Larry, Quit acting defeated.... you say you have nothing, but you also said "We have plenty of dirt and money to move it".... So you have something, not, nothing. So move the dirt. If you have plenty of dirt for the berms, and money to move it then you also should have plenty of money to hire and architect to design it. You (meaning, your club, not you personally) are being re-active instead of pro-active. If they came to your club and told you the problem, then you know the problem, so fix it. The NRA isn't the end all be all of range guidelines.... Hire an architect. Design a safe range and then build it. Put the responsibility on the local authority to tell you it isn't safe instead of letting them make you prove that it is. If you have never had an unsafe incident then the range must be safe.... All you have to do is do it, OR sit back, complain and watch the club fold....... personally, if I was that worried about it, I would call the NRA everyday, at least once a day. Call different numbers. Call repeatedly. Become a pain in their a** until you get a call back. There are localized representatives for the NRA, so get their info and contact them. Go to an NRA banquet, ask questions, get contact info. Go to other clubs and get contact info for who they deal with at the NRA. There are a lot of things you can do but you have to do them.....