I hope you are all doing well.
I just wanted to provide a detailed update on what is happening with our license renewal for this year.
In November 2020 Fort Devens mailed us the proposed 2021 Range Use License (Contract). For the first time ever Fort Devens refused to waive its range use fees for our Club. They want to charge us $250
per range outing the same way they are charging all the law enforcement agencies using ranges there. The law enforcement agencies can pass those costs onto taxpayers. We can't. Our dues payments for 2020 totaled $1100. (The majority of that is used to cover our insurance policy)
After some prying, by email, the new civilian Deputy to the Commander sent us the attached 19 June 2020 MEMORANDUM from former SECDEF Esper concerning range fee waivers.
The general idea is that the DOD feels it has been subsidizing costs associated with operating ranges being used for civilian/LEO use for too long, and they want to start making sure that usage fees are applied to cover their ACTUAL costs of range operation by non-DOD organizations. This isn't specific to Fort Devens, it applies to ALL DOD facilities.
We do not feel it is unreasonable to be asked to pay for the ACTUAL costs incurred in the spirit of the referenced DOD memo, however,
$250 Per Use is more than our membership can reasonably bear. We also find that amount to be arbitrary, and exceedingly unreasonable considering the following....
First, Fort Devens supplies us nothing except a little electricity to run the powered ranges we get once in a while. The powered target carriers on GOLF have been in total disrepair for at least the past 3 years. They do not supply our targets, equipment nor do they supply personnel to control the ranges or provide safety briefings.
Second, our Club, a CMP affiliate, is supposed to be protected by 36 U.S. Code Section 40727-
https://www.govinfo.gov/app/search/{"query":"36 U.S.C. 40727","offset":0}
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Official Publications from the U.S. Government Publishing Office.
www.govinfo.gov |
Jim submitted the attached FIOA request to the garrison command a couple of weeks ago. We wish to have them disclose what the ACTUAL costs to the garrison are for our use. (He also copied the FIOA request to the Army Installation Management Command HQ at Fort Sam Houston.)
UNOFFICIAL communications have indicated a willingness to work with us on determining fair usage fees, but OFFICIAL communications have been silent for over six weeks now.
Ten years ago, under its former President Orest Michaels and Congressional Liaison J.B. Hudson, the CMP came to our rescue. They are both retired now and CMP, under its current leadership does not appear to be willing to assist us in this matter.
Jim has been in contact with NRA's chief litigation lawyer. He's not been very helpful either, probably since NRA just filed for bankruptcy.
We have also had cursory communications with GOAL. (I'll update if anything comes of that)
By law, we are supposed to receive a response to the FIOA request within the next 2 weeks. I'll keep you posted as we get more information. Unfortunately, the wheels of bureaucracy are incredibly slow.
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