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Net Zero 22
Join the Climate Collaborative in Demanding the Environmental Management Committee Stop the Proposed Machine Gun Range
Dear Commissioners Amidon, Montgomery and Suuberg: I am writing to express my strong opposition to the Massachusetts National Guard’s proposed multi-purpose machine gun range to be located at Camp Edwards. For the reasons explained below, I urge the Environmental Management Committee to deny this project. The proposed machine gun range project will have significant climate change impacts, but these consequences were ignored by the Guard’s environmental assessment. The Guard failed to account for or quantify the obvious and foreseeable impacts stemming from the loss of carbon sequestration capacity in clear-cut forest areas. Recent research on carbon sequestration shows that mature forests, such as those found on Camp Edwards, can sequester between 1 and 1.6 metric tons per acre per year. Yet the Guard failed to even consider and quantify sequestration losses and resulting carbon releases associated with clear-cutting 170 acres of forest lands. These impacts are substantial and must be analyzed and quantified. In a region that is an epicenter of the climate crisis and committed to achieving no net emissions of carbon by 2030, these releases represent a significant setback. Unfortunately, the Science Advisory Council (SAC) at its recent meeting stated that these climate impacts could not be considered in its review of the project, due to outdated (by the SAC’s own admission) environmental performance standards. That the performance standards do not consider climate change impacts to the area and its wildlife habitat makes them wholly inadequate as a measure of the project’s environmental impacts. I urge the EMC to reject this proposal and immediately undertake a revision of the environmental performance standards to include consideration of climate change impacts and mitigation, based upon currently available sound and accepted scientific analysis, monitoring data and other relevant information, as provided in state law in Chapter 47 of the Acts of 2002.
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