Dick Peddicord - Environmental Assessment and Management in Sediment and Shooting Ranges
 
Enviromental Excellence for the Shooting Sports
 
Environmental Experience and Services
Environmental Stewardship Plans
 
     
 
   Environmental Experience and Services
   for the Shooting Sports
 
 


Richard K. “Dick” Peddicord, Ph. D. has been providing environmental services to the shooting sports since 1986 when he began work for Remington Arms Company at Lordship Gun Club at Lordship Point, Stratford, Connecticut.  Since then, he has become one of the most broadly experienced leaders in the world in environmental evaluation and management at outdoor shooting ranges.

Clients include the National Rifle Association (NRA), National Shooting Sports Foundation (NSSF), Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI), and dozens of recreational, law enforcement, and military rifle/pistol and shotgun ranges.  Services to these clients fall into four broad categories:

  • Pro-active environmental investigations to identify and document potential environmental impacts, if any
  • Water quality, ecological or human health evaluations at ranges where potential environmental impacts have been alleged or identified, including identification of causes and practical solutions
  • Development and implementation of environmental stewardship plans to minimize potential environmental impacts
  • Support of clients in regulatory negotiations, obtaining permits, public information exchange, and, if necessary, litigation support including expert testimony

This work under a wide variety of conditions, in concert with 30 years’ experience in broader aspects of environmental assessment and management, has provided detailed technical knowledge of the potential impacts of lead, associated metals, and clay targets on ground water and surface water quality, human health, birds, wildlife, and aquatic organisms. 

Shooting range clients and activities include:

  • Testimony before the House Committee on Resources on environmental impacts at outdoor shooting ranges
  • Assistance to U.S. Environmental Protection Agency (U.S. EPA) in developing its “Best Management Practices for Lead at Outdoor Shooting Ranges
  • Evaluation of technologies for reclaiming lead for recycling at outdoor shooting ranges as a subcontractor to U.S. EPA
  • Development of environmental guidance for construction and management of outdoor rifle/pistol and shotgun ranges for the NSSF
  • NSSF guidance in user-friendly CD format to assist ranges in developing their own Environmental Stewardship Plans
  • Developed NSSF guidance on technical applicability of hazardous waste tests to shooting ranges, and possible alternatives
  • Review of the environmental mobility of lead, and the factors that control it, at outdoor shooting ranges for SAAMI
  • Lecturer on environmental management at NRA Range Development and Operations Conferences since 1998
  • Invited speaker and participant in the World Symposium on Lead in Ammunition, sponsored by the World Forum on the Future of Sport Shooting Activities, Rome, September, 2004. 
  • Invited speaker at World Forum on Sport Shooting Activities Workshop on Lead Reclamation, Sound Attenuation & Backstop Construction, Palermo, October, 2007
  • Chair of Environmental Session at the  National Skeet Shooting Association / National Sporting Clays Association by-invitation-only Workshop on Target Shooting in the 21st Century
  • Counsel for a private trap and skeet range in the Southeast shooting into a salt-water wetland that pro-actively evaluated their position in anticipation of litigation
  • Indian River County FL rifle/pistol and trap/skeet range shooting into a freshwater wetland seeking to establish an initial environmental management plan
  • Counsel for a mid-western resort facing both a Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Consent Order and a Natural Resources Damage Assessment at a trap and skeet range shooting into a wetland
  • Technical review of a range site assessment and documentation of the inappropriateness of CERCLA for managing active ranges for NRA
  • Counsel for New York Athletic Club trap range facing a Clean Water Act (CWA) and Resource Conservation and Recovery Act (RCRA) lawsuit, including field sampling, assessment of risks to waterfowl, negotiation and implementation of a settlement agreement, preparation of bid request, and selection of contractor for site cleanup
  • Pro-active initial environmental assessment so counsel for a large trap range could identify any potential water quality or ecological effects and respond appropriately
  • Counsel for Remington (Lordship Gun Club) at Stratford, CT, under a State Administrative Consent Order and a RCRA/CWA lawsuit, including field sampling, assessment of risks to waterfowl and water quality, and development of innovative lead removal
  • Westchester County, New York, including sampling, analyses, ecological and human health risk assessments at rifle/pistol/trap/ skeet ranges under a CWA and RCRA Consent Order, and development of modifications to range construction and operations to allow continuing use under environmentally acceptable conditions
  • Langley Air Force Base (VA) small arms training range and recreational trap & skeet ranges shooting into wetlands
  • Naval Facilities Engineering Command, Engineering Field Activity, Northwest, assessing environmental conditions at inactive pistol and shotgun ranges at Submarine Base Bangor (WA)
  • The U. S. Military Academy (West Point NY) on ecological and human health risk assessment of a trap and skeet range shooting into wetland and upland habitat
  • Counsel for Naperville IL Parks Department trap range facing a Clean Water Act lawsuit.  Assisted in obtaining the first NPDES permit ever issued for a range to shoot into waters of the United States
  • Invited speaker on environmental issues and management at 2nd, 3rd & 4th National Shooting Range Symposia
  • Environmental assessment, evaluation of management alternatives, development of preliminary engineering plans and initial cost estimates for Broward County FL at Markham Park Target Range
  • Environmental assessment and closure plan for law enforcement training range for City of El Centro CA
  • Site evaluation and management recommendations for Exeter (NH) Sportsman’s Club
  • Counsel for Bergen County NJ Law Enforcement Training Range concerning proper handling of material reclaimed from a pistol range backstop
  • Environmental evaluation & recommendations for re-opening trap/skeet/ sporting clays facility owned by Suffolk County NY
  • Evaluation of potential water quality and regulatory implications for counsel representing a sporting clays course at a resort in PA
  • Initial environmental evaluation for a Midwest State Trapshooting Association in relation to potential sale of range property
  • Invited speaker at 2003 Workshop on Shooting Ranges on Public Land sponsored by AZ Game & Fish Department at Ben Avery Shooting Facility
  • Development of Environmental Stewardship Plan format for NSSF consistent with U.S. Forest Service policies
  • Initial site evaluation and recommendations for Santa Ynez Valley (CA) Sportsmen’s Association
  • Initial site evaluation and recommendations for Hartford (CT) Gun Club
  • Initial site evaluation for Owens Station (MD) Sporting Clays
  • Counsel for a major trapshooting association concerning environmental aspects of property transfer
  • Counsel representing a recreational shooting organization in a real estate evaluation
  • Confidential utility industry client developing a firearms training range for its security forces
  • Counsel for the City of Huntington Beach CA seeking to enforce environmental insurance coverage for the City’s law enforcement firearms training range
  • Counsel representing Skyways Trap and Skeet Club (FL) in litigation over alleged environmental effects of range activities
  • Counsel representing the Illinois State Rifle Association in a zoning appeal for expansion of their range
  • Support of NSSF in assisting the States of Florida and Massachusetts in developing environmental management guidance and regulatory approaches for outdoor ranges
  • Determination of distribution of pellets in relation to property boundaries for counsel at two shotgun ranges in Colorado 
  • Estimation of cost of lead management for valuation of range property for tax purposes for counsel representing a confidential client
  • Counsel representing a CA range in restoration of adjoining property on which range activities had deposited shot
  • DE Department of Fish & Wildlife in optimizing lead reclamation and management at Ommelanden Hunter Education Training Center range
  • Counsel representing property owners in a case in which the U.S. District Court for the Southern District of California ruled that a range is not a “facility” subject to CERCLA.
  • Development of site-specific Environmental Stewardship Plans for shooting ranges:
  • Glendale Dept. Public Safety (AZ)
  • El Centro Police Department (CA)
  • Maricopa County Sheriff’s Office (AZ)
  • San Diego Shotgun Sports Assoc. (CA)
  • Winchester Canyon Gun Club (CA)
  • Delaware Fish & Wildlife Dept. (DE)
  • Central Florida Rifle & Pistol Club (FL)
  • Deer Creek Sporting Clays (FL)
  • Markham Park Target Range (FL)
  • Quail Creek Plantation (FL)
  • Illinois State Rifle Association (IL)
  • Confidential firearms retailer (ME)
  • Associated Gun Club of Baltimore (MD)
  • Berwyn Rod & Gun Club (MD)
  • Bethesda/Chevy Chase Isaac Walton League (MD)
  • Close Quarters Defense (MD)
  • Elk Neck State Park (MD)
  • Global Tactical Solutions (MD)
  • Minute Man Sportsmen’s Club (MA)
  • Elk Rapids Sportsman’s Club (MI)
  • Clark County Shooting Park (NV)
  • Single Action Shooting Society (NM)
  • Blue Mountain Sportsman’s Center (NY)
  • Peconic River Sportsmen’s Club (NY)
  • The Wilds Christian Camp (NC)
  • Pennsylvania Game Commission (PA)
  • Seven Springs Mountain Resort (PA)
  • American Shooting Centers (TX)
  • Denton County Sheriff’s Office (TX)
  • Greater Houston Gun Club (TX)
  • Vermont Fish & Wildlife Dept. (VT)
  • Rappahannock Pistol & Rifle Club (VA)

Dr. Peddicord’s broad understanding of potential environmental and regulatory issues at shooting ranges makes him exceptionally well qualified to assist in siting and designing new or expanding ranges to minimize potential environmental impacts, and to assess impacts, if any, of existing ranges.  If the situation cannot be resolved otherwise, Dr. Peddicord also provides litigation support including expert testimony.  In this context, he frequently works closely with internal and external counsel for a variety of clients. 

All range activities involve close coupling of the appropriate aspects of scientific and engineering considerations, range design and operation, regulatory issues, and public communication.  This often helps clients avoid problems by pro-actively developing and implementing cost-effective environmental stewardship plans appropriate to their ranges.  If challenges do arise, this approach provides the basis for negotiating acceptable resolutions and/or environmentally sound remediation objectives that can be met cost-effectively.

A stepwise approach is used to quantify realistic potential effects at each specific range.  Once risks, if any, are accurately described, an appropriate environmental stewardship plan can be developed or the possible environmental consequences and the need for management action can be determined and permits can be obtained.  If legal, regulatory or environmental conditions make management appropriate, a strategy that optimally fits the specific needs at that range can be designed and implemented.

Throughout the process, the goal is to constrain the client’s overall costs and liabilities by identifying real problems, if any exist, and designing and implementing creative site-specific solutions.  By carefully defining the specific problems at the range and solving only those problems, the range owner does not face the expensive possibility of reacting to partially documented regulatory or public speculation with standard, and perhaps somewhat draconian, approaches.

Dr. Peddicord is experienced in evaluating and successfully resolving unique environmental problems in which automatic application of standard regulatory procedures is not quite appropriate and not in the best interest of the range.  He uses properly focused risk assessment and risk management techniques to successfully limit client liabilities and develop cost-effective, innovative and environmentally sound resolutions of environmental problems at shooting ranges.   

A broad understanding of potential environmental and regulatory issues at shooting ranges provides exceptional qualifications to assist in siting and designing new or expanding ranges to minimize potential environmental impacts, and to assess impacts, if any, at existing ranges.  Assistance is available at any level, including:

  • Preliminary consultation
  • Initial site assessment
  • Discussions and negotiations with regulators, including permitting assistance
  • Development and implementation of environmental stewardship plans
  • Design and implementation of appropriate management actions, if necessary
  • Full ecological and water quality evaluations, including human health and ecological risk assessments
  • Public communication and information dissemination
  • Litigation support and expert testimony
Dick Peddicord & Company, Inc. offers the proven capability to evaluate conditions, integrate understanding of complex environmental issues, develop practical environmental stewardship plans, help obtain permits, and successfully minimize short- and long-term environmental liabilities at outdoor shooting ranges through design, planning, assessment, negotiation, and/or remediation in ways compatible with the practical requirements of day-to-day range operations.

1115 Cooper's Landing Road • Heathsville, VA 22473
Phone: 804-580-3320 • Fax 804-580-3360 • E-mail