This is the full complaint that was submitted to Redmond City by community members. It contains detailed information about alleged lead pollution, safety issues, Unauthorized expansion, and noise issues.

1/21/2025

Kelley Cochran

Finance Director, City of Redmond
15670 NE 85th St, Redmond, WA 98052

Subject: Complaint Against Interlake Sporting Association (Ordinance 5.80)

Dear Director Cochran,

On behalf of many residents of the Rose Hill communities Century-Prelude, Encore, Fox Hollow, Walden Ridge and Willows Crest, I am writing to formally submit a complaint under City Ordinance 5.80, section 100, against the Interlake Sporting Association (ISA), located at 13633 NE 97th St, Redmond, WA 98052.

ISA appears to have committed several violations of its operating license as outlined in Shooting Sports Facilities Ordinance 5.80. These violations raise significant concerns regarding compliance with the regulatory framework established to ensure proper land use requirements, public safety, environmental protection and community well-being.

In addition, the community has raised several other concerns about ISA’s operations. These can be found in the section below entitled “Additional Community Concerns” and highlight broader issues around safety, lead contamination and increasing noise that negatively impact the community and extend beyond ISA’s compliance and emphasize the need for a complete re-evaluation of city ordinance 5.80.

Suspected Violations of Ordinance 5.80

Unauthorized New Ranges

Applicable Ordinances:

RMC 5.80.065(1):

"New shooting types and new ranges for existing shooting types shall not be permitted until authorized by an amended license."

RMC 5.80.065(2):

"The application for a license amendment shall be made on a form prescribed by the administrator and shall include only information relevant to the amendment."

RMC 5.80.030(7):

"The shooting sports facility operating license issued under this chapter shall authorize only those shooting types that have been specifically applied for and that are identified in the license. The addition of new shooting types or the addition of a new range or ranges for existing shooting types at a shooting sports facility shall require amendment of the existing license before any such new shooting type is allowed."

RMC 5.80.080(9):

"Shooting sports facilities shall be used for the shooting activities they were designed to accommodate unless redesigned to safely accommodate new shooting activities."

Violation Details:

ISA appears to have constructed at least two new ranges—the North Pistol Range and the Steel Target Range—without filing for or obtaining an amended license as required in 5.80.
These expansions and changes in use represent an expansion of a nonconforming land use. Grandfathering of a nonconforming land use does not give ISA the right to expand use beyond that which was grandfathered. (See Appendix: Legal Precedents and Case Law).
Historical versions of Google Earth imagery show changes to the facility’s layout corresponding to the construction of these new ranges, including the clearing of land and removal of trees, apparently without proper permits (see Appendix: Maps and Visual Evidence).

Impacts on Community:

The new ranges are located very close to residential homes, resulting in significantly increased noise levels for nearby residents and additional safety concerns.
Residents surrounding ISA, many of whom lived there before these expansions, have pre-existing rights to be protected from the increase in noise levels and potential safety issues created by the addition of these new ranges.
In June of 2020, there was a documented incident of a bullet hitting a home in the Century-Prelude development bordering ISA property. The resident suspected it came from the new North Pistol Range which is 35-40 yards from the home as stated by RPD officer Colin Davies (see Appendix: Safety Documentation - RPD Report 20-011174)
The use of these unauthorized ranges has expanded the facility’s lead contamination footprint by introducing lead contamination into new areas of the property, compounding the existing lead contamination issues at ISA. (See Appendix: Environment)

Legal precedent and applicable case law:

As found in Rhod-A-Zalea v. Snohomish County and other similar cases in Washington State, "a protected nonconforming status generally grants the right to continue the existing use but will not grant the right to significantly change, alter, extend, or enlarge the existing use."
Kitsap County in their legal action against Kitsap Rifle & Revolver Club, filed suit against the Club, alleging that the Club “had impermissibly expanded its nonconforming use as a shooting range, engaged in unlawful development activities, and conducted activities that constituted a noise and public safety nuisance.”
The court ruled in favor of Kitsap County, stating that: 1) The Club's activities constituted an unlawful expansion of the existing nonconforming use. 2) The Club's use of the property was illegal because it had failed to obtain required permits for the development work. 3) The Club's expanded activities constituted a nuisance because of noise and safety issues.
Kitsap county invoked Washington State RCW 9.41.300(3)(a) as justification for their actions. The RCW states that “Cities, towns, counties, and other municipalities may enact laws and ordinances restricting the discharge of firearms in any portion of their respective jurisdictions where there is a reasonable likelihood that humans, domestic animals, or property will be jeopardized.” (See Appendix: Legal Precedents and Case Law).

2. Introduction of nighttime shooting (shooting in darkness)

Applicable Ordinances:

RMC 5.80.030(7), RMC 5.80.065(1), (2), RMC 5.80.080(9) (previously stated above)

Violation Details:

ISA extended its operating hours to allow shooting during total darkness, changing the closure time from '8 PM or dusk, whichever comes first' to a fixed 8PM, every day of the year
Shooting in complete darkness is unprecedented at ISA and apparently enabled by night vision equipment, constituting a new shooting type not specified in its original operating license.
These expansions appear to have been completed without a design/safety review, public input/oversight and adherence to the license amendment requirements of Ord 5.8.0.
These changes represent an expansion of a nonconforming land use and an increase in activities that constitute a nuisance due to increased noise in total darkness.

Impacts on Community:

This expansion in activities is inconsistent with the facility’s historical operations and poses possible new safety risks to the surrounding community. A 3rd party design review is needed.
These nighttime operations significantly extend ISA’s operating hours, creating additional noise and disruption in total darkness during the fall and winter months.

Introduction of steel targets without an appropriate safety review

Applicable Ordinances:

RMC 5.80.030(7), RMC 5.80.065(1),(2), RMC 5.80.080(9) (all previously stated above)
RMC 5.80.080(21):

"The use of steel targets at a shooting sports facility is permitted when the design, composition and placement of such targets will prevent the escape from the facility of bounced or secondary projectiles."

Violation Detail:

ISA reintroduced steel target shooting, apparently without accredited expert verification of safe design, composition, and placement of these metal targets.
To our knowledge, there is no evidence that ISA’s steel target range has been reviewed, inspected or verified for compliance and safety, by an accredited expert with certifications in steel target range design.
The safe design of a steel target range is essential to ensure safe capture of ricochet rounds. The lack of an independent 3rd party accredited expert review, heightens the risk of projectiles leaving the property and jeopardizing public safety.
Steel targets had been banned in the previous City of Redmond Ordinance 2120 due to suspected bullet ricochets leaving the range referenced in ISA’s shutdowns in 1999 and 2000 (See Appendix: Safety Documentation).

Impacts on Community:

In addition to safety concerns, the reintroduction of steel targets has significantly increased noise levels, adding a distinct “clang” to the sound of gunfire which now reverberates throughout the area. Communities established before this change should not have to endure this intensified disruption and deserve protection from these new intrusive impacts.

4. Failure to maintain required perimeter fencing and signage

Applicable Ordinances:

RMC 5.80.080(A)(19):

"All shooting sports facilities are required to have fencing surrounding the entire property a minimum of six feet in height. This does not apply to indoor ranges."

RMC 5.80.080(A)(8):

"Warning signs shall be installed and maintained along the shooting sports facility property lines. Such signs shall be posted a minimum of every 100 feet along the property lines."

Violation Details:

ISA’s perimeter fencing is in major disrepair, with multiple areas that fail to meet the requirements of ordinance 5.80 (See Appendix: Safety Documentation)
Damage to the fence and/or erosion of ground beneath the fence in several areas allows easy access to the property.
A fallen tree significantly damaged a section of the fence in the SE corner of the property. This damage occurred several years ago and has never been repaired, allowing easy access to the gun range shooting areas.
Warning signs are missing or damaged in several areas, further failing to meet safety standards.

Impacts on Community:

These gaps allow children, pets, and wildlife to easily enter the property, creating significant safety risks and liability concerns.
This again illustrates ISA’s lack of safety oversight. An independent 3rd party safety review of the entire ISA property and operations is needed.

Additional Community Concerns

Insufficient Safety Oversight Due to Weakening of Ordinance 2120 Language:

The original City of Redmond Ordinance 2120 included a requirement for a Range Master or Range Safety Officer. At the request of ISA, this requirement was repealed by Ordinance 2485 with the less stringent Person-in-Charge (PIC) designation. Under this new designation, any member of ISA can become a PIC as long as they pass an ISA provided training course and test, regardless of their prior experience or qualifications.
This approach fails to meet the standards of professional certification programs such as NRA Range Safety Officer training, which involves rigorous education and practical experience. By allowing all members to oversee safety procedures and operations, ISA significantly increases the risk of unsafe practices and accidents.
Unlike ISA, all other shooting ranges in the area have a dedicated Range Master or Range Safety Officer onsite to oversee safe operations. These individuals are NRA trained professionals responsible for ensuring safety and compliance, providing a level of oversight and accountability absent under ISA’s current system.
Redmond police Lt Tim Gately referenced this issue when reviewing ISA’s license application in 2020. Lt Gately stated that ISA should discontinue the practice of training all members as “PICs”. (See Appendix: Safety Documentation)

Lack of Third-Party Oversight in Facility Design:

Section 5.80.080(A)(9) states that shooting sports facilities must be used for the shooting activities they were designed to accommodate unless redesigned to safely accommodate new activities.
ISA has introduced new shooting types, new shooting competitions, new group training events and constructed new ranges apparently without independent third-party oversight to ensure safe design.
Without such oversight, there is no assurance that the expanded facilities meet modern safety standards or adequately contain rounds within the property.
By comparison, Kitsap County’s ordinance requires that “designs and safety procedures shall be evaluated by an NRA Range Technical Team Advisor (RTTA) or by a professional engineer with experience in shooting facilities or other qualified professional consultant with experience and expertise in the evaluation and design of shooting ranges. Qualified professional consultants must demonstrate their education, experience and expertise by identifying their certifications from nationally recognized shooting organizations that provide such certifications, the number and location of shooting facilities they have designed or evaluated and contact information for those facilities. Their home facility will not count towards this qualification.” (See Appendix: Supporting Materials - Ordinances)

Suspected Bullets Leaving ISA Property:

Since the late 1990s there have been multiple incidents of suspected ISA originated bullets leaving ISA property and endangering nearby businesses and residents. (See Appendix – Safety Documentation). The two listed below are more recent and highlight safety concerns with range design following ISA’s range expansions between 2017-2020.

On March 29, 2018, Redmond Police responded to a firearms-related incident where a complainant reported hearing a gunshot and observing a bullet splash in a nearby retention pond near Willows Road. The investigation highlighted concerns about businesses downrange from ISA and inadequate range safety features, including the lack of confirmed bullet-resistant materials in the plywood ceiling baffles. (See Appendix – Safety Documentation RPD Report 18-005641)

On June 12, 2020, a resident located at 13895 NE 97th Street reported finding a spent bullet on their concrete patio, which is directly adjacent to ISA’s property. The resident stated they heard a loud "thump" on their roof the previous evening. The bullet was later identified as a 9mm or .380 caliber round and entered into police evidence. (See Appendix – Safety Documentation RPD Report 18-001690)

These incidents underscore the urgent need for independent third-party expert inspections of ISA’s facility to verify compliance with safety standards, particularly for new or expanded ranges, and to ensure rounds are contained within the property.

Operating Hours and Community Impact:

ISA’s current operational hours are an anomaly compared to other urban shooting ranges in the area. ISA is the only shooting facility open 365 days a year from 9AM to 8PM.

This is a total of 4,015 hours annually, significantly more than facilities such as Kenmore Gun Club (2,340 hours), Issaquah Sportsman Club (1,664 hours), and Gig Harbor Sportsman Club (1,274 hours).

Unlike ISA, most urban shooting ranges in the area close by 6 or 7 PM, close at least one day a week, and observe closures on holidays. Based on our research, ISA appears to be the only range among these facilities to allow nighttime shooting with night vision equipment.

In 2017, ISA expanded its hours by moving its opening from 10AM to 9 AM. In 2023, it further extended its hours by eliminating its dusk closing, moving to a fixed 8PM closing thus enabling night shooting in fall and winter. These expansions represent significant increases in usage that should not have been allowed without proper review or amendments to their operating license.

The previous City ordinance 2120 required that "the days of the week and the hours of operation that the facility is or proposed to be open" be stated as part of the licensing process. Changes to these hours would require a new license amendment. Like several other key provisions, at the request of ISA this requirement was repealed with Ordinance 2485, eliminating this oversight mechanism and allowing operational expansions without community input or regulatory review.

While ISA is permitted to operate from 7 AM to 10 PM daily under the shooting range exemption in Redmond’s noise ordinance, the City of Redmond does have the legal right to override these hours under a revised ordinance using RCW 9.41.300 (A)(3). Kitsap County and the City of Gig Harbor’s ordinances are excellent examples of much stricter requirements regarding safety and hours of operation. (See Appendix: Supporting Materials - Legal Precedents and Case Law)

Extensive Lead Contamination:

Lead pollution from gun ranges is a very serious issue nationwide. Not only are lead bullets and pellets fired directly into the ground, but lead dust is ejected out of the barrel and chamber of every round fired, contaminating the shooter and ground in front of the shooter. Depending on the wind direction these dusts can travel great distances, landing on properties directly adjacent to ISA where children play in their backyards. Children are especially susceptible to effects of lead poisoning. (see video and documents in Appendix: Environment)

Lead contamination from gun ranges is particularly troublesome when close to wetland areas. Western Washington is acutely vulnerable due to high precipitation rates and very acidic soils. These two elements combine to extend lead contamination plumes far beyond most other soil types. ISA appears to be located on King County designated wetlands and within 1 mile of critical CARA I & CARA II Redmond aquafers used for Redmond’s drinking water supply (See Appendix: Environment).

Again, we point to the Kitsap County Ordinance which requires “Shooting facilities within five hundred yards of a shoreline, wetland or wetland buffer must orient the firing away from these areas or demonstrate how bullets are contained so that they do not enter these areas.”

Lead Contamination issues in Gun Club Creek wetlands area

Historical data going back to the late 1990’s indicate abnormally high levels of lead contamination in Gun Club Creek compared to normal background lead levels and other streams in the area.
Community members brought this issue to the attention of the City and the Department of Ecology beginning in 1997 when lead shot fired from Trap & Skeet shooting at ISA was leaving ISA property and landing on Willows Crest properties and in the Gun Club creek wetlands area.
In 1997, testing was requested and performed with sediment lead levels of 230ppm detected, just under the mandatory cleanup levels of 250ppm.
Residents requested additional testing, but the city and ecology elected not to proceed, sighting levels under the 250ppm threshold did not warrant further testing.
Residents brought this subject up again in 2010, 2015 and 2019, requesting further testing. The city deferred to ecology who again declined to perform further testing.
In 2023 and 2024, community members performed lead testing using an Ecology approved testing facility and testing protocol. This testing revealed very high levels of lead contamination.
Sediment samples taken just outside the perimeter of ISA’s property, adjacent to Gun Club Creek, show sediment concentrations as high as 1900ppm. This is over 7 times greater than the Department of Ecology's cleanup threshold of 250ppm. (See Appendix: Environment)
On January 17th, 2025, Ecology listed the Interlake Sporting Association area as a contaminated site under the Model Toxics Control Act (MTCA) which will require future cleanup.
ISA (King County parcel 0325059054) and Robert Propet, Great Market LLC (KC parcel 0325059057), have been notified of potential financial liability in the cleanup costs. The City of Redmond (Easement on the Robert Propet’s parcel) also received notice. (see Appendix)
Direct testing of ISA’s property will no doubt reveal much higher levels of contamination.

The previous City of Redmond Ordinance 2120 contained specific language regarding Lead Management: “A MANAGEMENT GUIDEBOOK SHALL BE MAINTAINED THAT INCLUDES PROCEDURES FOR OPERATIONS, MAINTENANCE, AND LEAD MANAGEMENT AND RECOVERY.” At the request of ISA, this language was repealed by Ordinance 2485 as part of the negotiation with the City of Redmond over the annexation of North Rose Hill in 2009.

By comparison, Kitsap County’s Ordinance 10.25 has a specific requirement for Shooting Facility Environmental Controls, stating “Each shooting facility operator shall develop and submit an integrated lead management program plan to reclaim lead deposited by shooting activities. This plan will be reviewed by the Kitsap public health district.”

In our research, it appears that all other urban gun ranges in the region have extensive lead management and recovery programs. (See Appendix – Safety)

Request for Action

In light of the apparent violations of Ordinance 5.80, the broader concerns raised by our community, and recently discovered serious lead contamination, we respectfully urge the City of Redmond to:

Conduct a comprehensive investigation into ISA's compliance with its operating license, with particular focus on unauthorized range expansions, the introduction of new shooting types and ranges, the safety of steel target designs, and the deteriorating condition of the perimeter fencing around ISA. To ensure an unbiased and thorough review, we respectfully request that the city engage an independent third-party organization recognized as experts in shooting range design and safety standards.

If determined to be in violation of Ordinance 5.8.0, issue a Notice and Order requiring ISA to immediately cease all unapproved activities and restore its operations to full compliance with Ordinance 5.80, as established in 2009, including rolling back any expansions or modifications made without proper authorization, which constitute a violation of its non-conforming land use designation.

Suspend or revoke ISA’s operating license if compliance cannot be achieved, as authorized under RMC 5.80.050. This provision grants the city the authority to 'deny, suspend, or revoke any license issued under this chapter if the applicant, any of its officers, directors, partners, or members have violated any provisions of this chapter as determined through a documented investigation, or if the information supplied by any applicant in connection with any license issuance, inspection, or renewal under this chapter is found to be false or a misrepresentation.

Conduct additional testing on ISA property to determine the full extent of lead contamination, including its impact on surrounding areas. Testing should also be extended to properties directly adjacent to ISA to ensure the safety of homeowners and their children and to mitigate any potential risks of lead poisoning.

Recommendation for Revising Ordinance 5.80

The issues and apparent violations outlined in this letter represent more than isolated incidents—they reveal systemic flaws in the regulatory framework established by Ordinance 5.80. In our view, these deficiencies have allowed unauthorized expansions, unsafe practices, environmental degradation, and unchecked operations at the Interlake Sporting Association (ISA).

It is clear that Ordinance 2485 significantly weakened the safeguards of its predecessor, Ordinance 2120, and failed to anticipate the challenges posed by an outdoor shooting facility in a rapidly urbanizing environment. This inadequacy has left the city unable to effectively enforce compliance, protect public safety, and address environmental concerns.

The Department of Ecology's recent decision to list the site due to significant lead contamination underscores the urgent need for action. This development highlights the immediate responsibility of the City of Redmond to insist on comprehensive testing of ISA’s ranges to determine the true extent of contamination. Allowing this issue to persist unchecked not only jeopardizes the environment but also exposes the city to potential long-term liability for failing to enforce environmental standards.

The City of Redmond has both the authority and responsibility to act decisively. As demonstrated by other municipalities, such as those in Kitsap County and the City of Gig Harbor, stricter local ordinances can coexist with state law when framed within RCW 9.41.300(3)(a). By utilizing this legal pathway, Redmond can craft ordinances tailored to the unique needs of its community, ensuring that safety and environmental stewardship are prioritized.

We respectfully request that the city not only take immediate action to investigate and address ISA’s apparent violations, but also consider reinstating critical provisions from Ordinance 2120, including:

The requirement for NRA trained and certified Range Master or Range Safety Officer to be present during ISA operating hours.
Mandatory compliance with NRA safety standards documented in the NRA’s “Range Source Book”.
A detailed lead management and recovery program, now more essential than ever in light of the Department of Ecology’s findings.
Independent and accredited third-party oversight of facility design and range safety.
Reinstate operational hours language to clearly define enforceable operational hours that respect the pre-existing rights of residents who lived in the area prior to ISA's expansions.

The integrity of ordinance 5.80 and the trust of the community depend on enforcement and the continuous improvement of ordinances. I urge the City of Redmond to act now to uphold its commitment to public safety, environmental health, and the well-being of its residents.

As referred to throughout this document, the appendix below contains supporting documents, including incident reports, maps, and public records, to substantiate this complaint.

Thank you for your attention to this matter. I and other community members are available for further discussion or to provide additional information upon request.

Appendix: Supporting Materials

Maps and Visual Evidence