Shooting Range Safety

The proposed use is not capable of satisfying either the New Kent County ordinances, or the Federal standards for safe operation of a shooting range.

New Kent County Zoning Laws

The specific use conditions in the New Kent County code specifies that

“Direct fire zones extending a minimum of 3,000 yards [1.7 miles] shall be maintained directly down range.”i

Further, the New Kent County code specifies that

“All shooting stations will be designed so they are away from existing residential uses and firearms will be discharged only in a direction away from these existing uses.”iv

There are residential uses within half a mile (880 yards) on all sides of the subject property, many are immediately adjacent to the subject property.

Federal Government Standards

The US Army specifications for shooting rangesii specify a Surface Danger Zone (SDZ) that extends 2-1/2 miles or more for the caliber ammunition proposed to be used (7.62 mm). DA PAM 385-63 is the bible for design and construction of military firing ranges. It does not allow for the reduction of the SDZ through mitigation by range design as the NRA Range Manual does for recreational ranges. It is the standard which all military ranges must meet, including the local ones at NWS Yorktown, Cheatham Annex and Camp Peary.

The proposed use is to operate a military training range, using military weapons and military training scenarios. Our military has determined, through extensive experience and engineering analysis, the required safety standards for ranges conducting those identical activities. There is no basis for determining that a lesser standard of safety is acceptable for New Kent County citizens residing downrange of this activity.

The DOE Range Design Criteriaiii specify a Surface Danger Zone (SDZ) that should be controlled while firearms are being discharged, and typically extends from the firing line to the maximum range of the most powerful cartridge used. It says that the boundaries of the SDZ must be posted with permanent signs warning of the danger and prohibiting trespassing, and that if other methods to control access to the SDZ are not effective, then the danger zone should be fenced in.

The CUP application specifies .308 caliber / 7.62 mm rifles, or up to .50 caliber hunting rifles, and .45 caliber for handguns. The maximum ranges for these are shown in the table below. All of the standards (DOD, DOE and NRA) specify these same distances.

Caliber

Max. Range (yards)

(miles)

.45 pistol

1636

0.93

9mm pistol

1900

1.08

.30 rifle

3390

1.92

7.62mm rifle

4483

2.55

.50 AP, M26

6671

3.78

The subject property is not big enough to provide for any of these safe zones. The SDZ extends well beyond the boundaries of the subject property, so there is no way the area could be controlled or fenced.

The map below depicts the Surface Danger Zone for one firing station for 7.62 mm ammunition, with an estimated direction. The proposal actually calls for 5 firing ranges with 15 stations each, aimed in different directions, so the actual danger zone would be considerably larger.

Surface Danger Zone for 7.62mm ammunition
Surface Danger Zone for 7.62mm ammunition

Below is a map depicting the Surface Danger Zone (SDZ) for only 2 of the 75 proposed firing stations. The SDZ defines that area where there is a danger of being hit by a stray bullet, and is supposed to be kept clear of any people, according to US Army standards.

Surface Danger Zone for 7.62mm ammunition
Surface Danger Zone for 7.62mm ammunition

iNew Kent County Code of Ordinances, Sec. 98-745 – Specific use Conditions (b)(11) Pistol Ranges, paragraph d.

iiDepartment of the Army Pamphlet (DA PAM) 385-63

iiiRange Design Criteria, US Dept. of Energy, June 2012 (https://www.energy.gov/sites/prod/files/2013/05/f1/Range_Design_Criteria.pdf)

ivNew Kent County Code of Ordinances, Sec. 98-745 – Specific use Conditions (b) (11) Pistol Ranges, paragraph b.