March 28, 2005

To Whom It May Concern:

Based in Cashiers, North Carolina, the Smoke Rise Field Club, Inc. was formed in 1987
and, until recently, operated a skeet shooting range on land leased from the Carlton
family interests in Jackson County. According to club officer James H. Reynolds, in a
March 7, 2005 letter to the Jackson County Board of Commissioners, “We leased land
from the Carlton family at the same location just off Breedlove Road near Cashiers for
about 18 years and have utilized lead shotgun ammunition there continuously for that
period carefully avoiding wetlands and streams." Breedlove Road provides the primary
access to the nearby Panthertown Valley section of the Nantahala National Forest.

It is our understanding that the assessment and cleanup of abandoned outdoor shooting
ranges is regulated under the federal Resource Conservation and Recovery Act (RCRA)
and the federal Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA), and that excessive lead levels have been found in other skeet ranges
operated by similarly sized clubs over similar periods of time. Perhaps the best known
example of this is the Lexington Manor housing development in Liberty Township, Ohio,
which was declared a Superfund site in 2003.
http://www.enquirer.com/editions/2003/05/09/loc_libertylead09.html

It is also our understanding that the North Carolina Department of Environment and
Natural Resources, Division of Waste Management (DWM) has the primary
responsibility for enforcing the applicable federal regulations in these situations, and that
DWM sent notices to gun clubs within the past several years, instructing them that upon
closure of any range, the club should contact DWM for assessment of the closed range.
http://wastenot.enr.state.nc.us/

The North Carolina Division of Waste Management has issued guidelines for the
assessment and cleanup of inactive hazardous waste sites, such as abandoned skeet
shooting ranges.
http://www.wastenotnc.org/sfhome/stateleadguidance.pdf

In addition to the duration and volume of activity, aggravating factors at the old Smoke
Rise range are the presumed acidity levels of the soil, acid precipitation and the potential
for water contamination due to the proximity of the range to surface water bodies. Also,
due to the relatively rapid rate of construction and development in the area, there is
concern that excavation and dispersal of soil from the range may occur prior to a proper
review and remediation of the old site. And the possibility of toxicity to birds as a result
of direct ingestion of lead pellets is an ongoing concern.

The club’s lease on the Carlton property was terminated at some point within the past
several years and the club has been seeking a new location to establish a skeet shooting
range for its more than 100 members. A Cashiers area homeowner residing about one-
half mile from the old Smoke Rise location has observed the cessation of shooting by the
club, and reports that she and her neighbors were rejoicing upon the club’s departure.
Concurrent with the termination of shooting range activities on the old Smoke Rise
location, has been the negotiation and sale of portions of neighboring Carlton land to a
housing development company, Trillium Links & Village, LLC. On March 18, 2005, the
Carltons sold a 162.5 acre portion of a neighboring 1445 acre tract to Trillium for
approximately $8,000,000. The parcel number for the parent tract of 1445 acres is 7584-
42-5244 (may be changed to 7584-42-5245) and the parcel number for the acreage
purchased by Trillium is 7584-40-1129.

Access to the tract purchased by Trillium can be gained at approximately 1.5 miles after
turning onto Breedlove Road (State Road 1121), on the left side of the road, shortly after
going past the small lake located at the head of Logan Creek. As of March 25, 2005, it
appeared that at least one access road to the Trillium property has been excavated within
the past month.

Access to the former Smoke Rise range is found approximately 2.5 miles after turning
onto Breedlove Road (State Road 1121), on the left side of the road at a gated drive and
rustic fence. This tract of 391 acres (parcel number 7584-93-2515) is titled to Carleton T.
Clark, Trustee, who is a party to the Carlton Family interests. Signs near the old range
indicate that inquiries should be directed to Pat Carlton, P. O. Box 185, Cashiers, NC,
28717.

Here is the contact information for Smoke Rise Field Club:

Smoke Rise Field Club, Inc. (EIN 58-1774737)

PO Box 1791

Cashiers, NC 28717

Current Smoke Rise President:

Barry Moore

315 Angle Ridge Road

Sapphire, NC 28774

828-743-4095

Current Treasurer

James H. Reynolds

PO Box 1054

Dillsboro, NC 28725
828-497-2994, 828-506-6155 (cell)

The following resources available online provide a wealth of information on this subject.
http://www.epa.gov/region02/waste/leadshot/
EPA manual, Best Management Practices for Lead at Outdoor Shooting Ranges

http://www.epa.gov/superfund/programs/lead/products/firing.pdf
EPA document, TRW Recommendations for Performing Human Health Risk Analysis on
Small Arms Shooting Ranges

http://www.nps.gov/renew/rangewastemgt.pdf
National Park Service recommendations on firing range waste management

http://www.rangeinfo.org/resource_library/NSRS/04PolicyTrack/TestingRange.pdf
Report from Fourth National Shooting Range Symposium on Testing Your Outdoor
Range – Using the Right Tools, describing the technical details of the appropriate
environment testing procedures to evaluate ranges

http://www.solucorpltd.com/article3.htm
Article from Soil and Groundwater Cleanup journal describing the remediation of
contaminated soil at an abandoned skeet shooting range.

Thank you for your assistance in protecting the citizens of North Carolina from a
potentially harmful situation at the abandoned Smoke Rise Field Club skeet shooting
range.

Sincerely,
Concerned Jackson County Citizens