The EPA Risk Assessment report draws specifically on DRN/GeoSystem’s data in their conclusion that the PGC did not go nearly far enough in their Risk Assessment and that the contamination was worse than the PGC’s assessment led everyone to believe.  Worse in terms of possible other contaminants on-site and how much of the Delaware River could be impacted. 

According to DEP, upon receipt of EPA's evaluation of PGC's Risk Assessment, did not know about the DRN/GeoSystem's data.  Thankfully DEP had denied the Club’s assessment on other findings - albiet much weaker ecologically speaking reasons.  The PGC had scheduled a meeting with DEP to challenge DEP's denial, but cancelled the meeting once they recieved EPA's report. According to DEP, the PGC admitted they knew of the DRN/GeoSystem data but didn’t believe it so didn’t include it into their report.  DEP suggested that they could have collected their own data if the didn't trust DRN's data.

Background - I think alos that our comprehensive comments to PGC’s Risk Assessment report empowered and encouraged EPA to do a much more thorough job themselves.
If you stood next to a park or recreational trail used throughout the year and shot a gun up into the air so that gun shot rained down on that park or trail, even during times when people play, run, walk, cycle or otherwise use the area you'd be stopped by the authorities, probably ticketed or fined. If you continued those shoots 12 times a year every year you'd be in even bigger trouble. It would only take one call to get the authorities to act. 

If you stood on the banks of the Delaware River 12 times a year and for 4 to 6 hours threw trash in, handful after handful, you’d be stopped and probably get a fine. If you stood on the banks of the Delaware River and shot a gun up into the air so that gun shot came raining down onto the water, even when boaters were boating by, you’d be stopped and probably fined. If that is the case then why is it that the Philadelphia Gun Club can do that very same act, a whole gun club not just one person, and shoot their gun up into the air so gun shot rains out over and into the river, polluting the river and putting in jeopardy anyone boating by, with no permit and no repercussions? 

A curtain the Philadelphia Gun Club has hung to hide their actions on the site does not protect river users from the rain of gun shot, and does nothing with regards to the gun shot from the club’s shooters that stand and shoot openly from the banks of the river. Check out this video to see for yourself: http://youtu.be/W76vm4vTcr0 

Up to 12 times a year the gun club shoots out over the Delaware River. Boaters in open topped boats with no face, eye, neck or body protection power through the area at their own risk of getting pelted in the face or body with the falling shot, shot so dangerous it cut the skin of a person sitting still in a kayak when hit - could you imagine the harm to a person traveling at a high rate of speed on a motor boat who happened to run into a rain of shot? 

We have witnessed power boats travelling with the driver exposed and powering through the area right by the gun club during the time of a shoot. We at the Delaware Riverkeeper Network don’t understand how this dangerous situation can be allowed to continue. And as the boat season lengthens with the warmer winters we are seeing more and more boaters go by when the club does its shoots during the months of November through March. 

We have asked the Pennsylvania Department of Environmental Protection to act on the pollution that is raining into the water, and the Coast Guard to address the safety issue these shoots create – so far neither have acted. (To learn more about Delaware Riverkeeper Network legal actions on the matter:  http://www.delawareriverkeeper.org/river-action/litigation-item.aspx?Id=12)  

Now it is also time for our politicians to get involved.  To sign a statement of concern that can be used to help convince our legislators to take a stand on this issue go to our action alert at:  http://www.delawareriverkeeper.org/act-now/urgent-details.aspx?Id=135