Q. Why did the Guard stop using lead ammunition at Camp Edwards in 1997?

A. Due to concerns regarding the impacts from installation activities on the sole source aquifer, in 1997, the U.S. EPA issued an administrative order to the Guard under the Safe Drinking Water Act suspending a number of training activities including the firing of lead ammunition on the small arms ranges at Camp Edwards. This ban is currently in effect until investigations and applicable cleanups are completed and pollution prevention practices are put in place to ensure training with lead ammunition will not contaminate the groundwater.

Q. Why can't tungsten-nylon ammunition be used at Camp Edwards?

A. Due to military training needs tungsten-nylon ammunition was introduced at Camp Edwards in 1999 as an environmentally-friendly substitute for lead ammunition. Data available to the Guard at the time suggested tungsten was not a soluble metal and unlikely to break down and move through the soil and eventually to the water table. In 2003, the Environmental Officer for the state's Environmental Management Commission brought to the Guard's attention research indicating tungsten could be highly soluble and mobile. The Guard volunteered to participate in a study planned by the Army Environmental Command. That study is currently ongoing. In February 2006, tungsten was found in a groundwater monitoring well on a small arms range. Tungsten, considered an emerging contaminant, has limited information available and the health effects are largely unknown. In February 2006, Governor Mitt Romney took the precautionary measure of immediately suspending the use of tungsten-nylon ammunition at Camp Edwards. Since then, as a temporary solution, soldiers have been sent to other military bases to train on small arms weapons.  

Q. How will the environment and public health be protected?

A. Before the use of lead ammunition can resume at the base the Guard must put pollution prevention practices in place at each range. A Small Arms Range Working Group is working in close coordination on an overall pollution prevention plan providing general guidance for all small arms range management as well as a series of pollution prevention plans for each range, starting with Tango and Echo ranges. Each plan will identify preferred pollution prevention practices for the range that will ensure lead does not contaminate the soil and groundwater. These plans will compare and analyze available containment systems, describe a preferred bullet containment system, and outline operation and maintenance plans. A draft of the pollution prevention plan(s) can be viewed at www.EandRC.org. The Guard has already installed monitoring wells on the small arms ranges that can be used to sample groundwater regularly for lead. The Guard will also install lysimeters at the ranges to sample water close to the soil surface to detect lead before it reaches groundwater.

Q. If the use of lead ammunition resumes at Camp Edwards, will there be a system in place to ensure the pollution prevention practices are working?

A. Yes. The Environmental Management Commission (EMC), provides oversight to ensure current military activity in the Upper Cape Water Reserve/Training Area at Camp Edwards is protective of the environment. This includes training at the small arms firing ranges. The MMR EMC enforces the Environmental Performance Standards -- guidelines the Guard must follow to ensure protection of natural resources in the Reserve. Before the use of lead ammunition for training can be reinstated at Camp Edwards, a new environmental performance standard must be created that will ensure small arms range training is not harming the environment. This standard will be performance driven; its effectiveness will be measurable using set guidelines and monitoring protocols. Each pollution prevention plan will have three important components: containment of bullets, maintenance of systems, and monitoring to ensure lead does not migrate past the containment systems towards groundwater. The Guard proposes implementing the pollution prevention plans in phases. Phase I involves the implementation of pollution prevention systems at Tango and Echo ranges. Phase II and III will be implemented in the next few years. A total of nine ranges is an operational goal for training soldiers at Camp Edwards.

Q. How does lead ammunition (as opposed to plastic bullets) add value to a soldier's knowledge and understanding of the firing and sighting a small arms weapon.

A. Soldiers and airmen in deployable units are required to qualify on their assigned weapons annually and become familiarized with other standard small arms weapons systems . Plastic ammunition does not have the ballistic properties (e.g., muzzle velocity, projectile trajectory, and point of impact at distance) or realism associated with the lead core ammunition used in combat situations. Marksmanship proficiency cannot be attained, maintained, and demonstrated (during weapons qualification) using plastic ammunition. Weapons must be modified (i.e., the use of a different bolt in the firing mechanism) to train with plastic ammunition. Military personnel engaging targets with plastic ammunition do not experience conditions that are sufficiently representative of lead core ammunition used in combat situations. Although they allow military personnel to practice maneuver exercises and force-on-force, blank ammunition and simunitions (paint ball) do not enable military personnel to qualify with small arms. Blanks do not fire a projectile to practice and demonstrate marksmanship. Simunitions (paint ball) projectiles do not have the ballistic properties associated with lead core ammunition.

Q. Why is it important to have small arms weapon training at Camp Edwards?

A. Small arms ranges allow training with weapons of a small caliber, i.e. handgun, rifle shotgun or machine gun. Any soldier in a deployable unit must be proficient in the use of their small arms weapon and are required to “qualify” on the weapon annually. Small arms training programs are designed to train a soldier to be “qualified” in the use and maintenance of an assigned weapon. Qualification must take place on a range designated for this purpose. Military personnel must be proficient in all five phases to meet Army training standards. He/she must be familiar with the weapon, zero its sights, fire accurately, transition among various fighting positions, and qualify with said weapon in a combat simulation Field commanders and military personnel with recent experience in Iraq and Afghanistan identified potential future requirements, including force protection during convoy operations and sniper/counter-sniper training. The improvement of Camp Edwards SARs would provide more training opportunities with greater realism for soldiers and maximize the limited time Guardsmen have to train by having key training available in one location.

Q. What must the Guard do before lead ammunition can be reinstated at Camp Edwards?

A. Before use of lead ammunition can resume at Camp Edwards three major steps must be taken to fulfill environmental requirements. The Small Arms Range Working Group comprised of the military and state and federal environmental agencies will be actively involved in reviewing and determining that all the plans and reports developed are protective of the environment. The three major steps in the process are: Massachusetts Environmental Policy Act (MEPA) Supplemental Final Environmental Impact Report, creation of a new Environmental Performance Standard under state law Chapter 47, and the Guard must fulfill the requirements of the U.S. Administrative order banning lead ammunition at Camp Edwards. For more information please see The Process to Resume Lead Ammunition at Camp Edwards link.

Q. How will the community be involved?

A. The community's input will be sought for every step of the process to resume the use of lead ammunition at Camp Edwards, including public meetings and comment periods associated with the pollution prevention plan, the small arms range environmental performance standard, Administrative Order 2, and small arms range remedial investigation reports. The Guard is also conducting a Massachusetts Environmental Policy Act (MEPA) process by preparing a supplement to the 2001 Environmental Impact Report for Camp Edwards. The supplement will detail the possible environmental impacts of the proposed action to resume the use of lead ammunition at Camp Edwards and any mitigation measures associated with the action. The MEPA process ensures the community is informed and involved. The Guard is conducting an Environmental Assessment under the federal equivalent of MEPA, the National Environmental Policy Act (NEPA), to assess the use of lead ammunition and best management practices in the management of small arms ranges.