Draft Proposed Decision On The Michaux Target Range Based on current understandings of critical issues outlined in the Target

Range Progress Report and the consideration of public input received during the Public Comment period from October 15-November 15, 2011, DCNR Bureau of Forestry and the Michaux State Forest District are proposing a conditional 3 year reopening of the target range at the current location. The intent of this reopening is to implement an adaptive management process to ascertain whether or not range operations can be administered in a sustainable manner into the future. The following is a summary of the primary justifications for this decision: 1) The Bureau of Forestrys mandate provides for the opportunity to utilize state forest land for this activity if it can be done compatibly with other aspects of the agencys mission, and within existing operational constraints. 2) The range provides a popular recreational experience for many visitors to the state forest. 3) While there are numerous issues associated with the range (as outlined in the Target Range Report and Public Comments), none of these issues; either individually or collectively, clearly indicate immediate closure at the current site is the only or best public benefit option. 4) Save for the baseline site characterization study, current hard data to describe the level, impact, or trajectories of any of the problematic issues associated with the target range at the current site are not available. Therefore, a decision at this point to either terminate or relocate the range, absent compelling empirical evidence that it is in the publics best interest to do so; would be arbitrary at best.

The proposal to reopen the range is based on implementation of the following mitigation investments and changes to range management policies and procedures: 1) Controlled Range Access and Hours: Ability to control access to and range-use hours is the most critical best management practice suggested in most target range manuals. A woven wire fence and lockable gates will be erected around the range site and the range will operate around routine open and closed days throughout the week. Better control of site access and operational hours will address the following issues: a. Provide for greater safety by limiting accidental walk on b. Provide noise-free days at the lake and surrounding vicinity by scheduling non-use range days. c. Increase the opportunity for user-group self-policing by concentrating use hours and limiting low/unobserved use opportunities. 2) Establish Range Contaminants Management Plan and Mitigation Technologies: A site monitoring and mitigation plan will be developed for contaminants commonly associated with target ranges. Cooperating stakeholders for this effort will include the Chambersburg Water Authority, Bureau of Forestry 1

Draft personnel (Minerals Section geologists and District management staff) and DEP South Central Regional Environmental Clean Up Divisions Staff. Involvement of local academic expertise in an ombudsman role will also be desirable to ensure transparency and accountability. This site management plan will develop appropriate lead and other contaminant monitoring and management protocols to be used on the site to protect visitor safety, wildlife, and prevent ground and surface water contamination. As part of the process, least-cost lead mitigation backstop technologies will be sought and improved backstop technologies implemented at the site. Noise mitigation: Noise pollution and its impact on other forest uses was the most frequently cited concern based on public meeting comments. Overhead baffles at shooting stations will be constructed at both ranges (rifle and pistol) and shoot through mufflers will be provided for high caliber rifles at the rifle range. Limiting range hours to avoid early morning and late evening hours and splitting the week roughly in half between open and closed days (For example either Saturday or Sunday each weekend, and 2.5 days during the week) will also be used to mitigate conflicts with range use due to noise. Range Permitting: Access to the range will be provided through the Pennsylvania Game Commissions Target Range Access program (http://www.portal.state.pa.us/portal/server.pt?open=514&objID=620410&mode= 2) Either a current PA hunting license or PGC range permit will be required to utilize the range. Range Regulations: While many of the current range use policies and regulations will remain consistent, there will need to be some additions and revisions. Currently recognized issues to be addressed through range guideline revisions prior to reopening include: a. Development of shared understandings between DCNR and PGC on Michaux range enforcement i. Enforcement standards ii. Recommended level of deterrent/form of non-compliance iii. Process/jurisdiction for revocation of privileges b. Use of shoot through mufflers c. Process for opening/closing range Range Maintenance Standards and Coordinated Volunteer Effort: Maintenance standards will be established for litter, spent shell casings, signage, and infrastructure repair. The range will be open one non-use weekend day every month to facilitate volunteer clean-up and maintenance efforts to meet these standards. When volunteer efforts in any given month are insufficient to achieve range management standards, district maintenance staff hours required to ensure compliance with standards will be documented. Communication and Information: Range Hours and Guidelines will be posted on the Michaux State Forest Website, posted at kiosks inside the target range and on the access gate. The range will also be indicated on the Public Use Map and other Trail maps as appropriate. Range hours, guidelines, and information will also be posted at the kiosk at Long Pine Run Reservoir to keep lake visitors informed about the presence of the range and how to limit its potential to conflict 2

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Draft with their experience as forest visitors. Annual range reports will also be posted on the website over the next three years. Sustainability Indicators To Be Used During Three Year Trial Period: The proposed decision to re-open the range is based on the assumption that by implementing missing best management practices and mitigating critical issues identified in the progress report and public comment period; public target range activities at the current site represent a sustainable recreational activity within the Michaux State Forest that is in the publics best interest. Adaptive management is a process in which decision outcomes are monitored using a set of measurable indicators to test whether or not underlying management assumptions are sound. In this case, given existing uncertainties spelled out in the target range progress report, reopening the range could be the wrong decision if doing so creates long-term public liability due to site/environmental contamination issues, exceeds district operational capacity in other areas of its mission, or measurably reduces other use values associated with the state forest. Therefore, the proposal to reopen the range is for a discreet trial period of three years, and will be conditional based on a number of measurable indicators used to test whether or not continued range use trajectories support or refute the assumption that it can be done sustainably at the current site.

The following are indicator areas that will be used by the district to evaluate the sustainability of range operations over the three year trial period: 1) Target Area and Scatter Zone Lead (and other contaminant) Levels and Contributing Range Use Behaviors1 Indicators: Annual (??) measurement of Lead impact area Annual (??) measurement of Scatter zone contaminant levels Number of citations for birdshot/unregulated target use Shotshells/clay bird/wadding/bird fragments/unregulated target use encountered during routine site monitoring.

Reason for the indicator: At well managed small arms, single projectile ranges such as this one, scatter zone impacts should be minimal, as most of the lead and other contaminants should be concentrated between the shooting station and the target area. After clean-up of existing target area lead levels, the new lead management plan will require an annual sampling process to determine the average size of that years lead impact
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The Scatter zone is the area surrounding the target area. When contaminant levels in the scatter zone become problematic, mitigation is extremely costly. 3

Draft area around each target site. Keeping each successive years lead impact area as small and consistent as possible is critical to minimizing the short and long-term cost of site lead/contaminant mitigation. Scatter zone samples will also be taken on a periodic basis. Indications of short-term accumulation of contaminants in the range scatter zone would suggest that either range users are intentionally setting up unregulated targets in the scatter zone (rather than in front of the intended backstop) or using birdshot. There is observational evidence at the current range that both of these practices occur (even though at this point they are statistically undetectable) though they are a violation of range regulations. Early evidence that continuation or, worse, an increasing trajectory of such undesirable range behaviors is occurring should represent an unsustainable use-burden on the non-range using segment of the public. Monitoring range behaviors through enforcement and site monitoring as well as measurable site impacts will ensure range activities do not represent a long-term, time-lag public liability. If in the three year period, measurable site impacts are still negative, but enforcement and monitoring indicators show continued or increased evidence of range use behaviors that will eventually contribute to a scatter zone impact, the future viability of the range will be considered, even without measurable scatter zone contaminant levels, less sustainable than if all four indicators show positive trends; particularly if coupled with undesirable trajectories in other indicator areas.

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Impact on District Operational Capacity to Meet Other Areas of its Mission Indicators: Number of volunteer hours committed to range clean-up days Monthly maintenance staff hours needed to ensure Range Maintenance standards are met Annual Range infrastructure maintenance costs Availability of outside/partner funding to cover range management needs Ability to meet other recreational management goals and priorities during the three year period. (Example measures could include): Trail inventory and Assessment Completed. Michaux State Forest Multi-Use Trail system Map ATV trail re-hab on Log Sled and Grave Ridge Big Pine Flats Ecological Management Plan in place and being implemented 4

Draft No decrease in Road Grading/brushing maintenance schedule. Indicators for this area could be updated as needed based on ongoing operational objectives within the District Reason for the indicator area: Budget and resource constraints and transparency about the level of priority the district places on supporting target range activities/infrastructure vs. other recreational activities was raised as a concern by the Target Range Task force and numerous internal and external stakeholders during the Public Comment period. Prioritizing range operations at the expense of other recreational activities and infrastructure is not a sustainable option, given the heavy use and deferred maintenance costs associated with Michaux State Forests road and trail system. The components of this indicator area will provide a realistic test of range operating costs, the portion of those costs absorbed by the district in a given year, an indication of volunteer and partner support/defrayment of range operating costs, and the capacity of the district to achieve other critical management goals within the same three year period.

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Impact on other forest use values: Indicators: Focus group and survey sampling of forest users recreating in the vicinity of the target range.

Reason for Indicator Area: Concerns about recreational conflict between range use and other forest uses were critical issues raised by the progress report and reiterated during the public comment period. However no quantitative or systematically gathered evidence is available to measure how great this conflict is and how much management or mitigation measures might reduce or eliminate it. Creating specific measures of range impacts on other forest uses in the vicinity during the three year trial period will help to both quantify and qualify user conflicts associated with range operations and allow for a more informed management decision about the future of range operations after the trial period.

How Indicator Variables will be used during the trial period.

Draft An annual report will be produced each year during the three year trial period summarizing the variables measured for each indicator area and providing some analysis and interpretation based on that time periods management context. This report will be reviewed internally by BOF agency staff as well as by the Extended Range Task Force, cooperating partners and local elected officials. At the end of the three years, an evaluation process will take place based on overall trends established by tracking the established indicators during the trial period and the decision whether to continue range operations at the current site will be revisited.

Summary of Tasks Necessary for Range Reopening: Fence erected Lead Management Plan written Existing Target Area and Shooting station contaminant levels mitigated to levels established by plan Shooting Stations with Overhead Baffles and Mufflers Constructed Low-cost Lead Capture backstops erected Permitting and Enforcement Understandings in place with Pennsylvania Game Commission/BOF Division of Operations/District Enforcement and Management staff Task Force Expanded to include Volunteer Group Leadership Range Operating Hours Established Range Site Maintenance Standards established for monthly clean-up efforts Monthly volunteer clean-up days scheduled Range Rules and Regs revised (with PGC advisors and Expanded Range Task force) Strategic law-enforcement efforts agreed upon by partners and Task Force Informational Signage developed and posted at Long Pine Run Reservoir and Target Range Kiosks and on Michaux State Forest Website Summary of necessary data flows to develop annual indicators report for range: 1) Ranger Incident Reports/Citations 2) Annual Lead/Contaminant Monitoring a. Target Impact Area b. Scatter Zone Impact Sample 6

Draft 3) 4) 5) 6) Volunteer Clean up Day attendance Outside funds/in-kind services contributed to range operations Staff Maintenance hours and other Range expenses Quarterly range inspection reports: a. Infrastructure depreciation and depreciation factors b. Evidence of birdshot/unregulated target use 7) Progress/status report on other district management goals and activities