Dear County Commissioners,

On behalf of the Deercroft Community, we are following up with you to reiterate our concerns regarding the proposed zoning ordinance amendment related to combat and tactical training facilities that you again will consider at the October 5 meeting of the Scotland County Board of Commissioners. Members of the Deercroft Community expect you, our elected County Commissioners, not to take any action that decreases the property values in Scotland County.

We are well aware that this issue is much broader than the Deercroft Community, and by no means are our concerns limited to the parcel of land near Camp Mackall owned by DGCI. Any proposed zoning ordinance amendment clearly will have far-reaching and long-lasting implications for ALL Scotland County property owners. We believe the proposed amendment—the latest version you have made public—will have an adverse impact on our quality of life, environment, and property values. Indeed, we believe it will make it easier for such training facilities to locate in Scotland County, and it has the potential to make our County a magnet for such operations.

We fully support the U.S. military. Our opposition to the proposed amendment clearly is not an anti-military position. Numerous Deercroft Community residents are military veterans. We regard the noises related to nearby Camp Mackall as “the sounds of freedom.” The U.S. military is not seeking the proposed zoning ordinance amendment. Instead, out-of-state, for-profit, independent contractors want to re-zone land in our County so they can operate combat and tactical training facilities. Further, the proposed amendment does not limit the use of such facilities to the U.S. military. Per the proposed amendment, these facilities are allowed to train “law enforcement; military; federal, State, or local agencies; and private organizations’ personnel.”

We understand the differences between tactical training and combat training, as defined by the County in the proposed zoning amendment. We have no misconceptions about what the operation of such facilities entails. We have watched numerous videos (e.g., Gryphon Group, Robin Sage). The primary distinction is that tactical training does not use live fire and lethal explosives, while combat training may use both. Obviously, safety is more of an issue with live fire, but similar noise levels are generated by both types of training. There is a common myth that blank ammunition and/or grenade simulator devices produce less noise than live munitions. Anyone who has served in the military and/or is familiar with firearms is aware that blank ammunition can be louder than live ammunition due to the device needed to make the weapon’s mechanism work properly. For this reason, requirements for noise abatement for both types of training should be strict and should be the same (e.g., buffers, prohibited hours, prohibited over weekends and holidays).

For tactical training facilities to be allowed “by right” in four of the five nonresidential zoning districts is a major concern. These land parcels may be adjacent to, or geographically near, residences and residential zones. The commonly understood usage of the term “by right” is that when a proposed land use is defined as allowable within a particular zoning district and meets the district standards and requirements, then all that is required is a payment of a fee, and a permit is issued without any further review by any government board. We interpret this to mean that no public hearing would be required before a tactical training facility would be allowed adjacent to, or in close proximity to, residential zoning districts (i.e., private homes).

We continue to be concerned about how zoning ordinance requirements will be monitored for compliance and enforcement. Self-certification by facility operators, as would be allowed in the proposed amendment, is fallible, subject to falsification, and totally unreliable as a means of effective enforcement and compliance. Further, compliance should not be complaint-driven to trigger enforcement by the County, as this approach historically has proven to be inadequate. As an example of this point, numerous times within the last several months, Deercroft residents have asked for County enforcement relief for a clear violation of R1 zoning restrictions: an Airbnb business is being operated in our R1 community. To date, other than initial agreement that this is a clear violation, there has been no official action from the County to enforce its own existing Zoning Ordinance with regard to the R1 Residential Single Family zoning district.

In the Deercroft Community’s petition in opposition to the proposed amendment and in numerous other communications we have had with you, we have suggested, at a minimum, the following critical revisions to any proposed zoning ordinance amendment:

—Retain Section 16.4 of the existing ordinance that deals with buffers.

—Limit both tactical and combat facilities to areas designated as Heavy Industrial.

——Require a Conditional Use Permit for both types of facilities.

Specify valid means by which the County can ensure that compliance is enforceable and enforced.

You were elected to look out for the best interests of County citizens. We urge you to ensure that any changes to existing ordinances are defensible and justified on the basis of clearly defined benefits to the County and its citizens.

We trust that you will keep our serious concerns in mind as you consider your actions at the October 5 meeting. We will be closely watching the video of that meeting.

Gerri Stanton, President, Deercroft Homeowners Association

Sara Coble Simmons, Ph.D., Vice President, Deercroft Homeowners Association