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Today, Obama's radical EPA has claimed a broad reach of power over just about any drop of water that might flow to an ocean, create a swamp or might even linger around a few weeks in a low spot. While I doubt the EPA will directly go after gun clubs, state, county and local environmental agencies certainly might and neighbors who don't like the noise will surely use these regulations to close down clubs. Of course, the claim will be lead pollution.

Joseph Curl - The Washington Times - Wednesday, May 27, 2015

President Obama’s administration on Wednesday claimed dominion over all of America’s streams, creeks, rills, ditches, brooks, rivulets, burns, tributaries, criks, wetlands — perhaps even puddles — in a sweeping move to assert unilateral federal authority.

The Environmental Protection Agency, along with the Army Corps of Engineers, says it has the authority to control all waterways within the United States — and will exercise that authority.

“We’re finalizing a clean water rule to protect the streams and the wetlands that one in three Americans rely on for drinking water. And we’re doing that without creating any new permitting requirements and maintaining all previous exemptions and exclusions,” EPA head Gina McCarthy told reporters Wednesday.

Read more: http://www.washingtontimes.com/news...dominion-over-creeks-streams-w/#ixzz3bNxNB4r3
There is no use arguing that lead isn't a pollutant. These people don't rely on science, fact or truth in any form to make their decisions.

What a club needs to do is objectively look at its property and see if there is any way that these regulations might apply to it. If so, the club needs to mitigate that threat. This can often be done by creating drainage control features like swales and catch basins. A guy on a D6 can do a lot of under-the-radar work in a couple of days. The goal needs to be to have a drainage management system in place BEFORE the authorities show up. If you can demonstrate that you have the drainage under control on both your lead drop area and your target/wads field, you have a good chance of having that guy get in his car and leave.

The last thing you want is to have to create a drainage control system under the thumb of an agency bureaucrat because it will cost you 4-10 times as much as the guy with the D6.

You will have guys in the your club who will say to do nothing until some one makes us do it. It is these guys in denial who will get your club closed. Be proactive and get your club in shape and let's hope Congress gets the EPA and its draconian regulations back under control.
 

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They are WORSE than Communist! They are pure evil Tyrants! One guy was even sent to prison for digging a pond to catch rain water! They are the kind of tyrannical government our forefathers warned us about!
 

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I can sure see where some anti gun club places might use this to try and shut down a local gun club. Sure wouldn't put it past them!
 

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It worked in Naperville. I wasn't a member when it happened so I don't have all the relevant details, but back in the late 1990's there was a lawsuit that closed the facility because we were putting lead in a "navigable waterway" that lead to a river. The "navigable waterway" was an equalization channel between two small ponds that were dug to build a rifle/pistol berm back when the facility was built (40's-50's). There was a ditch/culvert that allowed water out of one of the ponds when the water got high and flowed into an "unnamed tributary" (basically a small ditch) to the DuPage River. Based on that they claimed pollution of public waters.

I think the people that filed the lawsuit figured it would close the place down, and while they won the lawsuit they didn't count on the facility changing to steel shot so it could remain open. But most places wouldn't do that, so generally it will result in closing the facility. Also the facility is publicly owned (city property, leased to the park district) so they had money to spend on legal fees that most private clubs would not have.

Since 2001 when the facility re-opened requiring steel shot/bio targets the city/park district has been required to submit samples to the Illinois EPA of any outflow, along with a raft of other forms and permits to continue operating. In 2014 the city/park district decided to remediate the entire property to remove all lead so they could get out from under the EPA oversight. They spent in excess of $3 million to clean up the entire 19 acres. The project took about 7 months (no shooting) and the facility re-opened in late December 2014. They also spent a bunch more money ($500K+ best guess) for facility improvements (re-poured all 3 trap fields, new sidewalks, new lights, paved parking lot and entry road, entire facility up to the latest ADA requirements).

Scott
 
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