Publius, what the City is arguing (and the Judge is agreeing) is that just because they require training before issuing their permit, they don't have to provide any place or even allow the means to train.
Notwithstanding its mandate that prospective gun owners obtain, and maintain, training at a gun range, the City bans the operation of gun ranges.
The gun range ban is flatly unconstitutional. The Second Amendment guarantees the right to train with firearms so that individuals can be safe and proficient in their use, in addition to securing the right to engage in recreational shooting. If there is a right to keep and bear arms – and there most certainly is such a fundamental, individual right secured in our Constitution – there is inherent within that right, a right to actually use arms for traditional lawful purposes. There is absolutely nothing more basic, more plain, more obviously inherent in the possession of guns than the use of those guns at a gun range. Gun ranges may be regulated in the interest of public health and safety, but a complete ban on gun ranges is unconstitutional.
That's the case in a nutshell.
Alan Guras brief in Opposition to the Motion to Dismiss, contains point by point, attacks on both the Cities position and that of the Judge (in her ruling in denying the TRO). The City has until Thursday, the 4th to reply to this brief.
This is not breaking new ground. It is cementing what flows naturally from Heller.
Alan Gura is not making the argument that the training requirement itself is unconstitutional (that argument is being made by the NRA in its suit - Benson v. Chicago - Alan is wisely staying away from those issues, so as not to have his case consolidated).