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 Remington 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 Sporting Arms and Ammunition Manufacturers' Institute (SAAMI), National Shooting Sports Foundation (NSSF), National Rifle Association (NRA), 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 audits 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
• NSSF guidance on technical applicability of hazardous waste tests to ongoing operation of shooting ranges, and possible alternatives
• SAAMI review of environmental mobility of lead, and the factors that control it, at outdoor shooting ranges
• NRA lecturer since 1998 on environmental management at Range Development and Operations Conferences
• 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
• 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 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
• The U. S. Military Academy (West Point) 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 U. S.
• 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
• Counsel for Bergen County NJ Law Enforcement Training Range concerning proper handling of material reclaimed from a pistol range backstop
• Environmental evaluation and recommendations for re-opening a 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
• Counsel for a trapshooting association concerning environmental aspects of property transfer
• 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 in litigation over alleged environmental effects of range activities
• Support of NSSF in assisting the States of Florida and Massachusetts in developing environmental management guidance and regulatory approaches for outdoor ranges
• Development of site-specific Environmental Stewardship Plans for shooting ranges:
  o Minute Man Sportsmen's Club (MA)
  o Peconic River Sportsmen's Club (NY)
  o Elk Neck State Park (MD)
  o Berwyn Rod & Gun Club (MD)o Bethesda/Chevy Chase Isaac    Walton League (MD)
  o Associated Gun Club of Baltimore (MD)
  o Quail Creek Plantation (FL)
  o Deer Creek Sporting Clays (FL)
  o Central Florida Rifle & Pistol Club (FL)
  o Rappahannock Pistol & Rifle Club (VA)
  o The Wilds Christian Camp (NC)
  o American Shooting Centers (TX)
  o Elk Rapids Sportsman's Club (MI)
  o Single Action Shooting Society (NM)
  o Winchester Canyon Gun Club (CA)
  o City of El Centro (CA)

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
• Full ecological and water quality evaluations, including human health and ecological risk assessments
• Design and implementation of appropriate management actions, if necessary
• 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