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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 meeting– Game, 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 doesn’t 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.

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

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

 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.

https://gfp.sd.gov/userdocs/docs/Land_Acquisition_Guidance_-_August_2016.pdf

 

  

 

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

 

GFP sheet about firing range.

https://go.boarddocs.com/sd/meade/Board.nsf/files/C9SU427A29C4/$file/RapidCityFirearmRange_OnePager.pdf

Plans/Drawings of proposed Range

https://go.boarddocs.com/sd/meade/Board.nsf/files/C9SU457A29C7/$file/RapidCityFirearmRange_01.pdf

 

Meade County Map showing area’s land parcels

https://go.boarddocs.com/sd/meade/Board.nsf/files/C9SU4A7A29CD/$file/Rapid City Range Complex.pdf

 

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

 

https://www.epa.gov/sites/default/files/documents/epa_bmp.pdf 

 

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:

https://static.ewg.org/reports/2001/LeadPollutionAtOutdoorFiringRanges.pdf

 

 

.  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 EPA’s 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

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

To submit written comments on-line:

https://www.meadecounty.org/commission

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:

https://go.boarddocs.com/sd/meade/Board.nsf/files/C9VV5G7F0FEC/$file/Board Letter 12.21.2021.pdf

.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.

 

https://sdlegislature.gov/Statutes/Codified_Laws/2053056

 

 

 

 

 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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