To: Warren County Zoning Commission & Board of Supervisors
From: Property owners and residents of surrounding farmland
Re: Opposition to rezoning from A-1 Agricultural to C-2 Commercial for New Pioneer Gun Club (“NPGC”)

We respectfully oppose the rezoning of the above parcels for the following reasons:

1. Agricultural Preservation & Spot-Zoning Precedent

• Iowa Code § 335.5 mandates that zoning decisions must support the county’s comprehensive plan and preserve agricultural land, protect soil and water, and secure public health and welfare. Rezoning this farmland to enable a shotgun range contradicts these priorities.
• Little v. Winborn (Iowa Supreme Court, 1994) addressed virtually the identical scenario: unrestricted farmland rezoned to allow a private shooting club. The court ruled this was illegal spot zoning, failing on three grounds¹:

a) Public benefit vs. private gain
The Court explained that rezoning a farm tract to enable a private shooting club primarily advanced the owner/club members’ interests, not a genuine, general public purpose. “Spot zoning” may be lawful only if the new zoning is (i) tied to a legitimate police-power objective (health, safety, welfare), (ii) has a reasonable basis to treat this tract differently, and (iii) is consistent with the comprehensive plan. In that case, Polk County failed that test; benefits were private and selective, not community-wide. The Court therefore affirmed invalidation.

b) Incompatibility with surrounding uses (farmland & rural homes)
The Court stressed use-compatibility. Inserting an intensive, noise-producing club into an agricultural block created an island use incompatible with surrounding farms and rural residences. That mismatch—traffic, noise, activity levels—was central to finding the rezoning improper.

c) Inconsistency with the county plan (agricultural preservation)
The Court emphasized counties must act “in accordance with a comprehensive plan.” Polk County’s plan prioritized agricultural preservation, and the rezoning cut against that core policy. Because it undermined ag-preservation and scattered non-ag use into farm country, it failed the plan-consistency prong and was struck down.

• “Under Little v. Winborn, spot zoning fails where (1) the claimed ‘public benefit’ is essentially private club gain, (2) the use is incompatible with surrounding ag and rural homes, and (3) the rezoning undermines the county’s ag-preservation plan.”
• This current proposal goes even further: it envisions tournaments, banquet events, and retail—exponentially amplifying the issues identified in Little v. Winborn.

 
2. Noise, Quality of Life, and Wildlife Disruption

• Loudness at the source (shotguns) & why impulse noise is worse: Federal occupational research shows 12-gauge shotguns produce peak levels ~155–170+ dB at/near the muzzle; Impulse noise has a greater hazard and disturbance effect than steady noise².
• How far can you hear it? Propagation depends on terrain, wind, humidity, and ground cover, but in open rural settings gunshots are commonly audible out to ~1 mile (1,600 m) and more under down-wind conditions³.
• Wildlife disturbance (deer & game species): Peer-reviewed research and federal syntheses show mammals (including ungulates like deer) exhibit heightened flight/vigilance and habitat displacement in response to human and impulse noises. Recent Forest Service-linked work shows wildlife were 4–5× more likely to flee and remained vigilant ~3× longer after recreation noise exposure; meta-reviews of ungulates confirm strong flight responses to anthropogenic noise/disturbance, modulated by cover, season, and time of day. Experimental studies on deer show space-use shifts and avoidance in response to acute noise⁴. These effects are stronger with unpredictable, high-amplitude impulses (gunfire) than with steady noise. This undercuts the claim that “deer get used to shotgun noise”—especially when paired with cars, people, lighting, loudspeakers, and large crowds typical of collegiate/tournament events. Additionally, the perception of deer maintaining a sense of calm at the current New Pioneer Gun Club location does not account for the fact that these deer are quite accustomed to human presence as they already dwell in a suburban environment.
• Even modest recreation noise increases flight and vigilance; impulsive gunfire with crowds, PA systems, vehicle caravans, and lights is the worst-case recipe for displacement of deer from core bedding/forage zones—the exact opposite of quality deer management which many of the surrounding farmers, bowhunters, and landowners have worked hard to achieve. The argument that “deer get used to it” is not supported by science⁴.

3. Environmental & Public Health Hazard — Lead & “periodic reclamation”

• Iowa’s own proof: Nahant Marsh (Davenport) EPA and USFWS documented ~243 tons of lead shot deposited over ~70 acres; waterfowl lead poisoning confirmed by necropsy; EPA executed a time-critical removal and sediment excavation/stabilization—multi-million-dollar action⁵.
• EPA BMPs: “reduce risk,” not “risk eliminated” EPA’s Best Management Practices for Lead at Outdoor Shooting Ranges (manual + EPA page) explain legal obligations: stormwater control, dust suppression, baseline & periodic media sampling, documentation of recycling to stay outside RCRA hazardous-waste status, and ongoing monitoring. BMPs emphasize that lead persists; “reclamation” is periodic mining of deposited contamination, not prevention. Gaps, storms, and operational lapses let lead migrate to ponds/streams and bioaccumulate in birds and other fauna⁶.
• Additional national documentation (beyond Nahant) Scientific reviews synthesize soil contamination and health/ecological impacts at outdoor ranges nationwide (Lead elevated in soils/sediments; pathways to humans/wildlife well-documented). State wildlife agencies and USFWS materials further explain why lead shot for waterfowl was banned in 1991—because ingested pellets kill waterfowl and harm raptors/scavengers⁷.
• Even if NPGC promises 1–5-year reclamation, (i) thousands to millions of pellets remain in between cycles, (ii) storms and overland flow move fragments and dissolved lead, (iii) reclamation itself generates lead dust and handling risks without strict protocols, and (iv) the County inherits post-closure risk if the operator ever falters. In farm country with ponds and drainages, this is a classic recipe for off-site migration—which is exactly what Iowa already lived through at Nahant Marsh⁵.

4. Property Value Impacts & Rural Lifestyle

Noise & peace of the countryside

• Shotgun peaks ~155–170+ dB at the muzzle; impulse noise is more disturbing and hazardous than steady noise². Outdoors, with little shielding, audibility can approach ~1 mile under calm/downwind conditions³; the startle factor and frequency of shots in competition settings make this uniquely intrusive.
• Daily operation (365 days, 7 a.m.–dark, lights after dark) means predictable loss of quiet. For families, livestock, pets, and hunters managing core buck bedding and travel corridors of Iowa’s beloved whitetail, this is continuous displacement pressure, not a “twice-a-year event”. Forest Service–linked work shows wildlife flee 4–5× more often and remain vigilant ~3× longer under recreation noise; ungulate meta-reviews confirm flight/avoidance responses⁴.

Hunting & Quality Deer Management (QDM)

• Deer alter space use, movement timing, and habitat selection under acute anthropogenic noise; studies document avoidance behaviors and activity shifts⁴. For bowhunters managing daytime movement and bedding security, sustained impulse noise plus human presence/cars/PA systems and night lighting degrade the very conditions QDM relies on.

Property values

• Generational impact on farmers and landowners: Many farmers in this area are approaching retirement age and, after decades of investment in their land, will inevitably look to sell or transition their property. The value of that land is not just economic—it is the culmination of a lifetime of labor. The imposition of a commercial shotgun complex in the immediate vicinity threatens to artificially depress those values, stripping equity from retiring farmers who have counted on their land as their retirement security.

• Barrier for young families and new residents: At the same time, younger families who are considering building homes in this rural community will face a very different reality. Instead of the peaceful countryside they sought, they would be asked to invest in land overshadowed by daily gunfire, night lighting, congestion, and the stigma of adjacency to a range. Over time, fewer families will see this as a place to settle, which means less rural investment and a gradual erosion of the community’s strength.

• Market stigma and resale concerns: Real estate is fundamentally driven by buyer perception. Even if some individuals claim not to mind gunfire, the broader buyer pool does. Realtors consistently flag shooting ranges as negative externalities, and homes near them sell for less or take longer to sell. A national Realtor.com analysis found that proximity to shooting ranges reduces home values by an average of **3.7%**⁸. This is not speculative—it is recorded in both national market data and county tax rolls.

• Cumulative community harm: Lower property values affect more than individual families—they reduce tax revenues, diminish neighborhood stability, and discourage investment. In areas like this, where farmers are planning retirement and younger families represent the next generation of rural stewardship, the consequences are profound. This proposal shifts wealth out of the hands of long-standing community members and places a burden on future families, draining the equity our community has built over generations while destroying the quiet, safe, and healthy environment that makes rural life worth living.

Traffic, lights, and “urbanization” of farm country

• NPGC’s plan ~240 parking spaces, 24-ft access road, banquet/retail, collegiate tournaments, and night lighting are urban-scale features. That is textbook C-2 highway-commercial intensity imposed inside an A-1 agricultural block—“a commercial event center plus range.”
• Incompatibility + plan conflict = illegal spot zoning.

 
5. This Is Not a General Public Benefit

a) Not a municipal/open-access amenity
This is a membership-based social club with a clubhouse, retail, tournaments, and private events. That is qualitatively different from a park/open-space asset. Little v. Winborn held that a club’s benefits are selective and private, not a broad police-power objective—especially when the costs are externalized to neighboring farms and homes¹.

b) Youth and conservation outreach while commendable does not equal plan conistency
The Court made clear that plan consistency and ag preservation govern. Even respectable programs cannot outweigh location/compatibility and plan conflict¹.

c) Other governmental records recognizing conflicts
Local governments that studied outdoor ranges often flag property value risks, noise, and environmental liabilities in rural contexts (example: Loudoun County, VA—planning memo noting adjacent-parcel value impacts and range-immunity constraints). These show planners nationally recognize negative externalities from outdoor ranges near homes/farms.


In closing, this rezoning would exchange farmland preservation for commercial intrusion, sacrifice quiet rural living for relentless gunfire, and strip long-standing families of both equity and peace. Zoning law was created to prevent exactly this kind of harm. We urge the Commission and Board to deny the rezoning on legal, environmental, economic, and community grounds.