:
1300 Sherman Street, Suite 212, Sturgis, SD 57785, 605.720.1625 | Fax: 605.720.1633
 

MCC could send that or another letter to the governor . Meade County does not have zoning but 
state law allows counties to create ordinances about shooting ranges that address construction and location
(SDCL 21-10-32 offers authority and 21-10- 28 limits it )
Draft letter:
.Meade County is asked by SDGFP to relocate a section line running east-west down to the south edge shooting bay area. SD law reserves 66 feet

 along the section line for public access – without the move, this reservation might influence  Range  design/management .Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance costs. Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance costs.

No formal section line relocation request has been submitted yet. Commission & GFP have not agreed on any road proposals — only ideas have been explored in discussions by GFP with Meade’s transportation staff.

 
 

 

 

 2. March 3 & 4th, was a formal Commission meeting- Game, Fish & Parks Commission meeting in Pierre & Zoom. GFP Commission considered a resolution to purchase the property from the Foundation, who bought it to hold for GFP while formal appraisal of the property was done.  

Results – Commission approved the land purchase. You can still write in opposition to it, but at this point, need to ask for strict environmental protections or to use the land for some other purpose – such as a park.

https://gfp.sd.gov/UserDocs/meetings/21-03_Resolution_-_Authorizing_purchase_of_Rapid_City_Shooting_Range_(3).pdf

hhttps://gfp.sd.gov/commission/archives/63/

https://gfp.sd.gov/UserDocs/nav/22-04_Resolution_-_shooting_range_land_purchase.pdf

 Written comments in opposition to the land  purchase or the shooting range can be uploaded here or submitted at an on-line comment portal   https://gfp.sd.gov/forms/positions/ .  

SD Game, Fish and Parks Commission meetings  Evening of 2/21/22, 5:30 – 7:30 pm CT, informal – one-on-one meeting opportunity at Arrowwood Resort, Oacoma, RSVP by 2/16/22, Rachel.Comes@state.sd.us,

 
 
 
3.   Deadline – January 28th, 2022 – letters to John Kanta Rapid City Shooting Range  –  Comment To SDGFP 
  January 28th, was the deadline to comment to John Kanta of SD GFP if you object to the National Guard assisting with construction of the shooting range proposal. john.kanta-state.sd.us” <john.kanta@state.sd.us> .If you don’t object by the deadline you waive the right to object.  A public notice says:
“This project can’t be completed in its’ entirety without assistance from the National Guard” However the National Guard said no to helping with the project – how will SDGFP afford the entire project without National Guard help at earth moving?

 
 

4. January 25th , 2022 House Agriculture & NaturalResources killed HB 1049, that would have appropriated 5 million for the shooting range. Senator David Johnson responded with a similar bill – SB 175 in the Senate, which has passed the Senate sent back to the House. Killed in Appropriations, Smoked out on floor, up on March 7th on floor. Killed on House floor. Attempt to insert funding text to another bill about funding roads near Palisades State Park –  HB 1166, in conference committee. That failed also.

5. January 4th, Tuesday, 2022 – range was discussed at the  SDGFP Commission Meeting

6. December 21st, 2021 Tuesday –  Meade County Commission Meeting discussed project and listened to to GFP and public proponents, and to opponents but took no action on the proposed letter about the shooting range.

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 : If you want the Commission  to read your comments before March 3rd, submit by midnight CT on Sunday Feb 27th. Comments can be given to Commissioners directly as individuals at any time:

.Meade County wants 3 miles of gravel on Elk Vale road paved, but GFP is proposing to share maintenance costs

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