The Health Risks of Shooting Ranges and Lead to Children, Families, and the Environment
Appendix A: Financing the Strategy
A Tax-Funded Coordinating Mechanism
Having developed its long-range survival strategy of building more shooting ranges to attract new shooters, the gun industry faced a threshold problem: How to pay for it?
Jody L. Williams, a member of the Utah Wildlife Board, told a national shooting range symposium in 1993 that "budgetary and political realities make development of new ranges today much more difficult."153 Since the gun industry either could not, or would not, put up the money itself to build more ranges, it needed financing from somewhere else. To overcome what Williams described as a "budgetary crisis" and subsidize its strategy, the gun industry turned to federal and state tax revenues and the use of other public resources.
Through the NSSF, the NRA, and a variety of compliant organizations like the International Association of Fish and Wildlife Agencies, the firearms industry is using federal tax dollars and other public resources both to (1) coordinate and promote the range-building strategy in general and (2) directly fund the building and operation of shooting ranges. Tax dollars the industry uses for these purposes include Pittman-Robertson federal excise tax receipts and other funds from the federal government, state recreation funds and licensing fees, and various forms of direct and indirect material and logistical support from government agencies at all levels.
Added together, these government programs amount to billions of dollars of federal tax subsidies supporting the gun industry's desperate strategy to stay alive.
Since at least 1990, federal tax dollars have underwritten the creation and operation of a centralized command and control structure through which the industry has coordinated and promoted its shooting range strategy. These tax-funded activities include encouraging political action to overcome citizen resistance to new ranges and seeking money to build them.
The heart of this gun industry structure is a series of "national shooting range symposiums." Held every three years since 1990, these symposiums have been paid for largely with federal tax dollars funneled through the U.S. Department of Interior's Fish & Wildlife Service. The Violence Policy Center's investigation of these symposiums reveals an unusual degree of self-dealing, apparent conflict of interest, and industry-hand-in-government-pocket operation.
The Violence Policy Center traced the genesis and growth of this federally funded mechanism for implementing the industry's shooting range strategy primarily through documents obtained through the Freedom of Information Act. The VPC's original interest was to review the record of the discussion of substantive issues regarding firing ranges at the symposiums. But examination of the records documenting the series of federal grants given to fund the symposiums raised troubling questions about conflict of interest, self-dealing, and proper disposition of surplus funds generated through the symposiums.
The process of self-dealing. The first issue these documents raise is a pattern of self-dealing among a handful of gun industry-related organizations.
The genesis of the symposium idea can first be traced to a discussion in 1988 among the members of a group of organizations calling itself the Hunter Education Council.154
Key members of the Hunter Education Council (the Council) were:
The self-serving actions that these Council members subsequently took demonstrate how the gun industry and government at every level are thoroughly interlocked.
The Council agreed that a national symposium on shooting ranges would be "beneficial" to those "interested in shooting sports facilities," and the International Association of Fish and Wildlife Agencies (the International Association) volunteered to "coordinate the planning of a National Shooting Range Symposium."156
The International Association convened a January 1989 summit meeting on shooting ranges in Washington, DC. This summit was attended by representatives of the International Association, the National Rifle Association, the U.S. Fish & Wildlife Service, the Wildlife Management Institute, and the Hunter Education Association. The agenda of that meeting included "how to further expand shooting ranges to maximize the use of available federal funds."157 The outcome of the meeting included an agreement to "develop alternative ways to hold meetings to focus attention on the development and use of shooting ranges."158
The NRA was working on a parallel track. The agenda for a January 13, 1990, meeting at NRA headquarters of the organization's Hunting and Wildlife Conservation Committee—transmitted by memo dated December 21, 1989—included a "range symposium update" by NRA staff.159
The International Association did not have to look far to "develop ways to hold meetings." The U.S. Fish & Wildlife Service, a member of the Council that originated the idea, also just happened to administer a multi-million dollar pot of federal tax dollars. Although it is not clear exactly when application was made, the International Association applied to fellow Council member U.S. Fish & Wildlife Service for a federal grant to fund the first national shooting range symposium.
Not surprisingly—given the evidence of the cozy development of the idea—the first grant awarding federal tax dollars was signed on June 26, 1990. Thus the loop of self-dealing among the members of the Council was closed.
Although the International Association fronted as sponsor for the symposium, the gun industry and the NRA were operating behind the scenes: the NSSF (the gun industry trade group) provided a "bridge loan" of $15,000, which was repaid to it after the federal grant was awarded, and a donation of $10,000. The NRA also donated $10,000. The federal government put up $44,813.66 in tax dollars.160
Two other symposiums have been held since, in 1993 and 1996. Federal tax dollars have paid for about 75 percent of the costs of the meetings.161 The costs have also dramatically escalated: the symposium's organizers were awarded a grant of $105,000 for the 1993 symposium162 and $174,580 for the 1996 symposium.163
Incredibly, the Fish & Wildlife Service even approved a $24,500 increase to the original $150,000 1996 symposium contract, based in part on this fact: "With budgets in public and private sectors being slashed, the amount of steering committee and speaker travel costs that the symposium will cover have increased sharply." The increase also helped pay for a "Shoot ‘N Feed" banquet and entertainment for delegates at a Florida shooting range.164
In sum, gun industry leaders (1) saw the need for an ongoing series of meetings to coordinate and implement their shooting-range strategy, (2) met with federal government officials in conveniently interlocked forums, (3) came up with the idea of tax-funded symposiums to meet that need, and (4) got the U.S. Fish & Wildlife Service to pay for the symposiums with federal tax dollars.
Some troubling administrative questions. An obvious question arises whether a certain conflict of interest does not reside in a federal agency that both generates and funds programs to benefit a given industry.
This potential conflict is crystallized in a question noted by Fish & Wildlife Service official Eugene Stephenson on an undated "Project Review Summary" form obtained under the FOIA. Scoring the proposal for the 1993 symposium on the form, Stephenson noted: "Does not meet criteria—costs could be absorbed in registration fee."165 The question is a good one—why shouldn't the industry pay its own way through registration fees? Although, in fact, some fees apparently were charged at the symposiums, the federal government nevertheless ended up footing most of the bill. This is in spite of the fact that an International Association official reported that "attendance may burst at the seams at 400 people" at the 1996 symposium.166
Other troubling questions lurk in the details of this tax-funded gun industry subsidy program.
Proper disposition of surpluses or profits. One such question is how the federal government and the symposium's sponsors should deal with "surpluses," which one might call profits, that the symposiums have generated. Should these surpluses remain in the hands of the grantees, or should they (or a portion of them) be returned to the taxpayers?
For example, as noted above, the organizers of the 1990 symposium received a federal grant totaling almost $45,000. Yet the organizers netted a surplus of $28,697.37 after all receipts and expenses were accounted for.167 It is not clear how that surplus was disposed of. However, the 1993 symposium "carried over" $10,500, which was subsequently counted as income for the 1996 symposium.168 Since the 1996 budget also showed only $10,000 in contributions from "sponsors," it appears that the "carryovers" have in effect been used in lieu of the "seed money" and "bridge loan" that the industry put up for the first symposium.
It is not clear whether a surplus was "carried over" from the 1996 symposium to help fund another planned symposium.
Proper use of "administrative" funds. Although the federal tax-funded grant for each of the three symposiums has been approved individually, it was clear that the 1989 summit envisioned a series of such meetings. In fact, industry leaders describe the symposiums as being on a regular three-year schedule, and appear to regard the federal funding approval process as a mere pro forma exercise.169 For example, in a letter to the Fish & Wildlife Service attaching a final invoice for federal tax dollars for the 1996 summit, Don McLaughlin, international resource director for the International Association of Fish and Wildlife Agencies, noted a planned meeting to "make sure the lessons learned from this experience are well documented so that they will be of use for the next symposium.170"
This raises a question about the propriety of the federal grants, which are from "Federal Aid Administrative Funds." A memorandum in Fish & Wildlife Service files from the acting director of its "Region 5" notes with respect to another proposal: "Administrative funds should be considered ‘seed' money to get projects started, not fund them indefinitely."171 It is interesting that the same source questions the "appropriateness of inviting staff from other Service programs to be involved in eligibility determination" as it is a "departure from policy and creates the potential for conflict of interest."172
These symposiums are invaluable tools for implementing the industry's range-building strategy. They bring range operators, representatives of the gun industry, state and federal government, hunting and wildlife groups, and the National Rifle Association together to share strategies and "brainstorm" plans to build more ranges and defeat opponents of those ranges.
The notion of "sides" in a global conflict. The symposium proceedings also reveal an "us" against "them" tone. For example, John Powell, the chairman of the Missouri Conservation Commission, sounded a tone of decidedly global conflict over shooting ranges and all that they represent in his welcoming address at the first symposium. Powell drew the following contrast between the two notional "sides" he saw contending over the question of shooting ranges:
Political issues. Some might also question whether it is appropriate for federal tax money to underwrite forums where speakers urge those who attend: "Get involved in politics," in the words of Robert N. Pemberton, Sr., administrator of the NRA's range conference program (speaking at the second symposium).174
"The ultimate control of shooting range activities will be political," Gary L. Anderson, the NRA's executive director for general operations, told the 1990 symposium in a talk titled "The Socio-Political Climate for Ranges."175 Anderson told participants that "political decision-makers will decide whether or which guns can be owned for use on ranges, whether or where a range can be built and how it can be operated."
He also spoke directly in favor of political lobbying at this tax-funded meeting:
Conley L. Moffett, a federal bureaucrat in the U.S. Fish & Wildlife Service, did a little lobbying of his own, explicitly criticizing proposed legislation pending before Congress during the second symposium in 1993, describing it as a "raid" on wildlife funds that his agency administers. That proposal (S. 868 and H.R. 2276) would have redirected Pittman-Robertson funds to hospitals and trauma units to help pay for the medical costs of treating gunshot victims. "No good will be accomplished by victimizing one of the cornerstones of wildlife conservation in this country—the P-R funds," Moffett complained, attending and speaking on federal taxpayers' time and dollars.
In summary, the
national shooting range symposiums are nothing less than a command and
control mechanism for the gun industry's shooting range survival strategy
underwritten by federal tax dollars.177
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All contents © 2001 Violence Policy Center
The Violence Policy Center is a national non-profit educational foundation that conducts research on violence in America and works to develop violence-reduction policies and proposals. The Center examines the role of firearms in America, conducts research on firearms violence, and explores new ways to decrease firearm-related death and injury.