Pollution hazards from sporting shooting ranges
Abstract
Summary: Sporting shooters, in their enthusiasm for their hobby, do not fully take into account environmental pollution when selecting sites for shooting ranges. This is obvious from a recent proposal for a complex of shooting ranges in Bodalla State Forest on the NE slopes of Mt Dromedary. It may fall to the community to protest unsuitability of proposals since applications are considered at Shire Council level, where a small number of staff copes with great diversity of environmental considerations. The present review was prepared initially in a slightly different form for submission in 2003 to a Commission of Inquiry, which finally did not sit owing to the withdrawal of the shooting complex proposal. It is presented here as an aid to communities that may be affected by threats of lead pollution and perhaps to Councils who wish to benefit from the experiences of Eurobodalla Shire NSW. The hazard from lead is underlined by the international banning of lead from petrol and paint and the banning of lead shotgun pellets from waterways. In NSW Far South Coast, extensive lead pollution has been found at a shotgun range formerly used by the Batemans Bay Clay Target Club, at West Nelligen near Batemans Bay. N.S.W. Environment Protection Agency has informed Eurobodalla Shire Council that the site is polluted and is declared a remediation site (Declaratio n Number 21029). The cost of remediation is estimated by EPA as $ 250,000. Batemans Bay Clay Target Club has disbanded. This review is offered to assist in the application of environmental principles to the location of sporting shooting ranges to avoid similar situations future. The reality of the environmental threats is seen by the recent development application to Eurobodalla Shire Council (ESC DA 01.5759.D) for a complex of ranges on a ridge from Mt Dromedary that drains directly through farmland into Wagonga Lake, which supports a fragile oyster industry. The development would make a mockery of Healthy Rivers Commission (HRC) report on oysters (2002), which refers to Wagonga and recommends that “new development proposals must specifically address the increased risks on oyster health” (p70 Appendix 2, of the HRC draft report 2002). This review presents lessons from international experience of shooting ranges and from the recent proposal for Mt Dromedary that are of broad environmental application: - Attention is drawn to the generally high level of lead in the environment and the fact that it is already at levels where it begins to affect human health and especially the proper development of children. A highly relevant document is the Guidance Document for Lead in Shellfish that has been produced by U. S. Food and Drug Administration Center for Food Safety & Applied Nutrition (1993). This document clearly states “Presently, there are no levels of lead exposure for children or adults at which it may be considered that no adverse effects occur.” This view is becoming stronger; for example the Canadian Medical Association Journal in 2002 states, “There is no evidence for a threshold below which lead has no adverse health effects. Blood lead levels previously considered safe are now known to cause subtle, chronic health effects. The health effects of lead exposure include developmental neurotoxicity, reproductive dysfunction and toxicity to the kidneys, blood and endocrine systems ” (Sanborn et al 2002). This means that there are no safety margins for lead in the environment. The firing of many tonnes per year (see below) of lead shotgun pellets from a hilltop that drains through farmland into an estuary in which oysters are farmed, is exactly the sort of development that will cause much damage. Attention is focused on the creation of an irreversible focus of pollution from which pollution will flow through the environment if an unsuitable site is used. The concentration of lead by shellfish and its effect on consumers is itemised. It is argued that this additional pressure on a fragile industry should be avoided since the oyster industry has been in decline since the late 1960s although it provides employment for 1200 people and has $30 m annual earnings in NSW. The recent Healthy Rivers Commission (2002) Independent Review of the Relationship between Healthy Oysters and Healthy Rivers, concludes (p56) that the steady linear decline in number of leases over the last 30 years predicts that the oyster lease area in NSW will be zero in 2019 unless active steps are taken. HRC includes Wagonga Lake in a category of lakes that is productive but now threatened; in which “any new development proposals must specifically address the increased risks posed by the development on oyster health and growth”. Shooting Complexes present a potential threat to waterways, especially since the solubility and toxicity of lead is not yet widely recognized at the Shire Council level where initial planning approvals are given. Furthermore, there is a risk of a health scare in the highly lucrative beef export market world wide, which is worth A$ 9bn per year to Australia and would be threatened by traces of lead in cattle. Some 20 creeks arise inside or very near the proposed complex and all drain through farmland to Wagonga Lake. An important principle is that high rainfall areas that drain through farmland are unsuitable. It would be an improvement on current procedure in NSW if EPA expertise was brought into the planning process as a critical authorising body at an early stage and before development approval is granted. Otherwise pollution that cannot be remedied may occur, with numerous adverse consequences. Five possible grounds of conflict with environmental objectives by ill-sited shooting complexes are identified in this review; each of which is illustrated by the recent actual proposal in Eurobodalla Shire: - Creation of a focus of noise and pollution when Minister Refshauge (28th October 2002) has declared the objective that South Coast “development works with the environment, not against it”. Incompatibility with maintenance of the social environment of private dwellings, which can be impacted with noise pollution from weapons including magnum rifles and with dust pollution from increased traffic on unsealed roads. Incompatibility with the maintenance of the natural environment including rare warm temperate rainforest and continuity of production from both livestock and oyster farms, which can all suffer lead pollution. Breach of the recommendations of the NSW Healthy Rivers Commission as presented its draft report on 28th October 2002, which warns that the oyster industry is precarious and threatened by pollution and for example Wagonga Lake requires “stringent controls on new…developments” that “must specifically address the increased risks posed on oyster health and growth”. A site that will cause run-off of heavy metals into estuary is clearly inconsistent. Flouting of the 1999 the National Environment Protection Council, which issued a National Environment Protection Measure for the Assessment of Site Contamination that requires new sites of contamination be avoided. Creation of a site in which many tonnes per year of shotgun pellets will be broadcast but cannot be recovered because of hilly, creek- fissured topography and wooded vegetation, constitutes a flagrant breach.
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