The site is owned by Australian Target Systems, the main provider of shooting facilities to the Defence Force. Two months after the training, the company lodged a development application with the local council to build a specialised range on the property that would train police in lethal force. Both NSW Police and the Queanbeyan–Palerang Regional Council told Fairfax the 2017 training was carried out under a special provision that allows authorities to set up temporary "emergency services facilities" without council approval. "Under this [law] NSWPF is permitted to assess and approve ... the training exercise on the Samuel's Run land," a police spokesman said. A second approval to use the site as a range was also granted, the spokesman said, but did not provide further details. In their letter to NSW Police in October, EDO lawyers argued the range was not set up by or on behalf of police and was instead part of the company's private enterprise, therefore they had "no legal basis to use it for [their] exercises".

"While NSWPF is permitted to carry out emergency services at an emergency services facility without consent, this does not have the effect of authorising a shooting range that was built unlawfully," EDO solicitor Meg Lamb said. Chief operating officer of the company Lee Bath said police used ATS shooting targets and facilities at the site, but the company's involvement with the approval "extended to providing NSW Police with details of the property". "From there we were issued [an access] licence. How the licence was arranged and the processes involved is not something we know about," Ms Bath said. Local James McKay, who has a background in law, said NSW Police should investigate its own conduct to see whether officers committed an offence by firing at an unapproved range. Under the NSW firearms regulation it is an offence to fire a gun on or operate an unregistered shooting range.

"It is beyond doubt that the property was used as a shooting range in the middle of last year...The tricky thing is that the activities may well have taken place with the involvement of police," Mr McKay said. Having sought his own legal advice, he has since reported the training to Crime Stoppers. The Canberra Times understands NSW Police cancelled upcoming events at Samuels' Run once neighbouring farmer John Reardon threatened further legal action through the EDO. Principal solicitor at the EDO Elaine Johnson said the organisation stood by its advice but it appeared to be a case of police being "accidentally" drawn into something unlawful and they had done the right thing by moving the events. Geoff Grey, who was left with severe hearing damage after 35 years in the Defence force, said gunfire from the training sessions had ripped through his home and art retreat three kilometres away.

He also raised legal concerns with the NSW government but was told in a letter from the Department of Justice that all "relevant assessments and approvals, as required, were undertaken". "The training...is vital to ensuring the Public Order Riot Squad is supplied with the knowledge and skills to resolve armed offender situations," a spokesperson said. "Samuels' Run provides the optimal training environment to develop those skills. I am advised that there are currently no other ranges in NSW that accommodate...this type of training." Loading While such facilities were available at the military base Holsworthy, access for police "was subject to Defence priorities", the spokesperson said.

Neighbours fiercely oppose the proposal to build a permanent range on the site, claiming the "loud and alarming" gunfire will disrupt local business and livestock, and even cause distress to several former and serving Defence members living nearby.